Low Appropriate Management Level (AML) for burros is only 2,101 nationwide. Low AML is the target for both wild horses and burros nationwide, representing 10,000 fewer animals than when the 1971 Act passed. For burros, a national population spread out over our western states of 2,101, represents genetic bankruptcy as burro populations around the world face real danger of disappearing due to the illegal trade in donkey hides to fuel the Ejaio industry.
More than half of the herds left in the U.S. are being driven to populations under 100. With the use of 4-10 year GonaCon primarily on older mares, our herds are sliding into the pages of history. Preserving herds is not the goal. Under political pressure, the goal has always been to move our herds back into the decline of the pre-1971 Act.
Breakdown of AML for the HMAs nationwide. Only 3 HMAs in the U.S. have an AML over 500. Only 31 have an AML over 150. These same ranges support thousands of cattle and massive extractive industries.
Our burros are facing a particularly brutal reality. Post-capture, death rates can rise as high as 24%. The physiology of a burro responds particularly poorly to helicopter capture. Helicopters should never be used.
WHE has filed an Appeal against the plan for burros at Tassi-Gold Butte.
WHE burro Specialist Laurie Ford has written a long article to show you how burros are being zeroed out (it seems because they are an easy target) through a series of plans that were slid through decades ago primarily without apparent public participation.
This article might seem overly long. But it represents the “buried in old paperwork” where “decisions were made” to “gather data and do research” that never happen. Then, the paperwork just carries forward a determination. In this case a determination to zero out burros without any real basis.
This article is for those of you that want to see what a “deep dive” looks like.
Part 1
It has been almost 30 years since the World Wide Web came on the scene and started changing how the public obtained information outside of written publications, the radio or turning on the 6 o’clock news. If you did not live in the locality of where regional news or notices were taking place you most likely remained uninformed. It wasn’t until 1995 that daily issues of the Federal Register became available online as well as in print, so any notices calling for public comments on land use/resource management planning or coinciding amendments went undetected by the majority of the public during those years – including those that made the decision to eliminate wild burros on NPS and BLM-administered lands in the Grand Canyon-Parashant National Monument and zero out the Tassi-Gold Butte HMA.
It began in 1994, when the United States Fish and Wildlife Service (USFWS) released the Desert Tortoise Recovery Plan which established 6 recovery units, including the Northeastern Mojave Recovery Unit, which were further split into Desert Wildlife Management Areas (DWMAs). The project area, included the Tassi-Gold Butte HMA, which was within the Gold Butte-Pakoon DWMA for desert tortoise.
While the plan cited numerous references regarding the threat of livestock – trampling of live desert tortoises by cattle has been observed in the eastern Mojave Desert – the burros themselves were barely mentioned. The only reference of feral burros damaging nests was the giant tortoises in the Galapagos, thereby reducing nesting success (Fowler de Neira and Roe 1984).
The plan listed numerous activities, that should be prohibited throughout all DWMAs because they are generally incompatible with desert tortoise recovery and other purposes of DWMAs, and grazing by feral (“wild”) burros and horses was simply one of many.
In response, the 1995 Lake Mead Wild Horse and Burro Plan was developed to implement the Recovery Plan and burro levels were set to zero on all NPS managed lands within the DWMAs.
In 1998 the Mojave Desert Tortoise Amendment EA (EA-AZ-95-01) was developed to also implement the Recovery Plan on BLM managed lands. The Pakoon Area of Critical Environmental Concern (ACEC) for desert tortoise was established and the AML was set at zero for that portion of the Tassi-Gold Butte HMA within Arizona. It also proposed to close the Tassi livestock grazing allotment within the HMA and portions of three others to grazing effective 2001.
A Notice of Intent to Amend the Arizona Strip Resource Management Plan was placed in the Federal Register on February 27,1995, providing a proposal summary and inviting comments from the public. A workshop was also held in St. George, Utah for the public – notice given through the local St. George Daily Spectrum publication and several radio stations in southern Utah – and 10 people attended.
On July 3, 1996, BLM sent copies of the Mojave Desert Tortoise Amendment EA, and requests for comments, to select State, Federal and Local Agencies, Indian Councils, elected officials, and individuals who either requested a copy or had affected interest status, including each livestock grazing permittee affected by the proposal. Seventeen comment letters were received
There is no mention of the EA being made available to the general public for comment.
Much like with the 1994 recovery plan, there was an absence of burro centric information in the amendment documents except for the statement Grazing by feral burros has many of the same impacts as grazing by cattle, plus additional factors. On the other hand, abundant information existed – incorporated by reference into the EA – describing livestock grazing operations, affected area, and relationships between grazing and desert tortoises.
