Biologist’s comments to save White Mountain & Little Colorado wild horses (Today is the last day YOU can comment)

CarolWalkerWhiteMountain-001                                                                                                        White Mountain Wild Horses (Photo:  CAROL WALKER)

by Robert C. Bauer, Biologist

Wild Horse and Burro Specialist
BLM Rock Springs Field Office
280 Highway 191 North
Rock Springs, Wyoming 82901
Fax: 307-352-0329

Ms. Wertz and to those whom it may concern;

I am writing in reference to the proposed action of the Bureau of Land Management,
concerning the wild horses of the White Mountain and Little Colorado HMA’s of Wyoming, and its
accompanying research project. This, according to the scoping letter, involves the radio collaring of
mares, placing of tail trackers on stallions, and subsequent spaying of mares. This will be coupled
with reducing numbers of wild horses, in both areas, down to the BLM’s appropriate management
level, a number which combined, for both areas, comes to 1 horse for every 1838 acres of BLM
controlled land. I would like the bureau to consider several scientific and ecologically sound
principles directed against its proposed action.

1. It must be realized that nature through its own mechanisms is fully able to maintain natural
ecological balance, without human intervention. It does this through physiological differences,
found within each species inside any given ecosystem. Each of those differences, contribute as a
vital factor in a broad ecological equation, allowing each species, including wild equine to fill a vital
niche in the balance of nature. It also accomplishes this through the numbers or density of any
given species of animal or plant within that system, in conjunction with competitive species, and the
carrying capacity of the land. Sterilization and or contraceptives have been proposed to check wild
equine population growth disregarding the presence of its predators, natural environmental
factors, and competitive grazers. Natural predation and environmental impacts are vital in
regulating the numbers of ungulates and ruminants alike in any given area. Density dependent
inhibition, however, must not be ruled out and plays an important role as well. In this scenario, the
numbers or density of wild equine, versus competing ruminants, as the pronghorn antelope, will
each fluctuate in response to the other based upon the carrying capacity of the land, yet always in
perfect balance. In essence, the pronghorn and other ruminants, need the presence of wild horses
and burros and vice versa. Each population will have the effect of keeping the numbers of another
competing population at levels that are ideal for the carrying capacity of the land.

2. Within the physiological and behavioral makeup of the wild horses and burros, there also
exist what could be called self-regulating mechanisms. These mechanisms serve to govern
reproduction and subsequent population growth or the lack thereof. An increase in the gestation
period of wild horses, (delayed implantation), and spontaneous abortion come into play during
periods of environmental stress within a system, as well as selective breeding by a stallion within a
band, if indeed the stallion breeds at all. In short, environmental stress has the overall effect of
limiting reproduction. Added to this are annual mortality rates established in a NAS study which
range between 14% to 50% in wild horses up to 1 year, and 5% to 25% for horses older than this.
These above mechanisms do, indeed maintain the proper density of wild horses in any given area,
perfectly, in balance with competitive grazers and predators. It does this without sterilization,
without the PZP contraceptive, and without roundups. It therefore establishes at any given time,
nature’s own appropriate management levels, levels which nature adjusts continually, based on the
above biological factors. This alone puts to rest the idea that a research project is necessary,
requiring the tracking, spaying, or removal of wild horses to examine behavior and band fidelity,
not to mention the spatial ecology and demography of these areas or any areas. A sound and
exhaustive understanding of herd dynamics and band behavior can be attained without
manipulating the wild equine in any manner.

3. Also, what must be understood is that nature is dynamic, and not static. This infers that it
continuously fluctuates and adjusts itself, through its own feedback loops, from the molecular, all
the way up the scale of organisms. Because it is dynamic and not static means that its functions
cannot be confined to finite thinking, and fixed statistics but must be allowed, through its own
mechanisms to maintain itself, hands off, so to speak. In other words, nature cannot be limited at
any given time to a given number, or average of numbers, that mankind deems appropriate. An
example of this is the Bureau of Land Management’s, “Appropriate Management Level”, of wild
horses in their legally designated lands. Mankind’s sole responsibility has to be focused on keeping
the restrictions off of nature, so that nature can be itself, and not an offspring of man’s seemingly
brilliance. The moment mankind seeks to alter nature according to a fixed number, or an average
of numbers, is the moment that nature and balance itself begins to break down. At first it occurs
little by little, yet as artificial alteration persists, the breakdowns become greater and greater. This
has occurred in every branch of nature, where mankind has endeavored to manage natural
balance, assuming nature to be static and not dynamic.

