A response to an article in the Deseret News by Amy Joi O’Donohue about managing wild horses, aka: ‘Mustangs’
Over the past years, many controversial ideas for managing wild horses in American have been floated, including some ideas cited in an article that appeared in Deseret News titled;
“Could wild horses feed the world’s hungry … or Siberian tigers and Amur leopards? Controversial ideas abound with U.S. populations of horses, burros”
That article stated:
“California’s William ‘Bill’ Simpson conducted a five-year study that started in 2014 to look at horses’ impacts on natural landscapes in about 5,000 acres in Northern California and Oregon. The land was host to 67 horses that were preyed on by coyotes and mountain lions. Over the study period, 52 horses remained.
In the interim, Simpson’s study looked at the horses’ positive benefits on fuels reduction — the understory and brush — that are a primary driver in catastrophic wildfires.
He wants to do a pilot project and introduce horses into select wilderness areas in the Pacific Northwest, where logging is prohibited, mechanized fuels treatment is forbidden and of course, livestock grazing isn’t allowed.
“We don’t need to have this range war,” he said. Natural predation will keep populations down, and the horses will play an important role in fuels reduction, he stressed.
“Forcing these horses into livestock production areas is not good for either the horse or the cow. It is bad resource management, it is bad all around.”
As it turns out, William E. Simpson II is not the only researcher who understands that wild horses have naturally evolved predators, which in fact do maintain wild horse populations in equilibrium within ecosystems, if their evolved predators have not been depleted. [1, 2, 3, 4, 5]
Contrary to genuine facts, the Bureau of Land Management (‘BLM’) published what is clearly a blatant fiction:
“Wild horses have no natural predators …” is a manifestly false statement promoted and published by the BLM.
That false statement appears in the BLM’s so-called management plan that was presented to the Congress of The United States in writing titled; ‘Report To Congress – Management Options For A Sustainable Wild Horse And Burro Program’. (See page 1, paragraph 5)
Only a corrupted agency would propose to manage any resource premised upon a lie.
Wild horses (mustangs) are suffering from unethical management and the results of short-sighted ideas promoted by people that have zero empirical experience with free-roaming wild horses living naturally in wilderness areas, as they had for millennia in north America.
A careful and unprejudiced examination of the evolutionary role and co-evolved mutualisms that wild horses uniquely have with numerous native species of flora and fauna (including apex predators) in north America, makes it illogical and ecologically egregious to suggest removing them from their critical evolutionary roles.
It’s egregious to suggest using America’s most important and only native ‘keystone herbivore’ for any purpose that removes them from their critical evolutionary role on the American landscape!
The Bureau of Land Management (‘BLM’) as well as the United States Forest Service (‘USFS’) have established artificial, economically motivated, population control guidelines for wild horses (aka: ‘mustangs’, ‘feral horses’), which so-called guidelines are amusingly termed as ‘Appropriate Management Levels’ or ‘AMLs’.
AMLs Are Arbitrary and Have No Basis In Natural Ecology.
AMLs are only ‘appropriate’ for establishing and maximizing commercial grazing and livestock population densities on public lands in a manner that allows an argument that wildlife (including wild horses) are taken into consideration. But in reality, we find that non-commercial wildlife on public lands, namely wild horses, are managed at population densities well below legitimate levels required to maintain genetic sustainability.
Sustainable Management Using Science and Genetics:
Since its establishment in 1948, the International Union for Conservation of Nature (‘IUCN’) has become the global authority on the status of the natural world and the measures needed to safeguard it. The knowledge and the tools IUCN provides are critical for ensuring that human progress, economic development and nature conservation take place together. The IUCN notes that the selective pressures wild equids have endured in the wild are likely shaping them genetically to be hardy stock that could prove useful as a genetic resource. The recommended population sizes for the conservation of genetic diversity fall into one of two approaches:
Captive populations — minimum size: 500 individuals, a studbook, and careful
genetic management; or
Wild populations — minimum size 2,500 individuals (no studbook, no genetic
Importantly, there is no record of the BLM or the USFS maintaining any studbook for wild horses (mustangs).
Wildlife populations other than wild horses, which have commercial value as determined by the hunting industry (deer, elk, grouse, etc.), are in fact managed to maintain genetic sustainability.
Imagine the outrage that would emanate from the hunting industry if deer or elk were to be managed using AMLs that had their populations at 1-deer or elk per 2,500 acres, with less than 100 breeding adults in a herd. It would not stand, so why is this allowed for wild horses? The answer is; money and corruption.
