Horse News

Urgent: Piceance-East Douglas Preliminary BLM Wild Horse Environmental Assessment

Report by Lisa LeBlanc ~ Charter Member of WHFF’s Advisory Board

UPDATE: Comments Needed by EOB TODAY!

Editor’s Note: Lisa was kind enough to wade through this document crammed packed with disingenuous facts, figures and diagrams.  You may find the report by clicking (HERE).  If you do not have the time to read it in its enirety, yourself, please glean the high points from Lisa’s report and  follow these BLM instructions to comment.  ‘All comments must be submitted in writing and received by the WRFO by the close of business on August 8, 2011.  Comments may be sent via e-mail to  with “Wild Horse Removal Plan” in the subject line of the email. Comments can also be sent by regular mail to the Bureau of Land Management, White River Field Office: attention Melissa Kindall, 220 East Market Street, Meeker, CO. 81641. For additional questions or information please contact James Roberts at 970-878-3873 or Melissa Kindall at 970-878-3842. ‘  I thank you for the horses and thank Lisa for all of her hard work as this scheduled stampede is personal, it is one of the herds that we have been legally fighting with the BLM over as they went after it to zero out the horses last year.  This year it appears that their plan is to just destroy the herds genetic viability so that it will ultimately die out.  We are still engrossed in litigation in an effort to prevent this from happening.  If you would be interested in reading our legal documentation on this case you may do so by clicking (HERE) for the Wild Horse Freedom Federation.  This all about the ‘Advocate Education’ thing that we have been talking about.  Let’s go through this and talk about it, today.”  Keep the faith.” ~ R.T.

This analysis was not conducted with the intent of submitting comments in opposition of the round-up but instead to understand the White River Field Office’s reasoning for why this roundup should take place. There is acknowledgement of the history of this management area; but also how it’s past administration may now be contributing to the perception of range degradation and overpopulation. Also, there may be some personal bias evident and for that I apologize; I have tried to view this with a clinical eye and simply report facts as outlined in the Preliminary Environmental Assessment.

The Piceance-East Douglas Herd Management Area encompasses 190,130 acres, with an AML range for wild horses of 135-235 animals. This equates to 809 – 1,408 acres of forage to sustain a single wild horse within the HMA. Since 1997, Wild horses have been authorized 2,568 AUMs and, according to the EA, are currently responsible for consumption “128% above allowable use“. Cattle are allocated 6,935 AUMs, however, even exceeding allowed forage, wild horse use is still 1,110 units below what cattle are allocated.

Four Grazing Allotments encompass 166,888 acres of the HMA. And while wild horses are present throughout the year, cattle are permitted through the peak of forage growth and watershed. Cattle numbers vary between 50 in one grazing allotment to 550 in several others. Even at high AML for wild horses this exceeds their numbers by 315 animals. The only months of the year cattle are not authorized are August and September.

Some grazing periods will end on the last day of a month, only to resume the first day of the following month. For example (page 50, EA):

Two pastures, ‘Tommy’s Draw’ and ‘Hogan Draw’ lie within the Cathedral Bluffs allotment. Both end cattle usage for 250 cattle on 12/31 but ‘Hogan Draw’ resumes on 1/1 for 550 cattle. This period ends 2/28 but resumes again on 3/1.

Two concerns were cited within the EA concerning lessees and allotments:

“Private land owner added to the area known as the Greasewood Allotment to allow wild horse use of perennial water sources; agreements could be jeopardized if populations continue to be managed above AML.”

And ( Regarding ‘Soil Resources‘ and ‘Water Resources‘, Alternative A):

“Grazing impacts attributable to livestock would continue under this alternative.”

But other citations indicate benefits to livestock and lessees:

“ … increase forage and water availability and quality…”

“…operators would be able to fully utilize authorized grazing preference and operate at full numbers.”

Lessees have taken voluntary reductions in AUMs but will most likely resume standard usage after the round-up. It will likely be difficult to judge whether degradation can be exclusively attributed to horses.

Among the priorities cited to benefit from Alternatives ‘A’ through ‘C’ are livestock, recreation and Oil & Gas Development Page 90, paragraphs 2 & 3:

“New oil and gas development is likely within the Yellow Creek and Piceance Creek watersheds…

“…there is historic oil and gas development in East Douglas that would continue.”

