Comments Needed by May 18th on the Ochoco Wild Horse Management Plan
The Ochoco National Forest has an area designated for wild horse use called the Big Summit Territory which extends over 25,434 acres in the vicinity of Walton Lake south of highway 26 and about 25 miles east of Prineville that includes Ponderosa pines, Douglas fir and Grand fir forest, open meadows, multiple springs and about 17 creeks and tributary streams. The wild horses started out as horses released by or escaped from ranchers in the surrounding areas of Post, Mitchell, and Prineville, as well as from the U.S. Amry’s Remount program and possible thoroughbred race horses that were released. They have since become wild herds that share the Territory with wildlife, including elk and deer, and seasonal (three and a half months in the summer) use by domestic sheep. Currently there are two bands of sheep totaling 2,200 animals completing with the wild horses (currently estimated at 135 horses) for forage and a recently increasing number of elk and deer.
The Wild Free-Roaming Horse and Burro Act of 1971 described wild free-roaming horses and burros as living symbols of the historic and pioneer spirit of the west, contributing to the diversity of life forms in the United States, and enriching the lives of people in the U.S.. The Act was brought about by citizen efforts to stop the inhumane capture and slaughter of wild hoses for pet food meat by various people in the west who would, for example, drive them off cliffs, lasso them with truck tires from trucks next to the running herds, choking them to a stop, and pack them, often injured and bleeding, on top of each other in the backs of big trucks from trips to the slaughter house. (The Forest Service does not mention this history in the Environmental Assessment.) The Wild Horse and Burro Act has criminal provisions to stop the harassing, killing, or removing wild horses or burros from public lands without authority. Since 1971, the Act has been amended to: in 1976, allow helicopters to be used int eh capture of wild horses and burros and motor vehicles to be used to transport them; in 1978, “to continue the policy of protecting wild free-roaming horses and burros from capture, branding, harassment, or death, while at the same time facilitating the removal and disposal [adoption, sale, or humane killing] of excess wild free-roaming horses and burrows which pose a threat to themselves and their habitat and to other rangeland values”; in 2005 to require the BLM and FS to sell (without limitation) excess animals more than 10 years old or which have been offered for adoption three times; and in 2020 (apparently in response to the BLM in Burns, Oregon adopting out wild horses to their own employees and family and friends for commercial slaughter) placed a limitation on funding appropriated from the act for both the BLM and the FS, making funding unavailable for the destruction of any healthy, unadopted wild horse and/or burro under their jurisdiction or the sale of a wild horse and/or burrow that results in the destruction of the animal for processing into a commercial product. From this you can see the general trend of agency and rancher dislike of wild horses (in particular) competing with cattle or sheep on private and public lands for forage. The Ochoco Forest Service has long considered wild horses an inconvenience at best and has tried to drive down the wild herd numbers in the Big Summit territory for many years.
What the Forest Service is not proposing for management of the wild herd of horses in the Ochoco Big Summit wild horse Territory:
Alternative 1 is the “No Action” alternative under which the current plan would not change and the “Appropriate Management Level” (AML, or the limit on wild horse numbers beyond which they are considered “excess” and can be rounded up or bait-trapped and transported to a holding corral for adoption, sale, or euthanization if they are deemed to be too old, sick, weak, injured, or diseased.) The AML would remain at population range of 55 to 65 wild horses (which means that the Forest Service would remove at least 70 wild horses from the territory). Alternative 2, the Forest Service’s proposed action, would incorporate measures to slow population growth (temporary fertility control through contraceptive drug injections, permanent sterilization, and/or gender ratio manipulation), increase genetic variability in the herd (through introducing wild mares from other source herds), and maintain an “appropriate management level” of only 12 to 57 wild horses. Alternative 3 is an additional alternative that was developed at the request of some members of the public to manage at an AML of 150 to 200 wild horses, based on at least that many animals being needed to ensure genetic variability over the long-term, based on the best available genetic science. Alternative 3 would include any method of fertility control chosen by the agency, as well as bait trap captures to remove “excess” wild horses but does not include introducing wild mares from other herds into the Big Summit territory (BST) herds to immediately increase genetic diversity, which is needed, since two studies have confirmed low existing genetic diversity in the Big Summit herds. We see this as a form of blackmail to force the choice of the Forest Service’s preferred alternative 2, which is the only alternative offered that includes this boost to the herds’ genetic diversity.
