StinkingWater Comments

Please help stop this roundup — cross post and take action for Oregon’s wild horses!

We just reviewed the environmental assessment today for the roundup of Oregon’s Stinkingwater herd management area and made the following comments on this potentially disastrous roundup. Ginger Kathrens said that it is the most egregious EA she’s read in her 16 years with the wild horses. Not only is BLM proposing (and planning on) removing all but 40 wild horses from this area (and the 40 would include non-reproducing sterilized males) but they plan to start only 24 hours after foaling season ends (according to BLM- but in all likelihood many mares will still be pregnant or about to foal). The maze of livestock fencing on this herd management area combined with two helicopters chasing extremely young foals is bound to be a fatal disaster for many horses. In their standard operating procedures BLM “generally” does not roundup horses with choppers 6 weeks before or after foaling season. In Stinkingwater they have left those humane concerns behind due to “contractor availability.” Because the BLM relies on only 2 contractors, the Cattoors (the owner of which was found guilty for rounding up wild horses and sending them to slaughter) and KB Livestock (who do a poor job and kills many horses by running them directly into trailers etc); BLM plans to start this roundup just hours after their defined foaling season is over. The Cold Springs (OR) roundup will follow on July 11. In both these areas some of Oregon’s last wild horses are at risk. We’ve asked that BLM postpone these roundups at the very least.
Please request that BLM postpone both the Stinkingwater and Cold Springs roundups!!
As an Oregonian I’d like to have some confidence that BLM will not destroy these two herds and I know I’m not alone in this– these horses matter!

The clock is ticking for these horses and an immediate moratorium on all Oregon roundups scheduled for this year is necessary and warranted. The Cloud Foundation’s comments on Stinkingwater follow. Please call Oregon Senators, Congresspeople and the govenor to stop the potentially disasterous roundup of these beautiful and healthy wild horses.

All best and thank you!

Makendra Silverman
Associate Director
The Cloud Foundation

Bureau of Land Management
Burns Field Office
Richard Roy, Field Manager

June 21, 2010

Re: Stinkingwater Environmental Assessment DOI-BLM-OR-050-2010-0024-EA

Dear Mr. Roy,

The Cloud Foundation, a 501(c)3 non-profit corporation, on behalf of our thousands of supporters throughout the United States; The Equine Welfare Alliance, Front Range Equine Rescue, Colorado Wild Horse and Burro Coalition and the over 90 organizations represented thereby submit the following comments for your consideration. The Equine Welfare Alliance is based in Chicago, Illinois and represents horse organizations worldwide. The Cloud Foundation is dedicated to the preservation of wild horses and burros on our public lands and is committed to educating the public about the natural history of these animals and their place on America’s Western public lands. Front Range Equine Rescue is a Colorado horse rescue with years of experience in mustang rescue, rehabilitation and training, and the Colorado Wild Horse and Burro Coalition is committed to preservation of Colorado’s and the nation’s wild horse herds.

Genetic Viability/AML
With regard to the Environmental Assessment (EA) number DOI-BLM-OR-050-2010-0024-EA released last month we oppose the proposed roundup and removal of 174 wild horses from the Stinkingwater HMA. Though cited as a action to “ensure a vigorous and diverse breeding population” the removal of all but 40 of these mustangs would nearly if not completely devastate the Stinkingwater herd. Forty animals does not allow for a diverse breeding population. The “appropriate management levels” (AML) for wild horses are incredibly low for this 85,490 acre range on which over 700 cattle (or 3,500 sheep or goats) are permitted to graze. The assignment of these AMLs is clearly based in prejudice rather than science and before any removals take place it is necessary to re-evaluate AUM allocation for both wild horses and livestock. Removing down to low AML leaves the Stinkingwater herd far short of genetic viability, for which a base level of 150-200 adult animals has been established as a minimal number to insure the herd’s future survival without inbreeding. What is your scientific reference for the statement that leaving 40 (mares/stallions/geldings) on the Stinkingwater HMA ensures a vigorous and diverse breeding population?

Return of Geldings to the HMA
The replacement of functioning, reproducing stallions with geldings both violates the “self-sustaining” clause of the Wild Horse and Burro Act and leaves this herd with an even lower Ne (genetic effective number), further jeopardizing the survival of this small herd. Returning just gelded males to the range 24-48 hours post surgery does not allow for any sufficient monitoring and deaths may result. Specifically, which drugs will be administered to geldings prior to and following surgery? What pain medications will be given during their recovery? Have the presence of geldings in HMAs been studied and what precedent is being followed for the placement of geldings in Stinkingwater?

Blaming the Minority
While the purpose of BLM management should be to allw a thriving ecological balance, and prevent degradation of rangeland resources, the removal plan ignores the fact that wild horses are outnumbered over 20:1 by livestock. What the proposed action would do is to nearly eliminate a competing species while favoring extensive livestock grazing on this designated wild horse herd management area.