4. Another issue that must be considered is that the numbers of the wild horses remaining in the
wild are not even in the teens of thousands anymore, contrary to the BLM’s assertions to the
contrary. This statement may seem bold yet is based upon BLM’s own statistics, factoring in
reproduction, PZP, adjustment of sex ratios, and the thousands of wild horses and burros that have
been continually removed. Factored in also, are mortality rates, already mentioned above, both first
year and adult, that nature herself applies. These issues combined, have driven numbers in most
areas out west down to levels where genetic viability has been compromised and far below total
numbers that the BLM have stated as still existing in the wild. Also, with continued use of the PZP
contraceptive, population growth will be driven down even further. Reproduction will continue to
decrease dramatically because of PZP, but mortality percentages will remain the same. In essence,
with the use of the contraceptives, or sterilization methods, mortality will completely overwhelm
reproduction, accelerating population decline in our wild equine.

5. The free roaming habits and social behavior of the wild horses and burros, allow them to
harmoniously coexist with every competing ruminant. Their physiological makeup coupled with
continual movements have a revitalizing effect on soil and vegetation. This in turn positively
impacts other grazers, and subsequently predators as well, who prey upon them. The presence of
wild equine in a multitude of ecosystems has proven to result in a beneficial cascade effect,
rejuvenating entire areas where they have been reintroduced, both in terms of flora and fauna. This
has been documented in many geographical locations throughout the world. Noting these
indisputable facts, the wild horses and burros can without question be considered a keystone
species. Removing our native equine from their legally designated areas and or tampering with
their numbers has and will continue to have a reverse and detrimental effect on our western

Conclusion. The answer to ecological balance, therefore, in our western ranges doesn’t lie in
experimentation, sterilizations, contraceptives, adjustment of ratios, or the institution of removals.
The answer lies in the termination of all roundups and a release of the wild horses and burros, in
holding facilities, back into the areas from where they were taken. This must be followed by an
elimination of the Wild Horse and Burro Program of the BLM, which has proven to be unscientific
in its pursuits, motivated by greed and prejudice, and has opposed every intent of the Wild Free
Roaming Horse and Burro Act of 1971. All that is necessary for a “Thriving Natural Ecological
Balance”, is to keep the restrictions off of nature, and allow her to regulate herself untouched.
The wild horses and burros will continue as the poetically beautiful, yet vital components of
ecological balance if, and only if, we allow nature alone, through its own dynamic methods to
dictate the numbers in the wild that are to exist, at any given time.


  1. I am glad to see this biologist submit such a well researched, factual response to the BLM. I hope others with this kind of knowledge will take the time to also contact the BLM. While we all understand many in the BLM could care less about horses or any wildlife we have to hope and pray that the final decision made here will be one in favor of the horses. I also am praying for the 200 donkeys in Utah…….thank you for sharing your posts.

    Liked by 1 person

  2. I have read Dr. Bauer’s previous comments before, and this one also clearly states why it’s so important to maintaining our wild treasures as the others. Regretfully, the BLM will not listen unless they have an epiphany.


      • Yes, people need to raise a stink about this with their Congressmen. One of the main reasons the Salt River horses were left alone was because people mobilized and protested physically, forcing White House and several legislators to intervene.

        I’m fairly sure that, if this frankenstein plan gets time on mainstream media (with the media being in our side) BLM would have no way but to shred it. Aside from wild horses, once of the things BLM hates most seem to be mediatic controversy… althought it must be added that we can’t expect local residents to be supportive in this case, unlike Salt River’s.


  3. I feel that this is an accurate analysis, the band’s of horses in the Heber area have fluctuated over the years as nature permits .I have been coming up to the the White Mountains since the mid 70’s and witnessed the fluctuation over the years.


