Citizens Against Equine Slaughter Files a Formal Ethics Complaint Against a Sitting Congressman

©CAES Jan.24, 2018
This document may not be copied or used without consent of CAES. For permission contact our office at 541.315.6650


24 January 2018; CAES filed a formal complaint with the US Office of Congressional Ethics (OCE). We have alleged that Representative Chris Stewart (R-UT) did in fact commit ethics violations, and US Criminal Code Title 18 violations. We have also implicated several other elected officials in our complaint.

Conspiracy to Defraud – 18 U.S. Code § 371 
If two or more persons conspire either to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose, and one or more of such persons do any act to effect the object of the conspiracy, each shall be fined under this title or imprisoned not more than five years, or both.”

 Code of Official Conduct – House Rule XXIII no. 1 – Damaging credibility of the House
A Member . . . of the House shall behave at all times in a manner that shall reflect credibility on the House.”

 Code of Ethics for Government Service No.1
“Any person in Government service should: 1. Put loyalty to the highest moral principles and to country above loyalty to Government persons, party, or department.”

Representative Stewart et al. are in government service and should put loyalty to the highest moral principles and to Country (80% of Americans and our American culture) above loyalty to the Secretary of the Interior, party, or department.

We have asked for several items of relief including that Representative Stewart et al. are sanctioned at a minimum and are no longer allowed to “lead” on this issue even behind the scenes, and that all votes following their false testimonies to Congress be stricken from the Congressional record.

Below read the entire complaint:

  1. Subject of Allegation U.S. Representatives Stewart, Amodei, Simpson, and Cole
  2. Date(s) the Alleged Conduct Occurred:
    The alleged conduct started on April 27, 2016 to current.
    Specifically, July 12, 2017 and July 18, 2017.
  3. Concise Statement of Facts: (As well as the source of the information, in the event that the person   submitting the information does not have first-hand knowledge of the facts.)*

Attachment 1

Dog and Pony Big Government Show – All Tools to Kill Our Wild Horses

Courtesy U.S. Representative Chris Stewart of Utah

By Patience O’Dowd, CAES 1/11/2017

Attachment 2

STEWART HEARING REBUTTAL Final                                                                       7/5/2016

Re: Entry into the Federal Lands Subcommittee record: Cost Analysis/Data for the Subcommittee on Federal Lands on Wild Horse and Burro Hearing of 6/22/16.

Attachment 3

Lake Research Partners Poll – 80% of Americans disapprove of Horse Slaughter, 67% Strongly Disapprove.

Actual Poll Enclosed Attachment 2

Attachment 4

BLM Statement: “BLM uses latest science” . . .                       


“BLM uses the latest science in its efforts to ensure that viable populations of wild horses and burros can thrive on healthy public rangelands. For example, the BLM uses science to monitor rangeland vegetation, soils, water, wildlife habitat, and the effects of wildfire, and the BLM relies on sound science and monitoring data to determine appropriate management levels for wild horse and burro herds. 

As part of its efforts to manage the population growth of wild horses on public rangelands, the BLM has supported the development of an effective contraceptive agent for wild horses since 1978. Over the years, attempts at different approaches — such as hormone implants, chemical vasectomies, and intrauterine devices — were tried, but abandoned as ineffective or impractical at that time.”

Attachment 5

Affidavit Example from CAES President Dr. Lester Friedlander former USDA Veterinarian
This is an example of Affidavits to come from Dr. Lester Friedlander.

Attachment 6

Overview of the Management of Wild Horses and Burros

A report presented to the National Academy of Sciences Committee to Review the Management of Wild Horses and Burros, Prepared by: Animal Welfare Institute October 2012

Attachment (additional) 7

Restoration of Riparian Areas Following the Removal of Cattle in the Northwestern Great Basin
Bachelor, J. L., Ripple, W. J., Wilson, T. M., & Painter, L. E. (2015). Restoration of
Riparian Areas Following the Removal of Cattle in the Northwestern Great Basin.
Environmental Management, 55(4), 930-942. doi:10.1007/s00267-014-0436-2


Citizens Against Equine Slaughter contends that Representative Stewart et al. (Representatives Amodei, Simpson and Cole) are in conspiracy as well as Congress, against the people of the United states in an attempt to defraud them of their (property) their natural resource (federally wild horses).