Allocation of only 480 AUMs to wild horses in comparison to 8,456 AUMs for livestock does not allow for a functioning HMA and it is necessary to suspend the current action and reconsider AUM allocation. We will remind you that this is public land which was designated by congress principally though not exclusively for wild horses. Please explain the reason for this oversight in management. Most scientists and range managers agree that wild horses do no more damage than cattle to public lands and in fact, far less. In 1990 the Government Accountability Office Report underscored that wild horse removals did not significantly improve range conditions. The report pointed to cattle as the culprit as they vastly outnumber horses on BLM-managed public lands. They reported that wild horse removals are not linked to range conditions and mentioned the lack of data provided by BLM. It seems that very little has changed over the past 20 years.

Omitted Details
The map included with this EA is not representative of the actual area as it fails to show the maze of livestock fences criss-crossing the HMA and other natural and manmade obstacles in the area. This map, which would be more informative to the concerned public, is in existence in the livestock EA for the same Stinkingwater HMA. Why was this map omitted from the above referenced EA? What measures are being taken to insure that wild horses, and especially panicked foals, will not be run though the prolific fencing? The standard operating procedures (SOPs) included in this EA state that “humane procedures will be vigorously enforced.” The timing and nature of this roundup are in direct opposition to your SOPs. A high number of deaths and injuries and orphaned foals are expected if you proceed with this roundup as scheduled. Young foals will not understand or be wary of hard to see fences as they struggle to keep up with their mothers over long distances.

Costs of Removal
It would make more sense to pay the permittees who have been given grazing permits within the HMA not to graze on the public lands and leave wild horses on Stinkingwater public land in greater numbers. Although this is not allowed for in your current management practices, please work with the national office to more creatively and advantageously manage the range for all users. Please consider that the removal of a mustang costs already strapped American taxpayers over $2,000 in addition to a possible $2,098 to $470/year holding cost for the rest of the horse’s life if they are not adopted or sold. Has the option of reducing livestock AUMs been given any consideration? It is not our wish to harm the livelihood of ranchers but current inequities should be rectified. The BLM must transition from managing only for extractive uses to managing the land for the good of the public on the whole and the wildlife, including wild equids, that share this land with overwhelming numbers of privately-owned livestock.

Timing of Proposed Removal
Despite the clear statement in your EA “The BLM generally avoids gathering wild horses by helicopter during the 6 weeks prior to and following the peak foaling season (i.e., March 1 through June 30)”—the roundup is scheduled for July 1. Removing wild horses beginning one day after the conclusion of the foaling season, as defined by BLM, is inhumane at best. In this planned roundup foals who are days or even hours old may be run up to 10 miles over rugged country. Why has this roundup not been delayed until September or October when foals are older and mares are not possibly still pregnant. Putting extremely young foals through the stress and impact of a helicopter roundup is against basic standards of wild horse management and a later roundup is warranted. Foals have soft feet and a roundup at this time will be detrimental to their future soundness as well as causing untold pain. If there is not contractor availability this fall than the roundup should be delayed until 2011. The American public will not stand for egregious operations of this nature against wild horses.

The Numbers
We have great concerns about the reported population numbers as well. In September of 2009 the National BLM office reported that there were 70 wild horses in Stinkingwater and during the census on 7/29/09 reported 40 horses. In the EA it is now estimated that there are 214 horses and that a 9/2009 census found 179 horses. Foals, contrary to the EA, are not to be included in the AML. AML and population counts are to include only mustangs over one year of age when survival is more assured. Population estimates in general by the BLM ignore the fact that wild horse herds do not increase by 20% per year (an population increase of 10-12% is more accurate but varies from year to year and herd to herd). Also, mountain lion predation and natural death are rarely, if ever, taken into account when estimating population.

Values of Wild Horses on Public Lands & Comparison with Damaging Livestock
Across the board the BLM fails to acknowledge the value of wild horses to their native environment. It is well known that the horse, with its post-gastric digestive system can reseed the range and greatly aid in building nutrient-rich humus, a critical component of healthy soils. The horses break water, allowing pronghorn, deer, smaller mammals and birds to drink. Unlike cattle that ruminate— often near riparian areas where they defecate in the water—the horses keep moving for most of the day and night to assist in digestion. They prefer upland grazing habitat unlike exotic cattle that cluster in lowland areas along streams and water sources. Cows generally graze within a mile of water. In comparison wild horses are highly mobile, moving 5-10 miles from water and grazing on more rugged terrain. Cows not only eat 26lbs. of grass daily but they consume as much as 30 gallons of water a day and defecate in it as well. Given the above factual statements on cattle vs. wild horse behavior, a reanalysis of actual damage should be done before any removals take place.

The horse, as a returned native, fits into an environment from which they were missing for only 7,000 years—the blink of an eye in geologic time. The “green” wild horses should be embraced as part of the eco-system of this wild and beautiful area. Instead, they are marginalized and eradicated. Across the board BLM does not adequately control cattle on the public’s land and has not sustainably balanced the use of the “forage”, water and space. We’d like to see this remedied in the Stinkingwater area and across the west.