AMLs were established and are used by the BLM and USFS to provide shared use and grazing of existing finite carrying capacities of given grazing areas and regions under the administration of the BLM and the USFS. Due to the pressures of commercial economics, AMLs arguably primarily benefit the livestock production business.
Yet, it does so at the great expense of the genetic sustainability of wild horses as well as the angst of a large percentage of American consumers, who love America’s wild horses, and this has yielded what may be termed as a ‘modern range war’. 
Most AMLs established in Herd Management Areas (‘HMAs’), have wild horse herd populations reduced to numbers so small, it makes no sense other than to support the economics of livestock production.
Today we find BLM and USFS managed HMAs with wild horse population densities (AML) ranging from 1-horse per 1,500-acres to 1-horse per 3,000 acres, and herd sizes across the board well under the absolute genetic minimum of 250 breeding adults.
Furthermore, herd sizes are being reduced in many cases to well below 100 breeding adults, which is in conflict with the best science stating that in order to maintain viable genetic diversity and vigor, herds must be maintained at the absolute minimum of 250 breeding adults. Making matters worse is that the relatively few wild horses being left on the range are also treated with chemicals like PZP and GonaCon that render them infertile.
So, in reality, ‘breeding adults’ left on the range can arguably be ‘zero’ in many HMAs.
The problem with AMLs is that they do not consider or properly weigh the complete short and long-term ecological and genetic implications related to limiting the population of the only non-ungulate ‘keystone herbivore’ (wild horses) in North America. Wild horses have critically important co-evolved mutualisms with numerous species of flora and fauna, which through millennia of co-evolution depend upon wild horses for specific symbiotic functions.
It’s a scientific fact that livestock (cattle, sheep and most goats) have no co-evolved mutualisms with the flora and fauna of North America, and there are ‘zero’ cattle fossils in North America. As such, paleontology proves that cattle are in fact an invasive species.
On the other hand, horse fossils litter the north American continent and arguably date from 5,000 years old, to millions of years old, with the oldest horse fossils in world being found exclusively in North America. This proves two important points:
1. All horses found today in the world originally evolved in North America; and
2. Wild horses in North America are a native species as are all post-Columbian period reintroduced horses, such as the Spanish horses.
Science also informs us that; cattle do have co-evolved mutualisms with flora and fauna in localities outside the North American continent, such as in Africa. In Africa for instance, some plants and grasses have evolved seed-coats that are resistant to the powerful digestive systems of ungulates. This is of course the result of co-evolutionary processes between the cattle and flora of Africa over millennia of time.
Trying to mix oil and water; the current paradigm of wild horse management in areas of North America long-used for livestock production, which results from the pressures of consumerism.
Commingling wild horses in the same areas where livestock production has been ongoing for over 300-years is an illogical management paradigm, and flies in the face of solid ecological practices.
Many HMAs are situated on or around these longstanding livestock production areas that have, by design, been depleted of apex predators to enhance livestock production. However, forcing wild horses to remain in areas that no longer contain their evolved predators does a serious ecological and genetic injustice to wild horses whose genetic vigor depends upon the evolutionary process of ‘Natural Selection’.
The intent of the now aging 1971 Free Roaming Wild Burro and Horse Protection Act can be maintained by reallocating wild horses into designated wilderness areas where it is both economically and ecologically appropriate. Such wilderness areas are manifestly unsuited for livestock grazing and are the historic habitats of wild horses and contain populations of apex predators, which are the co-evolved predators of wild horses.
Relocation of wild horses into such designated wilderness areas is encompassed in a wild horse management plan called ‘Wild Horse Fire Brigade’.
The evolution of a new paradigm in wild horse management
In 2014, naturalist-author William E. Simpson II took-up residence in a cabin in a wilderness area. Using collegiate training in science and empirical experience in forestry and resource management, Simpson has spent the last 7-years living among and studying the free-roaming wild horses in the Cascade-Siskiyou Mountains as an embedded symbiont, which is an observational study paradigm that was originated and perfected by Miss Jane Goodall in Gombe Africa with the Apes.
Through what Simpson learned from Miss Goodall’s techniques and accounting of her African studies of Apes, he has gathered and documented some new and never-before documented wild horse behaviors in a naturally-operating wilderness ecosystem that is largely devoid of invasive species livestock.
As Mr. Simpson came to learn over the course of his intensive 5-year Study, wild horses are essential keystone herbivores in wilderness areas, and perform critical functions that benefit entire ecosystems. One such example is that; each wild horse consumes about 5-6 tons of one-hour class wildfire fuels (grass and brush) annually, thereby reducing both the frequency and intensity of wildfire according to numerous published 3rd party scientific studies. In and around forested areas, this reduction of key wildfire fuels helps maintain a fire-resistant forest, which in turn has many ecological benefits.
