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Would we want our children or grandchildren to see how America's horses are treated by our public agencies?

Alliance of Wild Horse Advocates'



Issue: The Calico Mountains Complex wild horse roundup.

Update: 12/31/09 on-site observation of the "Black Rock East" trap site at Paiute Meadows.

Persons present:

Craig Downer, Cloud Foundation
Deniz Bolbol, Animal Law Coalition
Elyse Gardner, Cloud Foundation
Willis Lamm, LRTC (author of this report)

Please note: This is a preliminary report, posted early to provide relevant information. Relevant follow-up information provided by Craig Downer regarding his return visit on Saturday, January 2nd follows this report.


The objective of this observation was to get an "eyes on the ground" look at the region and gather activities, and to better understand the planning and rationale behind this particular gather design and strategy. It is not the intent of this report to analyze land use priorities, overall herd management strategies or political issues, although some options are discussed later in this report.


The Calico Mountains Complex is a very large and in some instances a diverse region that includes several distinct herd management areas. Trapping operations involving five of these herd management areas have been scheduled to take place in multiple locations, with the trap site corrals and related equipment being relocated throughout the complex throughout the gather period.

Environmental conditions vary between the locations where horses are to be gathered.

Geography, range size and other factors (e.g., weather, impacts on wildlife) appear to make water trapping not a desirable or practical option for this complex. BLM decided to conduct gathers using aircraft in this complex.


The Dec. 31 gather location was on private land in an area known as Paiute Meadows. This is a semi-arid mountainous open range that is roughly north of, and relatively close to, the Black Rock Desert. It consists primarily of steep, rugged hills separated by relatively wide valleys. Vegetation is limited to floor level plant species such as grasses and sage. The area has no natural trees. On December 31, the valley floors were covered with about two inches of powder snow so identification of the various types of available forage was not practical.

The footing in this area is generally rocky, although by Nevada standards I wouldn't describe this particular area as being overly rocky. The snow pack was light and relatively moist (as opposed to melted and refrozen ice slicks) and traction was surprisingly good.

The trap site appeared to take advantage of natural land forms and an accessible road. Trap wings were placed at the easterly down slope end of a broad valley that had a relatively light longitudinal slope. The topography allowed the trap and sorting corrals to be connected as one large unit (as opposed to remote trap sites where horses have to be loaded into trailers, then trucked down to the sorting corrals to be sorted and loaded again for transport.) What appeared to be a significant amount of private fencing (fence wire and posts) had been temporarily removed to facilitate orderly movement of the horses.

View of wings and entrance to the corral structure.
The trap site and main corral system included connecting holding pens for separating "special needs" horses from the general population.
View of pens near the loading chute.
Shortly after our arrival we experienced a snow squall that grounded air operations so actual observations on this date were limited to the trap site layout and configuration.

This particular trap site appeared to be configured according to expected standards, making effective use of local topography, placed in an area where horse travel did not require movement over steep terrain and where the helicopter pilot could observe, and not lose sight of, all the horses in a band being brought in. If actual air operations are conducted as they should be, this particular site should not require the running of horses over long distances as a competent pilot could "herd" them down the length of the valley at a relatively easy walk, at least until the horses reached the trap wings.

I observed no unusual circumstances or safety problems with the trap site layout.

Overall trap site layout.
On-site discussions.

Since there were no active gather operations this day, some of the on-site time was spent in Q & A and discussions between observers and BLM personnel. Some of that information is relevant to understanding BLM's strategy with respect to this gather and therefore I am including it in this report.

Craig Downer raised questions relative to the standing of the horses on BLM public lands, particularly in regards to their status as defined by Congress.

BLM explained that there is a difference in standing with respect to herd areas (areas managed primarily for horses) and herd management areas (multiple use areas where horses are present, but not managed as the primary component.) In the herd management areas horse management priorities fall within a much larger matrix of land use and management laws and regulations.

The issue was raised regarding some herd areas having been redesignated as herd management areas. That was not a topic that the field personnel were prepared to address since such decisions came out of Washington, DC.

The issue was raised regarding this gather taking place in the winter. BLM's position was that throughout most of this complex, it was safer to move the horses in winter than in late summer (after the spring foaling season) due to heat and in some instance alkali dust and rocky valley floors. So long as traction remained good in the snow, it resolved the dust problems and provided a cushion over the rocks. Being relatively flat terrain where the horses would likely be moved, this explanation appeared to have merit.