Infertility Drugs
Has the application of infertility drugs, specifically PZP, been considered in this area? Removal of 174 horses with no consideration of the use of infertility drugs goes against standards set forth by the national office. If infertility drugs were used they should be applied at the correct time of year and funding for monitoring allocated.
Given BLM’s current situation (more wild horses in holding than in the wild and holding facilities at or over capacity) is this roundup being conducted on emergency terms or could a reduction in this population be delayed until 2011 or 2012? It is likely that only a small percentage of the wild horses and burros removed from Stinkingwater would be adopted into good homes. The rest would be moved to short term holding at a cost of approximately $5.75/day and then to long-term holding facilities in Iowa, South Dakota, Kansas and Oklahoma at a cost of around $470/year. In the recent opinion rendered by Judge Paul L. Friedman in the Calico Complex case, he stated the “BLM’s relocation of excess horses to those facilities for indefinite holding periods violates the plain language of Section 1339a.” He further stated that “such a large number of confined horses raises precisely the specter of the ‘zoo-like’ developments whose formation the Act (1971 Wild Horse and Burro Act) was meant to prevent.”

Adaptive Management
The piecemeal methods of BLM public lands management are not positive for the land or the wild herds and limit solutions. Adaptive Management must be utilized and the public allowed to comment and to suggest solutions on actions in a holistic manner. This is contrary to the EA, stating “[t]he decision resulting from this environmental assessment would not set or adjust appropriate management levels, which were set by previous planning-level decisions. The decision would not revise authorized livestock grazing permits, as these decisions are made by evaluating each individual grazing allotment and associated permits.” In fact, AMLs need to be reset and grazing permits reduced.

We appreciate the opportunity to comment on this Environmental Assessment. There is wide public interest in Oregon’s wild horses and burros.

We have the following questions regarding this EA.

1. Please outline the number of permitted livestock grazing on this HMA in both Animal Unit Months (AUMs) and total number of head at peak and minimum as per the granted allotments.
2. Please provide accurate scientific analysis of any damage done to the range by horses and burros and indicate how this damage is attributed to wild equids and not livestock. How will wild horse and burro reduction aid in restoration of disturbed areas when such high numbers of livestock are grazed on these same public lands?
3. Please disclose the exact fees charged per AUM for livestock grazing on Stinking Water HMA.
4. Given that you have the authority for managing both livestock and wild horses and burros, along with the other wildlife in the area, why has your office failed to increase wild horse and burro AMLs to levels that would benefit taxpayers by decreasing removal costs while benefiting the environment by concurrently reducing livestock grazing levels?
5. Please provide, for the interested public, a categorized budget and estimated total cost for this helicopter removal and subsequent processing to be conducted by the Cattoor Livestock company .
6. Please describe in full the planned capture process for the interested public. This would trap locations, procedure for moving horses and burros to holding location, outline processing and future plans for all removed animals.
7. What are the effects of mountain lion predation on this herd and the effect of other potential predators?
8. Should this removal proceed, will humane observers and the public be given full access to observe (while not disturbing the operation) any planned removal plans, processing and infertility control treatment. There is a high level of interest in this action.
9. Why was an Oregon resident told that they had a 300 word limit on their comments?
10. Why was an Oregon resident told that neither they nor the media would have no opportunity to observe any portion of this proposed roundup?

In short, we ask you postpone this inhumane roundup slated to begin July 1 until the fall or fiscal year 2011. Please keep us informed and add us to your mailing list for information on all herds managed by the Burns Field Office.


Ginger Kathrens
Volunteer Executive Director
The Cloud Foundation, Inc.
107 S. 7th St
Colorado Springs, CO 80905

The Equine Welfare Alliance
Front Range Equine Rescue
Colorado Wild Horse and Burro Coalition

The Cloud Foundation is a proud member of the American Wild Horse Preservation Campaign


4 Responses to “StinkingWater Comments”

  1. Marilyn Wargo Says:

    This Information is excellent and we need to follow through all together and keep the pressure on BLM. The roundups coming are going to be like Calico but could be far worse. There is no place for these wild ones but on their range. We must keep them free and not allow them to enter into the grey world of BLM Captives.

    Please do all you can this summer to save our wild ones! Letters, emails, donations and talk to all your friends and acquaintances. Keep our wild herds free on their own range. mar

  2. Jan Says:

    this is an excellent letter to the blm from ginger and sure hope someone reads it and puts it into effect immediately – shall we call her now wild horse ginger as she carries on the legacy of wild horse annie to save our wild horses??

  3. jean Says:

    Ginger does it again…always has just the right questions, with all the knowledge to back it up. Why in the hell aren’t they listening to the people?! I believe more pressure needs to be put on the BLM from the public, because right now they just seem to keep doing what their doing and not listening to anyone. This is a total disgrace, by our government to allow this to continue. The rights and humanity of all animals, big and small are being more and more reconized

  4. jean Says:

    To finish………The rights and humanity of all animals, big and small are being more and more reconized in recent years, thanks to all the humane animal welfare organizations. So, the public IS becoming more aware of their plight and speaking out. They must understand that these magnificent wild horses are part of our American history and must be preserved for all future generations. Thanks to Ginger for her beautiful letter and for all she continues to do for our wild horses.

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