Letter to Bureau of Land Management by Mary Beth Devlin: Reality Comes to BLM – Time for Change

18 Jul

June 12, 2019

Bureau of Land Management

Burns District Office (BDO)

28910 Highway 20 West

Hines, OR 97738

Attn:  Spay Project Lead

Full Title:     Spay Feasibility and On-Range Outcomes

Document: Environmental Assessment (EA)

NEPA ID:    DOI-BLM-ORWA-B050-2019-0013-EA

This letter responds to your solicitation of public comments regarding the horrific Mengelian experiments proposed for infliction on wild-mustang mares.  I submit my comments as an interested party in behalf of the wild horses of the Warm Springs herd of Oregon.

NEPA Project Summary Page

Link to pdf of the EA


Odious Experiments, Silly Objectives, Fraudulent Justification

BLM would subject 100 defenseless wild mares to an archaic, cruel, and dangerous surgery — ovariectomy via colpotomy.  This high-risk procedure would jeopardize the mares’ health, destroy their fertility, and in many cases even cause their death.  Misleadingly labeled “research,” the stated objectives include determining whether fewer births would result due to the majority of the herd’s females having been sterilized.  BLM claims to be curious how the spayed mares’ behavior as well as that of their herd-mates would be affected.

Forcing defenseless mares to endure painful surgical procedures for such silly and spurious objectives, which anyone can see through, is unethical.  These bogus experiments do not merit any funding, be it private or taxpayer-sponsored.  They are merely a fourth attempt to spend funds that had been inappropriately awarded to BLM-Oregon to solve a concocted crisis — a fabricated overpopulation based on an arbitrary herd-size, a preposterous stocking-density, and falsified records.

FONSI Prepared Before Comment Period

BDO included a Finding of No Significant Impact (FONSI) along with the new EA, yet again signaling that the proposed alternative was a fait accompli.  This move reflects BDO’s contempt for the public-comment component of the NEPA process.  Issuing the FONSI in advance announced to all concerned parties that it does not matter what the American People want.  BLM practices Authoritarianism based on the Big Con of “overpopulation.”

BLM Dismissed the Highly Controversial Nature of The Experiments

In the 2019 FONSI, BLM made the same false statement as in the earlier 2018 (initial and updated) FONSIs and the original 2016 FONSI, expressing recalcitrant disregard for how its proposed cruel experiments have inflamed and antagonized the public.  To wit:

Controversy in this context means disagreement about the nature of the effects, not expressions of opposition to the proposed action or preference among the alternatives.

That claim was and still is false.  This EA is highly controversial — just like the previous ones in 2018 and the one prior to that in 2016.  It has caused an uproar in the human environment.  Truth be told, tens of thousands of American citizens, speaking for millions of others, are voicing absolute opposition to the proposed action.  We demand that BLM renounce this EA and/or adopt the “No Action” alternative.  This is not merely an expression of our preference.  It is our demand.

BLM and USGS Go It Alone … for the Fourth Time

Three years ago, BLM attempted to ram through essentially this same scheme by cloaking it in academic respectability.  BLM’s partner-in-crime was to be Oregon State University (OSU).  However, following intense controversy and multiple lawsuits, OSU backed out, and the evil plan was stopped … for the moment.

But never one to admit it was wrong, BLM persisted.  In 2018, BLM came back with new partners.  Colorado State University (CSU) was chosen for academic cover, and United States Geological Survey (USGS) — also a bureau under Department of the Interior — was brought along to share in the spoils of the excess funds available.  However, as before, the university-piece fell through, as CSU wisely exited from what it realized was a problematic relationship.

BLM and USGS then opted to go it alone.  They partnered up without an academic component, hoping the third time might be the charm.  But that run failed too.  Displaying continued poor judgment, BLM and USGS are trying for yet the fourth time to pull off this con-job.

Follow the Money

With nearly $900,000 in funding at stake, BLM and USGS are hanging on tight to a pot of money they want to exploit.  They insist the experiments are necessary as are the funds to pay for them.  Otherwise, if unspent, Congress might conclude the funds weren’t needed, leading it to cut appropriations next time.

Meanwhile, every time BLM issues a new EA along with a FONSI, the District Office spends money from the study-grant.  Even the lawsuits that BLM inevitably has to fight help deplete the funds allocated for the “study.”   BLM transfers money to the local US Attorney to defend the Agency against lawsuits that have been and will surely be filed to stop this illegal scheme.

The Newly-Tweaked Design

As previously devised, BLM would hire rogue veterinarians to carry out the unethical experiments, and USGS would study the behavioral after-effects.  Clearly, BLM is unqualified to administer and oversee a surgical research program.  And, obviously, taxpayers should not be made to pay for USGS’ boondoggle of a study.  The only difference between the current study-design and previous ones is that the mares subjected to surgery would not be pregnant.  Glad to hear that you are proposing a less-gruesome model; but sorry guys, the answer is still “NO.”

