Hello again! 

I mentioned earlier that there have been a number of people who have helped us in our battle for the freedom of the wild horses of Theodore Roosevelt National Park.

No one has been more helpful to me than the person writing our second guest blog today.  It’s hard to believe that it has been 4 years already since I contacted American Wild Horse Campaign asking for help for the TRNP wild horses. Mary Koncel was assigned to answer my call.  She is no longer with AWHC, but she has become a wonderful friend to me. 

Mary is a long time wild horse advocate and was instrumental in explaining what could be done, how to do it and explaining the NEPA process to me.  If I had to guess, I would say that MINIMALLY, I spoke with Mary at least once a week over the last 2 years. 

Mary’s heart herd is the Devil’s Garden herd.  They are on the chopping block (AGAIN!) by the Forest Service.  There is a public comment period open and their Environmental Assessment (EA) is complex.  Mary wrote about it in our 2^nd guest blog of the day.  Please take a moment to read this carefully and submit your comments to the Forest Service by May 14^th.  Please note the new comment period end date.  Mary and her friends worked hard to get an extension due to the complexity of this EA. 

Thank you Mary for all of your help and support over the years.  Thank you also to all of you for helping to repay a HUGE debt to this lady as we work to help her herd now.  I don’t have a quick “one-click” button for you on this one. Please take a moment to send an email or mail a letter to help this herd.

The photos in this blog were sent to me by Mary and used with her permission. 

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Draft EA for Devil’s Garden Wild Horse Territory Panders to Local Livestock Interests

New Deadline for Comments – May 13, 2024

The United States Forest Service (USFS) is seeking comments on a “revised” draft
Environmental Assessment (EA) for a Territory Management Plan (TMP) that prioritizes private livestock grazing and continues the massive removals of wild horses from the Devil’s Garden Plateau Wild Horse Territory (DGPWHT).

The DGPWHT is located in the Modoc National Forest in Northern California. As determined by the 2013 TMP, the Appropriate Management Level (AML) is just 206-402 wild horses. At the same time, up to 3,700 cattle and 2,900 sheep are allowed to graze on the Territory for six months a year for pennies on the dollar.

In 2023, the spring census estimated that 1,339 horses live in this federally protected habitat. That’s after 3,345 horses had been rounded up and removed since 2016, costing American taxpayers millions of dollars and resulting in the deaths and injuries of hundreds of horses and foals.

So what’s behind this “revised” EA? First, after the 2013 TMP conveniently eliminated the 23,000+ acre Middle Section from the DGPWHT, wild horse advocates successfully sued the USFS, requiring the agency to reconsider its decision. Second, in 2017, a group of local ranchers from Modoc County filed a complaint against the USFS for not removing excess wild horses and reaching AML. This case was settled when the USFS agreed to implement several conditions that include removing a minimum of 500 excess horses each year to get to low or middle AML.

Not surprisingly, this “revised” EA for the DGPWHT – which is pretty much void of any solid science and data – spells a win-win for the ranchers. Besides adding a narrow 114-acre corridor through the Middle Section, the Proposed Actions maintains the same ridiculously low AML for the wild horses and allows the same ridiculously high number of private livestock to graze on the Territory.

Further, although the Proposed Action is considering fertility control, the likely choice is GonaCon, which is still experimental and has been shown to cause sterility in mares. And, as in the past, there’ll be more removals via helicopters and bait/water trapping.

Enough is enough! The USFS has missed the opportunity to do right by the wild horses and the vast majority of Americans who want them protected and preserved on our public lands.

Please personalize the letter below and tell the USFS that you want the Devil’s Garden wild horses to be managed humanely, efficiently, and sustainably.

All comments must be received no later than 5:00 p.m. Pacific Daylight Time on Tuesday, May 14, 2024. *Electronic comments can be submitted here: https://cara.fs2c.usda.gov/Public/CommentInput?Project=62741 you can also email your comments to: comments-pacificsouthwest-modoc-devils-garden@usda.gov

Please include “Devil’s Garden Plateau WHT – Middle Section” in the subject line.

*Written comments can be submitted to:
CHRIS CHRISTOFFERSON, Forest Supervisor
Modoc National Forest
225 West 8th Street
Alturas, CA 96101

LETTER

Dear Supervisor Christofferson:
Please accept the following comments on the draft Environmental Assessment (EA) for the Territory Management Plan (TMP) for the Devil’s Garden Plateau Wild Horse Territory (DGPWHT).

I strongly oppose the Proposed Action that will continue to prioritize privately owned livestock over federally protected wild horses by 1) maintaining an absurdly low Appropriate Management Level (AML) for horses; 2) allowing minimal expansion of the Middle Section; 3) implementing GonaCon, a unproven form of fertility control; and 4) maintaining current levels of cattle and sheep authorized to graze on the Territory.

Further, the EA raises more questions than it answers. In large part this is because the EA lacks pertinent and scientifically required information that must be analyzed before moving forward with the Proposed Action. For example, It provides no methodology for AML determinations in the Middle Section; therefore, these
determinations are arbitrary and appear predetermined.

It ignores current research that GonaCon is experimental in nature; therefore, the impacts cannot be analyzed because they are unknown. Further, it provides no research on the use and efficacy of remote wildlife vaccine delivery systems.

It provides no logical parameters for the decision to add only a narrow 114-acre corridor though the Middle Section to connect the East and West sections of the DGPWHT. This is especially important because the horses have historically wandered into other parts of the Middle Section.

It provides no evidence that differentiates the impacts of wild horses from private livestock on forage and water resources; therefore, claims that wild horses are solely responsible for range health degradation amount to nothing more than scapegoating.

It ignores/dismisses the research that finds that both wolves and mountain lions are apex predators who can help control wild horse population.

It provides no methodology/data for the inequitable distribution of forage resources that favors private livestock over federally protected wild horses. I appreciate that the United States Forest Service (USFS) has included Alternative 4 in the draft
EA. This alternative will 1) increase the AML to 500-1,000 horses while significantly reducing private livestock grazing; 2) limit the use of fertility control to PZP; and 3) enlarge the boundary of the DGPWHT.

However, when developing the final EA for the TMP for the DGPWHT, I ask the USFS to include the following mitigation measures:

PZP must be implemented before reaching AML. This is consistent with the
recommendations of the 2013 National Academy of Sciences report on the BLM Wild Horse and Burro Program. In the absence of this scientifically proven form of fertility control, the inhumane, expensive, and ineffective management strategy of massive roundups and removals of wild horses that was the cornerstone of the 2013 TMP will continue.

Rangeland improvements, such as the development of water sources and the removal of at least 50 miles of fences, must be implemented to allow the free movement of wild horses across all parts of the DGPWHT. This would result in fewer horses moving off the Territory as well as wider distribution of horses across the Territory and use of its resources, including forage and water.

Specific details about the proposed reduction of private livestock grazing, such as when, where, and how much, must be disclosed.
If any horses are removed, utilize only least intrusive capture methods, such as bait/water trapping that is much less expensive and traumatic for the horses than helicopter roundups.

Any horses removed from inside or outside the DGPWHT must be transferred to other USFS Wild Horse and Burro Territories. This would be in line with Regulation 36 CFR § 222.69(c) that directs the agency to relocate removed animals to other Territories.

Finally, given the scope and controversy of this draft EA, I ask that the USFS prepare an Environmental Impact Statement that provides for an actual, reason-based analysis of its Proposed Actions.

Thank you for your consideration.