Open letter to BLM & USFS Re WFLF & ISAHC Comments, Concerns and Proposals Re Montgomery Pass Wild Horse Management
To:
BLM and USFS
From:
Wild For Life Foundation (WFLF)
International Saving America’s Horses Coalition (ISAHC)
WFLF & ISAHC Comments, Concerns & Proposal(s)
Given the fact that there are roughly 200,000 acres in the MPWHT, we are extremely concerned that the MPWHT has an assigned allowable population of only 138 - 230 wild horses, (a mean of just 184 horses). Based on the same, the BLM and USFS would only allow one individual horse for every 1,087 acres, or 1.7 square miles. This is both absurd and contrary to the management goals and duties of the BLM and USFS.
Given the current estimated population of 654 horses, there are roughly 306 acres, or 0.48 square miles per individual wild horse. This population is therefore well within the established horse carrying capacity of moderate horse density in relation to available forage, water & shelter.
Per the proposed Wild Horse Management for MPWHT, (https://fs.usda.gov/detail/inyo/landmanagement/resourcemanagement/?cid=fseprd1145518 ) the BLM and USFS overly simplify consideration of this legally protected herd. Further, there is absolutely no evidence to support the assertion that wild horses are destructive presences wherever they live.
The BLM and USFS proposal further lack any alternatives to address the purported disturbances. WFLF and ISAHC experts have studied and visited the warm springs on the east shore of Mono Lake, including the high-use recreation areas such as Navy Beach and South Tufa, and have closely observed the mustangs around Montgomery Pass. Moreover, factual evidence clearly demonstrates that there are scant bands with very little negative impact.
The BLM and USFS have failed to consider the heavy snow last winter which created a natural emergency for the wild horses. As such, the horses were forced to seek areas where they could survive. We have yet to discover any attempt by the BLM and USFS to help the horses during this natural emergency.
This natural emergency does not provide any justification for the proposed reduction and or elimination of this important wild horse population. Further, per Sections 4 & 6 of WFHBA, Cooperative Agreements can be established with adjacent land management agencies and, or private landowners to provide all the year-round habitat requirements. Further, per the WFHBA, it is the agency’s legal duty to manage a sustainable and viable wild horse population; not to eliminate them.
Further, the BLM and USFS have failed to recognize the benefits of the wild horses’ daily & seasonal movements that, in fact, support the ecosystem through the constitution of natural rest-rotation which allows the various sectors of their habitat to rebound. Substantial scientific evidence documents how the broad-ranging, semi-nomadic nature of the horses supports the ecosystem.
Per the Wild Free-Roaming Horses & Burros Act they must be allowed to live naturally and freely and with minimum interference. Per the Act, they must be allowed to fulfill their natural niche and role in the ecosystem. BLM and USFS are actually in violation of this law by not working in favor of the herd, and by restricting, confining and removing them based on falsehoods and fabricated excuses.
Substantial scientific evidence has proven that wild horses are deeply rooted returned native species in North America. This fact is further demonstrated by fossil and petroglyphs found in the MPWHT. If there is merit to the suggested concerns of noticeable disturbance or conflict with visitors or traffic, it is the agency’s duty to develop and manage a protective plan that both mitigates & prevents the same.
We propose that BLM and USFS create alternative watering sources and natural shelter areas that are away from the extreme weather patterns including any heavy snowstorms & blizzards & cold weather. We further propose the construction of fencing and or other artificial barriers. For example, overpasses can be constructed at strategic locations along highways, and vivid traffic signs including speed control can easily be implemented. We further suggest the installation of speed control bumps which would be highly effective in slowing motorists down in specific areas.
Wild horses can be easily conditioned through both positive reinforcement & safe and humane negative reinforcement to stay away from sensitive habitats & areas of possible conflict. These safe and humane methods have been successfully implemented with other large wild animals including elephants, rhinos & zebras to prevent conflicts in farmland and human dwelling areas, as well as sensitive habitats.
We further propose that any plans to roundup and remove any wild horses from the MPWHT be canceled immediately, and that these management methods be instead implemented by the BLM and USFS. It’s important to additionally point out that these management methods would be far less expense to conduct than roundups, etc., which are in fact, far more destructive to the environment.
Per the WFHBA, wild horses & burros contribute to the diversity of life forms within the nation and enrich the lives of the American people. Further, a wild horse/burro range, or legal area, is the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros and should be devoted principally but not necessarily exclusively to their welfare and be considered an integral part of the natural system of public lands.
Wild horses naturally build healthy, humus rich soils and disperse many intact seeds of a great variety of plants including many native species. They can and will naturally adapt to their ecosystem in harmonious ways that enhance the environment if allowed.
Respectfully,
Katia Louise, President, Director
The Wild For Life Foundation (WFLF)
The International Saving America’s Horses Coalition (ISAHC)
