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Please Comment Today Against the Destruction of 40% of Wyoming’s Wild Horse Herds

By on • ( 25 Comments )
Published by Carol Walker on Wild Hoofbeats

The Bureau of Land Management is developing a new Resource Management Plan in Wyoming and has an Environmental Impact Statement (EIS) for proposed changes to the management of four wild horse herds in Wyoming: Adobe Town, Salt Wells Creek, Great Divide Basin and White Mountain. The BLM’s proposed actions in their “Preferred Alternative” would zero out the Great Divide Basin Herd, zero out the Salt Wells Creek Herd and the White Mountain Herd and cut the Adobe Town Appropriate Management Level by half. Comments are due on this plan by April 30.

Salt Wells Creek, Great Divide Basin, Adobe Town and White Mountain encompass 2,811,401acres, 70 percent of which is federally managed public land and 30% is mostly private lands with some state owned lands.

At issue here is the Checkerboard – a mix of public and private lands 20 miles wide that was set up in the 1870s, when the government was selling private land plots to raise money for the railroad. The private land, about 891,807 acres, is owned by Occidental, the parent company of Anadarko, and the Rock Springs Grazing Association, an association of 24 families. The Rock Springs Grazing Association has been working very hard over the last 8 years to get all of the horses removed from the Checkerboard area even though it is not all private land – it is a mix of private and public land. They have been involved in 4 lawsuits regarding the status of wild horses on federally protected public lands and this proposal is the latest, most sweeping and devastating attempt to have all the wild horses removed. RSGA and the BLM have been attempting to manage the Checkerboard as if it were all private land but it is not, and that is illegal.

I have been observing and photographing wild horses in these four HMAs for the past 16 years. All four herds are distinct, and the horses have different characteristics. They all deserve to be preserved. When 80% of Americans want to see wild horses managed humanely on our public lands, 24 families who only want to have livestock on our public lands should not be able to dictate their fate.

The White Mountain Herd boasts the “Wild Horse Loop Tour” which is an important feature to locals and to tourist alike. The road is a good one and there is interpretive signage. It is very easy to see wild horses if you drive this route. Tourism is a major source of income for the State of Wyoming, and tourists come to see wild horses in Wyoming. This is one of the easiest areas to see and photograph them and if the White Mountain Herd is zeroed out that opportunity would no longer exist.

This “Preferred Alternative” would mean that 4000 wild horses would be removed from the four Herd Management Areas, which is 40% of all the wild horses in Wyoming. The AML for Adobe Town would be 259 – 536 horses, and the BLM could use spaying of mares, gelding of stallions, skewing of sex ratios, helicopter roundups and other methods to keep the population in check, despite the grave danger and inhumane suffering that spaying of wild mares presents and the possible huge impacts to the wild behaviors of the horses that would be subjected to by all of these methods. Sterilizing this herd means instead of an immediate zeroing out, it will be a slow destruction – no more foals and as the horses age they will die out slowly.

I suggest that in your comments you select Alternative A which will manage wild horses in their respective 4 herds at the current Appropriate Management Levels (AMLs) for each herd with a total AML 1481-2065 and use the proven and humane birth control method of PZP to manage the populations of each of these herds if necessary.

Another suggestion would be to require land swaps from the private land holders so that public lands on the Checkerboard could be consolidated. Then wild horses could be relegated to the public lands areas of the four Herd Management Areas, leaving them wild and free and in their homes with enough room on the public lands where they belong.

I also suggest that you request that the BLM must reduce livestock grazing within these four Herd Management Areas. BLM has a statutory mandate to protect wild horses while livestock grazing is a privilege which is permitted at the discretion of the Department of the interior. Livestock grazing does not need to be allowed in order to fit the BLM’s guidelines of “multiple use.” It would be far more cost effective to remove the livestock from public lands since the BLM loses money on the grazing leases, than it would to remove and warehouse the 4000 wild horses it plans to roundup. The BLM’s program of warehousing wild horses is completely unsustainable and the effects on the wild horses are devastating. During the last Checkerboard roundup of 2017 hundreds of wild horses died within the months following the roundup in holding facilities. The very unsustainability of this broken program is heading toward a future where destroying the over 45,000 wild horses in holding may become inevitable.