Deadly Duplicative Experiments

Several years ago, a number of mares that used to inhabit the Sheldon Wildlife Refuge were sterilized per the same obsolete surgical procedure at issue here.  Approximately 30 mares died as a result of the surgery.  Those who initially survived ovariectomy via colpotomy were released without followup; so, it is likely that the death-toll was even higher.  It is a waste of taxpayer money to duplicate a failed experiment that led to the unnecessary suffering and death of so many horses.

Vetting the Veterinarians

Is your lead veterinarian the same one who was under investigation by his state board last year?  You know, the vet whose malpractice resulted in the deaths of the 30 mares at Sheldon, cited above.  He and all other veterinarians that agree to participate in this project would be violating their oath to “first, do no harm.”  Ethical veterinarians have already weighed in, expressing their opposition to performing this …

  1. Outdated and dangerous procedure
  2. On wild mares
  3. In a primitive, non-sterile operating-theater.

Sterilized Mares Are Not Found in Nature

BLM repeatedly proclaims that its goal is to maintain a thriving, natural ecological balance.  There is nothing natural about sterilization-surgery.  Mares with ovariectomies are not found in Nature.  Released back to the range, they will not contribute to a genetically-viable, self-sustaining herd.  If BLM were to implement such surgeries, it would be substituting harmful, expensive, intrusive meddling in place of the minimum-feasible management-model specified by the Act.  Moreover, having humans select which mares to sterilize would interfere with Natural Selection.  Wild herds need to be molded by their environment, not manipulated by humans.

Further, if the sterilized wild mares survived the surgeries and were released back to the range, their behavior would be abnormal.  They would experience abrupt menopause.  Herd-dynamics would become dysfunctional, creating chaos and causing suffering.  It is abusive to visit such torment on innocent wild horses.  BLM’s attempt to justify sicko experiments as “furthering knowledge” (another repeat FONSI catch-phrase) could not be further from the Truth.  The “detailed quantification” would be just another way for BLM to exploit the Warm Springs horses for the agency’s undeserved fiscal benefit.  Bad behavior should not be rewarded.  Otherwise, it will proliferate.

Freedom from Torture

The Wild and Free-Roaming Horses and Burros Act requires that these “living symbols of the historic and pioneer spirit of the West  … shall be protected from capture, branding, harassment, or death ….”  The planned experiments-in-question would include all such activities prohibited by the Act.  There is an aspect of sadism to them — like, “let’s see how many mares we can kill with risky surgery, and then track any survivors to see how they behave once their ovaries have been removed.”  Torture of defenseless animals — that’s what such “research” is.

Sicko Experiments

Please take my comments as feedback on how your project is perceived by American citizens, taxpayers, and voters.  Although there are many reasons why your proposed twisted scheme is ill-advised, you already know it’s wrong, don’t you?  But grant-money has been secured through the “overpopulation” trickery, and you are taking advantage of it to squander our tax-dollars on bogus studies that will hurt America’s wild horses.  While the poor creatures targeted for these brutal experiments may be returned to the range, they will arrive back thorougly traumatized.  There is no need for a study to determine that that is what will happen.

Stand Down

BLM must get out of the way of Nature.  That means no roundups, no birth control, no sterilization, no experimentation.  Natural Selection must be allowed to mold the herds.  Predators — especially apex predators such as mountain lions (of which there is an abundance in Oregon) and wolves — must be conserved as population-control agents.  With time, a thriving natural ecological balance will, finally, be possible.

Reject Experimentation on America’s Wild Horses

The proposed experiments are antithetical to the spirit and intent of the Law.  Responsible DOI, BLM, and USGS Administrators must withdraw from this ill-conceived project.  Spare the wild horses from cruel experiments.  Save taxpayers from wasting millions of dollars on specious research.


Sterilizations — Predicated on Falsified Population-Growth Data

BLM used the overpopulation-ruse to secure funding from Congress for population-suppression research.  However, the government doesn’t have a wild-horse problem — wild horses have a government problem.   The alleged overpopulation of wild horses is a pernicious lie, a concocted crisis, particularly in Oregon.

Arbitrary Management Level (AML)

According to BLM, the maximum number of wild horses that the 499,457 acres (780 square miles) of the Warm Springs habitat can sustain is 178.  That number represents a 12% reduction from the original high-AML of 202.   Such numbers are not environmental requirements but rather political constructs, set for administrative convenience and political expediency.  The reduced upper bound of the Warm Springs AML established a maximum stocking density of 1 wild horse per 2,806 acres — nearly 42/5 square miles.

Austere Management Level (AML)

However, BLM does not manage per the maximum but rather down to the minimum, that is, to the low bound of the AML — 96.  That number reflects a 131/2% reduction from the original low-AML of 111.  As with the high-AML, the low-AML is not a scientifically-determined number.  This austere management level corresponds to a stocking density of 1 wild horse per 5,204 acres —  well over 8 square miles!

Sparsely Populated, Widely Dispersed

Obviously, BLM aims to keep the Warm Spring wild horses few and far between.  The paltry stocking-density is designed to easily create the false impression of an overpopulation when, in fact, even when over the AML, the herd is underpopulated.