The amendment went on to state that the burro removals would be conducted in accordance with standard burro roundup procedures. At that time, and until 2019, the standard burro roundup procedure was to remove burros using bait and trap methods.
The 1998 Finding of No Significant Impact on the proposed action – designed to address tortoise recovery goals and objectives while reducing impacts on local communities and human activities that occur in the Mojave Desert – determined impacts from implementing the Proposed Action are not expected to be significant and an environmental impact statement is not required.
The final decision confirmed AML will continue to be set at zero on BLM-administered lands and Wild horse and burros will not be authorized on NPS-administered lands and was reaffirmed in the 2008 Grand Canyon-Parashant National Monument Management Plan (2008 GCPNM RMP/GMP Burro Management (Pakoon DWMA))
The decision text within the 2008 GCPNM RMP/GMP (2-49)– included the following minimal references to wild burros carried over from the 1995 Lake Mead NRA Burro Management Plan which stated, “the long term goal to manage for zero burros is not feasible in the foreseeable future.”
The NPS Burro Management Plan and the Mojave Amendment, and the final 2008 GCPNM RMP/GMP, superseded any existing habitat management plan that had set the herd size at 90 to 100 animals. These documents would remain buried until the gather EA was released 3 decades later in 2024.
Part 2
On August 9, 2024, after sitting dormant for three decades, “the long-term goal to manage for zero burros suddenly became feasible in the foreseeable future.”, and The Bureau of Land Management (BLM) and National Park Service (NPS) released a joint environmental assessment proposing wild burro gathers within and outside the Tassi-Gold Butte Herd Management Area.
The draft environmental assessment analyzed the use of periodic removals to reach and maintain a scientifically determined AML of zero despite the lack of supporting science ever being documented.
In fact, 3 decades after the 1995 Lake Mead HMAP decided – in the proposed action – that BLM and NPS would pursue additional research relating to burro movement patterns and use areas, sterilization and birth control techniques, efficient and humane trapping techniques, diet studies, burro/wildlife interactive studies, vegetation monitoring techniques, and aerial census techniques, little evidence of such science based research has ever been provided.
The proposed action to zero out the Tassi-Gold Butte burros in the 1998 RMP amendment – reinforced in the 2008 GCPNM RMP/GMP – was initially designed to address tortoise recovery goals and objectives while reducing impacts on local communities and human activities that occur in the Mojave Desert Recommendations of the 1994 Desert Tortoise Recovery Plan were to be implemented – the same plan that warranted a revision in 2003.
Yet, now in 2025, perhaps to fit the current narrative, the need for the proposed action is to protect monument resources and to prevent unnecessary or undue degradation of the public lands associated with excess population of wild burros within the Tassi-Gold Butte HMA and the greater Pakoon Basin including, but not limited to:
• Impacts to desert tortoise designated critical habitat.
• Impacts to desert springs and water developments from burro trailing and trampling.
When asked about supporting data for the claim that the burros must be removed in order to protect the desert tortoise BLM simply responded that there are multiple factors that contribute threats to the Mojave desert tortoise of which wild burros are just one of the those contributing factors.
Secondly, when questioned about documentation providing evidence that burros were damaging springs and water developments BLM claimed burro damage to springs is well documented in the literature and that resource specialists from multiple agencies have observed burro sign and damage at springs and water sources in the HMA. Attempts to locate this “literature” or documentation from “resource specialists” proved futile.
Claims persisted that burros would reproduce with a vengeance – further damaging the landscape, water, and resources that Desert Tortoise depend on – and that Desert Tortoises would continue to be at risk of trampling by burros. Meanwhile, increases in tortoise abundance in the Gold Butte-Pakoon DWMA, that includes the Tassi-Gold Butte HMA, are telling a different story throwing cold water on a prediction that, after 3 decades, has yet to materialize.
The EA itself even supports this fact while simultaneously confirming that it is the gather itself that will put the tortoise at greater risk than the burros themselves.
The most recent data is from 2021, and the population density estimate was higher than the previous data (USFWS 2022). Survey data and the presence of suitable desert tortoise habitat suggest that tortoises may have the potential to wander onto the trap, corral, and staging areas during project related activities.
This sentiment seemed to be confirmed by U.S. Fish and Wildlife Service in their written
Biological Opinion of the gather plan and determination that the proposed action may affect and is likely to adversely affect the tortoise within the action area.
