Advisory Board Comment – Comments due Tuesday, October 2nd, 2018
September 30, 2018
National Wild Horse & Burro Advisory Board
c/o Bureau of Land Management – USDI
3405 White Lake Parkway
Reno, Nevada 89502
Email to send comment: firstname.lastname@example.org
Tel. (775) 861-6594/6583
Subject line: “Advisory Board Comment” (Comments due Tuesday, October 2nd, 2018.)
For input to all board members for Salt Lake City-Utah board meeting on October 5th & following days.
Honorable Board Members:
Congratulations on having been entrusted to oversee the protection & preservation of America’s wild horses & wild burros under the Wild Free-Roaming Horses & Burros Act (WFHBA). I wish you every success in attaining this Act’s true and noble goal. The heart & soul of the WFHBA is to preserve, protect & restore our fellow companions – the horses & burros – to their natural & harmonious way of life here in North America, their evolutionary cradle. This is to take place in & adjacent to habitats that they occupied in 1971 at the passage of the WFHBA.
This central point must not be misconstrued into anything else but to signify their year-round habitat. Of key importance here also is that Sections 4 & 6 of the Act should be employed in order to secure complete & long-term-viable habitats for complete & long-term viable equid populations as well as to adapt to environmental & political changes that inevitably occur over the years. The noble fulfillment of these duties will assure that all the diverse, naturally living horse & burro populations regain & retain their natural vigor in adequately sized & composed habitats that are defended, not abandoned, by our government.
Our goal under the law must be for “long-term viable” equid populations in long-term-viable habitats. These herds should be composed of many bands in the case of horses & of many jack-territorial associations in the case of burros. The beauty of Sections 4 & 6 of the Act is their allowing for naturally defined wild-equid-containing habitats that meet all of their survival requirements during any given year & allow for changing conditions in future years. This can occur through the vital setting up of cooperative agreements with adjacent landowners & local, state, or other government agencies that have jurisdiction over lands that are important – even critical to the wild horses & wild burros. Such cooperative agreements have been established throughout the 47-year history of the Act, but need to be stepped up – & there exist many positively disposed entities who very much want to make this happen (see my Horse Mountain Wild Horse HMA restoration proposal to Carson City BLM attached). A major selling point here is the ability of naturally-living horses & burros to greatly reduce & even prevent major wildfires that are very much increasing today due to Global Warming (see attached documents).
As you probably noted, I am urging a reverse direction for America’s wild horse & wild burro program, for previous years have seen our wild equids overly diminished & compromised in terms of their Appropriate Management Levels (AMLs) of herd size, forage, water & other vital resource allocations, as well as the recognized land that they are being allowed to occupy. Very unnatural constraints are being imposed on their survival requirements, both as individuals & as populations due to an insidious & biased approach to them, one that is born of basically negative attitudes toward and presumptions about America’s wild equids. These attitudes must be transformed into much more positive ones that are not loathe to proclaim the positive contributions that wild horses & wild burros make as components in suitable natural ecosystems. These innocent and beneficent animals must not continue to be “set up for failure” by very ungenerous & selfish vested interests & those who dishonorably serve the latter as government officials. Also these “national heritage species” should be protected under the National Historical Heritage Act & also be recognized as deeply rooted North American natives whose origin is upon this continent. And we humans desperately need to seriously recognize that the solution to greed & selfishness is not more greed & selfishness, but all the opposite: generosity & a noble identification & expanded concern for & with species other than just our own human species … and furthermore with the greater life community which all species together compose, including both people & equids. This is the great & vastly important moral & at the same time practical challenge of the WFHBA. And meeting this has never been more important that it is today! This is not a minor insignificant law, but one that strikes to the core of the healing changes that are most needed today!
The AMLs that have been assigned for America’s last remaining wild equids total less than 27,000 individuals within a greatly diminished number of HMAs (now only 177 on BLM lands & a relatively few more on USFS lands). Furthermore, greatly diminished acreages have been assigned by our supposed public servants: wild horses & burros would only be allowed to remain on less than 27 million acres of usually the most marginally productive & watered quality. This mean-spirited treatment of our wild horses & burros is disgraceful & makes a mockery of the unanimously passed WFHBA! These figures work out to over 1,000-acres per remaining individual equid – which is practically a wild-equid-empty ecosystem! Viewing these figures, it becomes readily apparent that the BLM & USFS are abandoning their duty to protect & defend the legal rights of the wild horse & wild burros to sufficient & adequate lands, or habitats, & their accompanying resources – resources that are necessary to establish truly healthy & viable as well as widespread wild equid populations throughout the Western states. Here the WFHBA intends the wild horses & burros to be the “principal” presences – not relegated to the bottom of the list of priorities as mere token & dysfunctional, tampered with & overly constrained vestige herds that have been very much semi-domesticated contrary to this noble law’s true intent!