Unfortunately, Warm Springs is not alone.  LIsted below are other herds in Oregon that are also restricted by sparse stocking densities, down-to-which BLM culls these herds:

1 wild horse per  2,073  acres  —  3.2  square miles  —  Sand Springs

1 wild horse per  2,302  acres  —  3.6  square miles  —  Stinking Water

1 wild horse per  2,320  acres  —  3.6  square miles  —  Palomino Butte

1 wild horse per  2,832  acres  —  4.4  square miles  —  Pokegama

1 wild horse per  2,885  acres  —  4.5  square miles  —  Liggett Table

1 wild horse per  2,972  acres  —  4.6  square miles  —  Coyote Lake

1 wild horse per  4,381  acres  —  6.8  square miles  —  Beatys Butte

1 wild horse per  5,062  acres  —  7.9  square miles  —  Paisley Desert

Livestock Have Taken Over the Wild Horses’ Dedicated Habitat

BLM bemoans the phony overpopulation it has concocted via an arbitrary herd-size limit (96 wild horses) and a vastly-dispersed stocking-density (just 1 wild horse per 8 square miles).  However, BLM blithely ignores the fact that livestock numbering in the thousands rule the horses’ dedicated habitat.  The “active preference” distinction is meaningless because the permittees self-report their use of AUMs, thereby controlling how much they claim they didn’t use.

Please compare and contrast:

19,392 AUMs for Livestock —         94.4%

1,152 AUMs for Wild Horses —       5.6%


20,544 AUMs, L/S + WHs — 100.0%


Although BLM incorrectly alleges conflict between mustangs and livestock over forage, one of the dominant herbivores on the range are lagomorphs — jackrabbits, hares, and cottontails.  BLM has neither determined nor factored in their impact on the range.

A recent study — in neighboring Utah — found that jackrabbits were consuming 34% of the forage on local grazing-allotments.  Evidently, the creatures reproducing like rabbits were rabbits.

Instead of scapegoating wild horses for forage likely eaten by a different species, BLM needs to conduct a Ecological Site Inventory (ESI) to determine  actual use — including trespass use.  Such a formal inventory pro-rates actual use by each animal-species present, including rodents and insects, and even including creatures such as lagomorphs.

An ESI involves teams — a soil-survey team, a vegetation-mapping team, a vegetation-transecting team, and a phenological data-collection team.  There are minimum data-collection standards, and they are quantitative: Production and composition by air-dry weight (ADW) by species.

An ESI requires there be a Plan, which must include but is not limited to logistics, field measurements and techniques, compilation procedures, reporting, and quality control.  All kinds of maps are used — orthophoto quads, topographic and planimetric maps, and administrative maps.

BLM-Oregon should stop depending on qualitative assessments such as the Landscape Appearance method, for evaluating rangeland conditions.  Technical Reference (TR) 1734-7, Ecological Site Inventory, warns that such qualitative assessments “may result in reduced accuracy, limiting use of the data.”  BLM-Oregon should conduct a formal vegetation-inventory by means of an ESI.


In normal times, locusts — grasshoppers and crickets — consume 20-to-25% of the forage in areas where they are present.  However, in times of outbreaks, they can eat nearly all of the green biomass.

Below is the link to the 2019 USDA-APHIS map, showing areas where there is grasshopper-and-cricket infestation.  Oregon appears to be suffering an invasion.  As the map suggests, the creatures devouring the forage like locusts probably are locusts.

An Ecological Site Inventory would reveal the extent of forage-consumption by locusts and crickets in the project area.  Again, you may be surprised to learn who is eating what and how much.

Long Gestation Years to Reach Puberty Alternate Year Foaling

Having digressed by necessity into a discussion of the uninvestigated impact on rangeland health of livestock, lagomorphs, and locusts, let us now return to BLM’s universal scapegoat:  Wild horses.

Horses are a slow-growth species with regard to reproduction.  The gestation-period lasts an average of 11.2 months, and a mare produces just 1 foal.  There is a delay of two or — usually — three years before fillies begin to produce foals (National Research Council 1980, citing Eberhardt et al. 1982, and Garrott and Taylor 1990).  Further, there is evidence that wild mares tend to foal every other year, likely due to inadequate energy-reserves to sustain a pregnancy every year (NRC 1980).  Per Fisher’s Principle, the natural gender-ratio of a herd is 1:1.  BLM has been known to skew this ratio to favor males, thereby limiting the component of the herd that can produce foals.

The Birth Rate The Herd-Growth Rate

The birth rate and the herd-growth rate are different measures.  For a herd-growth rate to be valid, the birth rate must be reduced by the respective death rates for foals and for wild horses other-than-foals.

Foal-Mortality Is Very High

While birth rates vary, within a year, between 32% and 50% of foals vanish (McCort 1984, citing NRC 1980; and Gregg et al. 2014).  Thus, the birth rate is just a temporary blip in the data.

