2/5/2021

Bureau of Land Management
Applegate Field office
708 West 12th Street
Alturas, CA 96101

Attention Amanda Gearhart, project lead
Email: blm_ca_surprisegather@blm.gov
Tel. (530) 257-0456

Re: Surprise Complex Wild Horse and Burro Gather Plan Preliminary Environmental Assessment (PEA), comments due by Sunday, February 14th, 2021, by email, mail or via the EA online document (click on the Green “Participate Now” button)

Link to document: https://eplanning.blm.gov/epl-front-office/eplanning/nepa/nepa_register.do Select California then Applegate Field Office then the Surprise document.

Dear BLM Officials:
I have just reviewed your PEA concerning your proposal to greatly reduce the wild horses & eliminate the wild burros from the Surprise Complex of Herd Management Areas (HMA) including the Massacre Lakes, Bitner, Nut Mountain, Wall Canyon, High Rock, & Fox Hog HMAs. You indicate that you plan on gathering and removing these equids over a ten-year period & that any mare released back to any of the HMAs would be treated with fertility control. You also indicate that for the purposes of the National Historic Preservation Act, Section 105, the project is classified as: “4. Preliminary determination of no adverse effect to historic properties,” but you thus overlook the great historic value of these wild horses themselves as America’s “living historic treasures”. Additionally, I have the following critical comments & request your response to these important points. I have provided page & section numbers.
P. 3, 1.0: Your announced purpose is to bring the wild equids to the established Appropriate Management Levels (AML) and to implement a range of fertility controls to maintain the population to within AML over a period of up to ten years from the date of the initial gather … to allow for recovery of deteriorated rangeland resources. – Here I object to your assumption that the wild horses are the principal cause of this deterioration while ignoring the ecologically detrimental impacts of livestock, vehicles and many other factors which could include lowering of water tables by inordinate pumping to serve ranches, mining & energy extraction activities, etc.
You indicate that ‘Aerial surveys would be conducted just prior to gathers to verify numbers and location of animals and that the specific number to gather and remove to achieve/maintain AML depends on when the action occurs and how many wild equids are inhabiting the Complex. All female horses returned to Complex would be treated with an approved fertility control in accordance with current BLM policy & guidelines.’ – Given the extremely low AMLs that BLM has assigned to the various HMAs, I consider your proposed herd reductions to be a set up that will render the herds dysfunctional, leading to their decline, & that what would remain would be a mere token, largely domesticated herd, treated much more like livestock than members of the wildlife community. This would be contrary to the true intent of the Wild Free-Roaming Horses & Burros Act (WFHBA)!
1.2. Background: You indicate that the Massacre Lakes HMA horses are included in the Surprise Complex because it is adjacent to the Bitner HMA & wild horses have been observed moving between the two HMAs. The total acreage of the Complex is 396,674 acres of which 377,063 acres are chiefly public & the remainder are private lands (see Table 1-1). The area consists of a vast, diverse and remote landscape in northwestern, Nevada mainly in Washoe County with a small portion in Humboldt County. It is ca. 45 miles long from North to South & 25 miles wide from East to West. Portions are within the Black Rock High Rock National Conservation Area (NCA) administered by BLM. It is bordered to the northeast by the Sheldon National Wildlife Refuge (NWR). It is along Washoe County Route 8A & Washoe County Route 34. On lands adjacent to the eastern side of the complex are several HMAs administered by Nevada BLM’s Black Rock Field Office, namely, the Calico Mountains, Granite Range & Warm Springs Canyon HMAs that are all in the Calico Complex & managed under a different land use plan. The Complex contains many unique & important biological, geological, scenic & cultural resources. Besides providing forage & habitat for wild horses, the Complex is an important habitat for wildlife species including the Greater Sage Grouse, Pronghorn & Mule Deer. The other predominant land uses within the HMAs are livestock grazing, wilderness recreation and general recreation including hunting.’
