Wild Horse Fire Brigade Feud With BLM Is Not Just About Wildfires

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A conversation between Wild Horse Fire Brigade’s Creator and BLM‘s Research Coordinator.

On Nov 7, 2019, at 10:04 AM, Bill Simpson <[email protected]> wrote:

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Dear Mr. Fontana:

As I mentioned, I have been in contact (via telephone conversations and email) with both Bruce Rittenhouse and Paul Griffin about the WHB conundrum.This is of course in addition to numerous politicians, ranchers, wild horse advocates, fellow scientists, and more.

The media (NBC, ABC, FOX, NPR, theDoveTV, Lars Larson, etc) have welcomed my presentation since it is not political and benefits all sides of the debate. http://www.whfb.us/

Politicians and scientists who have taken to time to read and understand the Plan that I am proffering virtually all agree that; it's a win-win for all stakeholders.

Herein below is the rundown on the KEY parts of what I am proffering, starting with my recently published 5-year (continuous) Study (11,000 hours) of wild horses in a Wilderness Area devoid of livestock due to difficult terrain (transport and management costs) and robust populations of Apex predators.

By taking the time to understand what my experience as a former rancher (FFA), logger, forest manager and trained scientist, and someone who has actually spent 5-years living among wild horses (not on the outskirts of a herd, peering at them through binos or through a telephoto lens)... studying them (5-years) from within and among the herd, brings to dealing with the wild horse issue.

Here is the material that supports the concept with the nickname; 'Wild Horse Fire Brigade' (it's not just about wildfire)

New Study by Naturalist/Rancher William E. Simpson II published by ReWilding Europe's new publication GrazeLIFE:


Moreover, during said Study, a catastrophic wildfire (Klamathon Fire - 38,000 acres) actually tested the theory, which was validated via the wildfire (a valuable landscape; the Cascade Siskiyou National Monument was spared) something never seen before.

The Plan titled 'Natural Wildfire Abatement And Forest Protection Plan' is supported by what is arguably the best study of wild horse behavioral ecology available today. https://b32d739d-d185-4dd2-8388-9b640855e5bd.filesusr.com/ugd/6a30c6_39c677396bba4fbea3e2b49c94d3b97c.pdf

This Study, supports the foregoing Plan and is now being published in American and in Europe. https://b32d739d-d185-4dd2-8388-9b640855e5bd.filesusr.com/ugd/6a30c6_86f90f3dd9c44bf88bef87824fe4b4ac.pdf

Here is a Draft legislative bill suggestion: https://b32d739d-d185-4dd2-8388-9b640855e5bd.filesusr.com/ugd/6a30c6_aebef06ebdd54840b65172bb21adf202.pdf

Abbreviated cites, articles, media, TV NEWS, supporting the foregoing:

1) June 2017 - https://healthyforests.org/2017/06/william-simpson-wild-horses-and-their-value-proposition/

2) July 2017 - https://www.horsetalk.co.nz/2017/07/08/fighting-fires-wild-horses/

3) July 2017 - Wild Horse Conspiracy posted: https://thewildhorseconspiracy.org/2017/07/10/greetings-from-wildhorse-ranch/

4) RT Fitch - https://rtfitchauthor.com/2017/07/06/politics-of-wildfire-a-burgeoning-government-business-enterprise/

5) August 2017 - https://www.larslarson.com/wildfires-rage-horses-come-rescue/

6) Dec. 2017 - https://naturalresourcereport.com/2017/12/could-the-wild-horse-fire-brigade-work-for-oregon/

7) Dec. 2017 - Downer endorses Wild Horse Fire Brigade: https://www.horsetalk.co.nz/2017/12/27/renowned-wildlife-ecologist-wild-horse-fire-brigade/

8) Feb 2018 - https://www.environews.tv/022718-wild-horses-may-hold-solution-slowing-spread-fatal-chronic-wasting-disease-deer-elk/

9) Oct 2018 - Wildlife Ecologist endorses Wild Horse Fire Brigade with Simpson at Wild Horse Ranch: https://www.equineinfoexchange.com/index.php/health-education/829-wild-horses-can-re-balance-the-ecosystem-good-for-outdoor-sports-reduces-wildfires-toxic-smoke-2

Between these samplings of the many early published articles on my concept (Natural Wildfire Abatement And Forest Protection Plan - aka: Wild Horse Fire Brigade), there have been over 50 more articles, radio interviews (AM-FM Radio), TV NEWS, and Documentary Films. And dozens of related and supportive articles at:


Even publications that are adversarial to wild horses, such as Deseret News have published my work and concept:

