Open letter from Charlotte Roe
I urge the BLM to extend the deadline for comments to the Black Mountain Wild Burro Gather and Population Management EA, given the widespread disruption currently caused by the COVID pandemic. Given the strains placed on all agencies, those working in health and all members of the public, I urge a moratorium on any plans to roundup and remove the wild burros.
BLM Prisoner, photo by Terry Fitch of Wild Horse Freedom Federation
I have followed developments in the Black Mountain HMA since adopting 2 burros from that range in 2011. This is the largest BLM-managed wild burro herd. These desert burros are hardy, amazing survivors that have a long story to tell. They’ve inhabited the region since first being introduced by Spanish colonizers; they began packing in Arizona in the 1700s. They are important genetically; they are vital, unique partners in the delicate desert ecology; and they have great value as heritage wildlife. My objections to this incomplete, biased and fanciful EA include:
1. The EA posits a 10-year duration for a series of invasive interventions in the Black Mountain burro herd. This shuts out the public and undermines the purpose and intent of NEPA and the 1971 Wild Horse Act.
2. Removing 3/4 of this herd would have significant negative impacts not only on remaining herd remnants, but also on fragmented wild burro herds remaining in the West. Captive wild burros are already overloaded in the BLM’s holding facilities. In this pandemic period, the BLM is hardly equipped to care for more. Legitimate sanctuaries and families that care for adopted burros are largely at capacity. The swelling trade in donkey skin gel is so decimating global populations of wild asses and burros that half of the world’s donkeys could be exterminated by 2025; the US is now sourcing this trade: https://www.thedonkeysanctuary.org.uk/sites/uk/files/2019-11/under-the-skin-report-revised-2019.pdf
3. The Black Mountain burro population estimates — upon which the draconian removal plan is based — appear to be baseless. After stating without evidence that burro populations can “double every four years”, the EA takes a questionable 2014 helicopter survey (reporting 1389 adults) and bloats it to 2,205 adults by 2020, usig a “typical expectation” of 15% annual growth. Show the data, not a fuzzy “typical” expectation or an unfounded series of estimates. BLM staff have trouble distinguishing one burro from another, much less one band from another. By virtue of their coloration and behavior, wild burros can easily be double counted on successive days — or uncounted and simply imagined.
4. The EA asserts that wild burros do not self regulate their population levels and face such low levels of predation as to be insignificant. In fact, mountain lions are prevalent in parts of the HMA such as the Cerbat HA, where wild equids face considerable predation. The lions are killed to protect publicly subsidized livestock. Stop the lion extermination to make Thriving Natural Ecological Balance (TNEB) a real guideline, not an empty slogan.
5. The EA refuses even to consider raising the AML, citing out of context a 2008 quote by equine geneticist Gus Cothran saying 478 won’t compromise genetic variability. The rugged terrain, roads and highways, and fencing for cattle allotments breaks the Black Mountain burro herd into many segments. Removing a total of 1727 wild burros — 73% of the population, or possibly 90% if real population were counted — would do serious damage to their genetic health as well as hurt their will to survive. It would decimate the small sub-populations. It would harm the wild burro presence in other BLM lands, most of which are far below the 150-200 required for genetic sustainability. Please heed the National Research Council, in its 2013 examination of the BLM WHB Program, warning that permanently removing any burros from the range could “jeopardize the genetic health of the total population.”
6. The plan contemplates removal by bait trapping and helicopter. Helicopter roundups inflict unnecessary suffering and risks on wild burro. This is animal abuse. Burros don’t run together in response to being hunted by choppers. These stoical animals freeze in place. They scatter. What happens next is sheer cruelty, as the chopper pilot can run them over in efforts to push them into the trap. Mothers are separated from foals. Many burros die, are maimed, and experience unimaginable pain.
7. In numerous unsubstantiated claims, the EA states burros are overgrazing, ravaging the land, degrading riparian areas, competing with other forms of wildlife for food and being “more destructive to the range than cattle!” The proof? None.