“… will include the installation of pipelines, building well pads and access roads and infrastructure to develop natural gas and oil shale resources. Surface disturbance and loss of forage will increase the impact of wild horses on the landscape.”

Oil and gas development encompasses approximately 2,920 acres within the HMA, or 10 acres per well pad (292 wells). Three horses have been killed in vehicle collisions in direct connection to oil and gas infrastructure since 2007.

Shell Frontier Oil and Gas owns 19,000 acres of private land within the HMA plus an additional 200 acres near Cathedral Bluffs. A conflict with a livestock operator prompted the installation of a four strand barb-wire fence around their private land. According to the EA, this conflict has now been resolved; the fence has 100 foot gaps, allowing wild horses to pass through.

On cumulative effects of alternative ‘A’ regarding oil and gas development “Wastes, Hazardous and Solid” is the assertion,“These activities would generate, use and store hazardous chemicals and generate solid waste.”

Regarding the Flyover inventory which took place between February 2nd, 2010 and March 17, 2010:

Ten separate flights took place, encompassing 550,272 acres. The flyover summary found 265 animals within the HMA and an additional 201 living outside. The current estimated population – 318 – is based on a 20% foaling rate, however, the 2006 roundup released 28 mares treated with PZP. A separate table indicates a foaling rate based on 16.16712% through the recorded history of the HMA but the resulting ’estimate’ is very similar – 312.

But if the assumption is a 20% foaling rate, it’s probable it isn’t by ’natural’ selection; it’s likely due to intense human manipulation throughout the history of the HMA.

The first inventory of the Piceance-East Douglas was conducted in 1974; 139 horses were recorded during an observation flight. It appears populations were simply calculated at 20% per annum until another inventory in 1979; 1980 is the first recorded ’round up’. From 1980 until 1999 – a 19 year period – 13 roundups were conducted, removing 1,044 animals.

1984 and 1985 saw a loss of 200 animals, possibly due to a deep and intense winter. Still, roundups were conducted, removing another 17 animals.

From 1991 through 1994, roundups occurred yearly. In 1996 – a probable traumatic reaction to repeated and intensive losses – 527 horses were estimated, post-foaling. Three additional roundups in 1996,1997 and 1999 removed another 466 animals before roundups finally slowed. Since 2000, two round ups have been conducted – 2002 removed 151 animals and 2006 removed 212, releasing 28 mares administered PZP. Yet the population has remained relatively stable, even trending downward, since 2007. This has been the longest sustained period of non-disturbance since 1974 through 1979.

According to Page 62, paragraph 4, mortality is approximately 4% ‘from all causes’. There are no stipulations as to whether this is annual. However, calculating 4% loss from post-foal population estimates from 1974 to the present, it’s conceivable 445 wild horses, of varying ages, have died within this HMA. This is important as most Environmental Assessments will acknowledge mortality but present no practical application. As previously mentioned, 3 have been killed in vehicle collisions since 2007. Other mortality is related to accidental shooting associated with big game season. This may be under-reported due to the fear of potential legal action.

The West Douglas HMA is a subject of serious contention. The Bureau of Land Management has had plans to zero out this herd for over a decade. It was referenced little in this assessment but was included in the census flyover, indicating 73 animals present. This is less than Dr. Gus Cothran’s accepted requirements for herd viability but there is probable movement between the herds and hopefully, a continued influx of healthy genetic contributions.

Alternative ’D’ – the No Action Alternative – devoted 17 pages to effected environments and the catastrophic ecological disaster to follow – projected through 2019 – should this roundup not be undertaken. Page 115, paragraph 5 indicates wild horses are not “ a self-regulating species “ and will “continue to reproduce until their habitat could no longer support them.” If this statement is true, then the management of this HMA has contributed to that imbalance: by not allowing for more than a small overall population to exist without interference for any appreciable length of time, the potential for self-regulation will remain out of reach.