1) https://www.deseret.com/…/could-wild-horses-feed-the-worlds… "California’s Bill Simpson conducted a five-year study that started in 2014 to look at horses’ impacts on natural landscapes in about 5,000 acres in Northern California and Oregon. The land was host to 67 horses that were preyed on by c

2) Horse Welfare News - https://horsewelfarenews.com/f/more-than-30-million-allocated-to-wild-horse-management-plan

3) Tuesdays Horse - https://tuesdayshorse.wordpress.com/2019/10/14/american-wild-horses-set-on-path-to-extinction

4) NPR RADIO - https://www.ijpr.org/post/how-wild-horses-could-reduce-fire-danger

5) The Desert Independent - https://www.thedesertinde.com/Articles-2019/A-new-documentary-film-Fuel-Fire-and-Wild-Horses--0410.html

6) ABC NEWS: https://www.kdrv.com/content/news/Rancher-Says-Wild-Horses-Could-Help-Prevent-Wildfires-482987721.html

7) NBC NEWS: https://kobi5.com/features/five-on-5-william-e-simpson-ii-wild-horse-fire-brigade-110578/

The 'Natural Wildfire Abatement And Forest Protection Plan is a 'tool' that saves money, saves lives and landscape from wildfire, rewilds American wild horses and burros into ecologically appropriate areas that are not in conflict with livestock production, AND therefore, belongs in the 'tool box', and at the very least, deserves a large-scale test ASAP!

Capt. William E. Simpson II - USMM Ret.

Naturalist - Rancher

Creator: Wild Horse Fire Brigade

Author HorseTalk

Member: IMDb

Muck Rack: https://muckrack.com/william-e-simpson-ii

Contently: https://captbill.contently.com

From: Paul Griffin <[email protected]>

To: Bill Simpson <William E. Simpson II>

Subject: Re: [EXTERNAL] Relocating ('Re-Wilding') WHB into economically - ecologically suited areas

Mr. Simpson,

I generally do not respond to your broadcast messages. In this case I will because you mention my name, as if to imply that I am supportive of your efforts to introduce BLM wild horses onto USFS lands, which I am not. When we spoke on April 16, 2019, I made clear in no uncertain terms that it would be absolutely illegal for BLM or USFS to intentionally place wild horses outside designated herd areas where wild horses roamed at the time of the passage of the 1971 Wild Free-Ranging Horses and Burros Act. I also pointed out that it would be extremely irresponsible for a land manager to introduce wild horses into an area where they would almost certainly increase in population, where they could expect to see severe and increasing impacts on natural resources. You were seeking advice on how to structure a research project, and told me that you were looking for scientists who could help you to design a study with valid inference. I pointed out that you have no evidence for your hypothesis that native predators would limit herd sizes in any area where horses would be introduced. Rather, horse herds grow at high rates in most herd management areas and USFS territories including forested areas with native predators, such as at Murderers Creek in Oregon. One should not presume that the high horse mortality rates that you report would exist in a different area, and one should not move wild horses into an area where that movement would be illegal under federal law.

Thank you,

Paul Griffin

Research Coordinator, BLM

Wild Horse am Burro Program


2150 Centre Ave., Building C

Fort Collins CO 80526

Sent from my iPhone

On Thu Nov 07 2019 10:34:47 GMT-0800 (PST), Bill Simpson <[email protected]> wrote:

TO: Paul Griffin - Research Coordinator, BLM

Wild Horse am Burro Program

Dear Mr. Griffin:

I find your response to my email as being utterly intellectually dishonest and an affront to factual science and integrity. My inclusion of your name was to inform you of the latest published Study, which btw, disproves your politically motivated conjectures.

Moreover, your fingerprints seem to be on the most recent published lie to Congress by the BLM to the effect that; "wild horses and burros have no natural predators...".

Misrepresentations such as the foregoing being made to Congress and the Public is what is illegal; your department seems to be guilty of supporting and promoting misinformation in violation of the Data Quality Act and other Law(s).

Data Quality ACT

Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106-554)

Sec. 515. (a) In General.--The Director of the Office of Management and Budget shall, by not later than September 30,2001, and with public and Federal agency involvement, issue guidelines under sections 3504(d)(1) and 3516 of title 44, United States Code, that provide policy and procedural guidance to Federal agencies for ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by Federal agencies in fulfillment of the purposes and provisions of chapter 35 of title 44, United States Code, commonly referred to as the Paperwork Reduction Act.