8. The HMA allotments — 10 of 16 of them — lease 14,639 cow-calf pairs per year. Six of the 16 do not list AUM numbers. (The assessment should explain their status and average numbers for these N/A’s.) 14,639 cattle outnumber 7 to one the number of burros “estimated” in the EA. These herbivores supposedly graze only six months of the year, a promise which is seldom enforced by the BLM. A 2016 GAO report found widespread livestock trespassing to be more the rule than the exception: GAO 2016 Report: “Unauthorized Grazing” https://www.gao.gov/products/GAO-16-559 Managing this HMA primarily for livestock violates the 1971 Wild Horse Act.
9. The EA mistakenly says burros do more damage than cattle. Cattle hang out by riparian areas, contaminating water. Their selective grazing encourages aggressive invasive plant species. The methane they emit further degrades environmental quality. To quote wildlife biologist Erik Molvar, “the ‘take half, leave half’ mismanagement of the grass on typical grazing leases, permitting by design the removal of far more than the 25 percent removal of forage plants that is the allowable maximum based on range science, results in chronic overgrazing and serious damage to public lands and their wildlife.”
10. The Humane Society fertility control project, which is testing PZP darting on a sub-group of Black Mountain burros, will not be completed until 2021. Proceeding without knowing the results of this project is counter-productive. Nonetheless, the BLM proposes to forge ahead, even indicating, without justification, it will remove many of the burros treated with immunocontraception. I oppose the other proposed methods of population suppression. Gonacon would alter the natural cycle of jennies. Castrating jacks in the wild is dangerous and senseless. Wild burros are not zoo animals. Their wild behavior is integral to the natural balance and what the WRFHBA law was enacted to protect.
11. Wild burro droppings spread intact seeds as they graze in a mobile fashion. This facilitates the germination of a variety of plants in different areas, as their manure adds nutrient-rich hums to the soil. Burros graze down brush and other fire-prone vegetation. Many birds and insects depend on their ancient presence in these lands. By never mentioning their beneficial contributions, the BLM displays its pro-livestock bias. Burro bigotry has no place in an environmental review document.
12. The BLM must do an environmental impact statement that examines the past, present, future and interconnected environmental effects of wild burros on the HMA in relation to the whole ecosystem. It should include:
–The relative impacts of livestock vs. wild burro grazing, and measures to mitigate and prevent damage caused by either;
–The impacts on HMA range health of other industrial activities such as the Moss Mine;
–An up-to-date population survey using more effective techniques for tracking mammals such as fixed point photos, time counts, working with partners for ground-level grid counts;
–The costs of permanently removing burros from the HMA, including daily holding in short-term corrals, humane removal methods, and medical treatment;
–A comparison of those costs with alternative means of achieving population balance, including safe, humane, reversible fertility control, an end to predator killing, the introduction of jack/jenny pairs to underpopulated burro HMAs, and reductions along with increased monitoring of livestock grazing;
–A credible examination of the need to increase wild burro AML that doesn’t simply push the delete button;
–A serious consideration of risks from adding more captive wildlife such as wild burros to holding facilities, in view of the fact that zoonotic infectious diseases — 70% of which originate with wildlife — have quadrupled in the last 50 years;
–The risks that wild burros adopted or sold from BLM facilities have been or could become part of the murderous trade in ejiao, the impact of this trade on humans who cherish wild burros; and steps to implement improved vetting and followup on these transactions to ensure long-term burro safety;
–A consideration of the limitations placed by the COVID-19 pandemic on BLM staff and their capacities to ensure well-being of captive equids;
–A full examination, including public comments and the results of similar developments (such as the Pryor Wild Horse Range) of designating the Black Mountain HMA to a protected wild burro range by amending the Colorado River District’s Resource Management Plan;
–A discussion of steps — including a public awareness campaign and the installation of reflective lights — to avoid burro road deaths on highways, intrusion into public property, and intrusive, locally encouraged burro presence in the town of Oatman.
The EA must be reformulated, with real consideration of public views, the importance of preserving these vital heritage animals, and the momentous changes we are facing as a nation.