The BLM never considers the fate of the wild horses it rounds up and removes in its planning process. But I do. Removing wild horses from our public lands has an impact on the taxpaying citizens of the United States who lose an opportunity to observe, photography, study and enjoy these wild horses where they belong, in their homes, with their families, managed humanely and sustainably.

Please request that the BLM select Alternative A. Use your own words. If you sign onto a comment form instead of commenting yourself, 2000 comments just get read as 1. It only takes a few minutes to get onto the BLM site and submit comments online. Your comments will make a difference. Thank you for caring about our wild horses.

Here is the link to submit your comments by April 30th, 2020:

https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=23512

Click on the link above, and look down to the first line that says “Wild Horse Amendment” – on the right there is a button that says “Comment on Document.” Press this and you will go to the online comment form.

Categories: Horse News, Horse Slaughter, Wild Horses/Mustangs

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  5. Pingback: Please Comment Today Against the Destruction of 40% of Wyoming’s Wild Horse Herds — Straight from the Horse’s Heart – New Human New Earth Communities

  8. John Hay of the Rock Springs Grazing Association discusses land used for wind farms. He supports Tasco Engineering’s Wyoming Wind Energy Project.

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    • Wild horses & burros being removed for Richfield Tar Sands plan
      January 7, 2016
      Posted on STRAIGHT FROM THE HORSE’S HEART

      “The document goes so far as to say, ‘the management of wild horse and burro herds is not compatible within those portions of commercial tar sands lease areas.’”
      by Grandma Gregg
      In addition to the welfare ranchers, here is another major cause of our wild ones being captured & removed & sterilized … please become aware of the Richfield tar sands plan.
      The Richfield tar sands has already effected our wild ones and continues to do so as of TODAY with the BLM proposal to rid the White Mountain and Little Colorado of more/all of the wild ones and the same with the Sinbad wild burro HMA (comments due Monday).
      The Richfield tar sands plan has been in progress since about 2010 and if you look at the list below you will see that most of these HMAs (plus West Douglas HA) have been heavily captured/removed in recent years.
      The document goes so far as to say, “the management of wild horse and burro herds is not compatible within those portions of commercial tar sands lease areas”. How much clearer can it be. They want the wild ones GONE.
      Proof: http://www.riversimulator.org/Resources/BLM/OSTSdeis/OSTSfinal.pdf
      TABLE 3.1.3-1 Wild Horse Herd Management Areas within the Oil Shale and Tar Sands Study Area (page 3-167)

      Wyoming
      Little Colorado
      White Mountain
      Salt Wells
      Adobe Town

      Colorado
      Piceance-East Douglas

      Utah
      Canyonlands
      Muddy Creek
      Range Creek
      Sinbad

      [PLUS Herd Areas which are not discussed in this report – such as the West Douglas HA]

      More Richfield tar sands information:
      Click to access UT33-RichfieldFinalPlan.pdf

      Sinbad Wild Burro EA information:
      Click to access Sinbad%20Draft%20EA.pdf

      https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&projectId=51041

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    • John Hay, President of the Rock Springs Grazing Association and the President of the Rock Springs National Bank. … If it looks like a duck, swims like a duck, and quacks like a duck, then it probably is a duck.

      Although this court case is not new, the Shriners Hospitals for Crippled Children, Inc sued his bank for fraud and conspiracy. https://law.justia.com/cases/wyoming/supreme-court/1992/122736.html

      In addition, RSGA leases an additional 450,000 acres from the Anadarko Land Company, a subsidiary of Anadarko Petroleum Corp… and who are they? “Six things you need to know about Anadarko, the worst corporation you’ve never heard of”.
      https://www.ran.org/the-understory/anadarko/

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  9. For those who have not seen this Legal Declaration
    Legal declaration from former BLM official (removed from Google search because it violated their terms of service)
    BUT..it’s all over the web

    ” And, again, because the wild horses have a statutory right to be there, whereas livestock only have a privilege that can be revoked at any time by BLM, there also is no authority or precedent, to my knowledge, for the agency to zero out these two longstanding wild horse herds simply to appease private livestock grazers.”

    DECLARATION OF LLOYD EISENHAUER

    I, Lloyd Eisenhauer, declare as follows:

    1. I live in Cheyenne, Wyoming. I am a former Bureau of Land Management
    (“BLM”) official with extensive experience in the Rawlins and Rock Springs Districts in Wyoming and intimate familiarity with the public lands under BLM management in those areas. I have reviewed the consent decree proposed by BLM and the Rock Springs Grazing Association (“RSGA”) in this case and provide this declaration based on my longstanding knowledge of, and management of, wild horses and livestock grazing in the Rock Springs and Rawlins Districts.

