Horse News

Renowned Wild Horse Expert Disputes BLM’s Flawed Math

From: Craig Downer
Cc: Craig Downer
Sent: Sun, January 30, 2011 4:59:49 PM
Subject: Re: Triple B, Maverick-Medicine and Antelope Valley HMA’s Preliminary E.A. DOI-BLM-NV-L010-2011-0004-EA

Craig Downer and R.T. Fitch at Twin Peaks Roundup ~ photo by Terry Fitch

January 30, 2011

BLM Ely District Office

HC 33 Box 33500

Ely, NV 89301

Attn: Gary W. Medlyn, Egan Field Manager


Re: Triple B, Maverick-Medicine and Antelope Valley  HMA’s Preliminary Environmental Assessment DOI-BLM-NV-L010-2011-0004-EA

Dear Sirs:

Thank you for this opportunity to give input.  I have reviewed the E.A. and am disturbed by the repeated arguments that I have read many times before as concerns “wild horse overpopulation,” “multiple use,” “thriving ecological balance,” etc.  The employment of these terms to justify what you are planning to do to the wild horses makes a mockery of their true meaning.

Objectively there is no overpopulation of wild horses in the herd management areas/wild horse territories under consideration.  How can there be when the current estimated population of 2,198 wild horses translates into 766 acres per individual wild horse in 1,682,998 acres of hma’s (BLM) or wild horse territories (USFS)?  After the proposed roundup to reduce the population by 1,726 to 472 wild horses, there would remain an immense 3,566 acres of legal habitat per individual wild horse.  This would be a nearly wild-horse-empty wild horse hma complex.  This mocks the Wild Free Roaming Horse and Burro Act (WFRHBA) where it clearly states that wild horse/burro herd areas shall be dedicated “principally though not necessarily exclusively” to the wild horses/burros in the wild.  This latter is in keeping with the multiple use concept of the public lands (upheld by the Federal Land Policy and Management Act as well as the Multiple Use Act), since the wild horse and burro areas only represent a small percentage of the public lands (ca. 12%).  To squeeze their population down to such radically low levels expands the monopoly of livestock upon the public lands as a whole.  I detect a biased motivation operating to the detriment of the wild horses and burros. Year after year, this further displaces the wild equids and reduces their numbers, ignores their legal right to freedom and land, further disrupts their natural adaptation where found as well as their self-stabilizing societies, etc.

Examining Tables 3, 4 & 5 of your EA, I see that there are a total of 28 livestock grazing permittees/allotments of which 17 have 90% to 100% of their allotments within the hma’s.   These livestock graziers have a total of currently permitted livestock Animal Unit Months (AUM’s) of 88,978 on a year round basis.  Since the current wild horse population is 2,198, there are 26,376 AUM’s (2,198 x 12 months) currently being utilized by wild horses in the complex.  This represents a little less than 30% of livestock AUM’s and only 23% of the total livestock plus wild horse AUM’s of 115,354.  This is not an overwhelming percentage and in no fashion constitutes the “principal” in these hma’s.  Yet, unsatisfied with this, your plan is to reduce the herds to the lower end Appropriate Management Level (AML) of 472 wild horses.  This figure of 472 represents 5,664 AUM’s per year, which is only 6.4% of permitted livestock AUM’s and a little under 6% of combined livestock and wild horse year-round AUM’s.  The upper end of the AML is 889, which multiplied by 12 months equals 10,668 AUM’s per year.  This is still only about one-nineth of livestock within the wild horse complex …even less of the combined.

This is an extreme marginalizing of the wild horse presence and, for this reason, I urge you to increase the AUM’s for wild horses, and to decrease the AUM’s for livestock, with the goal being that wild horses receive at least 50% of the grazing allotments in order to comply with the “principal” mandate of WFRHBA.  I therefore favor the No Action alternative proposal in your EA and urge you to reformulate a more just plan here, employing principles of Reserve Design that involve buffer zones, natural barriers and predators, and the allowing of the wild horses to fill their niche and naturally self-stabilize.  This would obviate the cruel and biologically disruptive helicopter roundups that are now causing such enormous problems, suffering and death for the wild horses.