Among the final pages of this EA are the standardized applications of the Jenkins Population Modeling Program. Understanding the graphs, tabulations and theoretical fluctuations in birth and death rates over a proscribed period of time remains elusive. But of concern is this particular program utilized for this particular Herd Management Area, based on a formula endemic to the Garfield Flats area of Nevada. While wild horses may share some common traits and characteristics, each individual set of herds develops according to the specific nature of it’s environment. For example, wild horses native to Twin Peaks or the Pryor Mountains have grown and developed according to specific plants species, water requirements and climates: Twin Peaks is a high desert lava bed with pockets of bunch grasses that may not be available year round, so other sources of forage must be utilized – forage that may cause illness in wild horses living in a richer, moister environment. Twin Peaks wild horses, conversely, might sicken consuming forage native to the Pryor Mountains for which those wild horses have developed either an immunity or an affinity. It becomes essential each population model take this into account in some fashion, for what may apply to Garfield Flats, Nevada wild horses may be either detrimental or of no consequence to Piceance-East Douglas wild horses.

The standard catch phrases – ‘thriving ecological balance’ and ‘multiple use’ as they apply to designated Herd Management Areas – have been distorted considerably for this HMA, with a minute population of wild horses being labeled the primary destructive force behind range degradation, livestock reductions, decreases and increases in water flow in brooks and streams, economic downturn as it regards stocking levels of cattle, interference in birthing areas for ungulates – just to name a few. Grazing allotment acreage within this HMA accounts for nearly 86% – leaving perhaps 14% for wild horses to roam freely or at the very least, with minimal constraint. If not taking into account 292, ten-acre oil platforms.

Finally, photographic documentation taken in Spring, 2011 was presented describing levels of use – heavy, moderate, light and none for different types of forage and open areas. However, no specifics were indicated or implied as to what species of animal might use these areas, simply the levels of usage. An assumption could be made that the different levels are being applied to wild horses, as this document was prepared to illustrate purpose and need. However, a personal observation: several of these areas had an appearance similar to a BLM grazing allotment I had examined near a privately owned wild horse sanctuary in Northern California in August 2010. The allotment and the Sanctuary were mutually exclusive and shared no common resources.

No other implications accompanied the photographs, although there are pasture and allotment names on clip boards; some were legible. But these are areas that wild horses share with livestock and other wildlife, so the implications should be referenced, not simply allow the reader to make the assumption.

Since 19,000 acres belonging to Shell Frontier and 2,920 acres with well pads occur “within the HMA”, shouldn’t wild horses be ‘compensated’ in some fashion for the loss of habitat and forage? Either by increasing their allocated forage allowances to compensate for the loss of 21,920 acres (and more, due to road construction) or by an additional land mass inclusion beyond the barrier of the HMA?

Theoretically, with the exclusion of this acreage, which could easily support 300 wild horses, they are pressured into either over-utilization or to seek forage outside the recognized HMA boundaries. And according to the EA, more land will be utilized for additional gas and oil extraction and infrastructure. The horses are ‘allowed’ a certain amount of forage but are constantly losing space in the BLM’s efforts to conform to ‘multiple use’.

NEPAs submitted by various oil companies outline how many acres will be lost due to well pad installation and roads. While taken by themselves, the losses seem minimal however, with regards to wild horses, 2,9 or 15 acres of combined loss of habitat means the pressure is on them to find other areas of sufficient sustenance – effectively doing the same job with less resources. And whatever damage perceived to be caused by wild horses then becomes a reason to round them up.

So, if this Congressionally-Mandated Designated Wild Horse Herd Management Area is to continue to be utilized as an extraction site/cattle ranch in line with ‘multiple use’, wild horses should be compensated for the loss of forage, water resources and acreage, not punished.

22 replies »

  1. Good gravy….you need to be Sherlock Holmes with a PhD in logic and a JD to understand the kay-rap DOI/USDA puts out.

    But just when you are starting to get a migraine, shoot down to the last paragraph of Lisa’s summary…Amen, sister friend! Then go back and read again….and, again…


  2. I just emailed the following comment to Ms. Kindall:

    Dear Ms. Kindall,

    I have been a DOI-BLM Volunteer since 1998, supporting the Wild Horse and Burro Adoption Program, gentling horses, and teaching and demonstrating gentling at adoptions and clinics. I am also a B.S. in Watershed Hydrology and an M.S. Ed, teaching undergraduates in Equine Studies at Lake Erie College. I am a former Watershed Hydrology Trainee for the USFS.