On average, in the greatly reduced HMAs, livestock receive ca. 85% of the forage allocations while the remaining ca. 15% is allocated to wildlife including wild equids. This then pits big-game hunting establishments against the wild horses in these areas, although it has been amply proven that the post-gastric-digesting & semi-nomadic wild equids actually help, or complement, the pre-gastric-ruminant-digesting, cloven-hooved artiodactyl herbivores. Such actions & policies again perversely defy the WFHBA, which states that these herd areas are to be “devoted principally” to the welfare & benefit of the wild horses & wild burros, not to ranchers, miners & energy extractors, big game hunters & other exploiters of public land resources. The latter priority is done at a terrible cost to the long-term health of these vast ecosystems – ecosystems that are crucial to restoring much-needed balance within the Global Ecosystem that today is dangerously out of kilter in many respects due to modern humanity’s blind expansion & plundering of Nature. To overlook this salient injustice constitutes a grievous insult to the General Public who greatly value the wild horses & wild burros in the wild as a Quality of Life issue & do not want to see them displaced from their rightful legal habitats, or, if allowed to stay in greatly diminished numbers, to be allocated only a very unfair, minor portion of the forage, water, spatial & other critical resources & essential habitat components. – This is a very wrong abuse of all citizens of America & a dishonest perversion of a noble & progressive law that should not be tolerated!
Originally under the 1971 WFHBA, America’s wild horses & wild burros should have been allowed to inhabit at least ca. 55-million acres of BLM & USFS lands & that according to the USGS estimates, this figure could have been upwards to ca. 88-million acres. However, due to various often dishonest means, America’s wild equids have been displaced from/cheated out of at least half & likely much more of their rightful legal habitats. And, if this reminds you of what happened to Native Americas & the “broken treaties,” then – Good News! – your awareness & conscience is still intact & germane to what’s of crucial importance today in our shared home world.
And here’s another point I consider unavoidable: Given the great diminishment of both (1) the legal lands & their habitat resources; & (2) the wild horse & wild burro populations themselves, common-sense justice requires that in those unfairly reduced, legal core lands assigned for wild horses & wild burros (the Herd Management Areas on BLM lands), the horses & burros themselves should become the recipients of the major portion of the survival resources, including forage, water, shelter, etc., as well as be allowed to establish truly long-term, viably sized & composed populations (2,500 individuals according to the World Conservation Unions SSC Equid Specialist Group). This would be a way of justly compensating them for past injustice they have suffered from people. Yet the current proposals are all the opposite of this! For those in charge seem impervious to our calls for justice, remaining intransigent & unyielding in their obstinate & destructive intentions toward the naturally-living horses & burros & their legal & naturally suitable lands, or habitats.
There is so much more to be said for & about the wild horses & burros, & for this reason both as a wildlife ecologist & even more as a human being aware of his kinship with & obligation toward the wild horses & burros, I wrote a well-rounded, 313-page book, The Wild Horse Conspiracy. Copies of this book have been given to your board at its past meetings; & I am again offering copies to each new board member along with additional articles, reports, proposals & other information in the sincere hope & good faith that these, together with my personal testimony, can & will make a positive difference for the wild ones. You will find in these documents many important reasons why the present proposals by BLM to sterilize or semi-sterilize the legally protected wild equids & to otherwise tamper with & manipulate their inherent constitutions & natures are not only contrary to the WFHBA but biologically & ecologically unsound &, as such, immoral & abusive toward these highly evolved animals. Both the horse & the burro have done so much for our species. Now isn’t it high time we do something truly good for them. And what better act of beneficence than pulling in our devilish horns of worldly greed & selfishness & truly sharing an appropriate & generous portion of the land & freedom with them? Remarkably, we would then find that we humans would overcome what ails us most & is, in truth, in most urgent need of changing.
In closing, I again ask you to seriously consider the Reserve Design proposal I have elaborated as a professional ecologist & to redesign America’s program & approach to wild horse & wild burro protection & preservation, so that it will become more than mere hypocritical tokenism, because we humans will have truly learned to see that life is more than just all about us humans & our worldly domination & self-aggrandizement … for in truth it is about ALL THE WHOLE & GREAT FAMILY OF LIFE LIVING INTERRELATEDLY & INDISPENSABLY TOGETHER & LEARNING TO APPRECIATE ABOUT AND CARE FOR ALL FELLOW SENTIENT BEINGS.
Craig C. Downer
Wild Horse & Burro Fund
P.O. Box 456
Minden, NV 89423
Enclosures/Attachments included with this message to the Board.
Cc: Various interested parties.