(b) Content of Guidelines.--The guidelines under subsection (a) shall--

(1) apply to the sharing by Federal agencies of, and access to, information disseminated by Federal agencies; and

(2) require that each Federal agency to which the guidelines apply--

(A) issue guidelines ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by the agency, by not later than 1 year after the date of issuance of the guidelines under subsection (a);

(B) establish administrative mechanisms allowing affected persons to seek and obtain correction of information maintained and disseminated by the agency that does not comply with the guidelines issued under subsection (a); and

(C) report periodically to the Director--

(i) the number and nature of complaints received by the agency regarding the accuracy of information disseminated by the agency; and

(ii) how such complaints were handled by the agency.The full text of Public Law 106-554 is available through the Government Printing Office website.


It seems your logic has become corrupted by political bias and you are no longer holding true to the scientific principal and integrity that is required to carry forward any research of potential management solution(s) in behalf of American taxpayers to the costly problem we all face in the management of our public lands and American 'native species' wild horses, which are 'native' 'wildlife' according to the 9th Circuit Court of Appeals [1].

You are also incorrect in your global statement that wild horses cannot be legally introduced onto Federal Lands. State(s) fish and wildlife agencies can legally manage wild horses as 'wildlife' on any state or federal lands within state's jurisdictions, just as they do with cervids.

Furthermore, anyone from this part of the United States who lives in the country knows that; coyotes, bobcats, bears and mountain lions ALL take wild equids as their natural prey. (Bill Phillips also mentioned the same on a conf. call yesterday). The fact that you fail to acknowledge that fact demonstrates that you are either ignorant of the natural history and wildlife ecology on the western landscape, or are being intellectually dishonest, and as such should resign your position since you are no longer serving the greater good of American taxpayers and the management of their natural resources.

And to be clear Paul, you work for us, on our dime. Our taxes pay your salary!

>>>> [1] The U.S. Ninth Circuit Court of Appeals in California recognized wild horses as native species, explaining that BLM “establishes Appropriate Management Levels (“AMLs”) for populations of native species – including wild horses, burros, and other wildlife – and introduced animals, such as livestock.” In Defense of Animals, et al. v. U.S. Dept. Interior, et al., No. 12-17804, *6 (9th Cir. May 12, 2014). On Sep 28, 2011 (See Craters AR at 16698. Memorandum Decision & Order) the court addressed “sensitive” species pursuant to BLM’s 2001 Special Status Species Policy. This Policy requires that “sensitive” species be afforded, at a minimum, the same protections as candidate species for listing under the ESA. It called on BLM managers to “obtain and use the best available information deemed necessary to evaluate the status of special status species in areas affected by land use plans …” See Policy at § 6840.22A. Under the Policy, those land use plans “shall be sufficiently detailed to identify and resolve significant land use conflicts with special status species without deferring conflict resolution to implementation-level planning.” <<<<

Thank you for helping us to more clearly understand your position.

Sincerely, William

Capt. William E. Simpson II - USMM Ret.

Naturalist - Rancher

Creator: Wild Horse Fire Brigade (www.WHFB.us)

Author HorseTalk

Member: IMDb

On Tue, Nov 12, 2019 at 3:41 PM Carla Bowers <[email protected]> wrote:

Mr. Griffin - Being involved with the WHB issues for a long time, I wholeheartedly concur with Mr. Simpson's email to you regarding your intellectual dishonesty & inability to fulfil your role as a research scientist for the BLM WHB Program. The lies & misinformation have to stop. If you're not willing to do your job with honest integrity, speak the truth & support viable, out-of-the box solutions for our WHB, then you should step down.

Carla Bowers

On Wednesday, November 13, 2019, 11:21:03 AM EST, Kathleen Hayden <[email protected]> wrote:


I hope you will avail yourself of the opportunity to absorb the herein extensive research contributions required to amend resource management plans. The court in Mt. States v Hodel found that “In structure and purpose, the Wild Free-Roaming Horses and Burros Act is nothing more than a land-use regulation enacted by Congress to ensure the survival of a particular species of wildlife. Every land-use plan is required to comply with historic and species preservation mandates. That opens up a plethora of options for rewilding as I have previously outlined ad nauseam. It is the unwillingness to apply these findings that perpetuate the obstruction of law and pave the path to extinction.

