Direct Comments to the BLM by Charlotte Roe

May 17, 2020

Malheur Field Manager
Vale District BLM
100 Oregon St.
Vale, OR 97918

Submitted by email to: BLM_OR_Vale_WHB@blm.gov

Subject: Barren Valley Complex Population Management Plan (DOI-BLM-ORWA-V000-2019-0040-EA)

I am submitting these comments on the Draft EA for the Barren Valley Complex (BVC) in southeastern Oregon.  The EA’s chosen path of action would harm me in a deep and personal way.  One of my adopted mustang mares was rounded up in the 2011 helicopter gather for the Sheepshead/Heath Creek HMA, one of the three composing the combined Complex.  She was held in the Burns corral for several years, hungry, desperate, frightened and scroungy.  By luck, she was selected for EMM training; by a  further flip of the coin, she arrived at our homestead.  She’ll never lose those memories of being crowded into a shelterless, desolate holding pen where mustangs and burros fight for their lives and are treated like hogs penned for slaughter.

To have this EA propose rounding up 100 percent of the BVC mustangs and remove 75 percent to make room for taxpayer subsidized grazing; to select nearly two thousand horses to be shuttled off to an unsecured holding corral, with some mares potentially ovariectomized, and many to be vaccinated using hormone-disrupting Gonacon, is a desecration and a violation of the 1971 Wild Free-Roaming Horses and Burros Act (WFRHBA).  If this plan goes forward, I will live with the wound.  Our mare has never forgotten her homeland where wild equid family roots and their ties to the land mean everything.  Nor can I ignore what happens when wild horses are mistreated and the 1971 Wild Horse Act is undermined.  My specific objections follow:

1.  This is the most confusing EA I have ever encountered, and if I am baffled, much of the public must also be thrown off.  The e-planning site for BLM’s Vale District lists two different documents, one a Population Management Plan(BVC PMP Draft EA) and one a draft EA.  The second document cannot be opened on the e-planning site.  Are we to comment on two documents or one?  This is just the start of many contradictions and bizarre statements.

2.  That the BLM’s Proposed Action would lock in a radical wild horse population reduction for 10 years is completely unacceptable.  This violates the intent of the National Environmental Policy Act, as well as persistent input from the National Academy of Sciences.  In 1982, a National Research Council report on the Program encouraged the BLM to be more responsive to public attitudes and choices.  In 2013, the NAS Report reiterated this point, specifically recommending that the BLM improve methods to “engage with the public in ways that allow the public to influence agency decisions.”  Instead of taking this approach, the EA favors the subsidized grazing lobby by maintaining discriminatory forage allotments.  It would shut out public input.  It would freeze its outdated AML, which in the aforementioned Report, the NAS found to be arbitrary, inflexible and lacking in scientific foundation.

3.  The population management plan should never be allowed to proceed given current and probable future restrictions of the COVID-19 pandemic.  BLM holding corrals — which would house swelling numbers of captive BVC mustangs until sorted, as well as those deemed “excess” post-sorting — are closed to the public.  That means no taxpayer, potential adopter or representative of an equine or animal rights organization would have access to view the status of captured horses or monitor the surgical procedures that the EA considers.  How can the pubic know what’s happening without access?  I shouldn’t have to tell you that adoption via online is not a reliable way to secure a safe, long-lasting home for BLM mustangs.  It opens the door to kill buyers.  Since the BLM does not care to, and hasn’t the resources to monitor those who offer to take mustangs offered for sale or adoption, removing BVC horses will widen the slaughter pipeline.  The nearby border of Canada where horse slaughter is legal and common should give pause.

4.  The BLM’s just-released Report to Congress calls for removing up to 20,000 wild horses and burros a year to achieve the miniscule AML of 26,690, nearly the same level that triggered the Congress to pass in a unanimous vote the WFRHBA to keep these heritage animals from “fast disappearing from the West.”  The BLM’s FY21 budget authorization request contains no provision to assure the safety or upkeep of the wild equines it proposes to remove from their federally designated homes.  By the BLM’s own admission, it lacks the holding facilities to carry out its plan.  The EA’s plan to add more mustangs to the agency’s already overfilled holding pens is irresponsible and abusive.

5.  On pages 7-8, the EA proposes rounding up 100 percent of the BVC horses.  Those in excess of AML — 75 percent of the estimated wild horse population — would be removed to holding, and the remainder released, but when and under what conditions is unclear.  I oppose this radical and harmful plan.  I also object to the lack of vital information needed to evaluate the alternatives.  The EA presents spirals of confusion that makes it nearly impossible to the public to grasp the plan.  On page 7, the document states “bait, water, horseback and helicopter could be used to intensively apply available fertility control to reduce population between gathers.”  What in the world does that mean?  Apply immunocontraceptive vaccines via horseback or helicopter?  Please clarify this muddled statement.

6.  The Proposed Action would implement an “intensive” fertility control program.  The primary fertility control vaccine used by your district office is Gonacon, although PZP-22 is also mentioned.  Gonacon has not been adequately studied.  The ongoing research being conducted in Theodore Roosevelt National Park has raised some significant concerns.  This treatment shuts down natural estrus cycles in mares.  It could lead to permanent sterilization.  The unusually large foal die-off of 2019 could possibly be connected to the treatment, although this is unclear at present.  The EA needs to address the physiological impacts of inducing premature menopause in young animals, presenting the scientific information available.  It must also address the impacts of disrupting natural social herd behavior through hormone-disrupting vaccinations.  Given these concerns, I cannot support using Gonacon.

