February 3, 2020

BLM Fillmore Field Office
Attn: Trent Staheli
95 East 500 North
Fillmore, UT 84631
Tel. (435) 743-3164

Re: Swasey HMA Wild Horse Gather Plan E.A., public comments due February 20, 2020 by letter or via BLM website see: https://www.blm.gov/press-release/blm-seek-public-comment-proposed-wild-horse-management-swasey-herd-management-area for link to EA & window for input.

Dear Sir/Mame:

After reviewing your EA & on behalf of my organization dedicated to protecting, preserving & restoring the endangered Perissodactyla of the world & their appropriate & viable habitats, I am submitting the following timely input: As a wildlife ecologist & wild horse advocate, I have visited & observed the Swasey HMA mustangs to the west of Delta, Utah, on several occasions dating back to the 1980s. Over the years there has been an increasing squeeze play against these unique & beneficial, naturally living horses by both local public lands ranchers & the government officials who are charged with protecting them. This gross unfairness is most apparent in the insultingly low Appropriate Management Level (AML) and tied forage allocations that has been assigned to them, which is only for 60 to 100 horses.
Given there are 120,117 acres in the HMA, at the AML mean of 80 horses, BLM is allowing only one individual wild horse for every 1,501 legal acres. This AML makes a mockery of the Wild Free-Roaming Horses & Burros Act (WFHBA) & should be disallowed & rescinded. It violates section 2 (c) of the Act that mandates that the legal Herd Area be “land devoted principally to the welfare and benefit” of the wild horses, not cattle or sheep ranchers, hunters, mining or energy companies, or other exploiters of the public lands. From Section 3.2.1, page 27 of the EA, I see there are seven livestock operators in the HMA & that they receive 13,954 AUMs (Animal Unit Months) of forage per year, which is equivalent to 1,163 year-round adult cattle or cow-calf pairs – that latter corresponding to 2,326 individual cattle – or to 5,815 year-round sheep. This shows how extremely disrespected the wild horses are within their legal HMA, since the mean wild horse AML of 80 horses times 12 months equals only 960 AUMs per year. So the Fillmore BLM Field Office is giving 13,954 divided by 960 = 15 times more forage to the seven livestock ranchers in & around the Swasey Wild Horse HMA than it is giving to the Swasey wild horses themselves, who possess a legal right to be the principal resource recipients within their legal Herd Area. This situation makes a brazen mockery of the WFHBA, for the wild horses are only being allocated 6.25% of the forage that the ranchers are. And even given that their livestock don’t graze entirely within the HMA, still a major portion of the grazing is there and especially during the favorable grazing seasons, which greatly compromises the year-round survival ability of the wild horses. Clearly Swasey’s wild horses are being discriminated against & the BLM – our public servants – is grossly favoring public land ranchers at the expense of the “national heritage” & “returned North American native” naturally living horses. The House Range Resource Area RMP/ROD, 1987 was renege & extremely unfair & should not have been approved. Section 2.4.1 claims that the wild horses are being reduced to this genetically non-viable population level in order to comply with the federal Multiple Use & Sustainability Act though in actuality it is doing all the opposite: promoting the monopolization of the public lands & their resources in the HMA by livestock while minimizing the number & resources available for the principal legal presences – the wild horses themselves, whose reinstatement at truly viable herd levels would be the true fulfillment of the Multiple Use Act! Such lopsided decisions subvert the core intent & purpose of the WFHBA by reducing the herd to a mere token level, one that is being given mere crumbs in the allocation process. To claim this complies with the law is hypocritical & mendacious!
According to the EA, there are ca. 721 wild horses currently in the HMA. Given 120,113 legal acres here, there would be 167 acres per individual horse. This amount of land would not be over the Carrying Capacity (aka K) in this area, provided the horses are receiving their fair share of the forage, water, shelter, space, elevational gradient for seasonal movements & other necessary habitat components that are requisite for their long-term survival. These horses obey nature’s age-old laws in seeking to fill their ancestral niche, & we should honor, respect & allow them to do so, rather than impose a disharmonious resource-monopolizing lifestyle upon these public lands. And it is unfair to claim, as the EA does in its evaluation of the No Action Alternative (throughout the document) that, when left to their own resources, wild horses only blindly reproduce to overwhelm & destroy their habitat. This is not the case & fails to recognize the horse as a Climax Species that can & does self-stabilize its population numbers once its ecological niche is filled. I object to this serious mischaracterization of the naturally living horses & their harmonious place, niche & role in the Swasey HMA ecosystem, in the West, as elsewhere. This is a tendentious filtering of the facts according a thinly disguised anti-wild-horse agenda. It is plain to me that the preparers of this plan have negatively targeted the legal wild horses of the Swasey HMA for discrediting as harmonious & beneficial presences in order to pseudo-justify their cruel gutting, or reduction to a non-viable, dysfunctional & mere token population level that is in-no-way commensurate with its true ecological niche here.
