Craig Downer appeals to National Wild Horse and Burro Advisory Board

In preparation for the pubic meeting of the Wild Horse Horse and Burro Advisory Board in Phoenix, March 10-11, 2011, renown wildlife ecologist Craig Downer has contacted the Board appealing them to reappraise and correct their handling and treatment of America’s wild horses and burros.

Posted here in its entirety, with permission.

March 3, 2011

National Wild Horse and Burro Advisory Board
1340 Financial Blvd.
Reno, NV 89502

For Board’s Phoenix, AZ, meeting on March 10-11, 2011
Attention: Ramona DeLorme,
(Please distribute to all board members.)

Distinguished Board Members:

Greetings for the New Year, a year in which a major turn around for America’s wild burros and horses must occur. As I see it, these “national heritage species” have been quite unfairly reduced upon the public lands to which they are entitled. And they have been further marginalized even within their substantially reduced Herd Management Areas (HMAs – BLM) and Wild Horse/Burro Territories (USFS) though still permitted to remain as token numbers. As a way of spuriously justifying these assaults, officials have subjected them to an intense disinformation campaign aimed at discrediting them – especially as free, naturally living animals. This negative campaign has been fomented not just by the traditional enemies of the wild equids but by the very government agencies that we expect to equitably uphold all legislation passed by Congress and signed into law by the President. In short, the unanimously passed Public Law 92-195, better known as the Wild Free Roaming Horses and Burros Act of 1971 (WFRHBA) has been subverted by the very officials who are sworn to impartially execute the law. Unfortunately our supposed public servants have buckled under when confronted with the ruthless demands of greedy ranchers, big game hunters often represented by state fish and game departments, water monopolizing and contaminating mining corporations, urban sprawlers and subdividers, and, now more than ever, unbridled alternative energy developers who would do better to place their solar panels and wind turbines on the numerous vacant roof tops and in more urban areas near power grids than in the last remaining natural regions of the public domain.

It is high time for a serious reappraisal of values and priorities. And here the wild burros and horses enter in with a major role to play. To begin, they should be officially recognized as returned natives and as restorers of the North American ecosystem. As post-gastric as opposed to ruminant digesters, their enormous potential for building nutrient-rich and moisture-retaining soils and of broadly dispersing germinative seeds of many native species should be recognized. Also recognized should be their major role in reducing dry flammable vegetation and in preventing those catastrophic fires that are now on the upsurge due to the effects of Global Warming. They fill an empty niche that is complementary to the great majority of species in the North American ecosystems where they evolved, and this includes the equally deeply rooted Pronghorn.

And let us not forget that because they combine power and beauty in a remarkable way, these animals are inspirational. In the wild and through respectful and moderate visits, they uplift us from the doldrums of a civilization too exclusively fixated upon mankind and its creations, too artificial and out-of-tune with the greater world of Nature. The wild horses and burros will show us a better way of life, when we learn by observing them in the wild and on their own terms, not our imposed ones. But these wonderful animals who have done so much for us over the centuries will not be able to fulfill their role on Earth if humans continue to botch their relations with them – as the following facts prove has been – but need not continue to be – the case:

The proportions of wild burros and horses in relation to livestock and big game on the public lands is grossly weighted in favor of the later, especially livestock. The 1971 Act authorized a small fraction – namely, one-sixth – of the public BLM and USFS lands for wild horses and burros. Here, in these relatively minor areas, these two splendid species are by law authorized to be the “principal,” though not exclusive, presences. Perversely, this core legal intent has been ignored by authorities, since rarely do wild equids receive even one fourth of the available forage allocation within their legal areas.

For example, within the Triple B, Maverick-Medicine and Antelope Valley Complex of HMAs in Nevada BLM’s Ely District, BLM plans to reduce wild horses from 2,198 to 472 individuals, thus cutting the horses from a 23% realized forage allocation to slightly less than 6%. Even at the high end of 889, this AML represents only ca. one-ninth, or 11% of available forage. This extremely marginalizes the wild horse presence; so to be fair to the horses as well as the wild horse supporting public, I have asked BLM to allocate at least 50% of available forage in order to complete with the “principal” mandate of the law. At present the complex’ sparse wild horse population of 2,198 within 1,682,998 acres translates to one wild horse per 776 acres – hardly an overpopulation! But if BLM’s proposal is adopted, the wild horse population would be reduced to 472, meaning there would remain an immense 3,566 acres of legal habitat per individual wild horse (see attached letter of 1/30/11 to Ely BLM).

