Action Item

Urgent! Comments Needed to Protect All Wild Horses!

Will more wild horses be trucked off the range to protect Sage Grouse?

Will more wild horses be trucked off the range to protect Sage Grouse?

A massive Draft Environmental Impact Statement is accepting public comments. The document is intended to protect the Greater Sage Grouse. The documents for comment can be found here:

The sage grouse is a large chicken sized bird that engages in elaborate courtship rituals and is disappearing from the western landscape primarily due to habitat destruction. States like Nevada benefit from tag fees as the bird is a popular target for hunters. The listing of sage grouse as an endangered species would create sweeping non-negotiable changes for hunters, extractive industry and the livestock producers, all of which are incredibly skillful weavers of the web of public land management laws.

Cows in riparian area on the range in Nevada just moments after they were released onto the range

Cows in riparian area on the range in Nevada just moments after they were released onto the range

In a recent article by AP attempts to stave off actual listing of the sage grouse, by creating preemptive policy, is supported by those that hold positions in government that actively support various special interests on public land. ”This listing is further proof that we need to work together to protect sensitive species before they get to such a dismal point and negatively affect our rural economies,” Nevada Senator Harry Reid said in a statement. The article also quotes the son of state legislator Pete Goicoechea, “For guys talking about expansion and going to the bank for loan, I’m not sure what the bank is going to tell me,” said JJ Goicoechea, a rancher and veterinarian who is president of the Nevada Cattlemens Association. JJ is talking about the loans that ranchers are currently able to obtain using allotments as collateral.

At a recent meeting of the NorthEast Resource Advisory Council (RAC) on proposed sage grouse management policy. The draft Environmental Impact Statement is a thousand page document open for public comment through January 29th was discussed. RAC board members, most of which hold a grazing interest on public land, were offering language to be added to the final policy. Much of the suggested language involved the killing of predators like ravens or coyotes instead of habitat restoration. The comments that did address habit focused on comments that included decreasing wild horses because they eat forage yet increase cattle use to eat forage to prevent fires. It may not make much logical sense to most American’s however those types of language changes are likely if the American public does not get involved in a process of public comments that the federal government makes about as clear as mud.




Below is a letter composed by Wild Horse Education. You may use that as a template for your own comments and email or send them here:

Email comments can be sent to Please put NVCA GRSG Draft EIS Comment in the subject line.

Comments can also be mailed to:

Bureau of Land Management
Attn: Greater Sage-Grouse EIS
1340 Financial Blvd
Reno, NV 89502

Or you may go to this “click and send” link to email comments created jointly by Wild Horse Education (WHE) and the American Wild Horse Preservation Campaign (AWHPC):

Comments on Greater Sage Grouse Planning Strategy NV-CA Sub-Region

The Greater Sage Grouse Planning Strategy (GSGPS) document that will effect much of the land base in the NV-CA sub-region. Changes in public land management practices will require revisions in Land Use Plans (LUP’s) and Resource Management Plans (RMP’s). Both LUP’s and RMP’s stand as the framework for public land management for decades. Changes of this magnitude must include all available information. The consequence of each potential change of procedure must be fully evaluated before triggering such massive changes in management. Thank you for the opportunity to comment and identify potential issues with the planning strategy.

The information contained within this report that pertains to wild horse and burro management is outdated and incomplete.

In the description of wild horse use only sections of the Wild Free Roaming Horses and Burros Act (WFRH&B Act) that could be interpreted as restricting wild horse use are are included omitting the basic premise words such as “protected, integral.” When quoting FLPMA again only the section that could be interpreted as limiting wild horse use are quoted yet the fact that FLPMA was not intended to derogate any existing premise of law, such as protecting wild horses on public land. As but one example of the possible misrepresentation of the WFRH&B Act can be seen in this statement made on page 62 of Chapter 3: “BLM and Forest Service policies and regulations also direct that wild horses and burros are to be managed as self-sustaining populations of healthy animals at minimal feasible levels.” The actual language of the Act is: “All management activities shall be at the minimal feasible level.”   The statement made in the GSGPS limits horses, the actual statement in the Act limits management. This should be rectified.