    I oppose the gather alternative in the removal plan, because after overall review it contravenes the spirit of the 1971 Act, and its science is inconsistent and untested. I will only cite one example among many: there is no way to test if the “No Action” Alternative D is true. You cite wild horses as “unable to self-regulate” regarding their populations in an area. On the Piceance-East Douglas, because of a history of continuous human manipulation on the HMA, this assumption cannot be made. Wild Horses have NOT been left alone long enough to make it. Yet the Plan anchors its rationale for a gather in this and other faulty assumptions of the same kind.

    As a BLMer and a believer in the American Way, and as a taxpayer, I am disappointed in BLM people, time, and money being used for this kind of false rationale for gathers. It only obfuscates and retreats from the real opportunities to create and implement a plan which would be good for the bureau, good for its lease holders, and ultimately, good for the horses. In retreating from that opportunity in this day and age, with what we know today, I find that cowardly.


    Robert Pliskin, M.S. Ed
    EAGALA Equine Specialist
    Shaker Heights OH USA


    • Thank you, Rob.

      During the class I took through our two county NCDOA Extension Service, one of the speaker stated that horse genetic adaptation is believed to be so specific that a foal born on a warm day will have a lighter (hair density and length) coat than foals born on a cool, rainy day. These are foals born on the same farm in the same climate. This person has years of experience as a breeder, so if he made this statement, I believe it is true.

      This fact would certainly support several ofnthe points in R.T.’s article regarding how herds adapt to the forage in their area.

      Among other details in this class that relate to the BLM’s failure to use scientific principles is that horses and cattle do not eat the same grass. This is important to know for management purposes for farmers who own both cattle and horses. People here apply this principle to pasture rest.

      I don’t know if Craig Downer or any other scientists have studied which animals eat what forage. It does not sound like it from anything I have read about BLM public lands management. This is a weakness that a farmer or rancher who grazes horses, sheep, cattle, goats, bison or other animal can not afford to make if he is using a limited amount of acreage on land he or she grazes—either through ownship or leasing.

      This is one of the sources of serious frustration I have. If someone like me can take a 12 hour course and learn principles of land management, why don’t I see any evidence that they actually know anything about land management? Given that most of the public lands where HMA’s are located are in arid climates with different terrain, I know there would be differences in the particulars. However, the scientific principles would not change.

      It is infuriating to me as a citizen of this great country, who grew up in an area where agriculture was was a very big business, to see a government agency so fatally incompetent. If all BLM needs to do is keep up with issuing permits and leases, we need to outsource this to a legal firm, and do away with the rest of the department.


  3. Petition on AWHPC site. Be certain to add your own comments so your signature will count. There isn’t much time, but you can also write a letter and fax it:
    Speak Up for Colorado Mustangs: Oppose Another BLM Roundup
    BLM to Capture 100 Percent of Mustangs Living in Piceance-East Douglas Herd Management Area and Return Only 135 Wild Horses to the Range
    Comments Are Due by August 8, 2011

    White River Field Office
    220 East Market St.
    Meeker, Colorado 81641
    FAX 970-878-3805
    TDD 970-878-4227
    Field Manager: Kent Walter
    Staff Directory
    Melissa Kindall
    BLM White River Field Office
    Edwin Roberson, Asst. Dir., BLM


  4. Lisa, THANK YOU. The operative word here is COMPENSATION, as Mar keeps trying to drill home….

    ” Since 19,000 acres belonging to Shell Frontier and 2,920 acres with well pads occur ”within the HMA”, shouldn’t wild horses be ‘compensated’ in some fashion for the loss of habitat and forage?”


    • Thanks Debbie…but is there a map with all this ash-and-trash human greed and extraction consolidated? Saw the list of NEPA activities, but having a hard time visualizing with wild equine HA/HMAs. Any link for viewing for the simple-minded?