Finally, I urge you to hold your ground in the water issue in Nevada and not be cajoled by vested interests — under the guise of state’s rights — into relinquishing water for the wild horses.  As a 4th generation Nevadan and holder of my high school’s history award, I know that the Nevada State Constitution gives top priority to the federal government on all lands that were not claimed during the first several years after the Civil War and the formation of Nevada.

Please feel free to contact me for further details about my protest of your proposal, reserve design, etc.  Again I appreciate this opportunity to give input and look forward to hearing from you again soon.


Craig C. Downer, Wildlife Ecologist

33 replies »

  1. No one states the facts like Mr Downer, and no one hits home like Mr Fitch. Well said, and thank you, to you both. Give ’em hell, guys, the horses need you!


  2. Thank you Craig. Time after time, HMA after HMA we see that horses are being given the extreme short end of the stick. Yet still our wild horses are being stampeded in front of helicopters by contractors that are more and more inane and inept. Still they try to blow smoke in our eyes with statements and reports that should end with “abracadabra” and a rabbit coming out of Salazar’s “cowboy” hat. Yes once again we will all respond to the comment period. During one court case they actually did count the number of response, maybe one day they will actually read and consider the opinions of well-informed, intelligent and caring advocates. Thank you RT for posting this.


    • Have to agree with Catherine…you are awesome!! We all sincerely appreciate the time and knowledge you and RT put forth in bringing the facts to light, which they continue to overlook and dismiss. Let’s hope those in Congress will see it for what it is and really do something about it. We must keep the pressure on, if we are to be successful. Thanks again, Craig!


  3. Logic runs amok in the world of the BLM. Rounding them up is a cash cow, a gift from the taxpayers. The truth means nothing as millions of dollars change hands from the helicopters, to the truckers, the hay, feed, vets, branders, the men with plastic flags. It’s a multi million dollar industry and not likely to stop just because were right. In my opinion only one man can stop it, we talked about it before, we must somehow make this President the one that is responsible for the elimination of Americas living symbol of freedom.


    • In doing so, please remember that President Bush signed their death warrent by signing a bill allowing these round ups and the sale of our national treasures. I implore President Obama to stand up and do the right thing. The people have spoken. Now it is up to him.


      • Jan I agree that the persecution and “death warrant” on the Wild Horses & Burros was signed by Bush, however our President Obama, (…..I regret to say, I supported) is just as bad by turning deaf ears, and refusing to even acknowledge our pleas! Currently the only thing that is “Bi-partisan” is CORRUPTION, AND GREED”!


  4. There is another important deadline to have in by tomorrow. These
    Resource Management Plans are where the damage starts and the Wild Horses and Burros get edged out. When you sign a petition, be certain to comment, as well, so that your individual signature will be counted:

    Submit Your Letters Today!

    Comment on Draft Jarbidge Resource Management Plan

    The Bureau of Land Management’s (BLM’s) Jarbidge, Idaho Field Office is accepting public comments on a draft Resource Management Plan (RMP). When approved, the RMP will set policy for managing a 1.4 million-acre public lands area in southern Idaho for the next 15-20 years. Submit your letters by January 31st! Take easy action here:


  5. Thanks much, fellow wild horse enthusiasts. I am meditating that the message will really reach home in the minds and hearts and wills of those who can do something about the abominable injustice that is being perpetrated against those beautiful and powerful healers and restorers of the West — its wild horses and burros. But no change occurs without sacrifice. It’s like this: in order to move one step up on the ladder one must relinquish ones position on the lower rung and move to the higher. So it is with humanity’s learning to live in harmony again with all the wonderful species and to share habitat and freedom. We can do it! We must learn a better way that permits living with such wonders as the horses and burros in the wild. This was and remains the very heart of the Wild Free Roaming Horses and Burros Act of 1971 … still on the books, by the way Mr. President!


    • Evolution of man”kind” comes without great opposition.
      Excellent letter. The facts make everything all too clear. Time is of the essence at this point.


