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.
Categories: Horse News, Wild Burros
Straight from the Horse's Heart 
When u take Mother Nature out of the equation u unbalance Nature’s scales . Stop killing the wolves and stop rounding up our wild horses and burros . BLM u need to start protecting our public lands and the natural inhabitants . Thank you
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Please stop rounding up our beautiful wild horses and burros. And stop killing our wolves bears coyotes. America the beautiful will not be anymore! Future generations will not see the beauty and how proud we are of our country!
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I agree, how will we explain this to future generations??
Total disgrace here! We must stand up here to be the voices for the innocent ones who have no voice! Shame on our current government leaders who only care about mining & $$. We need our voices to be heard. What ever happened to “WE THE PEOPLE ” ??
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I’m sick of all of this! Get rid of the corrupt BLM. They are paid by cattlemen/ranchers and I am sick of it! They want to kill everything in their path. They do not listen to any comments we give or any scientific logic. They are brain dead to what will eventually happen! I am writing every single Congressman/woman and Representative until something is done to get rid of these creeps!
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Sadly, the BLM is paid by us, the US of the United States. We should insist on a moratorium of all BLM actions not subject to independent review, and especially any actions taken in a time of national and global emergency that cause permanent results. With an election looming in about six months, nothing that can’t be readily undone should even be considered. It was good enough reason to ignore a Supreme Court justice nomination in recent memory; decisions that cost lives should have at least equal importance to our citizens.
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Absolutely agree with your comments here!
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ICYSPOTS I think maybe you missed my point on who pays the BLM. What I meant was they are on the side of the cattlemen and big business and not our wild horses. They are in the “pocket” of those who would destroy our horses. Thank you for your comment.
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This is a very well written and concise letter. Everyone who cares about these wild burros needs to write a letter as well. Please get involved. Thank you, Charlotte Row for your letter.
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The guy in the blue shirt was and still is working for BLM AZ.
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How is this clown not in jail? Disgusting is not a strong enough word!!!
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https://rtfitchauthor.com/2016/01/18/blm-photo-documents-72-wild-burros-but-submits-written-report-of-1378/
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Told all how corrupt the BLM is & someone else should be in charge of taking care of the Wild Horses & Burros! How disgusting is that picture of that poor Burro being abused? Just think what free rein the BLM has to do these things all the time, makes me sick!
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It’s time to get Public Land from cattle grazing and give it back to our Wild Horses & Burros so there won’t be any need to move or wipe out any herds. There are millions of acres that these great animals should be using & it’s time that they do. During this horrible time of Covid 19 there shouldn’t be any decisions made without the public having a chance to comment. All these animals belong to the American people and we should be the ones to decide their care. It is the American taxpayers money that pays for the care of the horses & burros & so far I don’t like what I see for my money!
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Dr. Lori Eggert, University of Missouri – Genetic Diversity
BLM Advisory Board meeting Sept 9-11, 2013
12 burro HMAs with populations between 2 and 49 animals.
Burro populations do need priority for genetic management.
.”Maintenance of genetic diversity over time is going to require higher population size than even the largest HMA now has..”
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The African Wild Ass, including Nubian & Somalian subspecies, is Critically Endangered (IUCN SSC). It is basically the same interbreeding species as the wild burros found in the Black Mountain HMA. We should remember that all branches of the horse family Equidae originated & evolved over the great majority of their time on Earth in North America. Given the above, the establishment of genetically 3 viable burro populations in the wild, i.e. in their natural habitat where their true vigor is restored & preserved, is crucially important for the species’ survival. We should be restoring the wild burros of the Southwest United States to truly long-term viable populations, not reducing them to mere token, genetically non-viable levels. These animals should actually be protected under the Endangered Species Act. The Black Mountain wild burros constitute the largest wild burro herd on U.S. public lands, which certainly numbers among the largest in the world. They should not be cut down by 1,727 living, breathing, feeling individuals! Their conservation value for the survival of their species is critical
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Craig Downer’s public comments on the Black Mountains Wild Burro Herd Management Area
Click to access BlackMountainHMAWildBurroGatherPopControPlanEAPublicInputdueApril12020PDF.pdf
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IMPORTANT that the Decision Making Public be given accurate information
BLM Photo Documents 72 Wild Burros but Submits Written Report of 1,378?
The aerial census documentation over the nine days fails to adequatelydocument the BLM’s wild burro population count
Complete data received via FOIA
Black Mountain Wild Burro Herd Management Area: Analysis of Bureau of Land Management Aerial Census
April and October 2014 Flights
Independent Study by Independent Environmental Researchers
https://rtfitchauthor.com/2016/01/18/blm-photo-documents-72-wild-burros-but-submits-written-report-of-1378/
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