Page 4:
Table 1-1: Federal & Non-Federal Acreages for HMAs in Surprise Complex:
HMA BLM Acres Non-BLM Acres Total Acres
Massacre Lakes 36,084 3,842 39,926
Bitner 47,766 5,966 53,732
Nut Mountain 38,396 1,840 40,236
Wall Canyon 39,119 2,033 41,152
High Rock 94,612 77 94,689
Fox Hog 121,086 5,853 126,939
Total 377,063 19,611 396,674
The aggregate AML range within the Complex is 283 to 496 wild horses & zero burros, although burros have bene observed in the Complex. (If the burros were here in 1971, they should be legal!)
Critical comments: At the low AML of 283 wild horses for the Complex, which is the goal for the proposed gather, there would be 396,674 divided by 283 equals 1,402 acres, or 2.2 square miles, per individual wild horse; while at the high AML of 496, there would be 396,674 divided by 496 equals 800 acres, or 1.25 square miles, per individual wild horse. At the mean of 389.5, there would be 1,018.42 acres, or 1.59 square miles, per individual wild horse. – Any of these figures would be grossly unfair to the wild horses. I consider your plans extremely prejudice toward these “national heritage species” and urge you to revise them to allow much more substantial numbers of wild horses with much greater forage allocation & other habitat necessities that will allow them to more completely fill their ecological niche in these HMAs consistent with the core intent of the WFHBA, concerning which in 2021 we should be celebrating on the 50th Anniversary of its passage. But with this unfairness there is little to celebrate (see https://www.horsetalk.co.nz/2021/01/02/where-wild-horses-little-to-celebrate ). I urge a serious revision of the 2011 High Rock Complex Wild Horse Population Management Plan (DOI-BLM-CA-N070-2011-04-EA (see especially Section 1.5) & the Cowhead-Massacre Management Framework Plan (MFP) of 1981 & its Record of Decision (ROD) of 1982. These unfair documents affect the Massacre Lakes, Bitner, High Rock, Nut Mountain & Wall Canyon Herd Areas. For the Fox Hog Herd Area, the Tuledad/Homecamp MFP/ROD of 1979 needs to be revised. And for the AML of the Massacre Lake HMA, the Environmental Assessment of 2013, DOI-BLM-CAN070-2013-0021-EA also needs fair revision.
P. 5: Here is a list of the ridiculously low & extremely unfair population assignments by BLM officials, being pressured, undoubtedly, by livestock permittees grazing their cattle/sheep in the legal HA/HMAs as well as other traditionally biased, tunnel vision wild horse enemies including some but not all hunters.
HMA AML
Massacre Lakes 25 – 35
Bitner 15 – 25
Fox Hog 120 – 226
High Rock 78 – 120
Nut Mountain 30 – 55
Wall Canyon 15 – 25
OMG! Such grossly unfair population assignments by our supposed public servants, sworn to uphold all the laws of America, not favor just certain interests such as certain overbearing ranchers & hunters & the greedy organizations representing them.
P. 6: Adjacent Lands Outside of HMAs: Evidence exists of excluding wild horses from habitats to which they should have legal right as part of the year-round occupied habitat in 1971. I question the claim that the “public land portion of the High Rock Complex adjacent and to the west of the six HMAs in the Surprise Complex are areas that did not have wild horses at the time of the passing of the Wild Free-Roaming Horses and Burros Act of 1971 (as amended),” since much of this is based on hearsay evidence from ranchers and others who were their traditional enemies. I have accumulated much evidence for such in my book The Wild Horse Conspiracy.
Current Population Estimate: Here you discount the reasons that there could be an overestimate, for example the airplane-chased wild horses would be more likely to run to another part of the aerial census flight path and be counted twice or multiple times, especially if they are not being identified as individuals.
P. 7: Your line of reasoning seems very tendentious. I pick up that the preparers are trying real hard to discredit the wild horses to the extent they think they can get away with.
Figure 1-1: Wild Horse Population Estimates for Surprise Complex from aerial census 2010 – 2019.