  1. Wild Horses have been managed under the Department of Interior’s Bureau of Land Management and the United States Department of Agriculture’s Forest Service since Dec 18, 1971 under Public Law 92–195. This was enacted due to overwhelming public pressure to protect wild horses from animal cruelty as well as preserve them for future generations.
  2. An independent poll by Lake Research Partners in 2012 showed that 80% of Americans strongly oppose horse slaughter. This poll was administered with similar results in New Mexico, Missouri and Oklahoma. The National Poll is widely and openly discussed during the committee meetings in question. The stated results of this poll are not under debate and it is taken as fact during Congressional discussions in committee.
  3. On 2013 The National Academy of Sciences published their consensus review entitled Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward(2013)
    Consensus Study Report On the basis of the information provided to the committee, the statistics on the national population size cannot be considered scientifically rigorous.FINDING: Management practices are facilitating high horse population growth rates.

    FINDING: The most promising fertility-control methods for application to free ranging horses or burros are porcine zona pellucida (PZP) vaccines, GonaCon™ vaccine, and chemical vasectomy.

    FINDING: Predation will not typically control population growth rates of free ranging horses.

    “A large predator, when abundant, can influence the dynamics of free-ranging ungulates. However, the potential for predators to affect free-ranging horse populations is limited by the absence of abundance of such predators as mountain lions and wolves on HMAs


  4. BLM Statement Regarding Science:“BLM uses the latest science in its efforts to ensure that viable populations of wild horses and burros can thrive on healthy public rangelands. For example, the BLM uses science to monitor rangeland vegetation, soils, water, wildlife habitat, and the effects of wildfire, and the BLM relies on sound science and monitoring data to determine appropriate management levels for wild horse and burro herds.“As part of its efforts to manage the population growth of wild horses on public rangelands, the BLM has supported the development of an effective contraceptive agent for wild horses since 1978. Over the years, attempts at different approaches — such as hormone implants, chemical vasectomies, and intrauterine devices — were tried, but abandoned as ineffective or impractical at that time.”There is no stated reason and in fact there is no factual reason why humane and feasible ‘On Range Management’ with contraception cannot be used.


  5. The BLM has only utilized PZP (Native PZP and PZP 22) on less than 1% of the wild horses. PZP 22 is less effective than PZP which is known to the BLM. PZP 22 should be used with a booster.
  6. Legally wild horses are not livestock. 29 CFR 780.328 – Meaning of livestock. The term “livestock” includes cattle, sheep, horses, goats, and other domestic animals ordinarily raised or used on the farm. This is further discussed in 780.120.780.120 Raising of “livestock.” “The meaning of the term “livestock” as used in section 3(f) is confined to the ordinary use of the word and includes only domestic animals ordinarily raised or used on farms.”
  7. Wild, undomesticated horses are not estray because they are not livestock – Wild Horse Observers Association (WHOA) v NMLBTherefore: Wild horses are protected by the federal, state and local animal protection laws of the states once captured.Wild Horse Observers Association, Inc., Plaintiff–Appellant, v. New Mexico Livestock Board, Defendant–Appellee, and Susan Blumenthal, Ash Collins, Susan Collins, Jon Couch, Peter Hurley, Judith Hurley, Zane Dohner, Carolyn E. Kennedy, Lynn Montgomery, Joe Neas, Mike Neas, and Pamela Neas, Defendants by Intervention–Appellees.
    • Alternate Citation:  2015 WL 4712152 (N.M. Ct. App., 2015)
    • Attorneys:  Steven K. Sanders, Steven K. Sanders & Associates, LLC, Albuquerque, NM, for Appellant. Andrea Buzzard, Karen Budd–Falen, Budd–Falen Law Offices, LLC, Cheyenne, WY, for Appellee. David G. Reynolds, Corrales, NM, for Intervenors.
    • Docket Num:  No. 34,097