The Genetic Science:
A 2018 census in the Territory counted 135 wild horses, which is a little over double the high end of the current AML range established in the 1975 Management Plan and the 1989 Forest Plan. “The average population growth of this herd appears to be around 7-8% with high annual variation. Two recent studies of the wild horses in the BST indicated low genetic variability (Cochran 2011 and Mills 2010). Low genetic variability can lead to lowered resilience and increased expression of recessive traits. According to the National Academy of Sciences, ‘Theoretical and empirical studies have demonstrated substantial fitness costs associated with the loss of genetic diversity in both free-ranging and captive populations. … Isolation and small population size, in combination with the effects of genetic drift, may reduce genetic diversity to the point where herds suffer from the reduced fitness often associated with inbreeding. That would compromise the ability f herds to persist under changing environmental conditions’” (EA pg. 2).
From our point of view, the best available science contradicts Forest Service plans to reduce the wild herd size to only 12 to 57 animals, which is far too low to ensure genetic variability and individual horse health fitness and is contrary to the intent of the Wild Free-Roaming Horse and Burro Act to protect the wild horses and burros from extirpation and from removal of most of them from the wild.
Impacts to Riparian areas (creeks, streams, springs, fens, and wet meadows):
However, the situation is being presented by the Forest Service as that much culling of horses is needed to allow for riparian recovery from wild horse damage to riparian areas in the Territory. So we also need to consider the impacts to the riparian areas and associated wildlife such as Sensitive Columbia spotted frogs and Redband trout residing in the area, as well as a number of Sensitive riparian associated plants that have suitable habitat in the Territory. While the federal agencies tend to use wild horses as scapegoats from cattle or (in this case) sheep damage to riparian areas, the damage to some of the riparian areas in the Big Summit Territory is real and severe—based on a long history of legacy impacts from overgrazing by sheep and cattle, logging, and road construction, as well as ongoing sheep grazing by 2,200 sheep over three and a half months and ongoing and increasing wild horse use, as well as increasing numbers of deer and elk in the area.
The Environmental Assessment (EA) makes clear the long-term legacy impacts of logging, road-building, and livestock grazing: “Within the Territory, most of the streams exhibit poor entrenchment ratios which correlates with field observations of historic incision/down cutting of the stream channel in every stream and an overall disconnection from floodplains. Historic grazing, logging practices, and road building have contributed to the loss of high stream flow energy dissipating mechanisms such as large woody debris, access to floodplains at a variety of flows, stable stream pattern and high pool frequency… This lack of floodplain access is in part die to lack of large woody debris within the channel to help capture sediment and raise the base elevation of the channel….The majority of streams within the Territory fall well short of meeting management objectives of more than 96 pools per mile [for fish refugia] with no apparent trend in changing conditions” (EA pg. 113).
Our comment in response: All the past evident clearcutting to create even-age plantations no doubt contributed a great deal to the lack of large woody debris, channel entrenchment, low pool formation, loss of access to floodplains, and increased sedimentation of streams. Road-building and use contributed to excess fine sediment entering streams and to higher peak flows and blocked flood plains. Tens of thousands of cattle and sheep grazing contributed to loss of shrubs, forage, and riparian plants, as well as to increased erosion and sedimentation. All of this still apparent legacy degradation creating the existing condition of Territory streams is not just die to the wild horses and will not be restored to better functioning condition just by removal of wild horses.
Impacts to Redband trout and Columbia spotted frog:
Likewise, the EA identifies long-term legacy impacts to Redband trout and Colubia spotted frog and does not single out wild horse use as a primary factor: “over the past 50 years (Stuart et al. 2007), lower numbers of Redband trout have resulted from the cumulative effects of loss of riparian vegetation (particularly hardwood trees), bank erosion, increased sedimentation (which can suffocate incubating trout eggs), entrenched streams, loss of beaver and woody debris, and altered stream channels” (EA pg. 112).
Our comment: With all this acknowledged long-term degradation of stream and meadow systems and habitat for Redband trout and Columbia spotted frog, why is there no discussion in the EA of Forest Service riparian restoration efforts within the Big Summit wild horse Territory? It seems like the Forest Service is choosing this opportunity to use riparian damage from cumulative impacts of logging, road-building, and use, and sheep and past cattle grazing to blame wild horses from riparian damage and get rid of the wild horses as scapegoats.