— Where are the relative proportions of livestock & big game & other herbivores such as jackrabbits & insects such as locusts, etc., vis-à-vis the wild horses? This is a major oversight! Another point: since the wild horses are able to survive here & make a comeback, even after severe reductions, this would indicate that they are suitable to this ecosystem, i. e. have a valid ecological niche & role to play here!
Proximity to other HMAs: You suggest coordinating gathers with Winnemucca BLM in order to gut the commingled bands of both the Surprise Complex & the adjacent Calico Mountain Complex. – Your plan comes across as cold-blooded & ruthless with the object of minimizing the wild horses to an outlandishly low population level, with hardly any consideration shown for the wild horses themselves, of their generations of adaptation to this harsh land, of their inherent positive contributions to these habitats, of their aesthetic value to visitors & many related points! And you plan to additionally gather the McGee Mountain HMA wild horses nearby, making this a real wild horse sweep, giving them “no place to run to for safety, no place to hide,” even those who are most fit & possess the most will to live! This will greatly set back the natural process of adaptation & ecological harmonization that has occurred. It will also throw into terrible disarray the social structure, the intra- & inter-band relations that are so important to the health of the herd and the ecosystem. This is so twisted, ignorant, arrogant & mean spirited!
P. 8: 3. Concerning riparian assessment between 2011 & 2020, you heap the blame for degradation on the wild equids but ignore other major factors that could be the main causes of this degradation, namely cattle and sheep, Off-Highway Vehicles, fences that force the wild horses into having very limited places where they can access water – and the list goes on!
4. Concerning cultural & archeological sites: Again, you put 100% of the blame on the wild horses, not even mentioning any other factors, such as those just named.
5. Concerning riparian/wetlands – again 100% of the blame is placed on wild horses, ignoring major destructive factors especially livestock, vehicles, roads!
P. 9. The total forage allocation for wild horses in the Surprise Complex ranges between 3,396 Animal Unit Months (AUMs) at the low AML to 5,952 AUMs at the high AML (Table 1 – 2). Here BLM should have given the reader much needed perspective by contrasting how many AUMs are allocated to livestock including especially cattle & sheep, and also how many are assigned to big game animals such as mule deer and elk.
P. 10. Under 1.3. Purpose & Need for Action. Here you make no mention of other alternatives such as Reserve Design, or reducing livestock, OHV damage, possible mining and energy extraction, etc. For my Reserve Design proposal go to https://thewildhorseconspiracy.org/documents/reserve_design.pdf .
1.4 & 1.6: Concerning the Greater Sage Grouse and Rangeland Health Standards & Guidelines: Your statements seem so perfunctory & tendentious, indicating that you are targeting the wild horses & ignoring the greater picture of what is going on! You need to weigh each of the major factors to arrive at a just assessment. Livestock could be the major factor, also vehicles could be causing major destructive impact to the ecosystem. … Concerning the footnote re: IBLA’s decision: it is clear to me this supposed USDI interior policing agency is caving into the wild horses’ & burros’ traditional enemies while letting livestock and other majorly damaging factors pass without scrutiny!
P. 11: In your statement: “The decision would not set or adjust AML, nor would it adjust livestock use, as these were set through previous land use planning decisions” you block any meaningful attempt to remedy this extremely unjust plan for the wild horses who have legal right to receive “principal” resources in the Surprise Complex of HMAs according to Section 2 (c) of the WFHBA.
2.0: Description of Alternatives: This part of the PEA document glosses over all proposed alternatives that would be beneficial to the wild horses and burros and instead concentrates on twisting all laws & observations dishonestly in order to disfavor the wild horses, thus targeting them for unnatural reduction to a degree that nearly eliminates them from within their legal habitats.