    2. I grew up in Pine Bluffs, Wyoming with a livestock and farming background, served in the Marines for four years, and then owned a livestock business from 1952-1958. I enrolled in college in 1958, studying range management. From 1960-1961, BLM hired me to assist with collecting field data for vegetation assessments and carrying capacity surveys related to livestock and wild horses. These surveys were conducted in the Lander, Kemmerer, and Rawlins Districts. When I graduated in 1962, BLM hired me full-time to serve in the Rawlins District in Wyoming, where most of my work focused on grazing management involving sheep, cattle, and wild horses. From 1968-1972, I was Area Manager of the Baggs-Great Divide Resource Area in the Rawlins District. In 1971, the Wild Free-Roaming Horses and Burros Act was enacted, and in the spring of 1972, on behalf of BLM, I conducted the first aerial survey of wild horses in Wyoming, recording the number of horses and designating the Herd Management Areas (“HMAs”) for the Rawlins District. After a stint as an Area Manager with BLM’s Albuquerque, New Mexico office, in 1975 I took over as the Chief of Planning and Environmental Analysis in BLM’s Rock Springs District for three years. I was the lead on all planning and environmental assessments. During that time, I also served as the Acting Area Manager of the Salt Wells Resource Area, which is located in the Rock Springs District. In 1979, BLM transferred me to its Denver Service Center to serve as the Team Leader in creating the agency’s automated process for data collection. I received an excellence of service award from the Secretary of the Interior commending me for my work as a Team Leader. In 1982, I became the Head of Automation in BLM’s Cheyenne office, where I managed and implemented the data collection and processing of various systems related to BLM programs. I retired from BLM in 1986, and have stayed very involved in the issue of wild horse and livestock management on BLM lands in Wyoming, and have written articles about the issue in local and other newspaper outlets. I have won various journalistic awards, including a Presidential award, for my coverage of conservation districts in Wyoming. Along with a partner, I operated a tour business (called Backcountry Tours) for six years, taking various groups into wild places in Wyoming – without a doubt wild horses were the most popular thing to see on a tour, in large part due to their cultural and historical value. I also served six years on the governor’s non-point source water quality task force.

    3. Based on my longstanding knowledge of wild horse and livestock management in the Rawlins and Rock Springs Districts, and in the Wyoming Checkerboard in particular, I am very concerned about BLM’s agreement with RSGA, embodied in the proposed Consent Decree they have filed in this case, under which BLM would remove all wild horses located on RSGA’s private lands on the Wyoming Checkerboard.

    4. The Checkerboard is governed by an exchange of use agreement between the federal government and private parties such as RSGA. However, due to state laws, property lines, and intermingled lands, it is impossible to fence the lands of the Wyoming Checkerboard, which means that both the wild horses and the livestock that graze there roam freely between public and private lands on the Checkerboard without any physical barriers. For this reason, it is illogical for BLM to commit to removing wild horses that are on the “private” lands RSGA owns or leases because those same horses are likely to be on public BLM lands (for example, the Salt Wells, Adobe Town, Great Divide, and White Mountains HMAs) earlier in that same day or later that same evening. Essentially, in contrast to other areas of the country where wild horses still exist, on the Wyoming Checkerborad there is no way to distinguish between horses on “private” lands and those on public lands, and therefore it would be unprecedented, and indeed impossible for BLM to contend that it is removing all horses on RSGA’s “private” lands at any given time of the year, month, or day, considering that those horses would only be on the strictly “private” lands very temporarily and intermittently on any particular day .

    5. Another major concern with BLM’s agreement to remove all horses from the private lands of the Wyoming Checkerboard is that BLM is undermining the laws that apply to the Checkerboard, and wild horse management in general, which I implemented during my time as a BLM official. Traditionally, BLM officials (myself included) have understood that, pursuant to the Wild Horse Act, wild horses have a right to use BLM lands, so long as their population numbers do not cause unacceptable damage to vegetation or other resources. In stark contrast, however, livestock (sheep and cattle) have no similar right to use BLM lands; rather, livestock owners may be granted the privilege of using BLM lands for livestock grazing pursuant to a grazing permit that is granted by BLM under the Taylor Grazing Act, but that privilege can be revoked, modified, or amended by BLM for various reasons, including for damage to vegetation or other resources caused by livestock, or due to sparse forage available to sustain livestock after wild horses are accounted for. BLM’s tentative agreement here does the opposite and instead prioritizes livestock over wild horses, by proposing to remove hundreds of wild horses from the Wyoming Checkerboard without reducing livestock numbers – which, in my view, is contrary to the laws governing BLM’s actions as those mandates were explained to me and administered during the decades that I was a BLM official.