  5. I’m a dodo bird when it comes to EAs, NEPA, etc.

    Maybe I missed it (I’m still rereading, rereading, rereading) but who or what agency is the final approval for EAs….please don’t tell me it is internal to DOI or USDA?

    p.s. mosey on over to Horseback and read the kay-rap United Organization of Horsekillers put out about wild equines. Last visit it was on the crawl at the top header. It is a doozie.


  6. This is why I think it matters that we all comment in these EAs:


    Each time we speak up on behalf of the mustangs, we are
    building an important record of public opposition to the
    federal government’s current costly and cruel management
    policy. This record will play a critical role as we work to reform
    the Interior Department’s wild horse and burro program
    and secure a safe and humane future for these iconic
    animals for generations to come.


  7. The last three Environmental Assessments I’ve read – the High Rock (Fox-Hog)Complex (235 pages), the Calico Complex (113 pages) and the Piceance-East Douglas (209 pages) – have been HUGE. The High Rock and Calico EAs were released almost simultaneously, the deadlines within days of each other, perhaps to force a choice as to which to comment effectively on.
    We all have areas within Assessments we have a ‘passion’ for, whether it’s wild equines and their relationships with other wild life, theoretical foaling rates, the size of the HMA in relation to the allowable population, range damage attributed to wild equines exclusively, watersheds – there is something in an Assessment that YOU are well-versed in, that will speak to YOU. The rest is chaff, designed to get in yer eye and irritate you and throw you off your path.
    Use the little ‘search’ window when you open an EA; input your personal perameters – the subjects you know best – and follow where they take you. Make notes. Use a calculator. And don’t forget history: find the last EA, if you can, or archived population estimates.

    This site is an enormous resource:
    It’s a huge site and if you’re an insomniac, will fill the hours like nothing you’ve ever seen.
    And remember the phrase “…outside the scope of this Assessment.” It’s used in answer to Comments to render that comment null and void. However, if it was brought up within the EA, then it isn’t really outside the scope, is it?

    I hope this doesn’t come off as snotty or know-it-all. This is what worked for me. After coming to tears with the realization I could not author an 11 page commentary on subjects I knew nothing about, with encouragement from a friend it finally occurred to me to address those things I knew within a certainty and could prove with data thoughtfully provided by the BLM.


    • Lisa – Thank you so much for your help in giving me direction and fortitude to get my comments in to BLM for this EA. BLM has many paid people to write these things … but that does not mean that what they say is accurate or even legal … not to mention morally correct. So, regardless of what their responses may be, we have to continue. We can not give up until the horses and burros give up … and as we have witnessed over and over … they will not give up until the bitter end … and we must do the same. If we believe in them then we have no choice … it is ALL about the “wild ones”.


  8. Here is the letter I just sent….
    To Melissa Kindall/BLM,

    This letter is in response to the Piceance East-Douglas preliminary Wild Horse Environmental Assessment – This is the most outrageous attempt at pseudo-science I have ever read. As well as the assessments for the entire BLM and their denigration of America’s wild horses.
    I am fully aware of the nature conservancy, wwf, the sierra club and the global invasive species council’s categorizing them as invasive species, which they are not. How many millions, if not billions do these groups take from the govt. to do their so called invasive species studies and removals? Americans are extremely tired of every Govt. agency telling us what must be done in the name of nature. I have news for everyone, we were doing just fine until all the green groups discovered how much money they could make off of the backs of hardworking Americans and of course, lets not leave out the massive land and water grab. We all know that is what this is really all about. So, don’t insult our intelligence by stating these horses are hurting the land. If agencies and green groups were really that concerned with helping nature they would stop the use of depleted uranium and white phosphorous and be more concerned about the radiation coming from Fukishima. If they isn’t stopped immediately and dealt with properly, none of this will matter. The entire planet will be contaminated.
    Shame on all of you…..



  9. Holy Smokes…Do we have two days to read and digest all that information? So what is the bottom line? If I read that correctly there are far reaching impacts. But somehow I think it boils down to the same princple. Wild Horses and Burros vs technology, GREED AND MONEY! I just read the email and its
    probably too late to respond, but I will anyway. At least it will show that interest regarding the Wild Horses and Burros goes beyond the Western part of the US.


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