P. 12. 2.2.1: Management Actions Common to Alternatives 1, 2 & 3: — This is a draconian approach to wild horse conservation that treats them more as domestic livestock than the deeply rooted, returned North American natives they in fact are. This contradicts the true spirit & intent of the WFHBA! This wild-horse-ruinous policy needs to be changed! It is a cave-in to the wild horses’ worst enemies that the WFHBA was designed to defend against. Wild horses constitute a General Public & Quality of Life issue, but you appear to be pandering to the public lands exploiters who have long targeted the wild, naturally living horses & burros for discrediting & elimination. Your plan evinces blatant coarse & cavalier disrespect for the equids & their legitimate place on the public & associated lands. And you repel any attempt at reform, as though you were a branch of the public lands livestock industry, the big game industry (even though the equids often compliment ruminant bovids, cervids, etc. in an ecosystem (see: https://www.researchgate.net/publication/239848265_Facilitation_between_Bovids_and_Equids_in_an_African_Savanna & https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2781800/ & https://www.researchgate.net/publication/223007520_Horse_dung_germinable_seed_content_in_relation_to_plant_species_abundance_diet_composition_and_seed_characteristics & https://esc.rutgers.edu/fact_sheet/horses-and-manure/ & https://www.researchgate.net/publication/281822984_A_Geographic_Assessment_of_the_Global_Scope_for_Rewilding_with_Wild-Living_Horses_Equus_ferus ).
P. 13 – 16: Fertility Control: I very much oppose all these cruel & unnatural forms of invasive manipulation of the wild horses. These contradict the true intent of the WFHBA, being major invasive interferences with the naturally living horses. They go against their age-old wisdom & adaptations that have allowed them to survive for millions of years. You would be particularly in violation of Section 3 (a) of the WFHBA that mandates you protect, preserve & manage these animals so as to “achieve and maintain a thriving natural ecological balance on the public lands” and “at the minimum feasible level”. And “manage” should be taken in its benign sense of devising & implementing plans that are beneficial to the wild horses & help them to realize their positive place within the public land ecosystems. “Manage” should not be construed to mean all the opposite of this – as you would be doing with your proposed plan in this PEA. Please put in its place a wholesome Reserve Design strategy that would result in a truly long-term-viable population that is harmoniously adapted to its adequate & legally rightful habitat and that, by filling its age-old niche & role therein would naturally self-stabilize. As an ecological climax species, the horses do this as they fill their niche space & by being allowed to establish mature social groupings, or bands, in which the older mature stallions & mares inhibit reproduction in the less mature horses. These social units are destroyed when you gut the herds through the violent helicopter roundups, after which the remaining wild horses in the bleak aftermath are thrown into terrible disarray – yet they still desperately seek to reestablish their noble & natural place/role as benign components of the western ecosystems. Such noble souls! The every bounce back & seek to restore a wonderful harmony with all the life forms with which they share the Earth as home! This they could do, provided they are not subject to sinister “squeeze plays” by selfish & tunnel-vision vested interests who seek to lord it over what should be honorable & courageous public officials preforming their duty to uphold & defend the wild horses’ basic rights! … I have described in detail how the Reserve Design strategy works & why it would be the true fulfillment of the WFHBA & several related Acts. You can read this in Chapter IV of my book The Wild Horse Conspiracy and in the link given above.
P. 20. 2.3: Alternatives Considered but Dismissed for Detailed Analysis: I think it is appalling that you dismiss Alternative 2: Remove or Reduce Livestock within the Complex. I very much disagree with your statement that this would be “contrary to the BLM’s multiple-use mission as outlined in the 1976 Federal Land Policy and Management Act”. –On the contrary, by restoring the wild horses to truly long-term-viable population levels & giving them adequate habitat commensurate with these population levels, you would be practicing true multiple use on the public lands, because you would be undoing the monopolistic use of the public lands by livestock, which is perpetrated in your current Land Use Plan, both within the Surprise Complex of HMAs & nationally on all the BLM as well as other lands such as those of the US Forest Service. Remember that Code of Federal Regulations 4710.5 & 4710.6 specifically provide for the curtailment or cancellation of livestock grazing privileges on public lands in order to ensure thriving healthy herds of wild horses & burros in their legal areas.