This EA’s preparers have overlooked many important positive contributions that naturally living horses make within each unique & special ecosystem they inhabit, including the Swasey. These include healthy soil restoration & maintenance, intact seed dispersal & germination of a great variety of species, as well as the mitigation & even prevention of catastrophic wildfires – a major concern given present Global Warming brought on by our species’ pollution of the ecosphere & destruction of many ecosystems including healthy semi-arid & arid ones. The naturally living horses should be seen as healers & restorers of the diverse Herd Area/Heard Management Area ecosystems they possess a right to live in. This includes the soils & aquifers of the vast grassy Steppe-Sagebrush, Pinyon-Juniper communities & other biomes found throughout the Great Basin. And of critical value today is their role as mitigators & preventers of devastating wildfires & as much-needed balancers vis-à-vis the overly promoted ruminant herbivore hordes that are foisted onto the land, especially cattle & sheep & certain game animals including deer. In fact, these ruminant herbivores would greatly benefit from more wild horses were we humans to allow the natural & balanced ecological succession to take place among all these species instead of our stubborn & dis-attuned imposition & foisting of just certain species upon the land! The latter, through no fault of their own, find themselves used & abused for harvest by us humans, who thus rob the ecosystem of the mortal remains of these creatures in order to devour them — in order to feed an out-of-touch consumerist lifestyle or just for pure vanity and self-indulgence! We must see these plain facts today with 2020 clarity rather than continuing to ignore them; & I urge you as our trusted public officials & servants, whose roles in society I greatly value, to face them, for so much of our shared future here on Earth depends upon your doing so.
Of the limited Alternatives A, B, C, D & E in your EA, I favor E: No Action, though you dismiss it as contrary to the WFHBA throughout your document. None of the other Alternatives give any truly fair consideration to the wild horses themselves but are slanted to grossly disfavor these legitimate presences within their legal area. As before in other EAs, etc., I propose a Reserve Design Alternative & ask that you give it serious consideration in your revised Environmental Assessment. Reserve Design involves allowing the horses to fill their ecological niche at a viable population level. Once they have filled their niche because allowed (by us people) to harmoniously adapt to the unique Swasey herd area ecosystem, they will naturally self-stabilize as ecological Climax species. The problem has been that we have not allowed them to realize their natural place, niche & role here, but only treated them as escaped domestic livestock rather than returned native species. Only when we treat them for what they most truly are will we fulfill the core intent of the unanimously passed WFHBA, only then will we realize its true meaning & spirit.
You can find a more complete description of my Reserve Design Proposal at: https://www.gofundme.com/mstngreservedesign.
I sincerely hope that we can work to realize this just wild-horse & nature-respecting alternative!
The following are points I also consider important for you to consider. I provide references to their corresponding sections in the EA.
Introduction & initial pages: I see that the wild horses are being arbitrarily blamed for resource impacts, & that the EA preparers are questioning their habitat suitability but offering no proofs, only opinions. Also the relative numbers & grazing pressures of wild horses, livestock & wildlife including hunted animals are not clearly revealed within & surrounding the HMA, nor is damage from other factors like Off-Road Vehicles, Roads, Mining, Energy Extraction, etc., which affect vegetation, water, soils, air, etc.
This EA decision would last for ten years & minimize monitoring, public input, etc., thereby prescinding the PRIA-mandated adjustment of wild horse numbers & forage allocations for a decade. PRIA refers to the Public Rangelands Improvement Act of 1978 & the just spirit of this law should be followed. The ten-year-plan would perpetuate an even more extreme monopolization by livestock of the public lands & greatly disfavor the wild horses & their habitat needs. In short, it would be wrong to freeze the AML.