    As published

  8. Native PZP has been used successfully for over 25 years under the Department of Interior’s National Parks at Assateague National Park with On Range Management. A 48,000-acre remote island. No adoptions or roundups.
  9. Animals have been successfully darted in the African continent for decades. Two PZP scientists have both stated that PZP is easy to dart from helicopter. One has stated it is much more humane than helicopter roundups as it is very quick.
  10. Representative Stewart, Amodei, and Simpson specifically led Congress, along with the BLM to ignore Science, ignore animal humane laws: The Burns Oregon BLM planned an illegal surgical sterilization, ovariectomy experiment which even classifies as vivisection experiments:Mare Sterilization Research Environmental Assessment DOI-BLM-OR-B000-2015-0055-EA
    Decision of Record:
    Final Environmental Assessment:
    Finding of No Significant Impact: Academy of Sciences “The possibility that ovariectomy may be followed by prolonged bleeding or peritoneal infection makes it inadvisable for field application.”
  11. The Burns Oregon plan for Ovariectomy sterilization experiments was stopped by Citizens Against Equine Slaughter (CAES) Administrative Appeal once the BLM understood that the IBLA was not going to dismiss the CAES Appeal based on standing. The BLM had designed their sterilization experiment in a way that would potentially make it next to impossible to gain standing in court.The public did not know where the horses came from, and that more were coming or where more would be coming from. Also, people had not been going to the remote location holding pen at Burns Oregon to view and aesthetically enjoy the wild Horses in a corral awaiting their fate, in general.However, CAES both retained conversations with the Burns BLM staff which disclosed information that was not in the information available to the public, regarding where further wild horses would be culled from, and, CAES Board member Ms. Cecama-Hogsett as a disabled citizen had visited the remote Burns Oregon horses in their holding pens.
    (Ms. Hogsett states that citizens with disabilities are often unjustly barred from their due process rights to gain standing due to inabilities to go out into the field.)The BLM motioned the IBLA to dismiss all three Administrative Appeals on standing, however the IBLA could not, and did not, dismiss the CAES et al. appeal.  Hence after multiple rounds of briefing, regarding the CAES Administrative Appeal and Motion for Stay, the IBLA did not dismiss CAES on standing, the BLM then withdrew their sterilization plans, (Vacate and Remand). This in turn ended the other two court cases FRER and FOA filed against this experiment as determined by a PACER review. There were no other court cases opposing this experiment that could be located on PACER.

    IBLA 2016-243 Citizens Against Equine Slaughter et al.
    Wild Horses and Burros
    Motion to Vacate and Remand Granted.
    Excerpt – footnote 2 from Defendants Motion to Vacate pg. 2 excerpt pg. 2 footnote 2.

    “2 Two other appeals (with accompanying petitions for stay) challenging the DR were filed with the Board: Janet Lynch, IBLA No. 2016-238 and Susan Carter, IBLA No. 2016-242. BLM filed motions to dismiss both those appeals for lack of standing and the Board granted those motions and dismissed both appeals in separate orders on September 7, 2016. Thus, this appeal is the only pending appeal of the DR before the Board.

    Janet Lynch
    Sue Carter

    Citizens Against Equine Slaughter (CAES)  excerpt pg. 2 paragraph 1

    “On September 9th, 2016 Before the Board could rule on either the appellant’s stay petition or BLM’s motion to dismiss, counsel for BLM filed a Motion to Vacate and Remand.

    September 9th
    Before the Board could rule on either the appellant’s stay petition or BLM’s motion to dismiss, counsel for BLM filed a Motion to Vacate and Remand.

    The Motion to Vacate and Remand was then communicated to the two other court cases filed and which had not yet established standing as there had been no rounds of briefing yet but had been filed well before the BLM vacated.  These two court cases ended on 9/12/16, one was Front Range Equine Rescue and the other was Friends of Animals.

    There was reportedly a third court case, filed by a BLM Advisory Board member in collaboration with another wild horse advocacy group, to watch the experiments, but not to stop them. There was a filed and stamped case no. reported for this case, however, for some reason, this case and its case number could not be found in the Pacer system. This Advisory Board member (and those organizations party to the case) also reported that this third court case to watch the experiments had actually stopped the sterilization experiments, as did the other two organizations who had filed lawsuit.