From: MARYBETH DEVLIN <[email protected]>

To: Paul Griffin <[email protected]>; jfontana <[email protected]>; brittenh <[email protected]>; riley.bushue <[email protected]>; robertcl <[email protected]>; lmorgan <[email protected]>; boicec <[email protected]>; attorneygeneral <[email protected]>; ben_ward <[email protected]>; eleanor.blume <[email protected]>; carissa.bunge <[email protected]>

Sent: Thu, Nov 14, 2019 8:52 am

Subject: Re: [EXTERNAL] Relocating ('Re-Wilding') WHB into economically - ecologically suited areas

On: November 14, 2019

To: Paul Griffin, Research Scientist

Wild Horse and Burro Program

Bureau of Land Management (BLM)

Cc: Reply All

Fr: Marybeth Devlin

Re: Scientific Integrity Demands Your Resignation

Dear Mr. Griffin:

I call for you to resign. In your email to Mr. Simpson, you made materially false, fictitious, and fraudulent statements and representations regarding wild horses. You did so in your official capacity as Research Scientist for the Wild Horse and Burro Program.

Misrepresentations made within the jurisdiction of a Federal government agency constitute fraud under Title 18 USC 1001 of the Federal criminal code.


Misrepresentations also violate the Department of the Interior's Code of Scientific and Scholarly Conduct. The Code mandates integrity. It prohibits scientific misconduct, which specifically includes fabrication or falsification in the reporting of the results of scientific activities.


The reasons you gave for opposing Mr. Simpson's plan contained not only misinformation but actual disinformation.

First, you falsely claimed that wild horses have no natural predators. Because that claim is contrary to the facts, it is a false statement, a misrepresentation made regarding the wildlife-at-issue. For the benefit of readers not familiar with predation on wild horses by mountain lions, I have curated several studies and provided them below.

Second, you falsely claimed that wild-horse populations increase "at high rates." That statement misrepresents wild-horse reproduction, which is a slow process. But what you inadvertently revealed by that lie is your own failure to ensure science-based data-collection for the Program. Specifically, had you been properly supervising the reporting of population-growth data for the annual Herd Area and Herd Management Area Statistics Reports, you would have easily spotted the many biologically-impossible increases reflected therein. You would have realized, for example, that the Blue Wing burro-herd could not possibly have increased 753 percent in one year. You would have discerned that 15 wild horses on the 278,105 acres of the Chicago Valley HMA cannot, by any scientific standard, constitute an overpopulation. You would have recognized that restricting the Silver Peak herd to a maximum of 1 wild burro per 40,410 acres is absurd. You have failed to correct the blatantly-arbitrary — versus appropriate — management levels (AMLs), most of which do not provide for genetically-viable, self-sustaining herds. Because you failed to responsibly oversee the herd-growth reports, they give a false impression of fast-reproducing herds, which you then cite. Truth be told, an "overpopulation" is found only on your spurious spreadsheets. The public has been misled. Our taxpayer-dollars have been misspent because you have not performed your job with scientific integrity and responsibility. Director Pendley has been subjected to public ridicule after he called wild horses an "existential threat" to our public lands per your bogus reports.

Third, you are abusing your authority by misrepresenting and actively obstructing Mr. Simpson's creative, cost-free plan to reduce the incidence of wildfires. When implemented, his proposal will save lives, protect property, and safeguard clean air. It will eliminate $50 million a year in holding-costs for captive wild horses. It will save the taxpayers untold billions of dollars in fire-suppression costs. It will protect people from suffering illnesses caused by toxic smoke inhalation, some of it from "prescribed" burns.

Fourth, you misrepresent the laws that apply to wildlife. You seem to willfully refuse to acknowledge the difference between Federal versus State authority. You didn't even refer to the Wild Free-Roaming Horses and Burros Act correctly. Instead, you called it the Wild "Free-Ranging" Horses and Burros Act. When a person in your position does not know the name of the Law that he is administering, then his suitability is questioned.

Your egregious misrepresentations appear to violate Title 18 USC 1001 and DOI's scientific-integrity standards. You should stand down.

I call on you to resign without further delay. The Wild Horse and Burro Program is in urgent need of an honest, responsible scientist at its research-helm.


  1. Mountain lions prey on wild horses.

Research has shown that mountain lions prey on wild horses more frequently than previously believed. Canadian biologists found that cougars tended to kill younger animals when preying on feral horses. Nearly all cougar-predation events (86%) involved animals less than 2 years old. However, decrepit elderly — and no-longer-fertile horses — would also likely be taken by lions.

Knopff KH, Knopff AA, Kortello A, Boyce MS. (2010). Cougar Kill Rate and Prey Composition in a Multiprey System. Journal of Wildlife Management. 74(7):000-000; 2010; DOI: 10.2193/2009-314

Retrieved from http://sci-northern.ab.ca/wp-content/uploads/2010/12/CougarKillRateandPreyComposition.pdf

In an interview, the above study's lead researcher, Kyle Knopf, described observing a cougar bring down a feral horse less than 30 yards from where the cat first launched its attack.

