September 8th, 2020

Dear Honorable Board Members
National Wild Horse and Burro Advisory Board
Care of Bureau of Land Management, national office

The unanimously passed Wild Free-Roaming Horses and Burros Act of 1971 (WFHBA) should be protecting America’s last remaining wild horses and burros. But our federal government has been either eliminating or reducing them to mere token, non-viable population levels upon their legal Herd Areas (BLM-USDI) or Territories (US Forest Service). Here they are supposed to be the “principal” presences, yet they continue to be victimized because of the selfish demands of public lands ranchers, big game hunters and other narrow-minded “resource” monopolizers.

The current proposed $102-million budget for the coming year’s wild horse and burro program is now being considered by the Appropriations committee of the U.S. Senate. In 2020 alone, contractors with the federal government are proceeding to gather 12,584 wild equids and remove 11,400 of these in states throughout the West. According to the deceptively named “Path Forward” now before Congress, similar large-scale roundups would proceed over the next decade. This plan would obliterate America’s remaining herds, reducing them from a very modest level of about 60,000 to around a third of this or 20,000. When spread out over about 200 remaining herds that have not been zeroed out, this represents around 100 wild equids per Herd Area, or Territory. Since each area usually contains thousands sometimes even millions of acres, the gross injustice being perpetrated upon our nation’s last wild horses and burros becomes apparent. This outrageous attack on our free-living mustangs and burros and their legal habitats must stop before it becomes too late!

BLM and USFS officials, including especially the newly appointed BLM Director William Perry Pendley, have been using deceptive and distorted information couched in hysterical, demagogic language. This they do in order to foment a false narrative concerning America’s relatively few remaining wild horses and burros. If their perverse plan goes forward, after the herds are gutted, those horses and burros who remain would be subject to intensive semi- or full sterilization treatments that would take the “wild” out of our wild horses and burros. This would be entirely contrary to the true spirit and intent of the WFHBA. Such would not be “A Path Forward” but a shameless and hypocritical mockery of the laws of our nation including also NEPA, FLPMA, PRIA, Multiple Use & Sustainability Act and the Administrative Procedure Act.

If carried out, this plan would cripple the horses’ and burros’ ability to survive in the wild by converting their legal Herd Areas and Territories into intensive livestock operations with frequent allotment fencing and cross fencing aimed at maximizing cattle and sheep production and, though to a lesser degree, big game hunter harvest. The equivalent of several million year-round cattle and sheep and many million deer, elk and other game animals are deliberately given grossly favored advantages while a tiny minority of wild horses and burros are persecuted, overly reduced and even eliminated using the misapplied pseudo-justification of “over-population,” “over-grazing” and “habitat destruction” that are, in fact, being caused by a variety of other factors, principal of which is public lands livestock ranching, but also including wildfires, off-highway vehicles, trespass livestock, illegal plunder of plants and animals on the public lands, mining, energy development, monopolization and diversion/draw down of water tables – and the list goes on!.

– To scapegoat wild horses and burros for these abuses, to blame these animals who, in fact, restore the public lands life communities, is detestably dishonest, mean-spirited and depraved! (See J.M. Ladendorf. 8/31/2016. The Ecological Impact of Horses as a Keystone Species Critical to the Regeneration of the Earth. VENews. Also: S. Luokkala. 10/26/2015. Casualties of the Vanishing West: The American wild horse continues to lose habitat to special interest groups. Earth Island Journal. Also ask me for my professional reports on various herds throughout the west, including the Pine Nut Mountain horse herd where I did an extensive ecological study listing disturbance factors.)

To describe in further detail what is happening. The massive helicopter drives terrorize the horses and burros. These mercilessly jerk them from their natural habitats where they have become adapted over the generations, causing injury and even death among a significant number of those gathered. Being rounded up by the giant, whirring metal machines traumatizes the horses and burros; those who survive suffer a persistent form of PTSD that causes them much suffering and anguish for the rest of their lives. Whenever they hear the whir of a helicopter, they panic. Many drop dead in the concentration-camp-like holding facilities where they are subsequently amassed, such as the one in Palomino Valley just north of Reno, Nevada, where I go to commiserate and lend them some modicum of moral support.