Craig Downer raised the question of the helicopter producing flying snow from the rotor wash and its potential impacts on the horses' respiratory system. The APHIS veterinarian on site acknowledged that this could be an issue, but suggested that the incidence of airborne snow should be minimal, and less problematic than summer dust. I formed the opinion that so long as aerial operations are conducted correctly, the amount of "exposure" to wind blown snow would be less than that experienced on a typical Nevada windy day with powdered snow on the ground.

A discussion took place regarding an aged mare that had been euthanized. This was one of a few areas where different personnel had a different take on what actually took place.

What was consistent in the explanations was that an aged and debilitated mare had been observed nearby that had become disassociated with her band. (This is typical situation involving elder "end stage" horses who eventually can no longer keep up with their bands and there was no evidence that this was an instance where her band had been driven away and she had been left behind.) The mare was moved to the trap site where the veterinarian determined that she was well into her twenties, had naturally declined and would not survive the winter. The mare was then shot and disposed of.

The decision to euthanize this mare was not unreasonable. Later discussions revealed that she also had what was described as a colt with her. Being disassociated from he protection of their band, the colt would be vulnerable to predators. (I later located the colt at Indian Lakes and it was in fact a dependent nursing foal that was too young to survive outside a protective social structure and without supplemental feed.)

The decision not to transport the pair to Indian Lakes was not extraordinary either. While it clearly is a myth that older horses (aged 10 or older) cannot adapt to a managed enclosed environment or even successfully be adopted, the relocation outcome for debilitated elder horses is seldom good and it may not only be inhumane, but illegal in Nevada to load a severely debilitated horse into a transport along with robust horses for a several hour trip.

Since each circumstance is unique and since it is not always easy to administer IV injections to a wild horse at a trap site, I am not going to speculate over the decision to use a rifle rather than barbiturates to euthanize this mare.

My personal problem with this euthanasia is that the carcass was buried which in my opinion was a waste of otherwise available nutrition for wildlife. If the mare had been allowed to die of natural causes, her protein would have been available to the ecosystem. Since the mare was not euthanized by use of barbiturates, a more eco-appropriate disposal would have been to relocate the carcass to an suitable location available to wildlife. I am not sure if the maze of regulations permits surface discarding of deceased animals by BLM, however if such disposal is allowed, it should be utilized wherever appropriate.

Another discrepancy arose as to the condition of the horses coming in. The veterinarian graded the horses as being in poorer condition than did the personnel who were actually receiving the horses. (A report on the horses follows this report.) The overall condition of horses being gathered is an interesting issue but its relevance is limited since the criteria for BLM's decision in removing horses is based on population and range impacts, not body condition.

A third discrepancy arose regarding possible upper respiratory issues with the horses. In my opinion the APHIS veterinarian was not candid on this issue and appeared to have selected his words carefully, that he had not diagnosed any upper respiratory issues with the horses that were gathered. I have a personal problem when public officials try to imply one thing when our years of experience have shown the facts to be otherwise.

There is some latent disease in some of the herd areas. Disease is part of the environment and is one of the natural forces that cull weaker members from a herd. One of the more notable events in this region involved the Jackson Mountains salmonella outbreak in 2007.

Some of the horses in this region exhibit some signs of an upper respiratory condition often referred to as "strangles." This is an illness that is caused by the streptococcus equi bacterium. The disease got the nickname "strangles" as it can produce swelling of the lymph nodes in the horse's throat latch area and in some instances produce noisy respirations. [Citation: Strangles, NDSU School of Agriculture]

This disease is not some horrible plague. It is limited to equines. The disease spreads by direct contact, generally among members of a band. While the bacteria don't live long in the "environment," streptococcus equi can remain present in locations such as watering holes that are frequented by numerous horse populations.

Strangles is generally not a serious threat to healthy mature horses. It can be harder on younger horses that have not developed immunity to the disease and to debilitated horses that are immune compromised. BLM's horses are not going to become vectors and spread the disease to the domestic horse population.

However in a closed facility where a great number of horses are sharing the same space, feeders, waterers, and are in contact with each other, the horses can experience what is sometimes described as a "flare up" of the disease until it runs its course and the population's immunity levels are sufficient to curb the bacteria's spread. The epidemiology here is not that much different than school children coming together in a classroom and "sharing" a cold, except that strangles is bacteria caused and most "colds" are virus caused.

The relevant issue here is that by going to the Indian Lakes facility, any horses that come in from the Calico that may be carrying strangles will be isolated from the horses that are brought in from "strangles free" regions to Palomino Valley Center. My opinion is that this discussion would have been better served by a simple, candid statement such as, "Yes, we can anticipate some health issues with some of the horses we bring in, and we've taken steps to isolate these horses from horses brought in from other regions."

