Horse News

BLM claims wild burro population increased 64% in 1 year. Baloney!



Be sure to ask the BLM to reduce (or eliminate) livestock grazing in the Blue Wing/Kamma Wild Horse and Burro Complex

Scoping comments due April 7, 2016. This public comment is for scoping which means it is our chance to tell the BLM what we want in the upcoming Environmental Assessment (EA) to remove wild burros from the NW-Nevada Blue Wing/Kamma Wild Horse and Burro Complex (6 HMAs).

By looking at the BLM’s herd stats, the BLM is claiming that between (March) 2013 and 2014 the burros increased by 54% and between (March) 2014 and 2015 they increased 64%.  Independent research has shown us that wild burro populations increase at only about 5% annually so ask BLM to prove their baloney – they can’t.

Here are some ideas of things you can ask the BLM to include in their upcoming EA:

  • All vegetative data for the past 10 years – photos and reports.
  • Maps that show locations of wild horses and burros at the time of their last aerial census AND all photos and data sheets and reports for those census reports that scientifically support their census numbers.
  • Scientifically defensible verification that these wild horses multiply by 20% each year and burros 13% as BLM has stated.
  • Maps showing ALL fences (perimeter and interior) on the HMAs and how these fences impact intermingling of the wild horses and burros to allow for genetic viability.  Note* these 7 small HMAs are connected by legal herd areas (HAs) that have been zeroed out which causes these WH&B to now be in small isolated and below genetic viability “islands”.
  • Scientifically defensible data that show that any previous wild horse/burro capture/removals have SOLELY been responsible for any range improvement (forage/water).
  • All data on ALL livestock on all of these (seven) HMA’s – including dates in and dates out, the number of acres, the number of AUM’s and the number of animals (cattle/sheep).
  • If any WH&B have been trapped in these HMAs in the past 5 years and how many and when.
  • If there has been sex ratio skewing or any type of fertility control given to these animals in the past 5 years.
  • Be sure to ask the BLM to reduce or eliminate livestock grazing in the Blue Wing/Kamma Wild Horse and Burro Complex

Email your scoping letter to Attn: Samantha Gooch, Project Lead, at: by April 7, 2016 to be considered in the development of the EA.

2 replies »

  1. The current appropriate management level of only 333-553 wild horses and 55-90 wild burros on the Blue Wing / Kamma complex is comprised of 1,230,364 acres acres is contemptible. As a frequent visitor to our American deserts I completely agree that this land is fragile and must be carefully conserved for all Americans – especially our future generations – but delegating only one wild horse or one wild burro for EACH 1,913-3,171 acres is absurd. Even the BLM itself states that a maximum of 240 acres per horse per year might be required in the very sparse arid portions of the legal wild horse and burro land such as parts of Nevada. Using this approved by BLM estimate of acres required theory, the Blue Wing/Kamma Complex could support at least 5,127 wild horses and wild burros.

    In your public comment letter, tell the BLM not try to tell the public that the subject of the appropriate management level set by the BLM for this herd is “outside the scope” because nothing could be further from the truth – as a matter of fact, it is the ENTIRE SCOPE of the issue! The NEPA law requires that all relevant scientific information be provided to the American public and that that information be taken a “hard look” at by the decision makers. The National Environmental Policy Act (NEPA) requires that to ensure that environmental assessment statements reflect a careful consideration of the available science, and that areas of disagreement or uncertainty are flagged rather than being swept under the carpet. Thus, the public and the decision makers must resist the urgings of agencies that low-probability risks of very serious harms be dismissed from consideration or that the risk is evaluated only under the agency’s favored theoretical model without taking into account the possibility that other credible models might be correct.

    As the district court explained in Dahl v. Clark, the test as to appropriate wild horse population levels is whether such levels will achieve and maintain a thriving, ecological balance on the public lands. Nowhere in the law or regulations is the BLM required to maintain any specific numbers of animals or to maintain populations in the numbers of animals existing at any particular time. The law states, “that wild free-roaming wild horses and burros are to be considered in the area where presently found [in 1971], as an integral part of the natural ecosystem of the public lands”. Thus, an AML established purely for BLM administrative reasons because it was the level of the wild horse and/or burro use at a particular point in time or imagined to be an advantageous population for BLM cannot be justified under statute.


  2. BLM Blue Wing Complex (Kamma HMA) wild horse roundup, Aug 2-3, 2013
    The Bureau of Land Management (BLM) used helicopters to capture 200 wild horses from the Blue Wing Complex north of Winnemucca, NV from August 2-4, 2013.


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