At least 36% of the 1971 legal Herd Areas have been zeroed out, that is, wild horses’ and burros’ presence on these lands has been declared invalid or a “nuisance” and they have been removed. Actually, more like three fourths of rightful wild burro or horse herd areas have been zeroed out, because at the inception of the 1971 Act many regions containing wild horses and burros were illegally ignored and their equids secretly assign-ed to ranchers, etc., and quickly shot or otherwise removed. It is well documented that such blatant crimes against the General Public and particularly the animals themselves occurred throughout the West and I have communicated with many witnesses of this. Arizona and eastern Nevada (especially Humboldt N.F.) were two egregious regions. Even according to published BLM figures, Montana and New Mexico lead the list with a zeroing out of ca. 80% of the legal acreages. California has zeroed out ca. 2/3rd of its legal herd areas while Wyoming has zeroed out over one-half and Colorado nearly one half. The remaining states also have zeroed out substantial portions of their herd areas.

In the ca. 800,000-acre Twin Peaks wild horse and burro HMA in NE California, a full 82% of forage has been allocated to livestock and a recent roundup there cut the herd down by about 2/3rd. In the Caliente Complex’s 1.4 million acres, all 12 HMAs were zeroed out, in spite of several valid legal protests. So a very under-populated level of ca. 620 healthy wild horses in this vast area was removed by BLM contractors during the Fall of 2009. The wild horse populations from the Calico Complex of five HMAs containing ca. 600,000 acres were gutted in the first months of 2010 leaving hardly any to be observed during the flyover I made in early April, 2010. Only 31 wild horses were spotted in a transection of each of the HMAs, while ca. 350 cattle were still seen out munching on the forage within the horses’ legal areas, mostly congregated around more grassy water sources, unlike the horses themselves, who were seen far from these sources and much more evenly distributed.

In spite of the WFRHBA’s legal mandate to protect and preserve wild horses and burros, over 27 million of the officially admitted 53&1/2 million Herd Area acres have been or are about to be zeroed out by the BLM and USFS in order to establish an unfair 26&1/2 million acres of HMAs or Wild Horse/Burro Territories still marginally populated with a ridiculous nationwide Appropriate Management Level (AML) of 26,578 overly fragmented individual horses or burros. This works out to one remaining wild horse or burro for every 1,000 acres and for every individual human public lands grazing permittee, each of whom may graze hundreds or even thousands of cattle and sheep upon the public lands. This is extreme tokenism toward the wild burros and horses and the general public who support them!

In addition to reducing the original 350+ wild burro/horse-containing HA’s to 180 HMA’s still to contain these animals, federal officials have proceeded to approve of AMLs that are, in nearly all cases, genetically non-viable within each given HMA. Most of these levels do not even meet the questionable requirement for Minimum Viable Population of 150 animals per head that is typically cited by BLM in its documents and based on equivocal statements by Dr. Gus Cothran. Obviously, these levels fall far short of the figure of 2,500 interbreeding individuals that is recommended for a viable population in the wild by the Equid Specialist Group of the IUCN Species Survival Commission (Duncan, 1992). Of the 180 greatly reduced HMAs throughout the West, a glaring 130, or 72%, have AMLs of less than 150 horses or burros, and many of these are much less than 100 equids, even numbering in the teens, e.g. Tonopah BLM’s Goldfield burro herd with AML of 37, Ely BLM’s Diamond Hills South with AML of 22 horses, or Carson City BLM’s Dogskin Mountain herd with AML of 15 horses, and Lahontan herd with AML of a “wink out” 10 wild horses to remain. According to BLM’s own typically cited standard of 150 equids, in California 19 out of 22 HMAs have non-viable AMLs; in Utah 17 out of 21; in Idaho 5 out of 6; in Montana, one out of one (6 of the original 7 HA’s having been zeroed out); and in Nevada, 67 out of 90 of the scant remaining herds are similarly non-viable.

