May 19th, 2009
Bureau of Land Management
Wild Horse and Burro Program
1340 Financial Blvd.
Reno, NV 89520
Attn: Jo Lynn Worley
Re: Helicopter Hearing for 20th May, 2009
I am opposed to helicopter roundups of wild horses and burros, for these are both unnecessary and cruel. They result in many injuries and deaths. And they have already greatly disrupted the social structures of the Western herds and decimated these populations, either entirely eliminating them from their legal areas or reducing them to non-viable population levels, even according to BLM’s very questionable standards of 150 for Minimum Viable Population (MVP). According to the IUCN Species Survival Commission Equid Specialist Group (1992), 2,500 individuals are necessary for the long-term survival, or viability, of an equid population living in the wild, and 500 for a tightly managed domesticated population. It is apparent from this erudite guidance that the BLM is again setting the horses and burros up for inbreeding and die out – something that seems to have been its plan all along.
I have noted the excellent work of Cindy MacDonald on her web page: www.AmericanHerds.com. Here is revealed what has happened in many of the zeroed-out herd and herd management areas, both in Nevada as throughout the West. The horses and burros are no longer present in spite of their legal right as the principal species named for these areas under the Wild Free-Roaming Horse and Burro Act of 1971. In their place are many livestock and/or big game animals. The Delamar HMA of Ely District, Nevada, is one herd I have visited – a beautiful place for wild horses but now only full of cattle, for zeroed out. Clover Mountain, South Pancakes, also Ely District, and in southern California Coyote Canyon for Spanish mustangs and Clark Mountain for a distinctive race of burros – also zeroed out in spite of the law and their popularity with the public. And the list goes on ad nauseam.
Why aren’t BLM and USFS employing C.F.R. 4710.5 & .6, a.k.a. Closure to Livestock, in order to maintain viable herds on what is, in fact, only a small fraction of the public lands legally designated for the wild equids? Clearly, the federal government is in the position to assure viable populations, but is refusing to do so and is, in fact, siding with the traditional enemies of the wild horses and burros in the wild. Alarmingly, 1.6 million acres of legal wild horse territory have recently been zeroed out by BLM in its Ely Nevada District alone. In Montana, 6 out of the original 7 herd areas have been zeroed out representing 83% of the legal acreage, and the one remaining herd, the authentic Spanish Pryor Mountain mustangs, has a non-viable so-called Appropriate Management Level below 150. In New Mexico 77% of the legal acreage has been zeroed out. In California, 65%! In Wyoming, 54%! In Colorado, 45%!. Refer to my Columbus Day-2008 speech “Forever Wild and Free” for fuller details (wildhorsepreservation.com).
Presently before Congress, Bill H.R. 1018 would reinstate the proscription against helicopter and other mechanized roundups as well as against sale to slaughter buyers, a.k.a. the Burn’s Amendment, both of which are being used to further decimate the herds. By breaking up the band and herd social structures, these roundups cause remaining horses to reproduce at very young ages, something that is prevented when the family units are in tact. Also these greatly traumatize the horses who are captured, causing them to experience an equid version of Post Combat Traumatic Syndrome that remains with them for the rest of their lives! – Business as usual cannot be allowed to continue for our nation’s scant remaining wild horses and burros, for the motto of such is: “the only good horse or burro is a slave or dead horse or burro”, similar to what used to be said of the Grizzly Bear, Wolf, Mountain Lion and even the naturally living Native American. Nationwide, there are now less wild horses and burros that were present on the public BLM and USFS lands at the passage of their protective act in 1971 when they were considered to be “fast disappearing from the American scene” – and this tells a lot about who their worse enemies are, i.e. those charged by law with protecting them and their right to freedom in their legally designated herd areas!
As a wildlife ecologist, I recommend that America’s Wild Horse and Burro program be revamped. Its focus must be placed on restoring truly long-term viable wild living horse and burro herds in areas of adequate size and resources to sustain such. Through the astute employment of Reserve Design, the wild herds can fill their ecological niche to become self-stabilizing populations and in the process greatly aid in preventing catastrophic fires now menacing the West. This they can do, true to their semi-nomadic life style, through the widespread consumption of dry flammable vegetation. In this alarming era of Global Warming, they are here to help if we can only recognize this and allow them to be themselves. Together with other components of the ecosystem, they will greatly aid in restoring the West: its soils, its waters, its biodiversity, its vitality and its beauty as the returned natives they, in fact, are, if we people can only learn to appreciate them in depth and just give them the chance.
In closing, as before, I offer my collaboration in this most crucial and timely challenge.
Craig C. Downer
P.O. Box 456
Minden, NV 89423
The 2003 Coyote Canyon Mustang round-up stole the last remaining wild herd from California!