Public servants in the BLM and Forest Service are miserably failing to uphold the basic rights of our cherished wild horses and burros, including their long-term survival in viable habitats and their free-roaming lifestyles. They are allowing over-fencing within their legal areas in order to accommodate cattle and sheep ranchers and other exploitive interests (e.g. the vast Owyhee Desert Herd Management Areas (HMA) in northern Nevada, southern Oregon & parts of Idaho). Also, they often fail to secure the water sources that are needed by these “national heritage species,” giving these waters over to lavish sprinkler-irrigated alfalfa fields of ranchers or mining operations that squander enormous quantities of water (e.g. the Bald Mountain Mine within eastern Nevada’s Triple B HMA). By relinquishing these and other vital habitat necessities, including highland summer (e.g. Pryor Mountain Wild Horse Range) and lower winter valley or piedmont habitats (e.g. Black Rock East Wild Horse HMA), our public servants put the squeeze on the horses and burros.

The hypocritical Herd Management Plans (HMP) these agencies put out for public review are fraught with negative spin against the naturally living horses and burros and almost always aim to either cripple or eliminate the herds. These plans accommodate the insatiable demands of pushy public lands ranchers, a segment of American society that has been unjustly favored similarly to how a spoiled child is treated. Often these people are incredible wealthy and almost always incorporated. They are enormously subsidized by the U.S. taxpayer and given practically interest-free loans by banks and government loaning agencies. Under the antiquated Taylor Grazing Act of 1934, they only pay the minimum (practically free) fee of $1.35 per cow-calf pair for what are supposed to be cancellable grazing privileges – not rights – upon our public lands! (See Eckhoff, V. Cattle vs. Wild Horses (2002-2018). All Data BLM. The Daily Pitchfork. October 9, 2018)

Naturally living horses and burros play key roles on the public lands’ ecosystems, restoring humus in soils and dispersing intact seeds to a greater degree than is the case with ruminant herbivores. Hence, they actually benefit these, because they restore a more wholesome balance within the life communities they inhabit. They also greatly reduce dry flammable vegetation and mitigate against and often even prevent catastrophic wildfires – now on the increase due to mounting Global Heating. This has to do with their different caecal, as opposed to ruminant, digestive system, their greater mobility, upper incisors and blunt rounded hooves, among other factors I write about in my book The Wild Horse Conspiracy (see www.amazon.com/dp/1461068983).

The early summer 2020 “Numbers Wildfire” in the south-central Pine Nut Mountain Range burned over 20,000 acres and tore through valuable Pinyon Pine & Juniper groves, streamside riparian habitats and vital spring meadow headwaters, undermining soil integrity and polluting the air all the way to South Dakota. As a wildlife ecologist who has observed the Pine Nut mustangs and their Pine Nut Mountain habitat all of my life and done professional studies thereof, I believe this fire could have been prevented if the Carson City BLM had allowed more wild horses to remain in this part of their original 1971 Herd Area. Rather, they reduced the Pine Nut Mountains Herd Area from 251,792 to 104,316 acres and declared a so-called Appropriate Management Level of only between 118 low end to 179 high end horses, which is far below the 2,500 individuals recommended for viability in nature by the IUCN Species Survival Commission Equid Specialist Group, and which the original Pine Nut Mountain Herd Area easily could and should have accommodated!

Wild horses and burros are restored North American native species whose lineages trace back millions of years upon this continent. They are “keystone” restorers of native species diversity and enhance the ecosystems they live in, making them more resilient to imminent changes, such as Global Warming. These facts were recognized by the WFHBA when it mandated their being recognized as “integral” parts of the public lands ecosystem not to be merely treated as escaped domestic livestock and branded as “feral”. Rather than cruelly denying them their adequate habitat requirements for long-term genetically viable populations, and rather than conniving to ever further reduce or even zero them out from their legal areas or reduce them to sterilized or semi-sterilized, basically crippled herds barely carrying on at mere token, non-viable levels, America should be reducing livestock, taking down fences and restoring viable populations back within their legal Herd Areas and Territories across the West! And a truly wise and caring Reserve Design approach to realizing genetically viable, ecologically well adapted and naturally self-stabilizing herds should be employed, not the present perversion of the WFHBA! This would involve identifying complete, long-term-viable habitats, incorporating natural and other type barriers, restoring natural predators and allowing mature social units, or bands, to become established. The older horses are also vital educators of their young and harmonizers with their natural home due to their acquired as well as inherited knowledge of how to survive where they have lived for generations.

I have submitted my Reserve Design proposal to the National Wild Horse and Burro Board on several occasions before, and would be glad to do so again. I look forward to testifying on the Zoom meeting of September 24th and have a confirmed time for this. I appreciate this opportunity to give input and welcome your questions and concerns.

Sincerely,

Craig C. Downer, Wildlife Ecologist
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423