Comment on Draft Environmental Assessment Nevada Wild Horse Range HMA Wild Horse Gather Plan
June 21, 2020
U.S. Department of the Interior
Re: Public Comment DOI-BLM-NV-S030-2020-0003-EA
Happy Summer! I am writing after considering the essentials of your Draft EA for the Nevada Wild Horse Range. I am a wildlife ecologist specialized in the Perissodactyla Order of Mammals that includes naturally living horses such as those inhabiting the 1,301,637-acre Nevada Wild Horse Range (NWHR). I have a long and abiding interest in these wonderful horses, who are returned natives to North America and who contribute many life-enhancing benefits to the Mojave Desert ecosystem that I have documented over the course of my decades-long career (In early January I was again just north of the NWHR making observations in the HMAs of the Tonopah BLM District and took many a curious look south into the NWHR). The mustangs are great soils builders, plant seeders and catastrophic wildfire mitigating/prevention agents — the latter being a subject of great concern today due to Global Warming! And they provide a much needed balance in relation to the more promoted ruminant herbivores, as major studies have scientifically proven. Under appropriate military clearance, I was given a tour of the NWHR back in the 1980’s when I worked for the Animal Protection Institute and even then around 2,000 wild horses were very sparse and underpopulated as concerns their appropriate habitat in this vast area. At that time, the allowable level was greater by several fold than it is now.
I greatly protest the extremely low Appropriate Management Level that has been assigned for the NWHR. In such a vast area as the NWHR, the BLM and US Air Force should allow at least the recommended population level for viability of equid species in nature: 2,500 individuals. Though itself possibly too low, it would be the least you could do in this large area. It was arrived at by some of the most knowledgeable and experienced equid biologists and conservationists in the world, professionals who take their work and humanity’s responsibility to these highly evolved and nature-contributing but alarmingly decreasing species quite seriously. The reference here is: Duncan, Patrick, 1992, Zebras, Asses, and Horses: An Action Plan for the Conservation of Wild Equids, IUCN Species Survival Commission, Equid Specialist Group, Gland, Switzerland, especially page 5. I strongly suggest you carefully read this and updates from this group and really do something to reestablish a long-term-viable, naturally living horse population in and around the NWHR, rather than the mere token level you have assigned and, apparently, expect people to accept without question.
Your Appropriate Management Level (AML) of 300 to 500 indicates that you want people to believe that, at the mean level of 400 horses, having 3,254 acres, or 5.08 square miles, per individual wild horse is really appropriate. This is an almost wild-horse-empty ecosystem and makes of mockery of any claim to conserving a healthy wild horse herd within their legal area. Even given the military activities that go on here, this is quite absurd. At the low end of the AML: 300, there would be 4,339 acres, or 6.78 square miles, per individual wild horse; while at the high end of the AML: 500, there would be 2,603 acres, or 4.07 square miles, per individual wild horse. — All of these figures prove just how very unjust you are treating the wild horses in one of the world’s largest wild horse refuges. It is clear they are extremely thwarted, being denied the right to fill their natural niche in their own legal sanctuary. Even in such dry deserts as the Mojave, a few hundred acres per wild horse would be adequate to meet its needs, provided that its water and habitat quality are not being compromised by nature-altering and disrespectful activities. We should let nature inform us as to what the right balance should be. — It would be such a sad fact if the very worst enemies of these highly evolved animals were the very authorities charged with protecting and providing for them and their future well being! Horses have done so much for humanity, yet the vast majority of their time on Earth (numbered in the millions of years) has been in the wilds and mainly right here in North America, including the very lands of the NWHR.
Remember the truism, so apparent to those who ponder and value life: “In the Wild, the True Vigor of the Species is Preserved” (as opposed to an enslaved species kept in an artificial or greatly altered environment). I am asking you to redo this Draft E.A. and to leave the wild horses alone and let them fill their natural niche here and establish a truly long-term-viable population number and one that is self stabilizing through the sound principles of Reserve Design (ask me for details). The present AML makes a mockery of the unanimously passed Wild Free-Roaming Horses and Burros Act and all those many people who cherish these animals and to whom their having adequate land and natural freedom wherein to realize themselves, both now and into the long-term future, means so very, very much!
Before closing I would like to add that since very seldom does anyone outside the Air Force or BLM go in to inspect the NWHR and the condition of its wild horses and their habitat and what other factors are operating here, the wild-horse-caring public is really left in a very compromised position and kind of “in the dark”. Are we merely supposed to take whatever those deciding policy concerning these animals as truly justified? — I for one am not so gullible and take this opportunity to speak up for a much better policy toward these “national heritage living treasures” and returned-North-American, ecosystem-restoring natives. They deserve much more respectful consideration and so does the American public and all people who appreciate horses everywhere and want them to have fulfilled lives and to play their very beneficial, healing and balancing role far into the future. — This would be to really protect and defend America! I refer you to my professional peer-reviewed article on this subject and urge the careful consideration of its points. Here is the link: sciencepublishinggroup.com/pdf/10.11648.j.ajls.20140201.12.pdf.
I would welcome the opportunity to again tour the NWHR and to judge for myself as to how the wild horses are faring as well as their habitat, and how fairly resources within the NWHR are being provided to this species and to all the various desert-dwelling species that harmoniously go together here.
Do not hesitate in contacting me with any questions or concerns.
I look forward to your thoughtful and timely reply.
Craig C. Downer