7.  Further confusing the matter, in a discussion of Alternative 2 on page 11, the document reads: “The EA proposes a component of sterile horses” using spaying and gelding.  On page 27, the EA goes into a lengthy justification of ovariectomy, which it considers to be a “100% effective fertility control” with only “minor or transient effects.”  True, killing a mare with a brutal, discredited form of field surgery would effectively prevent her from being fertile.  Such surgery is neither humane nor justifiable.  The EA cites the Collins-Kasbohm study as evidence that really, it’s no big deal.  In the Sheldon experiment cited in this study and in the EA, the majority of the mares and jennets subject to ovariectomy via colpotomy either died painfully or only survived through intensive veterinary intervention.  How is that “minor and transient?”  In previous attempts to promote this technique, sponsoring institutions including Oregon State University withdrew their support in response to public outcry and the truth about this procedure.

8.  The EA also blithely considers gelding and releasing captive studs, without any consideration of the physiological, social or welfare impacts of such a path.  It admits that castration of certain males would likely have little to no impact on population limbers.  It then compares the procedure to that used on dogs and cats.  That is hardly a valid comparison!  If the impact has almost nothing to do with the stated goals of the EA, why tinker with mustangs’ lives and vital herd dynamics?  Wild horses are not laboratory rats to be experimented upon.

9.  To be in compliance with the 1971 Wild Horse Act, the Barren Valley Complex should be “devoted principally” for the welfare of wild horses. Yet wild horse herds would be culled a fraction of their current estimated population, while thousands of livestock would continue to graze this ecologically challenged rangeland complex.  The majority of forage would continue to be reserved for private, taxpayer-subsidized livestock allotments: 71% of the AUMs to livestock and only 29% for wild horses.   The EA claims that livestock grazing levels cannot be altered for bureaucratic reasons.  This is disingenuous.  Authorization for the BLM to reduce or eliminate livestock grazing is completely doable pursuant to 43 CFR 4710.5.   At a minimum, 51% of the forage should be designated for protected wild horses.

10.  The EA states as its core purpose the prevention of range deterioration and the need to achieve “thriving natural ecological balance.”  Yet livestock and other commercial impacts are excluded from the equation.  This is wrong.  43 CFR § 4700.0-6 stipulates that “wild horses and burros shall be considered comparably [similar] with other resource values in the formulation of land use plans.”  This EA relies on land use plans that range from 15 to 45 years old which fail to consider the comparability of such impacts.   Before changing its management plan or even considering an alternative, the EA must analyze the Barren Valley Complex landscape including all wild species, all domestic livestock, and all commercial activities.  How has logging historically affected the ecology and what level of activity is projected? What are the impacts of past, present and projected future livestock on the health of the land, riparian areas and wildlife habitat, including federally designated wild horse habitat?

The GAO has consistently found that federal agencies’ decisions to remove wild horses have been based not on in-depth analyses of the carrying capacity of the land or the impacts of multiple activities, but on political pressure and unproven assumptions.  Further, in T-RCED-91-71 the GAO stated the number of wild horses that BLM has removed exceed the capacity of its adoption program.  Under the WFRHBA, wild horses are a protected wildlife species.  They should not be relegated to a miserable future because of anti-government rebellions in Malheur County or private interests in other parts of the BVC.

11.  The description of wild horses’ place and role in the BVC environment is deeply biased.  In places,the EA characterizes them as feral.  Yet paleontological evidence and mitochondrial DNA analysis support the conclusion that wild horses are native to North America.  This is where they evolved and, if in face most departed from 7,000 to 12,000 years ago, this is their evolutionary home.  Moreover, wild free-roaming horses are recognized under the 1971 Wild Horse Act as “living symbols of the historic and pioneer spirit of the West.”  They deserve respect and understanding, not mistreatment as extra baggage.

12.  Without on the ground evidence, the EA claims wild horses “compete with wildlife” for forage and may even “exclude pronghorns” from water sources.  This is conjecture.  Nowhere does the document mention the many benefits of wild horse presence.  Federal law defines them as wildlife contributing to the “thriving natural economic balance” in ways that promote natural processes. Their grazing on low-lying shrubs help prevent wildfires, an ever present danger as global warming accelerates.  They are walking fertilizers.  Wild horses’ presence helps protect sage grouse from predators.  Their sharp hooves can open up underground springs and break ice, assisting other wildlife to access sparse water.

13.  The costs of various alternatives are listed in a scattered form that omits essential elements.  The EA should include costs of unmitigated wildfires; of the euthanasia of horses damaged in helicopter roundups and crowded holding pens; of treating post-sterilization medical complications; of killing mountain lions and wolves in order to protect privileged livestock; of full projections that account for short and long term holding for more than a thousand horses that may be unadoptable in the pandemic and post-COVID 19 economy.  The full costs of the preferred alternative should be presented and contrasted with other responable choices, including a PZP darting program and a halt to the killing of predators.

I support the consistent, well-targeted and documented application of PZP or PZP-22 as a means of keeping population in balance.  Protecting predators would also help maintain natural controls that are in keeping with the spirit and intent of the WFRHBA.  The EA notes that following the 2011 roundups, all released mares were treated with PZP.  Was a followup booster given?  If not, why?  Americans overwhelmingly favor humane population management approaches.  Humane fertility control should not be confused with surgical sterilization or the use of hormone-disrupting vaccines such as Gonacon.

I do not support the proposal for huge roundups and the removal of the majority of the BVC herds.  I strongly recommend that, in keeping with NEPA, the BLM set forth and analyze an alternative that considers the ways in which an effective, responsible fertility control program and the protection of predators would keep the population in check and make a costly, risky mass removal unnecessary.  Failure to take a close look at this alternative makes the EA less than credible.

Thank you for considering these comments.  I ask that you inform me of the final EA and any future assessments or actions affecting this herd.  I and many more who care about the welfare and freedom of America’s wild horses and the health of our public lands will be watching.

Charlotte Roe
Berthoud, CO 80513