    • Thank you Craig – thorough and very well done. If you could get before congress personally or before one their committees such as Natural Resources, or at the least send your study to each member of congress, perhaps enough eyes could be opened to spur positive action. I think any permanent resolution that would stop this inexcusable criminal action by the BLM must come from congress. They are working on budget right now and they hold the purse strings for allocating funding to the BLM. If they can be convinced to cut off the money flowing into this egregious program it would have to grind to a halt. There is a great sense of urgency because if they are allowed to continue much longer, the damage they are doing will be irreversible. We do not need another law, they just need to reinforce and insist on adherence what has been on the books for decades. I am not holding my breath waiting for the guy in the White House to do something.


      • Thank you~well put. Why is it that it always takes another Law to make the other law worth what it states. You said it much better than I did.


  6. Dear Craig: I vote we send you to Washington and and have you explain this to our Congress. The people of the United States will understand your letter. This is what they need to see to fully understand this campaign of lies to subvert their will to protect the habitat and lives of our wild horses and burros. Thank you.


  7. A really well done piece Craig, thanks so much for your continuing work on behalf of the horses lives and freedom!! Leslie


  8. Craig and R.T. Fitch, we should have you at the helm, our guiding light beams from above. The heavens are speaking loud and clear. Well stated with facts and give it to them. Our horses need the land back and they need to come out of the holding pens.
    The cattle ranchers are making too much money. I have stopped eating beef. Some of my friends are starting to do the same thing. Boycott beef. No cows on this land, leave it for our horses along with water rights too.
    Protecting and defending our horses so they can experience freedom on the range. We must stand up and speak to the world. Let them know this is important and we believe in sustaining our horses on our public lands instead of cattle. It is time to take it back for our horses.


  9. As as always, Craig, you are the voice of sound judgment based in irrefutable science. I just hope there are some in DC that have enough sense to know the truth when they see it.


  10. Craig, excellent work as always, jam packed with FACTS and undisputable MATH :)) I agree this letter should be read to Congress by you,a life long “Ambassador of the Wild Horses & Burros. I am proud to call you a FRIEND and the Wild ones are indeed very fortunate to have your loyalty and undying support. With gratitude; Anne-Marie & the Mustangs:))


  11. As many have stated in a variety of words and ways, how a government agency funded by it’s funding organization….the American Taxpayer can continue to ignore the outrage and facts that are repeatedly presented to them is beyond comprehension.

    I would also add that if the likes of Mr. Downer and Ms. McDonald can put a brief statement together and provide it here at SFTHH with costs and numbers, we might be able to email ALL the leadership of Congress and the White House and say………….”not only are you elected officials wasting money, violating the intent of the 1971 ACT, and ignoring a legitimaste constituent of Americans that don’t like what is going on with regard to wild equines….you are spitting on everything decent about America and our history”.

    Mr. Downer…thank you. The numbers and monies just NEVER add up.


  12. So here we see an example of intellectual and rational thinking. This is so far away from what the government is about. They know what they do is wrong. Not one of them has the means to say “stop”! Our society is so damaged.


  13. Craig’s letter could be sent to Congressman Burton

    Congressman Dan Burton Speaks Out Against Obama’s Mismanagement of Wild Horses
    2308 Rayburn House Office Building
    Washington, D.C. 20515-0001
    OR use Postal Code 46229 to Send an EMAIL thanking Congressman Burton for his outstanding leadership


  14. First, thank you, Mr. Downer. Your articulate and considered argument against the “gathers” and inequitable ‘sharing’ of public lands was both balanced and informative.
    However, I would like to comment about to cries for reduced funding for the BLM. We should be careful in this regard. The vast majority of the public has no experience with, or of, horses but everyone can relate to financial difficulties. America is still facing tough times and what we do NOT want is a public outcry which leads to demands for reducing the number of horses held by the BLM. This can lead to only one outcome – a trail of tears to Canada or Mexico. What the horses need is a reduction in grazing and mining permits on public lands….or…a SUBSTANTIAL set aside of dedicated lands with enough area to support genealogical diversity. Neither option is ideal, of course (the optimal would be a wilderness devoted to the wild) but in order to achieve some kind of equity, compromises may have to be made.


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