The opinion letter acknowledged that trapping burros through the proposed action could result in tortoise injuries, death, and displacement due to the increased human activity and vehicle traffic surrounding the roundup activities but also noted possible long-term beneficial effects due to removal of burros and subsequent potential for improved vegetation conditions.
Whether this concept was based on their own studies, or the rhetoric coming from BLM, has yet to be determined as neither party has provided substantial scientific data/research confirming such a statement.
In response to USFS concerns, BLM and NPS are proposing to implement conservation measures to reduce the potential for harm as burros are driven, by helicopter, through tortoise habitat but the effectiveness of the efforts “proposed” remains questionable.
BLM plans to minimize the threat by using “experienced, permitted staff” to relocate any tortoises that wander into trap areas. In addition, to the extent possible, infrastructure will be located in previously disturbed areas or outside of desert tortoise habitat, speed limits will be kept at 25 or under, and the roundup scheduled when tortoises are inactive (October 15 through March 15). Calls for gathers, or periodic removals, to take place year-round appear throughout the EA with no mention of date restrictions.
While discussing the gather plan, USFS stated BLM would first conduct a population inventory flight to provide current data on the wild burro population size and spatial distribution in the Tassi-Gold Butte HMA and the greater Pakoon Basin, yet the EA stated that another population inventory flight should be completed as soon as is practical.
The last aerial survey was conducted in 2017. In 2019 BLM alleged a “potential reporting error” in the estimated annual population that continue to leave the actual burro numbers in dispute as to if the 2025 estimated population is 108 or 191.
In all reality, since burros were first introduced to the Tassi-Gold Butte area in Arizona by miners and prospectors in the late 1800s, you would think the numbers being debated would be in the thousands not in the hundreds or less!
The Biological Opinion letter also voiced concern with the “take” that would be permitted during the roundup operation and any ensuing gathers over the years.
Under ESA The term “take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct; may include significant habitat modification or degradation if it kills or injures wildlife by significantly impairing essential behavioral patterns including breeding, feeding, or sheltering.
A long list of the most apparent threats currently facing the tortoise – those that result in fatality and permanent habitat loss across large areas –were provided by USFS in the opinion. It did not include the burros. The letter also noted that trends derived from years of range-wide monitoring provided a more accurate view of the status of tortoise populations – the same trends that put burros at low risk. Their contribution to tortoise habitat restoration was considered a moderate priority.
What appeared to be disregarded throughout the EA was the 2022 review that indicated the desert tortoise was on its way to recovery in the Northeastern Recovery Unit and Gold Butte-Pakoon DWMA (which includes the HMA). Increased abundance and density – criteria for 2 of the 3 objectives of the tortoise recovery program plan – indicated the objectives could potentially be met in the near future with the presence of a healthy burro population. (Where burros are it seems tortoise are in recovery. Where cattle are, they are not.)
The third objective’s criteria – that the quantity of he presence of a tortoise habitat within each conservation area be maintained with no net loss until population viability is ensured – has yet to be determined.
The review indicated wild burros are nowhere near being a primary threat to the desert tortoise and were considered to be one of the lowest ranking threats with minimal impact.
Rational for the EA’s final Decision of Record referenced a determination made by an interdisciplinary team analysis that excess wild burros are present with the Tassi-Gold Butte HMA and greater Pakoon Basin area and need to be removed to restore a thriving natural ecological balance between burros, wildlife, livestock, vegetation and the available water yet I was unable to locate any information pertaining to this “team analysis”.
Over 4,450 individuals and entities submitted comments in some form.
While many questioned the process, spanning over 3 decades, that brought us to this point the response from BLM remained the same that the purpose of the proposed plan was not to set or adjust AML or reanalyze the previous decisions as these were set or reaffirmed in the 2008 GCPNM RMP/GMP which is the controlling document that supersedes decisions made 1982 HMAP and the 1995 Lake Mead Wild Horse and Burro Plan.
The decision and impact analysis of this EA assesses the method of implementation of the 2008 GCPNM RMP/GMP. Documentation of public involvement and burro effects on desert tortoise population are contained in the previous decision documents.
The only issue seemingly open for discussion was the gather itself, including the methods used, yet BLM showed no interest in having this conversation. Instead, they do what they always do, deflect on decades old documents and literature.
Part 3
Despite the 2024 EA being a gather plan, BLM had no interest in any discussion regarding capture methods or gather related mortality beyond: Further details on reviews of gather-related mortality and conditions are included in Appendix D. This data supports that the use of helicopters and motorized vehicles are a safe, humane, effective and practical means for gathering and removing excess wild horses and burros from the range (BLM 2020).