Again, your EA fails to recognize the significant detrimental impacts of the proposed alternatives to the wild horses themselves & to their habitat needs for survival, aka long-term viability.
Concerning your Double-Count Aerial Censusing of 721 horses on 3/2018 & your assuming a 20% annual population increase for various years, including 2019-2020, there are many documented studies that show BLM’s assumed 20% increase to be very excessive & to overlook major mortality factors operating upon the wild horse population, including the death of newborn between birth & one year of age, as from predation, disease, inclement weather, accidents, harassment of wild horses & accelerating disruption of their habitat by humans, etc. First year mortality is typically 50% or higher. Also you fail to factor in significant adult mortality, including by illegal killing by humans as well as natural predators, accident, disease, weather, etc. Adult mortality is typically 8% or greater (See Wolf, Jr. Michael L. 1980. Feral Horse Demography: A Preliminary Report. http://www.jstor.org/stable/3897882; Berger, Joel. 1986. Wild Horses of the Great Basin: Social Competition and Population Size. U. of Chicago Press; Rogovin, K.A. & M.P. Moshkin. 2007. [Autoregulation in mammalian populations & stress: an old theme revisited]. Zhurnal obshchei biologii 2007: 68(4): 244-267 (in Russian); Jenkins, S.H. & M.C. Ashley. 2003. Wild Horse, Equus caballus and Allies. Ch. 53 In: Wild Mammals of North America… 2nd Ed. Feldhamer, Thompson & Chapman, Editors. John Hopkins Univ. Press. See pages 1148-1163).
Additionally, forage & water allocation to livestock & big game animals as well as mining & energy activities should be clearly revealed & integrated into the EA plan, but are not adequately considered.
Wild horses naturally move within their habitat establishing seasonal migrations. These movements naturally relax their foraging pressures for the various sectors of the ecosystem they live in. And horses practice patchiness of foraging that leaves islands of grass, etc., to set seed & reproduce. In other words, they practice natural rest rotation. If they were the destructive monsters in the world of Nature, as their enemies claim, they would not have survived all those millions of years that their fossil record reveals, but would have long ago perished because of habitat destruction. And it is also important to recognize that they quickly revert to wildtype &, in truth, are much more wild than they are domestic in nature. Their instincts quickly revive when they escape from human contact. (See MacFadden, B.J. 1992. Fossil Horses: Systematics, Paleobiology and Evolution in the Family Equidae. Cambridge Univ. Press.)
Your EA claims it would maintain a Thriving Natural Ecological Balance (TNEB), as WFHBA mandates, by reducing Swasey’s wild horses to mere token, genetically non-viable herd numbers – but this does gross injustice to the concept! This presents a warped definition of TNEB that relegates the horses to a very suppressed position by which they are unjustly thwarted within their very own legal habitat. For facts reveal they play an important Keystone role, one that has been established over the millions of years of their prior evolution that took place primarily in North America, including Swasey (op. cit. MacFadden).
Concerning your Alternatives A, B, C, D & E, nowhere do you present the Reserve Design Alternative above introduced but instead proceed to treat the wild horses as mere domestic animals to be minimized to genetically non-viable, ecologically unfulfilled & mere token levels through the use of reproductively & socially altering drugs, gruesome operations, social structure interference, catering to livestock & other interests within the HMA, etc., I strongly disagree with these proposed alternatives. They would be cruel tortures of these highly evolved animals & distort & dishonor their true nature. These animals have done so much for us humans – now isn’t it high time we do something truly great for them – like letting them be themselves within a suitable & sufficient habitat space where they can carry on with their awesome age-old trajectory?! –This was & remains the true intent of the WFHBA; & I remember this as a lesson from Wild Horse Annie herself. The main purpose of the Act is to allow them to realize themselves as revivified & realized horses, not to invade their most intimate reproductive systems by PZP or GonaCon or gruesome, cruel & life-threatening spaying or gelding on a massive scale. We must let the horses themselves inform us as to what is best for them & how they can restore a more exuberant health to so many regional ecosystems. Reserve Design is the answer & insisting that people learn both how & why to share the land & freedom for the common good of All.
