A Wild Horse Management Plan Benefits All Stakeholders

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William E. Simpson’s open letter to Deb Haaland, discussing that a wild horse management plan benefits all stakeholders and taxpayers.

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Wild Horse Management Plan

A family of wild horses symbiotically reduces wildfire fuels off a forest floor at no cost to taxpayers.

TO: The Honorable Debra Haaland, Chair

Subcommittee on National Parks, Forests, and Public Lands

CO: Lily Wang - Policy Aide, Subcommittee on National Parks, Forests, and Public


TO: Congressman Joe Neguse

Colorado's 2nd District in the U.S. House of Representatives.

CO: Carissa Bunge - Assistant to Colorado Congressman Joe Neguse

Erika Blum - Asst. to Congressman Neguse

CC: Wild Horse, Wildlife and Wilderness Advocates

RE: An Open Letter - Draft Solution (bill) For Plight Of American Wild Horses

Via Email Only - February 12, 2021

Dear Ms. Haaland, Mr. Neguse:

I trust that you, your staff and others at your offices are well.

My name is William E. Simpson II. I spent my formative years on my family's working ranch in southern Oregon as a rancher managing lands with forest and with horses and cattle, as a member of the Future Farmers of America (FFA).

I am now retired, and living on my ranch in the Soda Mountain wilderness area (OR-CA border) among the free-roaming wild horses that I have studied for the past 7-years.

The combination of my training in science, background in business, logging, livestock production and forest/land management (including firefighting), and wild horses have informed my perspective in a unique and synergistic manner.

The first 5-years of my ongoing and continuous Study ('Impact Of Wild Horses On Wilderness Landscape And Wildfire') of wild horses has been condensed and published at GrazeLIFE (a division of Re-Wilding Europe): https://grazelife.com/blog/wild-horse-fire-brigade-lessons-in-rebalancing-north-american-ecosystems-by-rewilding-equids/

My study is unique in that the wilderness Study site is virtually devoid of livestock (too remote and too many apex predators); there are only cervids and equids.

My experience, is both academic in regard to my background in science (attended Oregon State University as a Pre-Med Science major), and empirical, in regard to the behavioral ecology of wild horses and their management.

Some of my bona-fides (letters from legislators and public officials) are online at this URL: https://b32d739d-d185-4dd2-8388-9b640855e5bd.filesusr.com/ugd/6a30c6_9850ae624332457baf331499c1cca3e2.pdf

I am writing to you in regard to a Draft legislative outline, for a bill (attached PDF) that I believe can solve the longstanding dilemma facing public lands managers in regard to the conflict between stakeholders in public lands uses and the interests and well-being of native-species American wild horses.

Americans cannot allow any virus (Covid or not) to derail or stall the efforts to save native-species American wild horses, a National Treasure, especially at a time when rogue elements at DOI, BLM and USFS are engaged in what is arguably the largest and most reckless roundup in recent history.

As you know, the recent and ongoing roundups by the BLM and USFS are devastating to the wild horses.

Wild horses (and burros) are driven beyond their physical abilities, in many cases, some are dying from stress during or after the roundups. Foals literally run their hooves off, and some can't keep up and are lost, left behind for predators. Pregnant mares abort their unborn, some die from shock out on the range, some of these atrocities are concealed from the public.

Some atrocities are not, such as this BLM contractor helicopter ramming a fleeing burro, and a BLM contractor beating and punching a helpless little burro (he was never prosecuted); VIDEO EVIDENCE:

Ecosystems (flora and fauna) are devastated in wild horse roundups

Roundups that use helicopters and other vehicles, force wild horses to run for their lives randomly (abnormal behavior) across the landscape, and in the process of their desperately fleeing, they inadvertently trample threatened and endangered species of flora and fauna.

How does the BLM and USFS get away with this? Are NEPA and EIS just rubber-stamped for these now seemingly corrupted agencies?

Caused by the BLM & USFS roundups; the trampling-damage affects the nests, crushing eggs of ground birds (sage grouse) and the birds themselves, as well as numerous small mammals and reptiles (lizards, turtles, snakes, etc.), which are all crushed by the thundering hooves of escaping wild horses and other wildlife, all of which are running for their lives as helicopters disrupt the normal tranquility of the ecosystems subjected to what could be called the government's monetary biased War on Nature.

These wide-scale roundups are coupled with the systematic implementation of a combination of diabolical methods that are arguably designed to lead to genetic erosion and loss of genetic diversity, leading to the ultimate extinction of free-roaming native species American wild horses...