P. 21. Alternative 5: Designate the Complex to be Managed Principally for Wild Horse or Burro Herds: — Yes, you should & could do this if you wanted to. There is the legal justification. This would be the true implementation of the WFHBA; by employing the strategies outlined in my Reserve Design proposal, you could achieve a stabilized population of wild horses within the Complex & one that would be contained, by various means inherent in the Design adopted. The key to our success here involves learning to respect Nature – and this includes the greater nature of horses, which is much more natural than “man-made”! By doing this you would be honoring life rather than torturing life; you would be fulfilling the true intent of the WFHBA & many other worthy & noble laws. This would be a giant leap forward for humankind!
P. 22. 6: Raising the Appropriate Management Level for Wild Horses: –You should definitely do this because, as I have pointed out earlier, your assigned AMLs make a mockery of the true intent of the WFHBA & give the monopoly of resources to public land ranchers & their livestock, be this cattle or sheep or both, as well as to a lesser degree: big game hunters, natural predator exterminators & other despoilers of the public land ecosystem. … Of course, if your heart is not in helping the wild horses & you don’t believe in their natural place in the ecosystem because of your cultural biases that shut out the greater truth concerning them & the ecosystems in which they belong, then you would always come up with one excuse or another to deny the wild horses their right for legal & nature-harmonious, viable population levels & viable habitats. This would be in no way right & would subvert the true intent of the WFBHA, Multiple Use Act, Endangered Species Act, NEPA, National Historic Preservation Act (because these wild horses are a priceless “Living Historic Treasure”), the Administrative Policy Act, along with a number of related laws aimed at restoring & preserving the entire life community for the common good.
7. Wild Horse and Burro Numbers Controlled by Natural Means: — Again, you impose a warped interpretation of the WFHBA by denying the wild horses their legal right to truly become an “integral part of the natural system of public lands” as the WFHBA states they should. For example, they would fill their natural role as prey animals in the natural ecosystem. And it is a fact that mountain lions, wolves, bears & even coyotes as well as other natural mortality actors/factors can & do act as natural controls on wild horse population growth. These can select for the most fit & help adapt the population harmoniously & for long-term survival. (See http://www.jstor.org/stable/3897882 .) Furthermore, you ignore the natural ability of the wild horses to self-limit their numbers as they fill their niche space, establishing home ranges & mature social units, or bands. In well-functioning horse societies, vital knowledge concerning how to survive over the generations & in their unique habitats is passed down from older to younger members. This is a beautiful process – the true one that was envisioned by the conceivers of the WFHBA! Remember: I knew & worked with Velma Bronn Johnston, aka Wild Horse Annie, Hope Ryden & many others throughout the 50 years in which the WFHBA program has been in existence. And 2021 is this noble law’s 50th Anniversary. Thus, fittingly, it is high time that the wild horses & burros & their respective habitats be restored along with the true intent of this great & unanimously passed law!
P. 23 ff. 3.0: Affected Environment: Here you ignore that the horse is a returned North American native, not merely an escapee from ranches or the cavalry. This is extreme narrow mindedness – not at all fair (see Ch. I of my book The Wild Horse Conspiracy as well as my peer-reviewed article “The horse and burro as positively contributing returned natives in North America” whose link is: http://www.sciencepublishinggroup.com/j/ajls.20140201.12 & also Forsten, Ann. Ph.D. 1992. Mitochondrial-DNA timetable and the evolution of Equus … Ann. Zool. Fennici 28: 301-309, as well as MacPhee, Ross, Ph.D. 2013. The Wild Horse is Native to North America. http://www.thecloudfoundation.org/reading-room-faq-s-article/wh-ret
So much of the rest of your document is fraught with the same tendentious & negative interpretations that ignore the major points you should be acknowledging. You indulge in an extreme targeting of the wild horses, heaping blame upon them while ignoring that Greater Perspective concerning what is happening in the Surprise Complex ecosystem. I am particularly disturbed by Section 3.2.2: Livestock …, from the bottom of page 28 to the top of 29. To wit: though you state that “the effected environment … [is] being affected by multiple uses of the land including livestock grazing …”, you go on to state: “[a]djustments to livestock grazing permits is outside the scope of this assessment” – thus slamming the door on any reviewer’s hope that fairer numbers and forage assignments for the wild horses as well as other habitat needs including water & shelter could result due to their input. Yet, these are urgently needed if the wild horses are to truly thrive as a wild species in the long term. … In spite of this hostile treatment, we who appreciate the wild horses in the wild continue to argue with the greater facts and their just interpretation.