Black Rock East statistics.

The following horses were inventoried into Indian Lakes.


Of the foals, two are still nursing foals held with their dams in a mare and foal corral. A third foal is the orphan. Depending on the orphan's progress over the next couple of days, it may stay with the mare and foal pairs or be turned over to one of the non-profits experienced with orphan care for rehabilitation and foster care.

Other issues and opinions.

AML, AUMs, et al.

BLM reports that the number of horses found in the Calico Mountains Complex is 5.5 times the "low range," and 3 times the full carrying capacity of the complex. Since most of the area is non forested open range, I will assume that these population estimates are reasonably correct. This is one basis in which BLM justifies such a large gather target.

To be fair, a large number of cattle have also been removed from the public lands within the complex. It was explained that most of these reductions were voluntary. There is an assumption that in some instances putting the cattle out on poor range was not economically feasible.

In the discussion the usual confusion over AML, AUM and related terms arose. I will try to explain in simple terms a complex process.

AML is the appropriate animal management level for horses in a herd area or herd management area, typically expressed as a range from minimum to maximum population levels.

AUM is an animal unit month, or the grazing allocated to a particular animal unit for one month. One horse grazing for one month will consume one AUM. Because of a lower metabolism, one cow and her calf will consume one AUM. Smaller livestock such as sheep and goats could reach 6 or 7 animals per AUM.

BLM is required by law to manage for a "thriving ecological balance." Part of the process by which BLM is supposed to achieve this objective involves assessing the carrying capacity of specific ranges (available forage,) consulting with wildlife officials regarding the amount of carrying capacity that is reduced by wildlife grazing, then determining what forage is left that can be assigned to the horse herd and calculated as AUMs allocated to seasonal grazing permits and leases.

Here is where things often get confusing. An AML of 300 horses represents 300 horses grazing year-round. An AUM of 300 for livestock means that a livestock permittee or lessee can graze 100 cattle during a three month grazing season. So while it can be argued that private livestock significantly outnumber wild horses on public lands, the "face value" of numbers when comparing AML to AUM statistics do not represent accurate proportions of domestic versus free-roaming animals as an AML of "1" for horses is equal to "12" livestock AUMs.

Birth control.

We were advised that BLM would be providing birth control for some of the horses. Their strategy would be that those horses brought in that were in excess of the numbers scheduled for removal would be treated with PZP and released. While these intentions are good, I have a fundamental problem with this strategy.

First of all, no agency is going to launch an effective program if it is carried out as an afterthought. Applying birth control if "extra" horses are trapped is overly arbitrary and does not provide for a consistent representation of the horse population to be included in the program.

Understandably from BLM's position, they would be reluctant to birth control and release horses on a day when they experienced poor gather conditions and brought in few horses. However there needs to be some consideration for daily PZP application rather than simply treating the "leftovers." One alternative could be that on relatively successful gather days, one or more bands that are representative of the herd profile could be held aside in one or more of the special holding pens. If reasonable numbers have been gathered that day, the "reserved" bands could be treated, their backs marked with paint so they are not brought in again, and be released.

I also found it puzzling that the only immunocontraceptive birth control methodology that was being considered involved PZP. It is not my intent to disparage PZP, but the University of Nevada Reno and the UC Davis School of Veterinary Medicine appear to be making some advances in the area of longer term temporary equine birth control, both for mares and stallions and BLM didn't seem to know anything about it. From observing study horses both in our organization's possession and out on the range, some of the new formulations appear promising. If BLM wants to get out of the long term holding dilemma, they have to take equine birth control more seriously and consider all options.

Relocation strategies (or making use of available resources.)

Long term holding is becoming the most significant drain on the Wild Horse and Burro Program budget. In Nevada there are opportunities to help mitigate this growing problem through more contemporary strategies.

In a cursory review of historic range data, there appear to be at least a few HMAs with low populations where predation and other natural factors keep the herds within, or occasionally below, the established AML ranges. There may be locations where it is appropriate to boost stable populations with suitable horses from other ranges that would have otherwise gone to long term holding. In such instances restoring populations could help improve genetic viability. Given the reduction in the state predator trapping workforce due to budget cuts, predation as a means of herd population regulation may improve incrementally. While some special interests may object to horses being placed back onto public ranges, the expense of holding horses is a national issue and it makes practical sense to feed horses range grass that is already "bought and paid for" rather than board them with contractors.