Adult-Mortality Must Also Be Factored

Meanwhile, the mortality rate (extrapolated from the survival rate) for wild horses other-than-foals ranges from 3% to 20%, with a median of 11.5% (BLM Smoke Creek EA 2017, citing Wolfe 1980, Eberhardt et al. 1982, Garrott and Taylor 1990).  The use of 11.5% as a reasonable estimate of adult mortality among free wild horses is supported by two statements, found in BLM environmental assessments regarding captive wild horses kept in long-term, off-range pastures (ORPs):

  1. “Natural mortality of wild horses in ORP averages approximately 8% per year ….” and
  2. “Wild horses residing on ORP facilities live longer, on the average, than wild horses residing on public rangelands ….”

Invalid Year-to-Year Population-Growth Data

BLM declares a standard population-growth rate of 20% per year.  But that projection is clearly false because it does not consider the high foal-mortality rate or the other-than-foal mortality rate.  Per the independent studies cited above, it appears that BLM’s claim is exaggerated by anywhere from two to ten times the actual herd-growth rate.

Because the subject EA targets the Warm Springs horses for sterilization per an alleged overpopulation, let’s review what BLM claimed were the herd’s annual growth rates in recent years.  The chart below tracks BLM’s reported population-growth figures for the Warm Springs herd as of March 1 of each year since 2010, the year that will serve as the base, the starting point.  Note that contraceptive treatments (PZP) should have significantly reduced the growth-rate; but BLM ignored that effect.

Warm Springs HMA — 499,457 acres — 780 square miles

Low-AML = 96.  The level down-to-which BLM culls the herd.

Stocking-density = 8 square miles / wild horse

2010    362  —  November 2010 cullPZP given

2011  —  111

2012  —  133  —  20%  —  despite PZP in effect

2013  —  160  —  20%  —

2014  —  192  —  20%  —

2015    368  —  92%  —

2016  —  442  —  20%  —

2017  —  586  —  33%  —

2018  —  739  —  26%  —

2018  —  886  —  20%  —  after the foaling season

Even the 20% growth rates are inflated.  How curious that PZP had no effect, per BLM’s reports.  Please note that the implausible growth rates compound, as each successive year is calculated per those growth rates that preceded it.

It is according to these falsified growth rates that BLM claims an overpopulation, one that would appear to double every four years … or sooner (note the 92% increase that BLM reported in 2015).  However, without the fabricated appearance of an “overpopulation,” there would be no “crisis,” would there?  How would BLM justify its sinecures and paychecks at that rate?  It couldn’t; so, it invents a problem to “solve” at great trouble and expense, to gain the administrative funds that accompany contracts for research and roundups.

Falsified Herd-Growth Rates Found in BLM Reports for Oregon

Warm Springs is not the only herd in Oregon whose year-to-year population increases defy credulity.  It is important to consider the others because BLM claims one of the objectives of its experiments is to determine the feasibility of sterilizing the mares of additional herds that it claims are overpopulated.  Thus, BLM is endeavoring to establish a management-model based on fraudulent figures.

101%  —    South Steens

102%  —    Pokegama

104%  —    Palomino Butte

170%  —    Stinking Water

179%  —    Paisley Desert

256%  —    Beatys Butte

317%  —    Jackies Butte


Fraud Is a Crime

BLM’s representations with regard to Oregon’s wild horses are false and misleading.  Making false and misleading representations = fraud, which violates Title 18 USC 1001 of the Federal criminal code.  Embezzlement and theft — expenditures of government funds for fraudulent reasons — violate various sections of Title 18 USC Chapter 31.

Pattern of Fraudulent Reporting, Misuse of Government Funds

There seems to be a pattern to this fraud.  It appears to extend across BLM field offices, district offices, the state office, and the National Office.  As noted in previous comments, BLM offices in other states have reported fraudulent wild-horse herd-growth rates too.

As American citizens, we expect our government officials to administer programs and funds honestly.  In Oregon and elsewhere, BLM appears to coordinate the reporting of fictitious figures to secure increased funding to solve a phony problem.

Mandate to Ensure Quality, Objectivity, Utility, and Integrity of Data

BLM is bound by the Information Quality Act, better known as the Data Quality Act (DQA). explains the Act thusly:

The Data Quality Act (DQA) is an attempt by Congress to ensure that federal agencies use and disseminate accurate information. The DQA requires federal agencies to issue information quality guidelines ensuring the quality, utility, objectivity and integrity of information that they disseminate and provide mechanisms for affected persons to correct such information. It is important for natural resources and environmental attorneys to be aware of this law in the event that a client has an interest in filing a petition with an agency to challenge the quality of information it has used or disseminated.

However, BLM’s data is corrupt — falsified in the agency’s self-interest and perpetuation, with an aim to secure the biggest budget that the false appearance of a wild-horse overpopulation can generate.

Code of Conduct

BLM must also adhere to the Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct, which applies to all staff members as well as to contractors, partners, permittees, and volunteers.  The Code states:

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved.  Most importantly, it must be trustworthy.