In FY 2005, forage consumed on BLM lands by livestock summed up to 6,835,458 AUMs, contrasting with wild horse/burro consumption of only 381,120 AUMs, or 5.6% that of livestock. And the percentage is much less now with the recent, draconian roundups having taken place.

According to 2008 Public Lands Statistics, on USFS lands, livestock devours 6.6 million AUMs worth of forage, much in vital headwaters where cattle camp, while wild horses and burros struggle to get by on a meager 32,592 AUMs – an outrageous ½ of 1% of available forage.

For years, it has been the all-too-easy custom for established interests to “scapegoat,” or lay the blame, for overgrazing, erosion, threats to native species, and other ecological abuses upon wild horses or burros wherever they occur, by magnifying their impacts out of proportion – all the while conveniently ignoring mankind’s own enormously destructive traditions, particularly livestock grazing, predator elimination, open pit mines.

In June, 2010, I presented a solution to this unacceptable situation. Speaking positively, this will involve a restoration of higher wild horse/burro populations throughout the West and a reoccupation by these animals of zeroed-out Herd Areas on BLM and WH/B Territories on USFS lands. This will occur through the implementation of a Reserve Design strategy that is tailored to suit the unique character of each given herd and its habitat, in consultation with the local human population so as to create buffer zones and benefits to such as through ecotours and the revenues they generate. I strongly urge each member of the National Wild Horse and Burro Advisory Board to look seriously at Reserve Design as a way to achieve naturally self-stabilizing equid populations. This will occur by truly allowing the natural integration of each equid population within the particular ecosystem it inhabits – and we must learn to better value wild-horse- or burro-containing ecosystems. As a wildlife ecologist as well as one concerned for the humane treatment of these animals, I endorse Reserve Design as the rational and caring way to effect the reforms that are now so urgently needed to restore the very heart of the Wild Free Roaming Horses and Burros Act. This long-overdue restoration is being demanded by millions of American citizens and by many people worldwide. This reform will properly put the major emphasis of the wild horse and burro program back on wild horses and burros in the wild. And it will put a stop to what is, in effect, their domestication or semi-domestication, their decimation and the decimation of their freedom on their rightful public lands (including through the illegal overfencing of such), and finally the outright elimination of these wonderful presences from their rightful ancestral homes throughout the West.

Thank you for listening to my concerns and please do not hesitate in calling upon me for assistance in meeting this most crucial challenge. It is a challenge that is much more important than some elements of our society like to think.


Craig C. Downer
Wildlife Ecologist
Author: Wild Horses: Living Symbols of Freedom

P.S. In parting I leave you with this: one always gets back what one dishes out to others. This is a great and universal law, and it most certainly applies to humans’ relationship to burros and horses, who have done so much for us two-leggeds, yet whose greater place in this world is to be found in their living free with Nature and all God’s creatures. I humbly ask that you just think about this.

12 thoughts on “Craig Downer appeals to National Wild Horse and Burro Advisory Board”

  1. Thank you thank you. Your information to me and hopefully the thugs at the BLM is solid. Thank you!


  2. Dear Mr. Graig Downer, your Article is written with extreme Intelligence, and love for the Wild Mustangs and Burros, This letter should be plastered all over the front pages of every Newspaper in America, The truth known will set Our Wild Mustangs and Burros Free…………………………………………………..Free to Roam in the way that was meant for them, they way the American People want it to be………………………


  3. Thank-you Craig, if only the BLM had even 1/1000 th of your honesty, intelligence and integrity ! Thank -you for your knowledgable comments of BLM’s corrupt, cruel, cowardly, criminal treatment of Wild Horses & Burros.


    1. Thanks so much for your support. Susie. I wonder how many Senators and Congresspersons actually will read my statement and take it to heart, for that matter how many of the wh/b board will?!


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