Important information regarding sheep versus wild horse forage usage in the area:
A major rationale the Forest Service is using from greatly reducing the current wild horse numbers is that according to their calculations, there is a current deficit in the winter range of forage available versus the amount of forage consumed by sheep, wild horses, elk, and deer. Once study found a 21% dietary overlap in the summer between sheep and horses (Olsen and Hansen 1977) although sheep prefer forbs and horses prefer grasses (EA pg. 55). Dietary overlap is greater between elk and horses than between deer and horses (Hosten 2007, Salter and Hudson 1980). “Specifically, wild horse winter range utilization monitoring done in the fall of 2017 (sheep present) and 2018 (sheep not present) show a difference of at the most 13%, suggesting that sheep utilization in the winter range may be around 13%” (EA pg. 55). Our comment on this: Given the need for wild horses and elk and deer to use the winter range area for forage during winters, the permitted sheep should not be allowed to use the winter range area, as this could reduce forage at least by 13% and sheep to not need to be allowed to use the winter range area.
The EA also admits (pg. 55) that: “Utilization monitoring data in three sites in the winter range prior to 2010 when horse numbers were within the AML range [55-65], has consistently been bleow 30% utilization with one exception”. The Forest Plan allowable use level for forage in the witner range area, for providing for theneeds of all wildlife species needs, is 30%. This mean that wild horse numbers upt o at least 65 are compatible with total winter range forage use below the Forest Plan 30% utilization standard for average winter conditions. Thus there is no reason to drive wild horse numbers down to only a 12 to 57 wild horse AML range, as in the Forest Service’s preferred alterative, which would virtually guarantee eventual extirpation of the wild horse population in the Big Summit Territory. A dozen or more wild horses could easily perish in one severe winter or one extreme drought year.
Inadequate Range of Alternatives:
There is an inadequate range of alternatives in that none of the alternatives trikes a balance between maintaining a genetically diverse, viable, and healthy wild horse population and significantly improving highly degraded riparian conditions within a reasonable amount of time. Alternative 1 (No Action) has failed to accomplish either so far; Alternative 2 would sacrifice the genetic diversity and long-term viability of the wild horse population through very low population numbers; and Alternative 3 does not allow for increasing genetic diversity in the wild horse population through introduction of some wild mares from other herds and would further degrade, rather than improve riparian forage conditions to due the higher number of wild horses at 150-200 animals. None of the alternatives offered would implement needed active riparian restoration, including exclusion fencing (for sheep or horses) and riparian hardwood shrub and tree planting for the most damaged riparian segments, even though this is a reasonable and widely practiced approach for more rapidly improving riparian conditions, which is emphasized in the EA as part of the need for reducing the number of wild horses.
Our suggested Alternative:
We suggest an alternative with the minimum AML numbers of wild horse being 60 and the maximum 125, given that the wild horse population appears to stabilize on its own at about 115-125 wild horses, based on the Figure 26 chart on the EA (pg. 64), although we are open to higher numbers of wild horses once riparian conditions and forage availability improves significantly and/or if the sheep grazing is stopped or significantly reduced in the Big Summit Territory. Our proposed alternative also includes all of the following: allowing the use of bait trapping for removal of wild horses beyond the upper limit of the AML and the use of temporary horse contraceptives, but no helicopter use and no permanent sterilization; the introduction of wild mares from other wild horse populations to improve genetic variability of the Big Summit population; incorporation of active riparian restoration, including temporary exclusion fencing and native shrub planting in the most damaged riparian areas; prohibiting permitted sheep use of the winter range to reduce overall forage consumption; consideration of reducing sheep numbers permitted in the Big Summit Territory during the next allotment permit renewal process; and monitoring of any decision to euthanize captured wild horses by an outside group supportive of wild horses, such as the Central Oregon Wild Horse Coalition, to ensure that only wild horses not likely to survive on their own and currently suffering are euthanized, and are not euthanized just on the basis of old age or behavior.
Comments on the Ochoco Wild Horse Herd Management Plan and Forest Plan Amendment Environmental Assessment are needed by May 18th at the latest! See contact information below.
We ask that you consider the information above, as well as our responses,and to write your own comments on the Ochoco Wild Horse Herd Management Plan and Forest Plan Amendment Environmental Assessment. Following are a few more talking points to consider for your comments, and the contact information for sending in your comments:
You can submit comments online at: https://cara.ecosystem-management.org/Public/CommentInput?project=46228
Or mail comments to: Slater Turner, District Ranger, Lookout Mountain Ranger District, 3106 NE 3rd Street, Prineville, Oregon, 97754
Thank you for helping us show public concern about wild horse management plans. You can call Karen Coulter for more information by leaving a message at 541-385-9167. We welcome donations to support our work, which can be sent to: Blue Mountains Biodiversity Project, Eugene Office, 1560 Chambers St., Eugene, Oregon 97402.