Over the past millions of years of life in North America, and as a native species that originated and evolved exclusively in North America, wild horses have co-evolved with virtually all of the flora and fauna of North America and share many critical symbiotic relationships with numerous species of flora and fauna.
An example of one such evolved symbiotic relationship is a function of their single stomach and a digestive system that passes virtually all the seeds of the native plants wild horses eat back onto to the landscape encased in their droppings, which contain nutrients and humus for the seeds to flourish as well as essential microbiome.
Simply put: The plants and grasses provide sustenance for the wild horses, and the wild horses spread the seeds of the grasses and plants, thus assuring future generations of the flora; a true symbiotic relationship.
Soils that have been damaged (pasteurized) by unnaturally hot catastrophic wildfires benefit greatly by the reintroduction of the microbiome from horse droppings that is lost from the heat-pasteurization during wildfires.
Ungulates (deer, elk cattle and sheep) do not perform this critical evolutionary process; ungulates have complex multi-chambered stomachs and are very efficient digesters and render virtually all native plant’s seeds they consume unable to germinate, being partially or wholly digested.
One novel discovery that Simpson was able to make (and publish) as a result of being accepted by wild horses as a ‘symbiotic species’ himself, was their unique knowledge of botany, and the medicinal use of herb pennyroyal to enhance their lives. This is the sign of a highly intelligent sentient being.
This published article from August 2019, explains Simpson’s novel discovery about wild horses and their knowledge of medicinal plants: “New Paradigm In The Observational Study Of Native Species Wild Horses – The Embedded Human Symbiont”
A natural, holistic solution to a man-made problem with wild horses
Wild Horse Fire Brigade (‘WHFB’) is a plan that offers a solution that benefits, forests and wildlife, the livestock industry and America’s wild horses.
Via the WHFB plan, wild horses are relocated and rewilded into designated wilderness areas that are both ecologically and economically appropriate, and which cannot be used for grazing livestock for a multitude of reasons, including; laws protecting wilderness, predation by existing apex predators, and prohibitive management/transport logistics costs in extremely remote/rugged terrain.
In such remote wilderness areas, many of which have suffered a collapse of the populations of native species grazers (deer, elk, etc.), wild horses can be truly wild and free as they were centuries ago, and beyond the molestation of meddling people, including some wild horse activist non-profits (not sanctuaries). 
These ‘meddlers’, who by their own suggestions of mass castration of stallions and use of chemicals PZP & GonaCon on wild horses, prove their ignorance of natural evolutionary processes.
These evolutionary processes are critical to the long-term well-being and survival of the gene-lines of wild horses, including ‘Natural Selection’, and are adversely effected by the use of PZP, which is a genetic poison leading to ‘Selective Breeding’ that results in progeny with successively lower levels of natural immunity.
If Americans truly want to save America’s remaining wild horses and burros, then we MUST look to Nature, and only Nature for the answers.
Humankind have failed in regard to managing wild horses for the past 50-years! Time for a new management paradigm.
 “Cougar Kill Rate and Prey Composition in a Multiprey System. Journal of Wildlife Management 74(7):000–000; 2010; DOI: 10.2193/2009-314. Downloaded at: http://sci-northern.ab.ca/wp-content/uploads/2010/12/CougarKillRateandPreyComposition.pdf”
 “Ferocious appetites: Study finds mountain lions may be eating more than previously believed. Billings Gazette. Retrieved from:
 “Influence of Predation by Mountain Lions on Numbers and Survivorship of a Feral Horse Population. The Southwestern Naturalist. Vol. 46, No. 2 (Jun., 2001), pp. 183-190. Available at:
 “High foal mortality limits growth of a desert feral horse population in Nevada. Great Basin Naturalist: Vol. 59: No. 4, Article 10. Available at: https://scholarsarchive.byu.edu/gbn/vol59/iss4/10”
 “Lions blamed for deaths of Pryor foals. Billings Gazette. Retrieved from:
 “Wild Horse Wars – A series by: William E. Simpson II – Naturalist, Wild Horse Ranch – Siskiyou County, CA: https://www.sierranevadaally.org/2021/04/05/wild-horse-wars/
 “Collapse of the world’s largest herbivores: “By altering the quantity and distribution of fuel supplies, large herbivores can shape the frequency, intensity, and spatial distribution of fires across a landscape”. William J. Ripple, et. al. http://advances.sciencemag.org/content/1/4/e1400103.full
#Wild Horses, #WildHorses, #WHFB
William E Simpson
Wild Horse Ranch Productions
+1 858. 212-5762
email us here
Wildfire continues to devastate the American West at increasing rates. A plan that could reduce the frequency and intensity of wildfire requires wild horses
Categories: Horse Health, Horse Slaughter, Wild Burros, Wild Horses/Mustangs
If the Wildlife Service were brought under control, there would be predators to check the population.
