In a July 29, 2016, ruling, U.S. District Judge Susan Watters told the BLM it had used outdated information when it decided to remove wild horses in 2015 as part of the Pryor Mountain Wild Horse Range population management plan.

https://eplanning.blm.gov/epl-front-office/projects/nepa/70745/93955/113272/AML_Recalculation_with_RLH_Final_document_-_508.pdf

Mr. James Sparks
BLM Field Manager
5001 Southgate Drive
Billings, MT 59101

Dear Jim;

Thanks for allowing us to comment on the review of AML for the Pryor Mountain Wild Horse Range. On behalf of the Cloud Foundation we submit the following suggestions, ideas, and documentation.

While we do not challenge your monitoring data, we would like to point out why we believe the AML should be increased.

Administrative Pasture Additions

Acreage has been restored for wild horses with the removal of the North Administrative Pasture fence and, as we understand it, additional fencing and clean up is planned for the South Administrative Pasture in 2017. The total AUMs for the area are 135.6 or 11 horses, which would take the high AML to 131.

Experts familiar with the Pryor herd would likely agree with us that 131 is still well below the advisable minimum population size to maintain genetic variability.

Genetic Concerns

1. Gus Cothran, PhD, in his most recent (2013) genetic report concludes: “The best way to maintain current levels (of genetic variability) would be to increase population size if range conditions allow.” At the time he wrote the report, the Pryor herd contained over 150 animals.

Frances Singer, PhD, in his Habitat Suitability Study wrote: Wild horses are not prone to rapid disease die-offs. However, minimum goals for genetic viability in the Pryor Mountain wild horses ( Ne > 50) require that at least 160 animals be present on the range (Singer et al. 2000). Since the Ne > 50 goal is set for the breeding of domestic animals, and since the vagaries of drought, severe winters, predation, and other stochastic events cause stress in wild animals, larger goals for Ne (e.g. Ne > 100) for wild horses are even more desirable (USDI, BLM 1999; Gross 2000).”

In his article, A Demographic Analysis, Group Dynamics, and Genetic Effective number in the PMWHR 1992-1997, Singer wrote that “. . .any management scenario that includes a decrease in population size will decrease total Ne, and thus increase the predicted rate of loss of genetic variability.”

Dr Singer studied the Pryor herd in depth for more than a decade and suggested a herd of over 200 was advisable and recommended range expansion. Dr. Cothran has been analyzing the genetics of the PMWHR for 25 years.

Expansion Candidates

Limitations on acreage for the Pryor herd remain a threat to the existence of a healthy, thriving population. With this in mind we suggest the following expansion possibilities:

The Sorenson Extension.

The Sorenson Extension area bordering the north end of the existing horse range in the Dryhead area is managed by the Bighorn Canyon National Recreation Area-Park Service. In the early 1990s a Memo of Understanding (MOU) existed between the BLM and the Bighorn National Recreation Area. The wild horses were allowed to graze in this 1,600 acre area containing the highest quality forage in the Dryhead The MOU was cancelled shortly before I arrived in early 1994 to begin documenting the herd for PBS.

The reestablishment of a MOU between the Bighorn Canyon National Recreation Area and the BLM would allow the horses to once again use this area which would allow for an increase in the AML.

The current manager of the BCNRA rejected an idea to reinstate the MOU a year ago. However, the request came from TCF and the Pryor Mountain Wild Mustang Center not the BLM. A request from BLM would likely carry more weight.

Also, the current head of the BCNRA is leaving shortly and a new person might be more amenable. We do not know why the MOU was cancelled back in the early 1990s, but it is likely that the horses were not so carefully managed then. That was certainly my personal experience.

Demi-John Flat (Pasture)

In the early 1970s Ron Hall, wildlife biologist for the BLM, wrote the first extensive report on the Pryor Wild Horse Range and included a recommendation on expansion areas based on historic horse use. Hall writes: “Expansion of the existing boundaries of the Pryor Mountain Wild Horse Range would be returning wild horses to areas of historic use. Expansion is compatible with PL 92-195 and is also a sound management procedure.”