The decision made to implement the proposed action – to zero out the Tassi-Gold Butte HMA burros – was in conformance with the 2008 GCPNM RMP/GMP which carried forth – “proceed with an action” – both the 1998 Mojave Desert Tortoise Amendment and the 1995 Lake Mead Wild Horse and Burro Plan.
Yet, after 30 years, BLM and NPS have failed to “proceed” with taking action on the call for additional research relating to burro movement patterns and use areas, sterilization and birth control techniques, efficient and humane trapping techniques, diet studies, and burro/wildlife interactive studies that was in the Lake Mead HMAP decision.
Appendix D only reiterates the same old talking points and data acquired largely from wild horse roundups prior to 2020 when most burros were gathered using bait and trap methods. It was after 2020 that the number of animals being removed from the range doubled and most burro removals were conducted using helicopters and assisted roping.
The latest data BLM could provide was from a pre-2020 study that summarized mortality rates from 70 BLM WH&B gathers across nine states, from 2010-2019. Records for 28,821 horses and 2,005 burros came from helicopter and bait/water trapping. (Scasta,2020)
Without differentiating between horses and burros, Scasta (2020) found the overall mortality rate was 1.2% for BLM WH&B gathers in 2010-2019, with a mortality rate of 0.25% caused directly by the gather.
For wild burro bait / water trapping, mortality rates were 0.05% due to acute injury caused by the gather process. No mortality rates were provided for burro helicopter/assisted roping operations.
The 1998 amendment, written at a time when burros were typically being gathered using bait and trap methods, stated that the burro removals would be conducted in accordance with standard burro roundup procedures but what exactly were these” standard” procedures in 1998?
According to the 2024 EA (2.4.6) Due to the limited bait trap sites that are accessible by road, equipment and personnel, bait trapping alone would not accomplish the purpose and need of the action of reducing the amount of animals to the AML of zero. In addition to logistical reasons, bait trapping alone is of limited effectiveness due to burro behavior.
Apparently, the logistic issues surrounding any roundup are challenging for the agency. Combined with the additional complexity due to the endangered desert tortoise, a helicopter roundup would be a logistical nightmare in comparison to a much simpler and more humane bait and trap operation.
In 2019, 40 burros were removed from private lands within the Tassi-Gold Butte HMA by a contractor working with the Arizona Strip District BLM who set up temporary corrals to bait trap the wild burros.
“Burro behavior” is exactly the reason helicopters should not be used.
Burros travel in small groups of jennies and their offspring (average group size of 4.4) and jacks travel alone or with a buddy which require pilots to travel longer distances to locate these small, isolated groups and herd them back towards trap. This often takes hours with the burros – considered to be generally nonathlete – being pushed across rugged terrain at an abnormal pace. Because burros have more of a freeze, than flight, response pilots are also forced to become more aggressive to get them moving.
And, because burros have no defined foaling season, the gather will include heavily pregnant jennies, and young or newborn foals regardless of the time of year conducted.
Due to these unique behavioral and physiological challenges, burros are much more susceptible to stress induced illnesses and death triggered by the helicopter roundup. Necropsies have confirmed the deaths of healthy burros captured by helicopter to be associated with a variety of stresses.
Since 2020, along with the increased use of helicopters, burro gather related deaths have also increased – both during and after capture. The number of incidents when a burro breaks their neck during capture has also multiplied yet the EA failed to even mention this type of injury anywhere.
The helicopter roundup and “handling” are the initial events causing behavioral and physiological stress induced mortality.
When comparing gather related deaths occurring during, and within 40 days after capture, FOIAs have shown a 700% difference in mortality rates from helicopter and bait and trap operations. The leading cause of death is hyperlipidemia in pregnant jennies.
These FOIAs included data on 1314 adult burros from 3 separate bait and trap gathers, and 1317 adult burros from 3 separate helicopter gathers – all taking place after 2019.
The mortality rate averaged 1.1% with the bait and trap gathers. Non were attributed to hyperlipidemia.
The mortality rate averaged 7.7% with the helicopter gathers with 15% of all pregnant jennies captured dying from hyperlipidemia.
And, while BLM continues to cite the mortality rate at ORCs (off-range corrals) averaging approximately 5% (GAO 2008)) FOIAs found ORC annual mortality rates “averaging” as high as 16.5%.