    6. While I do not agree with every management action taken by BLM over the years in the Rock Springs District, I can attest – based on my longstanding employment with BLM and my active monitoring of the agency’s activities during retirement – that BLM has generally proven capable of removing wild horses in the Rock Springs District, including by responding to emergency situations when needed and removing horses when necessary due to resource damage.

    7. Considering that wild horses exhibit different foraging patterns and movement patterns than sheep and cattle, and also than big game such as antelope and elk, no sound biological basis exists for permanently removing wild horses from the Wyoming Checkerboard at this time. In particular, wild horses tend to hang out in the uplands at a greater distance from water sources until they come to briefly drink water every day or two, whereas livestock congregate near water sources and riparian habitat causing concentrated damage to vegetation and soil. For this reason, the impacts of wild horses are far less noticeable on the Checkerboard than impacts from livestock.

    8. In addition, because livestock tend to eat somewhat different forage than wild horses (horses tend to eat coarser vegetation such as Canadian wild rye and other bunch grasses, whereas cattle and sheep mostly eat softer grasses), there is no justification to remove wild horses on the basis that insufficient forage exists to support the current population of wild horses. Also, because cattle and sheep have no front teeth on the front part of their upper jaws, they tend to pull and tear grasses or other forage out by the root causing some long-term damage to vegetation, whereas wild horses, which have front teeth on both their front upper and lower jaws, act more like a lawnmower and just clip the grass or forage (leaving the root uninjured), allowing the vegetation to quickly grow back. These differences are extremely significant because if there were a need to reduce the use of these BLM lands by animals to preserve these public lands, it might be cattle and sheep – not wild horses – that should be reduced to gain the most benefit for the lands, and which is why BLM, during my time as an agency official, focused on reducing livestock grazing.

    9. BLM’s agreement with RSGA states that RSGA’s conservation plan limited livestock grazing, primarily by sheep, to the winter months to provide sufficient winter forage. This is a good example of “multiple use” management, since wild horses and sheep have very little competition for the forage they consume and the seasons during which they use parts of the Checkerboard. During winter, sheep use the high deserts and horses utilize the uplands and breaks (i.e., different locations) for forage and protection. During the summer, when sheep are not present, wild horses use various landscapes on the Checkerboard. This multiple use should continue for the benefit of the livestock, the wild horses, and the public and private lands involved.

    10. I am also very concerned about BLM’s agreement with RSGA to permanently zero out the Salt Wells HMA and the Divide Basin HMA, leaving no wild horses in those areas that have long contained wild horses. I have been to fifteen of the sixteen HMAs in Wyoming, and to my knowledge none has ever been zeroed out by BLM. It is my view, based on everything I know about these areas and the way these public lands are used by wild horses and livestock, that BLM has no biological or ecological basis for zeroing out a herd of wild horses in an HMA that existed at the time the wild horse statute was passed in 1971, as is the case with both the Salt Wells and Divide Basin HMAs. And, again, because the wild horses have a statutory right to be there, whereas livestock only have a privilege that can be revoked at any time by BLM, there also is no authority or precedent, to my knowledge, for the agency to zero out these two longstanding wild horse herds simply to appease private livestock grazers.

    11. The zeroing out of wild horses in the Salt Wells and Divide Basin HMAs is also concerning because it would mean that, in those two longstanding HMAs, there would no longer be the “multiple use” of these public lands as required by both the Wild Horse Act and the Federal Land Policy and Management Act. Currently, while there are other uses of this public land, such as by wildlife, hunters, and recreational users, the two primary uses in those HMAs are by wild horses and livestock. If BLM proceeds with its agreement with RSGA to zero out wild horses in those HMAs, the only major use remaining would be livestock use, meaning that there would be no multiple use of those BLM lands. Not only will that potentially undermine the laws that BLM officials must implement here, but it has practical adverse effects on the resources – multiple use is very beneficial for the environment, and particularly for sensitive vegetation, because different users (e.g., livestock, wild horses) use the lands and vegetation in different ways. When that is eliminated, the resources are subjected to an unnatural use of the lands which can cause severe long-term damage to the vegetation. As a result, zeroing out these herds would likely bedevastating for the vegetation in these two HMAs, because livestock would be by far the predominant use in this area.