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Just call them the Wildlife Dis-service. Great article with points pass on.
Excellent; well researched Article. The BLM is making so many mistakes.
May these horses be delivered from the hands of those who didn’t care into the hands of those who will love, support and provide. It is this prayer that is being answered, it is this miracle for which I am truly grateful.
Better yet – be left to live their lives in their home areas rather than rounded up!
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Intentional or not, the included photograph of an appaloosa foal provides an excellent reminder of what is happening. Though natural (and native) these particular genetics are disappearing from our wild herds at the hands of our paid “managers.” I sometimes wonder if it is easier to hoodwink the public and the wild-horse-disposal-pipeline by diluting the genetics such that we have larger and larger numbers of simply bays or sorrels, with fewer and fewer distinctive markings. We do know some trailers full of BLM branded solid colored horses were transported to slaughter using forged paperwork. Since the slaughter-bound trailers are often sealed, nobody can verify horse by horse which animals are inside, and if the papers say “30 bay studs” who will know the difference? We will never know how many horses supposedly in “long term holding” exist now only on paper. We cannot find or verify individual horses, and this is by BLM design.
Homogenizing the herds is not only dangerous, but unnatural selection writ large, and utterly contradictive of the 1971 protective law — law designed to manage the herds “where then found” as intact and largely undisturbed parts of their ecosystems, using “minimal feasible” methods.
It is clear we need new directions, but what isn’t clear is if anyone in elected or appointed office has the cojones to do anything different before it is too late for our wild herds. Like many, I get form letter responses from endless communicating about these matters to office holders for my local, state, and federal jurisdictions.
The wall of silence is deafening, and damning.
To paraphrase an older powerful quote: Mr. Biden, TEAR DOWN THIS WALL!
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Makes it that much easier to get rid of our wild horses if they look pretty much the same – who will bother to look further? And yeah, the silence from our supposed representatives and the administration. I very seldom will bother with a form letter – just delete it & make the effort to tell what’s happening & try not to “shout” why the H—arent you listening & DOING anything! One of my Dem. Senators sends the auto reply & I never hear another word! My current Rep (Repub) seems to think if she says enough about how she “feels” that will snow me enough so I wont realize she never acknowledges she isnt doing anything about it. I’m sure thats pretty much the same response most of us are getting. No conjones anywhere!
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I really wish this whole issue had a higher public profile. It’s all so low key, when what we need is a public outcry against the BLM and the Biden administration. Unfortunately people don’t read newspapers much anymore, so unless we find a way to put this front and center and create some anger, we’re not getting where we need to be to save the horses. Every member of organizations like the Sierra Club, the Humane Society, etc should contact their executive boards and demand that they take open, loud action for one thing.
And in Europe – they are RE-WILDING their almost extinct wild horses! While the goal here in the US is eliminating them!! The pictures of their wild horses look pretty close to what ours look like.
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When a trailer is emptied of new wild horses for holding, it leaves with with a trailer full. This has been observed numerous times.
So many valid points here. As a wildlife ecologist who has studied wild horses, burros and tapirs (all in the Perissodactyla order of the Class Mammalia) both in the field and through extensive readings and courses, I would just like to add that as an ecological “climax” species, i.e. member of the more permanent life community, rather than earl- or mid-successional, the horse, as the burro as well, are capable of self-limitation of their numbers once their ecological niche is filled. This they do by limiting reproduction in adjustment to forage availabity. I agree that they are an important “keystone” species that can enhance the biodiversity, stability and resiliency of many life communities both in North America and in other continents. But, as Bill emphasized, North America is their continent of origin and long-standing evolution, a statement that applies not just to the species, Equus caballus, but to the entire genus Equus and family Equidae. The are great Global Warming combaters and catastrophic wildfire mitigators and even preventers. I refer you to my article https://www.horsetalk.co.nz/2021/07/17/horses-carbon-sequesters/ as well as to my book The Wild Horse Conspiracy whose first Chapter concerns the evolution of the horses and burros as well as their history in America and whose second Chapter concerns the ecology of these real enhancers of the North American ecosystem.