However, BLM’s herd-growth figures with regard to the Warm Springs mustangs clearly violate the Code.  The numbers have been ginned up way beyond the high-normative growth rate.

It Is Wrong to Reward Fraud

The proposed research is predicated on falsehoods:  Overpopulation and a high reproductive rate.  Government funds should not pay for fraud.  Instead, if BLM finds itself with excess budget, that money should be redirected to improvements — such as placing guzzlers throughout the herd management areas and providing badly-needed shade and shelter for captured wild horses penned up in those feedlots that BLM euphemistically calls “off range pastures.”

Cut the Funds, Cut the FTEs

BLM finds itself with excess funds on hand.  It is desperate to find a way to spend that money, even if it means resorting to a spurious research project based on falsified records.  The administrative funds that would accompany the $900,000 grant would pay for a lot of staff-salaries, benefits, and overhead.  So, despite having been caught in a fraud, BLM pretends all is well and bulls ahead defiantly.

I call on the President and Congress to perform liposuction on BLM’s budget.  Stop these evil experiments, slash BLM’s funding, and revoke its budget-authority.  The bureaucrats who concocted this devious scheme and the administrators who signed off on it should be fired.


Wild Horses Do Have Native Predators

Nature provides its own population-control for wild horses by means of large predators.  There can be no “thriving natural ecological balance” without apex predators.  Mountain lions, bears, wolves, and coyotes effectively control wild-horse populations.  Predators promote survival of the fittest, as Nature intends.  Therefore, the best approach is for BLM to concentrate on conserving native predators to permit natural control of the wild-horse population on the range.

Mountain Lions Are Particularly-Effective Population-Control Agents

Many studies have established that mountain lions prey on wild horses more frequently than previously believed.  Canadian biologists found that cougars tended to kill younger animals, especially when preying on free-roaming horses.  Nearly all of the cougars’ predation-events (86%) involved animals less than 2 years old.

In an interview  with the Billings Gazette, the above study’s lead researcher, Kyle Knopf, described observing a cougar that brought down a feral horse in less than 30 yards from where it attacked.

Other research confirms that mountain lions are quite capable, all by themselves, of keeping wild horse populations in check.

The Montgomery Pass Wild Horse Territory, on the California/Nevada border, has had its population managed by cougars alone.  An eleven-year study by Turner and Morrison (2001) concluded that the growth of this herd was limited by cougar predation.  In fact, the population actually decreased over the course of the research.  Cost:  $0.

The Nevada Wild Horse Range (current designation) averaged negative population growth due to cougar predation from 1989 to 1998 (Greger and Romney, 1999

Per 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 — at the behest of BLM, so that the Agency could continue practicing management of the herd with PZP — did the wild-horse population begin to expand.

Healthy Predators, Healthy Ecosystems

Minimum feasible management means letting natural selection do its job.  Mountain lions, wolves, bears, and coyotes should be allowed to carry out their role of population-control agents.  Predators will cull the weak, and a thriving natural ecological balance will ensue.  Conservation Researcher Dr. Corey Bradshaw emphasizes

“… just how important predators are for healthy ecosystems.  Long story short — if your predators are not doing well, chances are the rest of the ecosystem is performing poorly.”

Due to pressure from livestock and hunting interests that mistakenly view predators as pests or competitors, it has been the Federal government’s practice to exterminate native predators outright or to allow them to be hunted on a massive scale.  That policy is wrong.  Predators function to keep the ecosystem in balance.  Without them, prey species decline, as do the forage-production species on which the prey-animals feed.  Dr. Bradshaw warns: “Without predators, our feeble attempts to conserve ecosystems are doomed to fail.”  Here’s the link to his article:

Predator Protection

HMAs should be safe-havens for predators, which serve as wild-horse population-control agents.

Again, absent predators, a “thriving natural ecological balance” is not possible.  Therefore, BLM should ensure the protection of native predators, instituting a prohibition on hunting them.  Conservation measures will work to enable the right number of predators to establish themselves.  Large carnivores will keep the wild-horse population in check.  Such an approach would keep the herd-population in equilibrium with minimal human-interference, just as the Wild and Free-Roaming Horses and Burros Act envisioned.  Predators are the “no-cost” option.

Recommendations:  A puma, bear, wolf, and coyote-protection program should be implemented.  BLM should collaborate with Oregon Department of Fish and Wildlife to prohibit hunting of predators in the HAs and HMAs.  Concerned livestock operators and residents of the surrounding area can be advised to use guardian-dogs to protect their animals.  There are several specialty-breeds that have been developed just for this purpose, and they are reportedly effective.  Protecting one’s herd is just part of the cost of doing business.


Facilitation, Commensalism Equids Enhance Livestock Production

BLM alleges a “potential for direct competition for forage” (EA, screen-page 62) between cattle and horses.  However, in fact, there is actually commensalism rather than competition.

Commensals are animals that eat “at the same table” but without competing.  Such is the case for equids, bovids, and ovids.  Perhaps counter-intuitive but actually true, research has shown that cattle gain more weight when grazed with equids.