The Helicopter Assisted Roping capture method outlined in the EA is in direct conflict with Public Law 92–195 which calls for burros to be “humanely captured”. In addition, the law states it is “unlawful to maliciously causes the death or harassment of any wild free-roaming horse or burro,” (SEC. 8. ø16 U.S.C. 1338).
Due to the extremely rugged terrain of the HMA any attempt to gather burros with a helicopter and assisted roping would, without a doubt, be inhumane and result in injuries and death – especially with young foals and heavily pregnant jennies who cannot withstand such trauma to their bodies.
We must wonder why BLM has chosen now to proceed with an action plan initiated in 1994 with the Mohave Desert Tortoise Recovery Plan that encompassed 64 million acres of critical habitat yet only 103,000 acres are the focus of the action plan?Why now? Why when data shows there is recovery of tortoise where there are burros?
And furthermore, at a point when the Plan’s delisting criterion 1 for the tortoise – when the population within a recovery unit exhibited a statistically significant upward trend or remain stationary for at least 25 years – was, according to the 2022 review, on an upward trend.
In 1994 the most serious problem facing the desert tortoise populations was the cumulative load of human and disease-related mortality but, based on a 1984 study that found feral burros damaged nests of giant tortoises in the Galapagos, it was decided to include grazing by feral (“wild”) burros was incompatible with desert tortoise recover (Population and feeding ecology of tortoises and feral burros on Volcan Alcedo, Galapagos Islands)
Three decades later BLM is still relying on this same study to support their final decision to proceed with the removal because it is expected that the desert tortoise population in the project area would ultimately benefit due to the reduced risk of trampling.
What they failed to include were additional findings from the study that dispute BLM’s additional expectation that the tortoise population would also benefit due to less competition for forage and water.
When discussing if burros and tortoises compete for food, the study found evidence that burro and tortoise dry season (when Side (grass) is a major item in both their diets) feeding behaviors were different and that these differences may serve to reduce or avoid possible competition.
The study also found:
When food is least abundant, tortoises can simply stop feeding and live off the fat they have accumulated during the rainy season which may reduce food competition between burros and tortoises to an insignificant level and have no effect on tortoise fitness. Some plant ecologists have even suggested that the feral burros may help to open pastureland for the tortoise population.
Instead, BLM continued to reference the Sonoran Desert study (previously mentioned), conducted 100s of miles SW off the Tassi-Gold Butte HMA in a different Recovery Unit, to support their stance that burros were competing with tortoises for food and that that burros should be considered along with other known environmental factors that can degrade tortoise habitat and demographic rates (Berry et al. 2020)
Finally, BLM really has limited knowledge as to the number of burros in the HMA with the EA estimating a current population of 105 – within AML of the original Lake Mead HMAP.
BLM continues to apply an annual growth rate of 15% with absolutely no idea of the true survival rate of these burros because there are no records of substantially unusual numbers of wild burro deaths during the period 2017 – 2024 in the HMA.
According to the 2020 Standard Operating Procedures for Wild Horse and Burro Double-Observer Aerial Surveys (SOP), not only does the BLM have an incomplete understanding of the average expected annual growth rate for most HMAs and HAs but little knowledge regarding how annual growth rates respond to such factors as annual variation in climate, the relative density of horses and burros, and other stochastic (random) factors.
They also acknowledge that the population is subject to continual changes since there are no physical barriers (fences) between the Arizona and Nevada state line, wild burros can travel back and forth between the Tassi-Gold Butte HMA in Arizona and the Gold Butte HMA just over the state line to the west in Nevada.
With so much information casting a dark, doubtful cloud over this entire removal plan, along with BLM’s confirmation that….
The proposed action might have direct impacts on the desert tortoise from activities related to burro gathering, and could include killing or injuring of tortoises, displacement of individuals, and increased potential for harassment of tortoises.
Drive trapping could increase the risk of a tortoise being trampled or a burrow collapsing; tortoises that wander into the areas near traps would be moved resulting in harassment. Indirect impacts could include increased erosion potential at trap sites due to concentrated burro trampling.
….we ask BLM, once again, “Why have you decided that now is the feasible time to proceed with such a costly, time-consuming operation that will result in both tortoise and burro deaths, to achieve “the long term goal to manage for zero burros”?
We hope this long article helps give all of you burro lovers some deeper insight into what is happening.
The zeroing out of burros in Tassi-Gold represent just one assault.
Our team has filed an Appeal.
Thank you.
Without your support, none of our work is possible.
Categories: Wild Horse Education
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