Citizens Against Equine Slaughter and Two Other Organizations Submitted a Joint Public Comment Today With a Clear Message the Proposed Plan is Not for Management of a Healthy Wild Horse Herd, but Rather a Plan to Protect Livestock Interests in That Part of the Apache-Sitgreaves National Forest.
16 March 2020
Citizens Against Equine Slaughter, along with Wild Horse Observers Association and Wildlife Protection of New Mexico submitted a joint public comment with affidavits from the CAES’ Ground Crew Coordinator for the Apache-Sitgreaves National Forest, veterinarian Dr. Lester Firedlander and other members of both CAES and WHOA.
We suggested several revisions to the plan proposal, and also asked them to clarify the process and order of documents, and objections. We addressed issues that are legal and/or problematic. Those include things like arbitrary AML that was predetermined. A fake working group that did not meet legally, nor did it meet the legal obligation Forest Service has to work with plaintiffs or the public per the 2007 Stipulation Agreement.
Other issues we addressed were fencing problems, and water. We also, of course, mentioned the issue of the illegal shootings of not only wild horses, but also poaching of bear, elk, and even critically endangered Mexican gray wolves. We feel until the Forest Service has this under control they really cannot implement a management plan that makes sense.
Some of our biggest issues with this plan were addressed when we got involved back in 2005, through one of our board members work with one of the attorneys who sued the Forest Service when they were caught hiring local ranchers to remove and ship to slaughter, horses from the forest.
Since then we had another board member who was on the working group to develop this plan, and when they found out she was a board member of our organization was prompl=tly kicked off the working group.
The other members of the working group, some affiliated with other wild horse advocate organizations, voted to have the meetings held in private and to kick off our person. They refused to include any of our suggestions when sending in the recommendations to Forest Service. HOWEVER, Forest Service ignored their recommendations as well and did what we knew was coming…their predetermined cattle protection plan.
The Forest Service first outlined the land they now call the Heber Wild Horse Territory as a result of the 1971 Wild Free-Roaming Horses and Burros Act. That Act stated they needed to map out where horses were at that time. Forest Service feigns ignorance now of where horses were at that time. They instead published a story with interviews from horse haters who claim the horses were sterile from extreme cold weather at one point, then repopulated from the nearby reservation.
Forest Service doesn’t say if the original population count was from the artificial boundaries they now call the Territory, or if the count was the actual entire acreage that has and is now being used by the horses for decades. We assert the original population count was only of horses on that artificial boundary area, not a count of the entire herd.
For decades the horses have migrated between the reservation and the public land managed by Forest Service. What forest Service is attempting to do is omit a huge portion of land between the reservation and the boundary lines they drew on the map. This would make 2 different populations as if they are different herds. The courts ruled that since no DNA was ever done to prove the Heber population is different from the reservation horses, they are one and the same.
What we insist the Forest Service does is to include the area they left out, it is and was obviously land they horses were on at the time of the passage of the law. The other reason Forest Service would try to leave this land out is that it is where the majority of the horses live.
The artificial territory they outlined is completely fenced, and if a horse is already off the territory, which most are, they couldn’t easily get back on it if they wanted to. And they want to leave a few token horses in that boundary area and remove all the rest of the herd.
We want to know…If the Forest Service believes this land was not historically, and currently used by the horses to move from point A to point B how did they get back and forth? Teleportation??
Additionally, we know the count they presented is not true. They gave an estimated population of 500 horses. We know there are maybe 200-225 out there. We want to know how they arrived at this estimate because we are out there and documenting!
We also addressed issues of helicopters, even though it is not in the language of the body of the plan it is included in one of the attachments to the plan. We have also addressed issues surrounding surgical or chemical sterilization, given our opinions of various forms of immunocontraceptives and the use of radio-collaring.
We have provided plans, and charts for management that we know works and which we have assisted in implementing in other places across the west. We are offering to be a partner in this plan IF Forest Service really wants to do the job of managing for the wild horses, for them to be a healthy and viable herd. Now we wait and see if they are going to follow the typical status quo, and attempt to send this herd off to slaughter, or if they want to really work with advocates to do their jobs the right way. Right now all we know is they put out a plan that leans toward livestock first, game animals, like elk second, and the horses who should have principle use of their lands (according to the law) get the bottom of the barrel.
We sincerely expect this to become a court case we will be involved in again. If you want to help CAES stay in the fight for this herd until the end, or support our legal battles all over the west for wild horse herds please consider making a donation below or by mailing a check to:
PO Box 115
Drain, Oregon 87435