Sex-ratio skewing would terribly inflict the wild horse, as it causes interminable stress due to too much vying for mares by the stallions who would be present in unnatural overabundance for this naturally harem-type species. Drugs & vaccines should not be employed neither should any surgical alteration of wild mares or stallions. These should be forbidden by dint of WFHBA’s Section 3 (a) mandating BLM & US Forest Service manage wild horses & burros so as “to achieve & maintain a thriving natural ecological balance on the public lands and at the minimum feasible level.” An objective interpretation of these words would prohibit the tortuous semi-domestication of the wild horses & burros through highly invasive means, such as those proposed in this EA. (See https://www.facebook.com/notes/craig-downer/will-there-be-a-healthy-future-for-Americas-wild-horses-and-burros-in-the-wild-p/1120228514679820.)
Section 2.4. Alternatives considered but discarded.
You should not have ignored some of these sound proposals, including the justified reduction of livestock, the expansion of HMA back into the original HA, the allowing natural predators to restore themselves, such as the puma, and also, one I would like to suggest: the setting up of Cooperative Agreements (as permitted by Sections 4 & 6 of the WFHBA) with adjacent land entities in order to ensure the long-term viability of the herd (a critical part of my Reserve Design). By not taking these to heart, you are missing the true spirit & intent of the WFHBA & you are siding with the very traditional enemies of the wild horses against which this law was passed to defend these animals! You must not abandon your honorable responsibility to uphold all the laws of the land both fairly & equitably. As well as to the wild horses, this is grossly unfair to the General Public as concerns a paramount Quality of Life issue. And, again, your EA must not overlook all of the many positive contributions that naturally living horses & burros make to ecosystems, including their very important mitigation & prevention of catastrophic wildfires! (See: http://www.sciencepublishinggroup.com/pdf/10.11648.j.ajls.20140201.12.pdf; & https://www.horsetalk.co.nz/2017/07/31/wild-horse-fire-brigade-work/ .)
Concerning Alt. B, GonaCon is a particularly cruel & ill-advised treatment of the wild mares that would affect their hormones & natural cycling. Its equivalent for women was abandoned by standard medical practice years ago because of the torturous effects that even led to suicides. Please do not subject our wild mares to this!
Alt. D: I highly object to the establishment of non-reproducing wild horse population segments by means of various sterilizations, including the cruel ovariectomies! These would cause excruciating suffering & often death of many innocent mares & should not be permitted. Instead, Reserve Design would realize WFHBA’s true intent, which is to respect & beneficently treat the naturally living horses & burros.
Section 2.4.1: This alternative: Remove or Reduce Livestock in the HMA should most definitely be adopted for reasons already given. How can you say that allocating only several percent of available forage to the wild horses but allocating the rest almost entirely to livestock is in any way honoring the law?! This wise & fair alternative would be the true fulfillment of the Multiple Use Act as it would permit a greater, more truly viable population of wild horses, one that could have the habitat space & time in which to more harmoniously adapt to the ecosystem, thus disproving many false claims against them.
Section 2.4.6: Control of Wild Horse Numbers by Natural Means: Reserve Design fits well here & would be the true realization of the WFHBA, in place of some warped mockery of this well-conceived, nobly motivated, as well as ecologically & morally attuned act. You should not portray wild horses as incapable of self-regulation, of equilibrating their population numbers in tune with the other species, the climate, the seasons, etc. They do self-regulate when given the chance, but it is us people who must give them this chance. We must replace overly selfish, short-sighted & narrow minded, nature-disrespecting attitudes, priorities, value systems & disharmonious lifestyles with all their opposite! Then we will see that once the wild horses are allowed to fill their niche & establish mature social units (with elder stallions & mares suppressing the reproduction of younger members), they do, in fact, self-stabilize. And many examples of self-stabilizing herds exist, both in the West & elsewhere. Some examples are: the Montgomery Pass Wild Horse Herd on the California-Nevada border above Bishop, the Cerbat Spanish Mustang herd in NW Arizona &, north of Montgomery Pass, the Palmetto & Fish Lake Valley herds on BLM HMAs. These are self-stabilizing & have been for years. I have visited these & other similar herds & have observed that human persecution often enters strongly into the equation as to why there are so few wild horses or burros & that, typically, BLM &/or US Forest Service does little to stop this serious violation of the WFHBA.