Hall goes on to say: “Wild horses have occupied all of the Pryor Mountain Complex in the past. Man has now eliminated the horses on most of these areas.

Expansion of habitat could occur if the barriers to movement of the horses were eliminated. The barriers to movement into additional areas are fences, private land and natural barriers. (emphasis added) PL 92-195 states that expansion of horse herds into areas not occupied by wild horses on December 15, 1971, would not be considered. Areas considered below probably had wild-free roaming horses on them on the above mentioned date.”

Hall recommended numerous areas for legal expansion. The fifth area recommended was “Area 5-BLM-Frail Lands and Demijohn Pasture-Acreage 7657. C.C. 33 HU’s.” He goes on to write: “These areas have been used in the past by wild horses. It is not known for sure whether wild horses on this land on December 15, 1971.

Excellent forage conditions exist on the Demi-John Pasture. The frail lands provide a smaller quantity of forage. Crooked Creek Canyon essentially prevents movement of horses from the present horse range into the above areas. Trails could be contsructed at two points to provide access for horses to the enter this area. . . .An additional advantage of having horses on this area is increasing their viewability. Tourists driving down Crooked Creek would be able to view wild horses.”

We recently sent an informal suggestion to you on building a bridge over Crooked Creek. We agree with Ron Hall, Demi-John has high quality, abundant forage. The acreage is BLM land so there is no conflict with other agencies and I have not seen cattle in that specific area for decades.

Demi-John might also take the viewing pressure off the herd that lives in the higher elevations in summer. Demi-John can be accessed by non 4 wheel drive vehicles and has beautiful views looking east toward Burnt Timber Ridge, Sykes Ridge, and beyond to the Bighorn Mountains. It would be a great area for a roadside, interpretive area to educate people about this unique herd. I would also be an opportunity to underscore the rules of the range regarding off road use in the PMWHR, not disturbing he natural behavior of the wild horses and of course not to feed any of the wildlife. If fire bans are in place, it would be a good way to inform the public about this or any other special regulations.

­USFS Lands north of existing boundary fence

As you know TCF has submitted a plan to the Custer National Forest for a seasonal opening of the gates into the Custer National Forest atop the mountain. The 2 mile long fence currently prevents the horses from migrating into the CNF in late summer and fall. CNF has not responded to this proposal. TCF and others who value the Pryor Wild Horse Herd thank BLM for your support of this plan.

The Intangibles:

Philip Sponenberg, renowned color geneticist, acknowledges the importance of the PMWHR, and identifies the herd as a Spanish Colonial Herd because of links to the horses of the Conquest. Some of the closest living relatives of the Pryor horses are the Puerto Rican Paso Finos. This seems logical as the Conquistadors started breeding farms in the Caribbean, raising horses for the conquest of Mexico and South America. It is remarkable that we have these living reminders of events that took place nearly 500 years ago.

I remember standing with Phil atop the mountain years ago. He was talking about the remarkable primitive colors—the striped up duns and grullos below us in Mustang Valley. About that time, a young bachelor stallion raced from the snow fed waterhole and floated by. I asked Phil what color he called the young stallion and he said, I thought rather fondly, “Palomino.”

For these esteemed scientists, millions of people around the world, and those of us lucky enough to visit the Pryor mustangs on a regular basis, this historic herd holds a special place in our hearts and they deserve to safely live on in their mountain stronghold.

I know you share our feelings for them and will do all you can to make sure they have what they need to persist into the future.

If you would like to discuss some of the suggestions we have made to increase the AML and allow the population to remain at roughly the numbers they are now, don’t hesitate to call or email. Thanks again.

Sincerely,

Ginger Kathrens
Executive Director
The Cloud Foundation, Inc.