The draconian methods currently being used by the BLM, USFS and their cronies, include these;

1) Reducing breeding populations so low (less than 200 breeding adults in a herd) as to induce in-breeding and loss of genetic vigor; and,

2) Castration of stallions, which results in the loss of genetic diversity (we don't even know which alleles are responsible for the resistance that wild horses have to Chronic Wasting Disease), and this also interferes with evolved evolutionary competition for breeding rights (survival of the fittest); and,

3) Chemical interventions (PZP & GonaCon) which interrupt critical social structures in family bands (matriarch mares lose status and their intuitive knowledge for survival is lost to family bands; some mares become infertile, etc. Darting wild horses with chemical contraceptives, as some of wild horse organizations lobbying legislators want to do, is not ecologically correct and it disintermediates evolutionary processes.

4) Wild horses are being shot to death by people now embolden by what seems to be an 'open season' on wild horses by the BLM and USFS, resulting from what the public sees as a total disregard for the value of these sentient beings by these government agencies.

5) The BLM even has the audacity to propose using an outdated procedure known as “ovariectomy via colpotomy,” where a metal rod-like tool is blindly inserted through a vaginal incision in order to sever and remove the ovaries of wild mares while they remain conscious!

These government agencies (DOI, BLM, USDA, USFS) which are arguably influenced by money and politics around public land livestock grazing, are devastating the remaining populations of the relatively few (based on genetic diversity) remaining American wild horses....

The BLM is still engaged in an ongoing campaign of 'willful ignorance' and 'campaign of misinformation' via their ongoing propagation of manifestly false statements, including but not limited to:

"Wild horses have no natural predators..." IS a false statement promoted by the BLM (and now widely repeated) (Page 1, Executive Summary, paragraph 5) that was presented to Congress in writing as a part of their so-called 'Report To Congress - Management Options For A Sustainable Wild Horse And Burro Program'.

Only a corrupted agency would manage a resource starting with a lie.

It's a well-know scientific and common-knowledge fact that: All north American apex predators (mountain lions, bears, wolves and coyotes) are the evolved predators of wild horses and burros.

We need to restore ecological-balance and the trophic cascades in areas where that is still possible, in the remaining remote wilderness areas, where the American wild horse is a critical keystone-species large-herbivore, as is the case in many ecosystems.

The BLM paying ranchers more than $100-million annually to house wild horses off-range is a serious waste of our tax dollars (it's obscene; one ranching family alone, the Drummond family, has already been paid $24-million by the BLM!).

This waste of tax dollars is totally unnecessary when there exists a readily available, virtually cost-free path for solving the entirety of the wild horse dilemma, while concurrently reducing wildfire fuels; a concept supported by peer-reviewed, published science.

Treating wild horses (deemed as 'native species' & 'wildlife' by the 9th Circuit Court of Appeals) with any chemicals is wrong on so many levels it's just obtuse, and there are numerous experts who agree with this position.

The Natural Path To Successful Wild Horse Management

Relocating wild horses from holding (thus initiating immediate reductions in expenditures for offsite holding), and also, relocating wild horses from areas where they are in conflict with livestock interests (subject to potential BLM-USFS interventions) via humane relocation methods [unmolested family bands are baited-in and relocated together as family bands], into select wilderness areas with abundant water and forage, that are nevertheless manifestly unsuited for livestock wildfire grazing (for many sound reasons; I.E. loss of profits due to; predators, management logistics in rugged remote terrain, etc.) is both economically and ecologically appropriate.

A new article was out (Friday, Jan 5th) in Colorado at the Pagosa Daily Post, detailing how American taxpayers and Counties in Colorado can save (literally) hundreds of $-millions annually by implementing new public lands management using Wild Horses!


This older article details why, exactly, wild horses are appropriate ecologically on the American wilderness landscape: https://pagosadailypost.com/2021/01/18/opinion-wild-horses-chronic-wasting-disease-in-deer/

And finally, this article that appeared in the Mail Tribune and the Pagosa Daily Post, outlines the common-sense solution that all stakeholders should consider in contrast to the ongoing dire situation:


I can only hope that there are enough enlightened people in the mix to implement a final solution that is fair and just to these magnificent, highly evolved, sentient beings.....

So far, in our short stead on the planet, we've done a fine job of wrecking almost everything we mess with... especially things in the Natural world. Maybe we proceed with that thought to guide us as we evaluate our next plan to save wild horses....

*Scientific References herein below.


William Simpson

Capt. William E. Simpson II - USMM Ret.

Naturalist - Author - Conservationist

Wild Horse Ranch

P.O. Bx. 202 - Yreka, CA 96097

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

Author @ HorseTalk

Member: IMDb

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

Check out my FilmFreeway account for films, studies, TV & radio interviews, and more HERE.