    12. Turning the White Mountain HMA into a non-reproducing herd, as the agreement between BLM and RSGA proposes to do, is also a farce, and violates the meaning of a wild and free-roaming animal. This is essentially a slow-motion zeroing out of this HMA, and is inconsistent with any wild horse management approach I am familiar with that BLM has implemented on public lands.
    Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.

    Lloyd Eisenhauer

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  10. Cashing in on Degrading Public Lands: How Welfare Ranchers Reap a Beef Bonanza From Weeds They Caused (excerpts)
    MARCH 24, 2020
    by KATIE FITE

    Instead of ranchers being held accountable to the public for weeds, fouled water, and sage-grouse sliding towards extinction, they’ll be able to ransack the public lands with even larger herds, and garner greater federal subsidies.

    Abolish BLM – Create a New Biodiversity and Climate Mitigation Agency

    Any hope of BLM public lands management effectively conserving biodiversity and ameliorating the climate catastrophe is a pipe dream. BLM is systemically implanted with a commodity (cows, logs) and extractive (energy, mining) use agenda.
    The industry hacks, lobbyists, end-timers and all-around ghouls infesting Trump’s Interior Department are doing a splendid job dismantling the agency. If political change ever happens, the first step on a path to a Green New Deal or any preservation sea change must be to abolish BLM. Don’t try to resuscitate an agency so firmly rooted in 1800s Manifest Destiny domination.
    Walk away. Create a whole new agency and mission. Scrub the hidebound agency from the books. BLM has had 44 years since FLPMA’s passage to get it right. It never really embraced FLPMA’s better elements. Pursuit of change within the confines of BLM would be thwarted by antiquated legal interpretations enshrined in a byzantine appeal system under the Interior Board of Land Appeals (IBLA) cocooned in Arlington Virginia. The Board never really took notice of NEPA, the ESA, the Clean Water Act or other environmental laws, and brushes science aside. IBLA makes rulings based on “preponderance of evidence” and “rule of reason”. There are stacks of IBLA decisions showing that the primary “rule of reason” applied is that if you are an environmental group, you get squished like a bug. What’s “reasonable” to IBLA is whatever BLM’s contorted, often obviously flat out lying documents, or the livestock/energy/mining industry profiteers, may claim.
    https://www.counterpunch.org/2020/03/24/cashing-in-on-degrading-public-lands-how-welfare-ranchers-reap-a-beef-bonanza-from-weeds-they-caused/

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  11. Pingback: Please Comment Today Against the Destruction of 40% of Wyoming’s Wild Horse Herds — Straight from the Horse’s Heart – Sarah's Attic Of Treasures

  12. I submitted my comment this morning. I agree that the commentary you provided in the post was very helpful in understanding the issue better and formulating a response. Thank you.

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  13. Who should we donate to which orgs. to make a positive difference here for the innocent ones. Need Input here, plz? Of course, WHFF, H4H in Texas, Cloud Foundation, AWHPC? I have to reduce my donations here bcuz of current situations, How can I make my donations count to make a difference here?? Must continue to be a voice for our innocent ones!
    😩🐴❤😩🐴

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    • Who should we donate to which orgs. to make a positive difference here for the innocent ones. Need Input here, plz? Of course, WHFF, H4H in Texas, Cloud Foundation, AWHPC? I have to reduce my donations here bcuz of current situations, How can I make my donations count to make a difference here?? Must continue to be a voice for our innocent ones!
      😩🐴❤😩🐴

      Would it help to donate to ALDF?

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    • Who should we donate to which orgs. to make a positive difference here for the innocent ones. Need Input here, plz? Of course, WHFF, H4H in Texas, Cloud Foundation, AWHPC? I have to reduce my donations here bcuz of current situations, How can I make my donations count to make a difference here?? Must continue to be a voice for our innocent ones!
      😩🐴❤😩🐴

      Would it help to donate to ALDF? For legal assistance?

      Like

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