Section 2.4.7: Raising the AML & forage allocation for wild horses & securing greater water & other habitat needs for long-term survival. This should definitely be done concomitantly with reduction in livestock grazing & other monopolies on the public lands. The current Swasey AML is genetically-non-viable & in no way commensurate with the ecological niche space that exists in this sizeable HMA. This tiny AML perpetuates a monopolization by livestock. And this is a disgrace to America as well as being a flagrant crime that violates not only the WFHBA, but also the Multiple Use Act, NEPA & the National Historical Preservation Act, since this herd is a precious historical “living treasure heritage.”
Section 2.4.8: You should designate the HMA as a Wild Horse Range whose resources should go principally to the wild horses, not the livestock ranchers. This would genuinely fulfill the WFHBA … & this should be the case for every legal wild horse &/or burro area, whether on BLM or US Forest Service lands, for this was the law’s original intention.
Section 2.4.10. Making individual-by-individual excess determination to remove old, sick, lame, etc. I disfavor this, as it runs contrary to natural selection & the original intention of the WFHBA, which mandates that the horses/burros not be domesticated but allowed to achieve their natural place in the ecosystem. The latter should include the wild horses & burros contributing their mortal remains to natural predators, scavengers & soil decomposing microorganisms & insects & thence to nutrient absorbing grass, forbs, bushes & trees & on up the food chain/web to higher animal trophic levels, etc. This would occur when each individual horse’ or burros’ time comes (as it does for each & all Earthlings).
By allowing natural selection & integration the true vigor of the species, whether horse or burro, would be restored and preserved far into the future, as species degenerate under domestication. Allowing natural selection is a transcendently wise provision that fulfills WFHBA meaning as expressed in its preamble. To wit: (a) wild horses & burros are living symbols of the historic & pioneer spirit of the West; (b) they contribute to the diversity of life forms in the nation [scientifically proven as post-gastric, soil-enriching digesters who balance over-populated ruminant herbivores unnaturally promoted by people]; (c) wild, free-roaming horses & burros shall be protected from capture, branding, harassment or death; & (d) they 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 [the natural ecosystem where they belong]. So let’s have some respect & learn from the horses. These are ancient presences upon the Earth who can teach us so much about how to live – & how to verily save precious life on Earth today!
Page 25. This discussion concerning water overlooks wild horses’ positive contribution to increasing soil retention of water. We must not overlook the fact that horse feces are less degraded than ruminant feces & consequently hold much more water & a lot longer when mixed into the soil. (See: https://esc.rutgers.edu/fact-sheet/horses-and-manure/ & https://advances.sciencemag.org/content/1/4/e1400103.full & https://youtu.be/HQAk7FIQCJA & https://www.researchgate.net/publication/281822984_A_Geographic_Assessment_of_the_Global_Scope_for_Rewilding_with_Wild_-Living_Horses_Equus_ferus/ & https://awionline.org/content/wild-horses-native-north-american-wildlife/ & https://www.researchgate.net/publication/223007520_Horse_dung_germinable … &
Bernier, B. 1961. Forest humus, a consequence and cause of local ecological conditions. Northeast Forest Soils Conference.
Section 3.2.1. House Range Resource Area RMP/ROD, 1987 was extremely unfair to wild horses & the general public & should not have been allowed!
Section 3.2.2. Drier conditions in recent years should obligate reduction in livestock in HMA. Because of their post-gastric digestive system & greater mobility, wild horses are better able to adapt to drier weather & vegetation & to help combat the dire effects of Global Warming that is, indeed, upon us. Think about it. … As for example, they sequester more Carbon in the soils than ruminants.
Final Statement: This Draft Environmental Assessment is very unfair to the wild horses who should possess a legal right to live at genetically viable population levels & to become ecologically integrated & well adapted within & around the Swasey HMA. However, the proposed alternatives are contrary to the WFHBA. BLM should redo this the Swasey wild horse Environmental Assessment to offer alternatives that will truly restore this unique & special, valued population of wild horses. I offer my services as a wildlife ecologist who has done in depth investigation of horses & other Perissodactyla in their natural habitats & who appreciates the naturally living horses “in the wild” – true to WFHBA core intent. I would welcome the opportunity to work with your team to fulfill the WFHBA & to realize a holistic vision for what this great freedom-honoring land of America both should & can yet be.

Sincerely,

Craig C. Downer
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423
ccdowner@aol.com
Cc: Various interested parties.