P. 30: To appreciate how unfairly large the livestock numbers & forage allocations are relative to those for wild horses, we have but to compare the figures on Table 3-2: Cattle Grazing Summary in the Surprise Complex. Though the grazing allotments are not all within the HMA: still the relative proportions clearly demonstrate how unfairly favored the public lands cattle ranchers are relative to wild horses & the millions of U.S. citizens, aka the General Public, who support them. Yes, both American – and World – citizens are being grossly disfavored concerning this greatly valued Quality of Life Issue.
The table shows a total of 7,483 cattle grazing in & around the wild horse HMAs & having 30,587 Active AUMs. Dividing 30,587 AUMs by 12 months reveals that there are the equivalent of 2,549 year-round cattle occupying this area, compared with the very low AML for the wild horses of only 283 to 496 with a mean of 389.5 wild horses. By dividing 389.5 by 2,549 we see that cattle seem to be getting 85% of the forage pie in this region while the wild horses are restricted considerably less than 15%. And this is in spite of the core proviso of the WFHBA in its Section 2 c that defines the wild horse and burro legal areas as “the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros … and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple use management concept for the public lands”. Also bear in mind that the livestock are placed on the range often at the most favorable seasons to consume the most nutritious forage, then jerked off for consumption by people, thus robbing the natural life community of their recycled remains. Also, evidence of how twisted the interpretation of this noble law has now become concerns how BLM has for years only very imperfectly applied this mandate to a handful of “ranges” that have been declared for the wild horses & burros, while abandoning the true intent of the law that was intended to apply for all the year-round 1971 occupied wild horse & wild burro habitats on BLM & USFS lands. Furthermore, largely ignored are the benign Cooperative Agreements under Sections 4 & 6 of the WFHBA that could and should be established to assure that the wild horses & burros could live in habitats that are commensurate with truly long-term-viable population levels. This, according to objective wild equine experts, should be 2,500 individuals, not the ridiculously low AML assignments that BLM (& USFS) in cahoots with the wild horses’ worst enemies have been putting out in their various EAs, RMPs, HMPs, LUPs, RODs, EISs & other documents. (See Duncan, P. 1992. Zebras, Asses and Horses: An Action Plan for the Conservation of Wild Equids. IUCN Species Survival Commission, Equid Specialist Group. Gland, Switzerland). Considering this, I recommend a full EIS, or Environmental Impact Statement be prepared concerning the Surprise Complex Wild Horse Management Plan in conformance with the National Environmental Policy Act, because the proposed action would have a major negative impact upon the wild horses in this awesome region of Earth as well as upon this traditionally wild-horse-containing ecosystem.
P. 31: Concerning wildfires, the EA is very renege in its failure to recognize the very important role that wild horses play in mitigating & often even preventing catastrophic wildfires on public & private lands. There is much evidence that this is the case & that their free service each year in reducing dry, flammable “tinder” vegetation & restoring healthy, water-retaining soil is worth many millions of dollars, at least, as well as being life-saving. (See pages 35-36 & 152 of my book The Wild Horse Conspiracy & also the “Wild Horse Fire Prevention & Abatement Brigade” proposal by Captain Bill Simpson (see https://www.WHFB.us and go to the plan, as well as https://www.horsetalk.co.nz/2017/07/31/wild-horse-fire-brigade-work/ ).
Also lacking in your document are the many beneficial contributions wild horses make to native wildlife, including ruminant herbivores including Cervids such as deer & elk and Bovids such as sheep & buffalo. This is because the horses have a different caecal digestion system that does not as thoroughly digest what they ingest. I explain this in detail in Ch. II of The Wild Horse Conspiracy. Other exhaustive studies have proven this compatibility. A classic one you should definitely read is: Bell, R.H.V. 1970. The use of the herb layer by grazing ungulates in the Serengeti. IN: Watson, A. Editor. Animal Populations in Relation to the Food Source. British Ecological Society Symposium. Blackwell Science Pub. Oxford.