Although stated in the report Under all alternatives, no direct change would occur to areas allocated as HMAs/WHBTs for wild horses and burros (page 50, CH 5). However the rest of the paragraph outlines how each alternative will restrict wild horse and burro use. (See BLM handout simplifying Alternatives at link ) Additionally information that pertains to “livestock” use (in many instances in this report that term is inclusive of wild horse use) indicates that reductions in Animal Unit Month (AUM, or “allowable forage use”) would be likely (with broad discretion given to districts in most cases and all AUM’s being retired in one alternative proposed). This actually creates a situation of contradiction that would result in discretionary interpretation district by district that would likely result in inconsistent management practices.

Alternatives A,B,D and E (with Alternative D being BLM’s preferred alternative) leave far too much discretion to each district in allotting AUM’s available to private livestock and wild horses. Alternative C eliminates all AUM’s entirely. Alternative F reduces AUM’s 25% for both private livestock and wild horses.

Wild horses and burros have a legal land base of approximately 12% of BLM/FS managed land whereas private livestock allotments exist on over 66% of that same base. To utilize the same equation to manage both uses is non-equitable under any of the proposed alternatives.

Also omitted from the evaluation is the impact of private livestock grazing as opposed to impacts from wild horse and burro use. There are extreme differences in the impacts generated by these users of public land. Both the Center for Biological Diversity and Western Watersheds have done extensive papers showing the impact of livestock production (and it’s cost) to public land management. Wild horses, when not impeded by allotment fencing and large turnouts of domestic cattle, have minimal impact to the range. To treat both of these uses as “grazing” is irresponsible to the purpose of the assessment to create an equitable management plan to protect the greater sage grouse that is compatible with other provisions of law.

All alternatives must include AUM’s available for wild horses and burros to the extent that a genetically viable population of wild horses and/or burros may be sustained. A matrix must exist that triggers increases of AUM’s for wild horse use if information becomes available that the population is at risk of genetic loss.  A current population of 200,000 Greater Sage Grouse has triggered this massive management document. The Bureau of Land Management estimates that 40,605 wild horses and burros (about 33,780 horses and 6,825 burros). Independent estimates range from 20,000-25,000 wild horses currently on the range. Wild horses and burros are only managed within the areas designated for their use.  To that extent any and all alternatives must include language that protects wild horses in any and all overlapping area.

When creating a final agency action all available pertinent data must be evaluated. Currently the management practices employed by the BLM wild horse and burro program have received severe criticism in the National Academy of Sciences (NAS) report released in June of 2013 (study was commissioned by BLM for the purpose of reform in the wh&b program). Currently the report is still “under review” with an expectation that changes will be made within the program based on the findings that indicate a severe deficit in the data used to manage wild horses. Any alternative adopted must allow provisions for increasing habitat (repatriation of HA) and increasing AUMs/AML where genetic threat is shown to be encroaching.

As the adoption of any alternative for management of GSG will likely require amendments to LUPs and RMPs all alternatives must clearly protect and preserve wild horses and burros. Any lack of clear direction is negligent fiscally as it is known that significant changes to managing wild horses and burros is imminent. Deficits in data that support current AMLs must be rectified. Any plan to manage GSG must consider all possible scenarios.

To summarize the major concerns with all alternatives presented:

  1. Any alternative adopted must include language that provides guidance to all districts that wild horses and burros must be preserved above a level that allows appropriate genetic diversity. Genetic diversity must be specifically defined.
  2. At no time should there be a reduction of current AUMs for wild horse use. Wild horses are currently managed at numbers less than 25% of that of the greater sage grouse. To reduce the numbers of wild horses to accommodate protection of the sage grouse is not acceptable.
  3. Provisions must be made to allow increases of AML/AUMs if data becomes available that demonstrates genetic viability of wild horses and burros is threatened.
  4. Provisions within the planning document must note that any resulting Land Use Plans (LUP) or Resource Management Plans (RMP) do not limit any reforms in wild horse management based on the 1.5 million dollar National Academy of Sciences report. (if this language is not included and reform in the wild horse and burro program may conflict with the GSGPS and subsequent planning documents requiring another lengthy amendment process).

Providing for the protection of a viable wild population of wild horses and burros (a population capable of reproducing itself without interference and the resources available to sustain that population) is not outside the scope of this document. This document is an all inclusive management plan that will significantly impact protected wild horses and burros.