BLM needs to stop the range-war, pitting wild horses against cattle.  Forage-grazing is not a zero-sum game.

Symbiosis Equids Graze Old Growth Cattle Prefer New Growth

Wild horses utilize coarse, old-growth forage.  They are like lawn mowers.  They take off the top growth — the dry, unpalatable layer.  This grazing method enables the plants to put down deeper roots, and it prevents weeds from maturing to produce seeds.  Grasses are encouraged by the horses’ frequent “mowing.”

Livestock, in contrast, prefer tender new growth.  They will even return to patches previously grazed — i.e., not rested — to get at that new growth.

Thus, by consuming the old growth and making available the new growth, wild horses make conditions better for the range and better for livestock.

Livestock and Horses Sharing Pastures “Of Great Benefit” to Both

When livestock and horses share — or rotate among — pastures, parasites are reduced.  That is because, with one insignificant exception, horses and livestock ruminants are not afflicted by the same parasites.  So, cattle and horses “serve as vacuum cleaners” — horses of cattle-parasites, cattle of horse-parasites.  They “clean up” the pasture for one another.  Such pasture-sharing is a holistic way to control parasites.  Please listen to the recorded interview on this topic-on-interest, linked below, with Ray Geor, BVSc, PhD, Dipl. ACVIM, professor and chairman of Large Animal Clinical Sciences at the College of Veterinary Medicine at Michigan State University.

Run-time:  2 minutes, 28 seconds

Holistic Approach to Parasite-Eradication — Essential

A recent study reported that chemical methods of reducing the parasite-load — namely, Ivermectin — is detrimental to dung beetles.  Those creatures have an important role to fulfill in Nature.  As their name implies, they clean the range of dung, something you don’t want an excess of.

Highlights of the Research

  • At the short term, ivermectin residues cause a strong decrease in dung relocation and dung spreading by dung beetles.
  • Conventional use of ivermectin disrupts diversity by affecting species richness, abundance and biomass of dung beetles.
  • Reduction in the functional efficiency of dung degradation resulted in the long-term accumulation of manure.
  • Use of ivermectin causes lower quality in soil organic C and the increase of the in-situ mineral N and P production.
  • The results of this study highlight that the effects of ivermectin must be investigated from a global perspective.
  • The use of this veterinary medical product must be monitored and controlled following a precautionary principle.

Verdú JR, Lobo JM, Sánchez-Piñero F, Gallego B, Numa C, Lumaret JP, Cortez V, Ortiz AJ, Tonelli M, García-Teba JP, Rey A, Rodríguez A, Durán J.  (2018).  Ivermectin residues disrupt dung beetle diversity, soil properties and ecosystem functioning: An interdisciplinary field study.  Science of The Total Environment.  DOI: 10.1016/j.scitotenv.2017.10.331  Retrieved from


Wild-Horse Fire Brigade

Overlooked in the uproar over BLM’s exploding spreadsheets is the critical service that wild horses perform:  Lowering the risk of fire.  Wild horses thrive on marginal forage — that coarse dry stuff that cattle don’t like.  The horses’ grazing-strategy helps reduce the fuel-load that would otherwise feed catastrophic wildfires.  Wild horses are perfect for fire-prevention duty.  In fact, there is a current proposal to deploy them to remote, rugged terrain, where they will graze down the overgrowth of grasses, brush, and twigs that, when seasonally dried out, can fuel a megafire.  The idea is to have that dried-out forage feed wild horses rather than wildfires.  The “Wild Horse Fire Brigade” — a smoke-free, cost-free, and ecologically-safe method of reducing excess dry brush and grass on public lands — already has the support of local elected officials in Oregon.

The short (8 minutes, 34 seconds) documentary titled “Fuel, Fire, and Wild Horses” provides an overview of how it would work.

BLM Should Maximize the Warm Springs Wild-Horse Fire Brigade

Rather than cull and cut the little Warm Springs herd, BLM should be doing everything possible to maximize the benefits and protections the wild horses confer on the public lands.  Now is the time to return all captured Warm Springs horses to their home-habitat.

Smoke Inhalation, Even from Controlled Burns, Is Injurious to HealthA special report coincidentally aired today, June 12, 2019, on NPR’s Oregon Public Broadcasting.  It discussed how firefighters suffer health-problems due to inhaling smoke — and its previously-unrecognized toxins — while suppressing wildfires.  The report further noted that even prescribed burns, normally of low-intensity, still emit smoke that has adverse effects in the short and long term.

Wild horses will happily dispatch the dry grass and brush that is the subject of controlled burns and the fodder for uncontrolled burns, thereby protecting the lungs of firefighters and local residents too.

Burns, Jes.  (2019, June 12).  “More Wildfires Bring Focus On How All That Smoke May Harm Firefighters.”  National Public RadioOregon Public Broadcasting.   Retrieved from

Prescribed Burns Damage the Soil

Despite the standard orthodoxy, burns are not necessarily always beneficial.  Two recent studies by University of California-Merced scientists found that even low-intensity fires, such as those typically associated with prescribed burns, can damage soil-structure and organic matter in ways that don’t manifest until later.