      Dr. Bruce Nock

      Let me explain. In 2010, the Bureau of Land Management (BLM), raised the possibility of gelding males (removing their testes) and spaying females (removing their ovaries) before returning them to the range.1 Now, they have once again proposed spaying females as a method to control wild horse populations. Technically speaking, horses have estrus cycles, not menstrual cycles.2 Nevertheless, spaying removes the primary source of estrogens and progestins from the body, just like menopause, and there is no reason to believe the consequences are less severe for mares than they are for woman. In fact, for woman the surgical removal of the ovaries results in more severe symptoms of menopause, because in natural menopause the ovaries continue to produce low levels of female hormones. It is hard to imagine that removal of these hormones from the body by spaying won’t compromise a mare’s ability to survive and thrive in the wild.

      You see, the ovarian hormones are powerful steroid hormones. They have
      widespread effects on physiology and behavior. Estrogen, for example, is essential for healthy bone. When estrogen production declines due to menopause, whether naturally occurring or surgically induced, or after exposure to radiation or chemotherapeutic drugs, bones become brittle and break easily. Spaying mares is likely to have similar effects on bones density and strength. I wonder, does the BLM really think returning mares to the open range in a condition associated with the increased risk of breaking bones is a good idea? Have they given it any thought at all? The image of a horse suffering with a broken leg on the open range due to compromised bone density isn’t a pretty one.


        Dr. Bruce Nock

        My endocrinology professor in graduate school, Dr. Alan Leshner PhD, drove home time and again the point that “No hormone works independently of other hormones.” Take away one hormone and it affects the levels of other hormones too.
        Remove ovarian hormones and pituitary hormone releasing and inhibiting hormone activity changes, gonadotropic hormone levels go up, adrenocorticotrophic hormone levels go up, cortisol levels go up, thyroid hormone levels go down, and so on and so on. It’s a fact. Moreover, the assessment of the long-term consequences of such hormonal imbalances requires in-depth, long-term comprehensive field studies by professional scientists … individuals trained and experienced in the art and science of science. Veterinarians don’t currently know the consequences. BLM personnel don’t currently know the consequences.
        The National Science Foundation doesn’t currently know the consequences. But, it is reasonable to suggest based on what we do already know that spaying is likely to have serious consequences for a mare’s ability to survive and thrive on the open range.
        So, the idea of spaying mares as a method of population control doesn’t sit well
        with me when I think beyond how it impacts reproduction. I’m also skeptical about
        whether it can be done safely in the field. Taking out the ovaries which reside in the
        abdominal cavity is a much more serious procedure than removing the testes of a male.
        When we ovariectomize rats for research, we do it in a state-of-the-art animal facility.
        We’re required, by federal law, to use sterile procedures and defined recovery and
        followup protocols. I’m wondering, can and will the BLM, a federal agency, adhere to
        the practices the federal government requires us to follow for rats when removing the
        ovaries of horses in the field? I seriously doubt it is possible.


        Dr. Bruce Nock

        Even if such precautions are effectively implemented, I doubt the wisdom of
        returning spayed horses to the open range when bone health, mental and emotional
        processes and social behaviors have been compromised. The endocrine system is one of the major signaling systems of the body and ovarian hormones are major
        They are powerful agents which function to coordinate behavior and physiology.
        Inducing what could be described as physiological chaos by removing ovarian
        hormones and disrupting the normal functioning of neural and other endocrine systems to boot is very likely, in my opinion, to compromise a mares ability to thrive as a fully integrated herd member.


      • I can just envision it… a few months after spaying them the BLM will round them up alleging they are suffering in the rage due to “debilitating disease”.

        And what’s the point in spaying when darting several times with PZP-22 renders the mares sterile for life anyways? Is darting a 1,000 pound animal all that difficult? Am I the only one who sees this as another BLM/Catoors money-raking scam? I can even see the shadow of AAEP casted all over this plan.


  4. Since it is more than evident the BLM takes comments only to indicate they did so, it seems the letter writing and comments would be better directed at members of Congress, the only entity which really could make effective and lasting changes to BLM mandates and policies.


    • Right Icy – I sent a long email to both of my senators & the representative here in NY. Both Senators have always been on “our” side, but I thought a little prod wouldnt hurt.


  5. This is totally correct. The wild is the wild and the horses and all the wild animals will take care of themselves and be culled as only mother nature sees fit. Man kind needs to leave these horses alone to live peacefully in the wild just as nature intended. The American horse has paid it’s dues to man kind over the years and man kind must return the favors and let them be free to live in peace. There is more than ample lands for the wild horses and burros therefore I submit BLM and all others leave them completely alone. They more than earned it so leave them be.


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