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July 16, 2011

Mr. Roland R. Mendez

BLM Black Rock Field Office Manager
5100 E. Winnemucca Blvd.
Winnemucca, NV 89445-2921
Email: Tri-State-Calico-Complex@blm.gov
Re: Calico Mountain Complex & Tri-State-Complex Wild

Horse Roundup

Dear Mr. Mendez:
I was a plaintiff in a federal case to stop the excessive helicopter roundup of wild horses that occurred in the Calico Mountain Complex during the winter of 2009-2010, as well as a direct witness to this roundup  I am also a wildlife ecologist and native Nevadan who has observed these wild horses for many years, I wish to register my protest against the renewed elimination of what is, in truth, a sparse and under-populated remnant herd of wild horses and burros in the region in question.  Your plan is an outrageous one that ignores both the rights and the well-being of the wild horses and burros, individually and collectively, as well as the general public who support them and derive a spiritual uplift from viewing them, being in physical proximity to them, or just knowing they are there.  What is most egregious about your plan is the marginalizing of the wild horses within their legal areas. You are completely ignoring one of the basic core tenets of the Wild Free-Roaming Horses and Burros Act where it clearly states in relation to the original 1971 ranges of the remnant herds that they shall be “devoted principally” [though not] exclusively to their [the wild horses’/burros’] welfare.  This act was passed unanimously by both houses of Congress, one of the few acts in American history ever to possess this honor.  The act represents a particularly high and soulful will of America, a special sweet strain, that should be considered as a check upon certain special interests whoare bent on exploiting and monopolizing the public lands and their resources– and upon milking the US taxpayers to prop up their broken down dinosaur of a life style.
Healthy, vibrant, naturally and freely living wild horses and burros are a great moral and aesthetic presence on our public lands, as elsewhere in the world.  They are innately appreciated by millions of people both in America and worldwide.  We are talking about a quality of life issue here, one important to the life of the soul, and of keeping ourselves aware of and attuned to this.  I believe that the great response of people to wild horses and burros is owing both to our long and intimate association with these animals — dating back several thousands of years — and to the greater fact that there exists a great belongingness of these animals in the North American ecosystem that cries out compellingly for their restoration. In the poetic words of the North American Indians: “The grass remembers them,” and this is so true when examined from an evolutionary and ecological perspective.  (Please contact me for more information including proofs of this.)  These animals are greatly valued by the general public, and their appreciation in a wild, free, and natural region to which they are suited (such as here in the West)  is a natural outgrowth of their justification for being here.  There is a greater truth about them which we recognize when our minds are clearer and our hearts purer that sets us at odds with those overly absorbed by short-sighted and materialistic pursuits that sear the conscience and blunt the higher spiritual awareness.  We should ask ourselves: what is the true value of all the great Family of Life and what is our relationship to one another? And how can we allow All of Life to pursue its august course out of the past through the present and into an ever more glorious future? In our democracy, we depend upon our public servants to be honorable men and women demonstrating true integrity and strength of character, noble individuals who refuse to allow themselves to be bullied by certain greed-driven and overbearing special interests, in this case those who have targeted the wild horses and burros for discrediting and elimination and have nothing but negative things to say about them.

You may know who these are, but I will reiterate in case not.  These are chiefly the public lands livestock grazers, or ranchers, mainly of cattle and sheep, who have and continue to monopolize the public lands and like spoiled brats are used to getting everything their way.  They refuse to share even a minor portion of the public lands with the wild horses and burros.  Next on the list of enemies is the hunting establishment – people who in their blinkered quest to promote a public lands shooting gallery would have the land managed for a plethora of overpopulated game animals chiefly deer.

This they do not in order to feed themselves but to satisfy some primal urge to dominate and kill.  This they do ever-so blithely, all the while turning their backs on the wild horses and burros rather than taking the time and the thought required to truly educatethemselves about these animals and their place in North America.  If they would do this they would learn moreabout how these different types of non-ruminant-digesting herbivores, called post-gastric digesters (including the equids) actually complement the ruminants by rest rotating, greatly assisting in building healthy soils and in dispersing germinative seeds of a much greater variety of plant species when compared with the ruminant species.  And then there is their role as a prey species of the wolf, the mountain lion, the bear, etc., whose populations they bolster, just as their less degraded feces bolster the population of myriad species, from tiny soil microorganisms to dung beetles, to birds (pecking the seeds), rodents (gnawing the seeds), lizards and on up the food chain to the larger animals.  But here I enter into the Forbidden Zone of these wild horse enemies.  For you see, one is not supposed to recognize these inconvenient facts or greater truths even though they stare one squarely in the face.  One of these is the fact that certain factions of our society continue their all-out war on the natural predators of the public lands – mountain lions, wolves, bears, coyotes and others conveniently labeled vermin, misfits, etc., even though they too are vital components of a healthy, well-functioning and diversely balanced ecosystem, and essential parts of its checks and balances that promote greater diversity of species — each with its unique role to play, niche to occupy.