Desert Research Institute. “Low-severity wildfires impact soils more than previously believed: Negative effects of low-severity fire on soil structure and organic matter.” ScienceDaily. ScienceDaily, 10 September 2018. <>.

Controlled Burns Can Get Out of Control

Intentionally-set fires can get out of control.  Just last summer here in Florida, what was supposed to be a controlled burn ignited a wildfire that destroyed 36 homes.

Fire Prevention — Saves Firefighters’ Lives Also

Although fighting wildfires is dangerous work, the increasing number and severity of those fires and the lengthening of the fire season are having an adverse impact on firefighters’ emotional health.  The incidence of suicides among firefighters is now 38% higher than that of the general population.  It is incumbent on BLM to use preventive methods to avoid burdening the already-stressed fire crews.  Wild horses should be allowed to carry out that function.  They work for food.

Deploy Wild Horses for Fuels-Abatement Duty in Remote Areas

Below are excerpts from the correspondence sent by William E. Simpson II, a citizen-reformer, to the respective administrators of BLM and USFS, with a copy having been sent to various Congressional Representatives and County Commisssioners, regarding the placement of wild horses in remote forested areas to carry out reduction of excess dry vegetation to mitigate wildfires.  Although Mr. Simpson focuses on Cascade-Siskiyou National Monument in Jackson County, Oregon, the same concept could apply elsewhere on Federal lands on Oregon and throughout the West.

RE: Solution For Hazardous Fuel Buildup and Fire Prevention in BLM Cascade-Siskiyou National Monument & Other Forests

Thank you for offering to provide the new BLM Director Mr. Bruce Rittenhouse with the hard copies of the research and Natural Wildfire Abatement And Forest Protection Plan (the ‘Plan’), which posits a novel solution for ultimately eliminating the corralled wild horse issue and in the same move, providing taxpayers with $4-Billion in wildfire fuel mitigation services over a 15-year period. Details here:

I am copying this email directly to Director Rittenhouse to alleviate you of printing it and the URL linked assets.

This plan, even in its pilot testing phase, would immediately relieve some pressure on grazing capacity of existing grazing allotments and HMAs and significantly reduce wild horse numbers in proximity to many livestock operations, all of which is accomplished in one cash positive move for the BLM.

*The total estimated costs of just the 2017 California wildfires was $180-Billion:

*The 2017 Oregon wildfires alone put 3.3-Million tons of the deadly toxic gas carbon monoxide into the atmosphere, exceeding the CO emissions of all on-road vehicles.

USFS estimated fuel treatment costs:

~$400/acre for fuel treatment using prescribed burns (puts more toxic smoke into our air); mechanized costs

~$800/acre, and these treatments apply only in areas accessible (terrain) and suited to such treatments where it’s not prohibited (methods are barred by regulations in most Wilderness Areas, some of which burn catastrophically now with greater frequency and severity due to prodigious fuels ripened and un-grazed due to severely depleted western black tail deer populations, ready for combustion during longer warmer summers).

Therefore, even if permitted in the Cascade-Siskiyou National Monument (in Jackson County, OR), the most cost effective fuel treatment (prescribed burning) would be ~$23.2-Million annually. While wildfire grazing using horses is virtually free.

As you will read in the email herein below, ODF District Forester Dave Larson who oversees the fire suppression contract for the BLM’s 58,000 acre (nominal size) Cascade-Siskiyou National Monument in Jackson County Oregon attests to the exigent wildfire hazard in subject BLM forest. He also cites the potential value of deploying wild horses from holding corrals from both a fire prevention perspective and economic perspective (preventing fire saves lives, trees, wildlife, property and wildfire suppression costs for the BLM).

There is a legal path to the implementation of a novel fuel mitigation solution under existing law, that was passed to the former BLM Director Brian Steed on Nov. 29th 2017 by Congressman Greg Walden. That letter can be found here:

Secondly the situation in the CSNM is exigent; it could be lost in its entirety due to catastrophic wildfire at anytime.

All professional assessments of the fuel loading in the CSNM have stated that the Monument is choked with grass and brush fuels (fine fuel that carries wildfire hot and fast to other heavier fuels). This places the entirety of that forest wilderness at grave and imminent risk for total devastation from catastrophic wildfire. And such a catastrophic wildfire could easily devastate an old west town like Ashland, Oregon (home of Southern Oregon University and the Shakespearean Festival, also in the same County as the CSNM.

Under restrictive regulations for protected wilderness areas, there are virtually no fuel abatement tools available; no chemicals, no motorized equipment, and no prescribed burns. This arguably leaves wildfire grazing as the last hope for grass and brush mitigation.

The reason the grasses and brush are so prodigious is that the populations of western black tail deer are severely depleted (down over 2.2 million animals over the past 5-decades in OR and CA). The best science informs us that when there is a depletion of large-bodied herbivores, catastrophic wildfire evolves due to un-grazed fuels.