P. 32. Your treatment of Riparian & Wetland sites is again tendentious. It lays the blame for deterioration upon the wild horses while ignoring all the other numerous factors & extenuating circumstances involved with what is happening to these sites. This includes putting the squeeze on the wild horses through restriction by fences & other means that impede their free-roaming lifestyle – something that should be guaranteed by the WFHBA but is being to a great degree being ignored by BLM officials. Of course, Livestock and Off Highway Vehicles, including 4WDs & ORVs, come particularly to mind when considering just exactly who is to blame for deteriorating riparian & wetland habitats.
I have spent considerable time in the HMAs of the Surprise Complex & did the famous High Rock Pass jeep route in a 4WD Durango. This was a formidable challenge, but I still had time to observe how, even in these remote areas, the ranchers & to a lesser extent the hunters, not to mention the OHVers obviously, were being catered to and the wild horses impacted & squeezed out of a large portion of their legal resources by these factors. – And how easy it is for BLM to set the wild horses up for failure in these remote areas by denying them their viable resources & forcing them into a desperate situation, which is exactly what has been and continues to happen! BLM could do so much to prevent the degraded springs & riparian habitats but continues to fail to take the needed actions. All the while it uses these degraded conditions to justify the near elimination of the wild horses from their legal habitats where, by law, they are supposed to be the “principal” resource recipients, not relegated to a minor portion thereof.
P. 38 ff. Special Status Species (SSS), Greater Sage Grouse, etc.: — The same sort of deceptive squeeze play is going on in regard to the SSS species as with the riparian habitats. The wild horses are being set up for blame while the major disruptive factors go largely ignored. This is not only exasperating but criminal behavior, especially for public officials sworn to fairly and equitably uphold all the laws of America & not favor money & power motivated interests to the exclusion of the natural values & presences, including the much cherished wild and free-living horses. The latter are a truly “world class” value that would draw many ecotourists to boost the economy, IF BLM & USFS & state & local agencies as well as locals were wakerife (Scottish for “alert”) enough to recognize their great value!
P. 40: Wild Horses and Burros: Here the EA uses the “metapopulation” observation of the 2013 NAS report as a justification for the outrageously low AML assignment of 283 low to 496 high for a mean of 389.5 horses. Remember that given the 396,674 acres in the Surprise Complex, this is the equivalent of allowing only one individual wild horse for every 2.2 square miles at the low AML, for every 1.59 square miles at the mean AML, and for every 1.25 square miles at the high AML. Overlooking the egregiousness of this population assignment would make one party to this crime.
From this PEA, it seems BLM’s goal is to domesticate a tiny & drugged up, sex-skewed, dysfunctional, mere token mustang remnant population in the vast Surprise Complex, while delivering the monopoly of natural resources to predominantly cattle ranchers, among other resource exploiters. As the PEA goes on and on about maintaining minimum genetic diversity in the herd by means of the metapopulation, it covers up the gross injustice it is, in fact, attempting to perpetrate upon the legal principal wild horses in their legal habitat!
P. 41. Concerning Diet & Overlap: — Again the PEA selectively skews the factual information & fails to emphasize the many positive benefits for an ecosystem when the horse, as a different type of mammalian herbivore, is allowed to establish itself in a way that brings greater balances to an ecosystem presently too dominated by a preponderance of cloven-hoofed ruminants. The EA preparers should taken seriously wildlife biologist Meeker’s findings concerning how compatible wild horses are with the Pronghorn, for example (see Meeker, Jo O. 1979. “Interactions between Pronghorn Antelope and Feral Horses in Northwestern Nevada.” Master’s of Science, Wildlife Management Thesis. Univ. of Nevada-Reno).