Yes, in the great community of life, each species and each individual in each species is in some special and indispensable way its brother’s and its sister’s keeper.  But too many among arrogant mankind have deemed themselves to be apart from the Rest of Life and immune to any system of checks and balances.  Consequently, it is our very own species.  Homo sapiens, self-proclaimed “wise guy” who continues to grossly overpopulate this planet – now arriving at 7 billion in number — and to throw regional ecosystems, including the Great Basin, and the entire planetary ecosystem off balance and out of kilter.  This is how we humans selfishly imperil life on Earth. Who will dare to break out of this obnoxious mold?
Enough said, yet we must realize these things and we must put this realization into practice in how we live.  And there is no better place to begin than by learning to share freedom and the land with such magnificent and deserving citizens of planetEarth as the returned North American horses and burros.  They have done so much for mankind, yet their greater place and their greater story as it unfolds is to be found in the natural life community, in the democracy of all living kinds and their majestic, age-old progress, a progress that is measured by the ticks of millenniums more so than the dimensionless and soulless nanoseconds of manipulative, control infatuated technocracy! Learning to identify with the Greater Whole of Life and to act for its greater fulfillment – this is the paramount moral challenge that presents itself in fulfilling the Wild Free-Roaming Horses and Burros Act of 1971.  To fail at this, as America is presently failing, would mark our moral death as a people.  And I do not write these words merely for dramatic effect.  Let us not let this happen, but rather dare to make sacrifice of a lesser way of life and value system that a greater one may emerge onward and forward with a vision that spans the very ages, rather than confining itself to one short and grubbing idée fixe that smothers our greater selves and consciousness under a ton of materialism.  Rather than seeing only a target in the free-living, wild world of Nature – mere things or objects to subdue and control, to enslave or to kill, to alter and to denature — we will behold in the natural ecosystem a supreme university, a teacher of lessons ever new and more greatly emerging.  We will expect and, indeed, find some awesome and unprecedented truth unveiling itself witheach new and unique rising of the sun, as well as some new challenge of vital importance to be met both individually and collectively.  You will know what it is if you will only still your mind and free your heart so as to clearly perceive it – then youwill know the next step you must take. A significant and indispensable part of this timely step today is for people here in the West to learn to share the land and freedom with wild horses and burros, to live in harmony with them and to become a benign and integrated caretaker of the ecosystem that harbors them. I vigorously protest the shameless violation of the Wild Free-Roaming Horses andBurros Act that is presented in the Tri-State — including Calico Mountain –Complex Proposed Wild Horse Roundup.  Thecurrent population of wild horses and burros in the 584,000 HMA acres here, which include the Granite Range, Calico Mountain, Trough Mountain, McGee Mountain and Black Rock Range HMAs, is an under-population not an overpopulation, though it is arbitrarily defined as an overpopulation to suit the agendas of certain wild horse enemies, chiefly those ranchers who continue to receive the hog’s share of the resources while the wild horses and burros are reduced to genetically non-viable populations, made dysfunctional through reproductive tampering (PZP) and unnaturally skewed sex rations (60% male: 40%female).  BLM’s merely pronouncing words such as “excess,” or “overpopulation,” or blaming wild horses/burros for damages to the environment that people, not horses, have caused will never convince the likes of truly thinking and caring people! Since when are 732 wild horses (mid value between 572 & 952 AML limits) and 52 wild burros (mid value between 39 & 65) within 584,101 acres a fair provision when this range is legally “devoted principally” for the wild horses and burros?  This is simply not the case.  Summing these figures, we get an average midrange AML for wild equids of 784.  Dividing this into 584,101 acres we get 745 acres per individual wild equid.  This is a nearly empty ecosystem, not a vital wild-horse/burro-containing ecosystem.  And the figure for burros is a clear set up for inbreeding.  Of the 179 burros currently in the region, none should be removed – plain and simple!  The current population of wild horses is 1,602.  Summed to the 179 burros, thisequals 1,781 wild equids in this vast area. Dividing 584,101 acres by 1,781, we get 328 acres per individual wild equid.  Again this does not constitute an overpopulation but rather is a sparse and moderate population that should not be further reduced.  The BLM should focus its efforts, instead, on making sure the wild equids here have access to year-round water and forage, summering and wintering grounds and unfenced habitat, and can fill their niche and self stabilize their numbers eventually when their niche is filled.  There are intelligent and caring ways of protecting and managing the wild equids and there are thoughtless and insensitive ways that result in turmoil, disharmony, and unnecessary suffering and death almost exclusively reserved for the wild horses and burros – ways that fly in the face of the true intent of the WFRHB

Act.  So the need is urgent for us to get back on track and in harmony with the true intent of this noble act.

Provided BLM defended and secured reasonably adequate water sources and reduced livestock, I estimate the complex should be able to sustain one wild equid per 100 acres without any deterioration.  This would work out to 5,841 wild horses and burros – a much more reasonable and fair figure for this region.

In closing, I commend the BLM for providing Table 7, which allows an allotment-by- allotment breakdown of livestock AUMs and upper range wild equid AUMs.  I think, however, that the median range rather than the upper range of AML AUMs should have been given.  I would also like to point out that even at the estimated October, 2011 equid grazing level of 71,378 AUMs, this figure is still 5,606 AUMs below that of livestock.  Again, this is not a range “devoted principally” to the wild equids, as the WFRHBA states it should be.  In light of the recent major wild horse roundup in the Calico Mountain Complex, I protest any further reduction in this sparse and under-populated herd and urge a reduction in livestock in order to assign a larger and fairer standard for both wild horse and burro populations in this vast and scenic region.  I further recommend more emphasis on in-the-field preservation and management strategies such as Reserve Design to allow for stabilized, niche-filling, auto-regulating wild equid populations and the promotion of appreciative wild horse/burro studies, innovative ways of providing for and containing their populations (non-invasive ones) as well as eco-tourist viewing.  This would serve as an a wholesomealternative to the present exploit (ranching), kill (hunting), and gauge (mining) activities to which BLM gives primary support while ignoring the soul-nourishing will of all Americans that was and continues to be expressed in the Wild Free-Roaming Horses and Burros Act of 1971, an act whose fulfillment we should be celebrating this year of its 40th anniversary, rather than bemoaning because of its subversion. Please respond to the important points I have raised here.


Craig C. Downer, Ecologist

P.O. Box 456

Minden, NV 89423-0456