Letter to Members of 117th Congress

Regarding Wild Free-Roaming Horses and Burros Act implementation by BLM-USDI and USFS-USDA

Date: January 26, 2021
by Craig C Downer, Wildlife Ecologist, Wild Horse and Burro Fund, P.O. Box 456, Minden, NV 89423.
ccdowner@aol.com.

The Public Rangelands Improvement Act of 1978 (PRIA) amended the WFHBA. It required a current
inventory of wild horses and burros to determine appropriate management levels, or AMLs, meaning
the number of wild horses/burros sustainable by the resources of the range. Under this law, AMLs are
supposed to be adjusted according to resource availability. This law also defined “excess” wild
horses/burros for any given legal area and mandated that these national heritage animals be considered
comparably with other values on the public lands. – The true spirit and intent of PRIA is not being
followed when it comes to the wild horses and burros, who are being reduced to mere token, non-viable
herd numbers and deprived of the principal resources which the WFHBA under Section 2 c mandates for
them within their legal areas (Herd Areas on BLM land and Territories on USFS land). It is especially
egregious how the wild horses and burros are not being considered “comparably” to the other values
and presences on their legal public lands. Also very lacking is the just overview of the big picture
concerning how very small their assigned herd numbers and survival resources are compared to that
given to cattle and sheep ranchers, oil and gas developers, big game hunters, etc.

Currently widespread livestock trespass exists on both BLM and USFS lands throughout the West, and
our public servants are doing little or nothing to stop this. Basically, the BLM has assigned several
ranching corporations throughout the Western states to call the shots when it comes to the
management and conservation of the lands they graze. This is a true abrogation of responsibility on the
part of BLM and a serious negligence of duty to uphold all the laws governing the “public” lands. This
suits the corrupt privatization and industrialization goals of those who have been placed in positions of
power, e.g. William Perry Pendley over BLM and similar officials in the USFS. They think they are beyond
the law and owe not allegiance to anyone except the exploiters of the public lands, hence their attacks
on the Endangered Species Act, delisting of the Gray Wolf, violation of the world’s greatest temperate
moist forest the Tsongas in southern Alaska — a dire betrayal of all those who care about combatting
Global Warming and the continuation of some of our planet’s most unique and life-preserving
ecosystems.

Oil and gas development are being given a total green light including enormous fracking operations that pollute aquifers and poison soils and the plant and animal communities which depend on them,
including ultimately us people. Case in point is the Red Desert Complex of five wild horse herd
management areas, or HMAs, in the Rawlins and Lander Field Office jurisdictions. A just concluded wild
horse roundup there gutted these five herds, leaving only a crippled dysfunctional remnant of what
once was such a magnificent and ecologically harmonious and contributing group of mustangs, many of
precious Spanish Colonial and even Appaloosa heritage. Now hundreds of additional drilling wells will infest this once scenic area, leaving an eyesore where there once was a splendid and intriguing
landscape populated by a modest, harmoniously integrated bands of mustangs.

The people calling the shots at BLM, as well as USFS, are targeting the wild horses and burros for
practical elimination and doing all the opposite of what the WFHBA mandated for these wonderful
animals. A further case in point concerns their plans to sterilize the herds, or nearly completely so, with
GonaCon, a hormone-interfering injection that causes great suffering and social disruption both in the
individual mares who are “force-drugged” and the stallions and the offspring of both. This is entirely
contrary to the WFHBA where it states that “wild free-roaming horses and burros shall be protected
from capture, branding, harassment or death” and that “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.” In fact, what our public servants are doing is the exact opposite of the true spirit and intent of
this noble law, which they are perversely subverting! This is a Public Interest issue for all Americans, and
really for all of humanity. It is a Quality of Life issue here that is at stake and it is also a question of our
high moral standards and basic honesty and adherence to all life’s greater truth and relatedness.
Particularly outrageous is the plan today to conduct very cruel, pain- and in many cases death-inflicting
ovariectomies on the wild mares in the field – and plans to do just this are going ahead in the Confusion
wild horse HMA in western Utah by BLM today! BLM’s insistence on such a gruesome act shows just
how mean-spirited and perverse whoever is calling the shots here has become! BLM had an ugly hand in
the recent introduction of a bill in Congress to allow slaughter of horses in the United States. Obviously,
the massive roundups that have and continue to obliterate the legal herds and that have resulted in
many thousands of formerly wild-living horses and burros being held captive in miserable spirit-killing
holding facilities are all part of this nefarious plan to basically eliminate the naturally living horses and
burros from their legal areas on BLM and USFS lands throughout the West. They would be the proverbial
canaries in the mine as the industrialization of the public lands proceeds. Also, they are being used as
“red herrings” in that they are blamed for nearly every public lands problem imaginable, but very falsely
and in the sick spirit of those who shamelessly love to lie and who love liars!

For over a decade as a professional wildlife ecologist, I have proposed Reserve Design as the true path
forward toward restoring wild horse and burro herds whose members would be allowed to prove just
how crucially important they are in restoring life on Earth. Reserve Design is a branch of Conservation
Biology which I studied in the universities I attended and which I implemented in my work as a wildlife
ecologist and conservationist, both in North and South America. It would tailor the true and benign goals
of the WFHBA to each special herd and its habitat so that each such would become a splendid example
of harmony and demonstrate how the horses can be brought up to a long-term genetically viable
population level, unlike the AMLs presently being set, while at the same time proving how they can
adapt well to their ecosystems and in a way that enhances such and by which they “contribute to the
diversity of life forms within the nation and enrich the lives of the America people” as the WFRHBA so
eloquently states. Furthermore, with a wise and thoroughly thought-out and implemented Reserve
Design strategy that is faithfully implemented, these herds would become naturally self-stabilizing once
they have filled their respective ecological niches throughout the West. So, I encourage people to
carefully examine the professional plan I have presented to the BLM, USFS and General Public at large
and to get back with me on how we can begin right away to implement this enlightened plan. This would
be the true fulfillment of the noble and life-restoring WFHBA – as opposed to the disgusting and
degrading torture and annihilation of the naturally living mustangs and burros that is presently
occurring! Here is the link: https://thewildhorseconspiracy.org/documents/reserve_design.pdf