  1. In rugged remote, predator-filled wilderness areas with poor access like the CSNM, livestock become predator meat.

The additional excessive costs of wildfire grazing using livestock to ranchers providing livestock in any wildfire grazing role far out weighs even the economic proposition of ‘free grazing’ in these areas. On the other hand, wild horses are virtually free from the BLM’s own corrals (and USFS corrals), and deploying them into wilderness areas in wildfire fuel abatement roles makes each horse so deployed worth $72,000.00 in fuel mitigation value (equivalent labor cost per acre) over their 15-year expected lifespan in the wilderness, as detailed in this article:

  1. Environmental issues: Wildfire grazing using livestock versus wild horses

Most protected wilderness areas are ecologically sensitive areas with native species flora that would be stripped from the land along with seeds by grazing ruminant cattle and/or sheep due to their highly effective complex digestive systems. Horses are monogastric (incomplete) digestors and reseed areas grazed with intact native plant seed that is deposited with humus and localized microorganisms back onto the ground as scat, all of which are highly beneficial and restorative to soils; more here:

I conclude with a quote from a letter I received directly from the Head of the USFS – Ms. Victoria Christensen on June 7th, 2018:

Large grazers are a valuable resource in reducing the flammable grass and brush components within our ecosystems…. It is true wild horses and burros, and other grazers, can impact vegetation and fuel loading.  In specific locations, grazing can be a tool to reduce fine fuel loading.


BLM-Oregon, and its Burns District Office in particular, need to stop this Spay-Study nonsense.  You have wasted everyone’s time and cost the taxpayers probably hundreds of thousands dollars so far on this scheme.

It’s time to do some real research that will advance human knowledge and help sustain the environment.  I recommend starting with an Ecological Site Inventory (ESI), as described in this letter.

It’s also time that BLM-Oregon recognize what valuable assets wild horses are.  With climate craziness and more-intense wildfires Out West, BLM should be increasing the number of wild horses to graze down what would otherwise become 1-hour fuels sparking into a wildfire.  Your state’s abundant population of mountain lions will keep the herds right-sized.  Just like the wild horses, the cats work for free.

It is time to stop falsifying data in order to increase revenue.  That is dishonest, even criminal behavior.  It cannot go on.  Eventually, you will be called to account by parties way above my level — those with real authority.


Marybeth Devlin

Miami, FL 33155-2916


Posted by on July 18, 2019 in Uncategorized


8 responses to “Letter to Bureau of Land Management by Mary Beth Devlin: Reality Comes to BLM – Time for Change

  1. grandmagregg

    July 18, 2019 at 11:55 pm

    And thank you, Marybeth and everyone who commented on this atrocious plan to literally carve on our wild horses.

  2. Louie C

    July 19, 2019 at 12:46 am

    I wish I had said that…WOW

  3. ccdowner

    July 19, 2019 at 11:08 pm

    Truly outstanding refutation of Burns BLM Oregon extremely obstinate attempt to foist an extremely cruel and illegal “solution” by torturing and killing the Warm Springs wild mares who should be back in their half-million acre HMA instead of languishing in the Wild Horse Holding Corrals out of Hines Oregon. They are beautiful horses of amazing conformation and to treat them this way is an utter shame and disgrace not only to America but to all of Humanity!

    • grandmagregg

      July 19, 2019 at 11:17 pm


  4. Maggie Frazier

    July 20, 2019 at 12:26 am

    As always Marybeth has covered every possible side of this! Now the larger problem – getting our “representatives” to actually make an attempt to understand how easy it would be to solve our wild horse’s government problem! The BLM’s behavior – corruptedness (may not be an actual word) and the moronic insistence on doing the same thing over and over and pretending there will be a different result!
    I have read a couple times that the problem of wild fires would be solved by putting cattle out to graze these areas – but as Marybeth stated above – they eat the young sweet green veggies – the wild horses would take care of the actual fuel that is the problem.

  5. Lisa

    July 23, 2019 at 5:58 pm

    This agency has gone rogue long enough. Putting profit before ethics, corruption rampant, and derelict in their duty to protect these American icons. No accountability. It’s way past time for change. Greed, inhumanity and corruption have no place among these animals.

  6. l j mauceri

    January 16, 2022 at 6:55 pm

    i 100% agree leave the horses and the predators to balance nature defund the BLM and stop the experiments and sterilization programs now before its too late we need the horses to protect our environments

  7. Barbara Drake

    January 20, 2022 at 4:46 pm

    A masterful, highly researched paper/letter by Ms Devlin & by the notable, common sense facts stated, the BLM’s ridiculous & heinous actions to attempt herd reduction or complelete annihilation of wild horses, is beyond comprehension. Significant monies available should b alloted to enhance this magnificent creature not destroy it. It is CRIMINAL that proposed sterilization of wild mares is ONLY bolstered by the avarice of the Cattlemens Association, the dollar overrides nature’s plan & n the end man suffers.


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