French, Brett. (2010, December 9). Ferocious appetites: Study finds mountain lions may be eating more than previously believed. The Billings Gazette. Retrieved from http://billingsgazette.com/lifestyles/recreation/article_d9cf046b-2c47-539f-a267-972e72e570b6.html

  1. The National Park Service recognizes that mountain lions prey on wild horses.

The National Park Service, a sister-agency to BLM under DOI, identifies wild horses as among the prey of mountain lions. NPS particularly noted: "In 2004 mountain lions took 27 of 28 foals on the Pryor Mountain Wild Horse Range."

Bighorn National Recreation Area. (Last updated 2012, March 31). Mountain Lions. Predator and Prey. National Park Service. Department of the Interior. Retrieved and screen-shot taken from https://www.nps.gov/bica/planyourvisit/mountain-lions.htm

Indeed, that massive take of foals made the news.

French, Brett. (2004, August 12). Lions blamed for deaths of Pryor foals. The Billings Gazette. Retrieved from


Actually, according to The Cloud Foundation, the Pryor Mountain herd averaged no population growth over a four-year period due to predation by mountain lions. Only when those lions were killed — so that BLM could manage the herd with the pesticide-sterilant PZP — did the wild-horse population begin to grow. Rather than allow the herd to be right-sized by natural predators for free, BLM substituted its staff and PZP at high cost to the taxpayers.

  1. Other studies found that mountain lions, all by themselves, effectively controlled wild-horse populations.

The Montgomery Pass Wild Horse Territory, on the California/Nevada border, has had its population managed for free by cougars alone. An eleven-year study concluded that the growth of this herd was limited by cougar predation. In fact, the population actually decreased over the course of the research.

Turner JW and Morrison ML. (2001). Influence of Predation by Mountain Lions on Numbers and Survivorship of a Feral Horse Population. The Southwestern Naturalist. Vol.46, No. 2 (Jun., 2001), pp. 183-190. DOI: 10.2307/3672527 Retrieved from http://www.jstor.org/discover/10.2307/3672527?uid=2129&uid=2&uid=70&uid=4&sid=21101018535373

An earlier five-year study of the Montgomery Pass herd showed similar results. Foaling-season peaked in May through June. By July, one-third of the foals had gone missing. By October, half of the foal-crop had disappeared. Mountain lions were found to be responsible for 82 percent of foal-mortality.

Turner JW Jr, Wolfe ML, and Kirkpatrick JF. (1992). Seasonal mountain lion predation on a feral horse population. Canadian Journal of Zoology, Vol. 70, No. 5 : pp. 929-934, https://doi.org/10.1139/z92-132

The research-study cited below found that the Nevada Wild Horse Range (its current designation) averaged negative population growth due to cougar predation over the period 1989 to 1998.

Greger PD and Romney EM. (1999). High foal mortality limits growth of a desert feral horse population in Nevada. Great Basin Naturalist: Vol. 59: No. 4, Article 10. Available at https://scholarsarchive.byu.edu/gbn/vol59/iss4/10

From: Bill Simpson <[email protected]>

To: pgriffin <[email protected]>; brittenh <[email protected]>

Sent: Thu, Nov 14, 2019 10:08 am

Subject: Abuse of Public Trust, Violations of Federal Law & Malfeasance by BLM employee [EXTERNAL] Relocating ('Re-Wilding') WHB into economically - ecologically suited areas

FYI: This matter, as further detailed herein below by researcher Marybeth Devlin and others including myself, is being referred to the press and the appropriate state's and Federal authorities for investigation and immediate action.

Furthermore, Mr. Bruce Rittenhouse (Acting Division Chief - BLM Wild Horse & Burro Program) has a fiduciary duty to also carry-out an investigation (in public with proper unbiased oversight) into these allegations of malfeasance now that he is hereby constructively informed of such abuse of the public trust by a public employee under his overview.

We The People of the United States of America are darn tired of some of our paid government employees acting as if they are above the laws of land and in this case, intentionally spending our tax dollars to misinform the Congress of the United States and its honorable members as well as the public as to matters relating to the management and behavioral ecology of American wild horses and burros. This egregious behavior by is a violation of law(s) and of the public trust, and is jeopardizing the health, safety and welfare of Americans as well as squandering their tax dollars via the costly mismanagement of our public lands and native species American wild horses that stems from the use of dishonesty in the management of our natural resources and wild horses.

This must be stopped! - William E. Simpson II

Capt. William E. Simpson II - USMM Ret.

Naturalist - Rancher

Creator: Wild Horse Fire Brigade

Author HorseTalk

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