The statement that “horses can be more destructive to the range than cattle” reveals a tunnel vision approach to the subject. This ignores the horses’ greater ability to build healthy soils through their droppings & to disperse more intact plant seeds of a great variety, both through epi-zoochory & endo-zoochory (see https://www.academia.edu/14320688/Complementarity_of_epi-and_endozoochory_of_plant_seeds_by_free_ranging_donkeys ).
The rest of page 41 is decidedly twists the facts in order to discredit the mustangs. Why do the authors ignore the major destructive impact of the much heavier utilizers of this range: the cattle? And to a lesser extent the officially promoted game animals, particularly Mule Deer? Furthermore, this document negatively spins the wild horses’ ability to disperse intact seeds and to aid in their germination by fertilizing the soils. The preparers just emphasize the non-natives, yet many native plants greatly benefit from the horses’ presence. This is logical since the horses coevolved with a myriad of these plant species for thousands & in many cases even millions of years. Also, the PEA cites researchers whose work is often biased against the wild horses and overlooks the “big picture”.
P. 42: The whole discussion concerning water & riparian effects of wild horses is designed to discredit them & justify their very unjust extreme reduction! Again, largely ignored are all the other factors operating here including livestock, fences, big game favoring, water manipulation & pumping, & the normal behavior of the mustangs to broadly disperse their foraging rather than lingering at springs & riparian habitats as domestic cattle do when foisted onto the public rangelands particularly in the Great Basin & drier Western habitats, e.g. in southern Nevada, Arizona & New Mexico. I think that the EA preparers have selected extreme examples & cited sources who are not objective but go out of their way to target & discredit the wild horses.
BLM could remedy this terrible situation by stopping its resource squeeze play against the wild horses – by stopping giving 85% or more of the forage to livestock, fencing off major water sources, eliminating prime wild horse habitat areas from the HMAs that typically goes on throughout the West & contrary to the WFHBA! It is egregious how the preparers of this document try to make BLM look like a hero who prevents wild horse suffering dehydration & death when, in fact, these same officials have, either blatantly or in concealed manner, deprived them of adequate water, forage & other survival resources or access to these.
Results of Win Equus Population Modeling: These fail to consider how the wild horses have a natural ability to self-stabilize their population numbers as ecological climax species, as opposed to subclimax species.
P. 43 & 44: Wilderness & WSA: Again BLM fails to recognize wild horses as restorers & enhancers of wilderness ecosystems, as returned North American natives & also how many of the General Public who appreciate wilderness also appreciate wild horses as integral components thereof.
P. 44 ff: Environmental Consequences: Again, this treatment is a heavy distortion of the greater facts & context. I am greatly offended by the “target mentality” displayed in this document. I know BLM employees have their orders, but it is shameful nonetheless. I used to work for BLM and remember that the prejudice against the wild horses and burros was so thick one could cut it with a knife. This is often due to the fact that those running the program come from livestock backgrounds and have been brainwashed on the subject from an early age.
Now at the 50th Anniversary of the noble Wild Free-Roaming Horses & Burros Act, it is high time that the true intent of this wonderful act be restored along with the herds and their habitats. And if the two agencies who have been charged by this law to honorably and fairly defend and protect the wild horses and burros – not just manage them to death – cannot get on board with this, then an amendment to the WFHBA should place the control of these herds and their legal lands into a genuinely pro-wild-horse-and-burro agency with autonomy over the herds and their legal lands.
The Surprise Complex is a spectacular place that is ideally suited to be home of a vibrant, thriving and viably sized wild horse population. But in order for this to happen, we people must learn to share the land and freedom with such magnificent beings as these. Now, I ask you: Haven’t they done such a world of good for us? And isn’t it high time that we do something truly good for them? For this was what the WFHBA is all about!
I look forward to your considerate response to the points I have raised and would welcome the opportunity to work with you in constructing a much fairer plan for these beautiful and highly evolved beings, one that includes a just and suitable share of habitat to sustain long-term viable populations that are allowed to integrate harmoniously – as the horses themselves are such superstars at doing!
Sincerely,

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

cc: various interested parties.