There have been HMAs in which the herd has been zeroed out due to issues relating to herd management. (Typically these have been areas where it is excessively dangerous to horses and/or personnel to periodically conduct gathers.) An alternative would be to reintroduce stallions to areas sufficiently isolated so that mares won't migrate into the population. Questions have been raised as to whether a herd of stallions would get along together. Our experience has been that if mares are excluded from the immediate area, the stallions typically behave like youngsters. [Citation: The Butterfield Stallions, Wild Horse Workshop 2003]

The following are links to the LRTC / Wild Horse Workshop video of the BLM Butterfield stallions.

Higher resolution (broadband) video

Lower resolution (YouTube) video

Clearly there are some opportunities to return horses to the range and at the same time save money without exacerbating the "recruitment" issue. While such options are not limitless and they will not completely resolve the long term holding dilemma, they are a step in the right direction and follow original Congressional Intent.

Resource issues.

BLM personnel agreed with our assessment that there were locations that had a great deal of range forage that could be available for horses and other animals however available water was the limiting issue. BLM confirmed the problems the agency experienced in obtaining water rights. In some instances water resource issues could be resolved through dual use (a use that was recognized by the Nevada Department of Water Resources that could also serve to water horses.) Such projects might require private or non-profit assistance, however such opportunities need to be brought to the table. Irrespective of population issues, the range habitat improves at low cost when those animals grazing the range can more evenly disburse their grazing pressure. Furthermore not having large numbers of animals congregateing at limited water sources could help mitigate some herd health issues.

Another option would be for Congress to assert its authority over water found on or under Federal public lands to the extent that the use of such water does not materially negatively impact other users of the aquifer.

Miscellaneous observations.

It was my impression that neither BLM or some of the out of state visitors really knew what to expect from each other. BLM went overboard with security (which ironically was appreciated by me when I ran into vehicle trouble.) The advocacy delegates present weren't from the Animal Liberation Front. I do acknowledge that had horses actually been coming in, BLM's strict on-site safety protocols were relevant to insure the safety of the horses and people that would have been present. I have to say that the implication that if observers didn't follow directions they could be led away in handcuffs was offensive and may have instilled jaded the perceptions in some observers. BLM could benefit from adjusting its protocol message according to its "audience."

People who haven't seen Nevada gathers also tend to have an expectation of more drama than actually takes place out here. While gathers aren't perfect and mistakes can be made, from my experience the Nevada crews deal with so many horses and so many gathers that they have learned how to organize things in a way that maximizes safety and minimizes risks to horses. While the weather prevented me from observing actual activities, I saw nothing to suggest that this gather departed from Nevada's usual standards. While horse advocates may not like to see so many horses permanently removed from western ranges, it is in the horses' interest for us to recognize, as well as insist on, safe and sane professionally designed gathers when those gathers do take place.

Recognizing that safety is a critical concern during gather activities, I do wish to thank the Winnemucca District personnel for organizing what would have been a practical and realistic viewing opportunity, complete with a horse trailer that could have been used as a "viewing blind" next to the trap's wings where the most critical elements of the gather could be observed.


The portion of the gather arrangement that I saw was reasonably well designed and did not require moving horses over extreme inclines and over or through other avoidable hazards.

The transportation of the horses to the new Indian Lakes contract facility in Fallon is sensible from a number of aspects, including a shorter hauling distance for the horses.

Continuing to send horses to never ending long term holding is not a sustainable practice. BLM needs to utilize available range resources where appropriate to reduce dependency on long term holding of horses. There appear to be opportunities available that would not exacerbate BLM's concerns about population growth.

BLM needs to take birth control more seriously, and consider all viable and safe options for limiting herd population expansion while maximizing genetic diversity (e.g., leave a greater number of mares that each produce a fewer number of foals.) It is probable that some cost effective solutions can be developed provided BLM isn't stuck on a myopic approach.

The region in which the Calico Mountains Complex is found appears to provide some opportunities where alternatives to removal (e.g., sex ratio adjustment, replenishment of depleted herds, introduction of stallion herds, releasing of gelding bands, resource development, a greater commitment to contraception options, etc.,) could be attempted. Practical and humane alternatives to sending more horses to long term holding should be encouraged by the wild horse advocacy community.

Finally, the people at BLM on the ground do not formulate national public lands policies. Therefore while advocates need to utilize every opportunity to encourage new horse management approaches, we all have to understand that field activities must fall within formal parameters that field personnel are required to work under. Advocates will have to approach Congress to enact legislative changes that would clear some of the roadblocks that prevent other opportunities from being explored.

Willis Lamm, January 3, 2010
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This report will be revised as may be appropriate after it has been posted.

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