Native Species American Wild Horses: Published Scientific References

[1] MANAGED TO EXTINCTION? A 40th Anniversary Legal Forum assessing the 1971 Wild Free-Roaming Horses & Burros Act; TRANSCRIPT: ROSS MACPHEE, Curator, Division of Vertebrate Zoology, American Museum of Natural History (AMNH): https://docs.google.com/document/d/1-zNiS1uqCWZ9PimwJpaVdY7NC57hxdGKDCLXbCEYb8c/edit

[2] Wild Horses as Native North American Wildlife: https://awionline.org/content/wild-horses-native-north-american-wildlife

[3] 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 addresses “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.”

[4] Land Held Hostage: A History of Livestock and Politics; Thomas L. Fleischner, Ph.D. https://www.academia.edu/11886843/Fleischner_Land_Held_Hostage_A_History_of_Livestock_and_Politics Citation by: Professor Thomas L. Fleischner, Ph.D: “The most severe vegetation changes of the last 5400 years occurred during the past 200 years. The nature and timing of these changes suggest that they were primarily caused by 19th-century open-land sheep and cattle ranching.”

[5] Foods of wild horses, deer, and cattle in the Douglas Mountain area, Colorado. Hansen, R. M., Clark, R. C., & Lawhorn, W. (1977). Journal of Range Management, 30(2), 116-118. https://repository.arizona.edu/handle/10150/646893

[6] Evolution of wild horses and cattle and the effect on range damage; https://www.horsetalk.co.nz/2017/09/25/evolution-wild-horses-cattle-effect-range-damage/

[7] Federal Forestlands In Oregon: https://oregonforests.org/sites/default/files/2017-08/Federal_Forestlands.pdf

[8] Collapse of the world’s largest herbivores: "By altering the quantity and distribution of fuel supplies, large herbivores can shape the frequency, intensity, and spatial distribution of fires across a landscape”. William J. Ripple1, Thomas M. Newsome1,2,Christopher Wolf1, Rodolfo Dirzo3, Kristoffer T. Everatt4, Mauro Galetti5, Matt W. Hayward4,6, Graham I. H. Kerley4, Taal Levi7, Peter A. Lindsey8,9, David W. Macdonald10, Yadvinder Malhi11, Luke E. Painter7, Christopher J. Sandom10, John Terborgh12 and Blaire Van Valkenburgh13 http://advances.sciencemag.org/content/1/4/e1400103.full

[9] Rewilding: Jozef Keulartz. "The removal of large herbivores has adverse effects on landscape structure and ecosystem functioning. In wetter ecosystems, the loss of large herbivores is associated with an increased abundance of woody plants and the development of a closed-canopy vegetation. In drier ecosystems, reductions of large grazers can lead to a high grass biomass, and thus, to an increase in the frequency and intensity of wildfires. Together, with the loss of a prey base for large carnivores, these changes in vegetation structures and fire regimes may trigger cascades of extinctions (Bakker et al., 2016; Estes et al., 2011; Hopcraft, Olff, & Sinclair, 2009; Malhi et al., 2016)." http://oxfordre.com/environmentalscience/view/10.1093/acrefore/9780199389414.001.0001/acrefore-9780199389414-e-545

[10] Wild horses: Are they being managed to extinction? William E. Simpson II; https://www.horsetalk.co.nz/2018/02/24/wild-horses-managed-to-extinction/

[11] Cattle Grazing Effects on Macroinvertebrates in an Oregon Mountain Stream; Rangeland Ecology and Management 60(3), 293-303, (1 May 2007) James D. McIver and Michael L. McInnis; https://doi.org/10.2111/1551-5028(2007)60[293:CGEOMI]2.0.CO;2

[12] Dr. Cassandra Nunez – PhD: Published research: https://www.nrem.iastate.edu/people/cassandra-m-nu%C3%B1ez

[13] Influence of ruminant digestive processes on germination of ingested seeds; https://ir.library.oregonstate.edu/concern/graduate_thesis_or_dissertations/v405sg230

[14] Ruminant Digestion: https://www.mun.ca/biology/scarr/Ruminant_Digestion.html

[15] Public lands bear the ecological brunt of livestock grazing: https://www.horsetalk.co.nz/2020/11/21/horses-public-lands-ecological-brunt-livestock/

[16] Wild Horse Fire Brigade - Rebalancing North American Ecosystems: https://grazelife.com/blog/wild-horse-fire-brigade-lessons-in-rebalancing-north-american-ecosystems-by-rewilding-equids/

[17] Yes world, there were horses in Native culture before the settlers came https://indiancountrytoday.com/news/yes-world-there-were-horses-in-native-culture-before-the-settlers-came-JGqPrqLmZk-3ka-IBqNWiQ?

[18] Project to Reform Public Land Grazing in Northern California https://wildcalifornia.org/wp-content/uploads/2016/01/Annual-Report_2015_final-final.pdf

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