A GiftJanuary 9, 2023
A Tribute to Washakie, Wild Stallion of McCullough PeaksFebruary 9, 2023
The Bureau of Land Management announced a Scoping Document on January 9, 2023 on the McCullough Peaks wild horse herd, which is one of the most beloved, iconic herds in the west. The public may submit comments to the Scoping until February 7. I am writing today to encourage everyone to comment and share to others and ask them to comment as well. In this blog I will outline suggestions of points to cover, but the most effective way to comment is to use your own words.
Here is the link to the Scoping Document: https://eplanning.blm.gov/eplanning-ui/project/2022012/570
Once the comment period is over, the BLM will analyze the comments and some time later in the year they will publish their Environmental Assessment where they publish their proposed action, and there will be another 30 day comment period after that, then the Record of Decision will be published. They say that bait trapping could proceed any time after November 1, 2023.
I have been visiting, observing, documenting and photographing the wild horses in this herd since 2004. I visit 1 – 3 times per year, every year. These horses are unique and precious, and they deserve to continue as a whole, healthy herd. This herd is beloved by people locally, all over the country, and all over the world. People want to see these wild horses, and because the herd is relatively accessible, they draw tourists and tourism to the area.
The Appropriate Management Level is a number that the BLM assigns to each wild horse herd, and the AML is 70-140 wild horses in the McCullough Peaks Herd Management Area, or HMA. Currently there are 179 wild horses, by direct count. This is an extremely small number over AML and this should not be considered constituting an urgent need for removal of horses.
In this Scoping letter, the BLM says that their plan is to remove down to low AML, which is 70. That means they are planning to remove almost 2/3 of the herd, which is 109 horses, and the Scoping document does not specify if that number will include this years’ (2023) foals. According to the leading geneticist on wild horses, Dr. Gus Cothran, who says that in order to insure genetic viability for a herd there needs to be at least 150 breeding aged adults. Taking the herd down to 70 horses is a threat to the herd’s very survival.
This herd has been being managed with PZP birth control since 2011. There is no reason to now decide to remove so many horses when the population has been being kept in check. The range can easily support at least 250 horses, so the best possible solution would be to raise the AML to 150 – 250. Generally AMLs are set during revisions to the Resource Management Plan which only occurs every 20-30 years, so this needs to be changed another way.
The other issue is this herd has an aging population, because of birth control being used and the low average number of foals. There are 23 older horses, some of whom may not make it through the winter. Before deciding how many horses are “over AML” it makes sense to see how many are left in the spring. Also lone older stallions who have trouble getting around will not be breeding mares. They should not be counted as a factor in increasing the population.
The other issue that was brought up in the scoping was “non-responding” mares. These are mares who do not respond to PZP and continue to have foals. Two of them are 17 years old, one of whom may not make it through the winter. The other mare is 14. Removing these older mares would be an act of incredible cruelty. And even if two of them continue to have foals for 1 or 2 years, that will not add a significant number of foals to the population. They cite the current growth rate of the population at 2% which is very low. Alternative methods of birth control should not be used on these three mares or on any of the mares in the herd. GonaCon has been proved to sterilize mares. Spaying mares is incredibly cruel, inhumane, and dangerous. IUDs are dangerous and inhumane and should never be used on wild mares.
The other issue that the BLM is certain to bring up is range degradation. Somehow they never study the damage the cattle have done and are currently doing to the range. The small number of horses on 120,000 acres get scapegoated for all of it. I have observed the damage the cattle have doe to the range, and given that wild horses are supposed to be managed as the principle species where they are found, retiring the grazing leases would be the best solution for the health of the range.
There is currently no room in holding for these horses. Nor should any of them be sent to crowded, disease-ridden facilities where no one from the public can see them when they are safe and perfectly suited to stay in their home with their families.
Another point is that this is a 10 year plan, meaning all the actions they are planning to take over the next 10 years this is the only opportunity they are giving for the public to comment on their plan. This is a violation of NEPA, the National Environmental Policy Act. They need to give the public an opportunity to comment each time they are taking action against this herd.
Here are my suggestions for comments to submit on this Scoping Document:
- Do not remove wild horses down to low Appropriate Management Level of 70 horses. This will destroy the genetic viability of the herd.
- Keep all of the wild horses that are on the range on the range.
- If bait trapping is used, do it “in house” by BLM staff, not using an outside contractor.
- Do not use GonaCon or any other “alternative birth control.” PZP is already being used to control the population. Do not fix what is not broken. This herd has been held up as a model for managing herd populations by the BLM.
- Leave the older horses on the range so they might live out their lives in their home, with dignity and respect. Do not remove them and then put those that have issues down.
- Change the AML at the first available opportunity to 150-250 horses.
- Retire the livestock grazing leases in the Herd Management Area.
- Set up a plan for managing the horses, but do not try to do a 10 year plan. This would be a violation of NEPA. One comment period per action is required.
Comments are due by end of day February 7, 2023.
Please use your own words for comments. Do not rely on a “sign on” letter – the BLM counts those as 1 comment. It is important that you take the time and submit your own comments.
You may comment online through the BLM’s eplanning site here: https://eplanning.blm.gov/eplanning-ui/project/2022012/570 Click on the green Participate Now button.
You can also submit written comments here:
Refer to: DOI-BLM-WY-R020-2023-0003-EA
BLM Cody Field Office
Attn: Abel Guevara, Wildlife Biologist
1002 Blackburn Street
Cody, Wyoming 82414
Thank you from the bottom of my heart for caring about the McCullough Peaks wild horses.