  12. The IBLA decision in the Citizens Against Equine Slaughter Administrative Appeal IBLA 2016-243 ruling is not listed on the chronological listing of IBLA decisions and neither is that of Janet Lynch.
  13. Representative Stewart confirmed his leadership or claimed his leadership role on April 27, 2016 where he stated to the House of Representatives, “wild horses are taking over the ranges”, “I grew up ranching” and “Help me solve this problem” while discussing alleged BLM planned cattle removals from BLM lands.Rep. Stewart Urges for More Local Control of Wild Horses in  speech on the House Floor on April 27, 2016.  00:00:20, 0:00:25, 00:1:05
  14. Representative Stewart has utilized one picture of a thin mare and her foal in the Cold Creek herd, the only incident in 46 years since the 1971 Act was passed. He has used this picture as an aide to help him convince Congress that we will have “tens of thousands of animals that look like this out on the range.” Which he stated on May 25, 2016 @ 00:01:08
  15. Representative Stewart brought the Stewart Amendment to the House on May 25, 2016This Amendment allows for the BLM to transfer any wild horses to any requesting federal state or local government requesting a work animal. The provision prohibits these horses from ever being slaughtered. However, this is not legally enforceable because upon “transfer” the horses would lose all Federal Protection status and would then become property of the transfer recipient.This is another major change in policy which, past issues with the BLM have shown, increases likelihood of selling large numbers of wild horses to the same buyer where those horses ended up at slaughter or at auction to known slaughter buyers.  @00:01:07
  16. Representative Stewart again utilized this one picture of a thin mare and her foal of Cold Creek of the only incident in 46 years since the 1971 Act was passed, a second year in a row on July 18, 2017 in the Interior Appropriations Committee meeting, to convince Congress that:
    these horses are starving, they’re destroying the range, they’re crowding out the deer and the elk because we cannot manage them”Representative Stewart does not mention in committee any investigation into any mismanagement or root cause investigation of this one incident at Cold Creek. However, Representative Stewart states that:
    “these horses are starving, they’re destroying the range, they’re crowding out the deer and the elk because we cannot manage them” and that “I desperately want to protect them” though Representative Stewart is actually working to provide to the Secretary of the Interior, all the tools to kill these wild horses, both by slaughter for human consumption, and mass euthanasia.   @ 02:50:46 andRepresentative Stewart is serving the Secretary of the Interior’s stated desires in this, however not the overwhelming majority of the people in this country.
  17. Representative Stewart along with Representative Hatch work to protect ranchers. BLM is neither capable nor equipped to manage wild horse populations, and federal stewardship has allowed their numbers to reach unsustainable levels,”
    Sen. Hatch said. “Deferring management authority to states and tribes is a commonsense solution that will mitigate the devastating ecological consequences horse overpopulation is causing to public lands in the West. Ranchers shouldn’t have to pay such a steep price for the federal government’s inability to manage wild horse populations successfully.”There is no mention of the taxpayer support of ranchers and no mention of the number of non-native cattle on these same public lands.
  18. Representative Stewart et al. has worked legislatively to have wild horses managed by unlimited sale on May 25, 2016, by slaughter for human consumption on July 12, 2017, and by killing them en-masse on July 18, 2017.He started out with H.R.5058 – Wild Horse Oversight Act   July 10, 2014
    A BILL: To amend the Wild Free-Roaming Horses and Burros Act to provide for state and tribal management and protection of wild free-roaming horses and burros, and for other purposes.
  19. Representative Stewart does not mention in committee any investigation into any mismanagement or root cause of this one incident at Cold Creek, however on July 18, 2017 Stewart states that:“these horses are starving, they’re destroying the range, they’re crowding out the deer and elk because we cannot manage them” @02:50:46 in hearing or 3:05 on this link.In contrast, on April 27, 2016 to the House, he had stated that “I desperately want to protect them.” However, Representative Stewart is actually working consistently to kill these wild horses, using both slaughter and euthanasia as shown by his amendments and his votes.
  20. Representative Stewart has specifically stated in the Interior Appropriations committee on July 18, 2017, “All we are asking is to give the Department of Interior, what the Secretary has asked, in fact what he has begged for, the tools to manage.”Full Committee Markup FY 2018 Interior Appropriations Bill
    July 18, 2017 @ 2:50:55 committee or 3:14 on this short.Also see quotes of Representative Stewart et al. in Attachment 1 regarding Horse slaughter.The tools Mr. Stewart is working toward are ALL the tools to kill for the Secretary of the Interior, rather than the people and the resource for the country.
  21. If Horse slaughter is started up in the United States and there is no “rider” disallowing monies being spent to kill wild horses, wild horses may be sent to slaughter.
  22. Representative Stewart et al. have not discussed or asked for any investigation during committee, into food safety issues regarding horse meat, though there is a Food Safety Act H.R. 113 – Safeguard American Food Exports Act of 2017, and which 208 House Representatives are currently co-sponsoring.
  23. MISLEADING with intent/conspiracy*/cover-up/collusion/credibility for the House, out the window  – Representative Stewart brought an amendment to the House Interior Appropriations Committee on July 18, 2017 that would allow healthy federally wild horses under the 1971 Act to be euthanized. Representative Stewart defended this amendment with non-specific rhetoric, not with factual information, including much misinformation regarding the BLM’s brutal planned illegal surgical sterilization experiment on 200 conscious mares, with 75 of them being pregnant and all of them in filthy field conditions intentionally.

    PZP/contraception studied at Burns Oregon.

    This amendment passed, in part at least due to their false testimony. Representative Stewart was in a position to know this was false testimony, heard this false testimony previously on July 12, 2017, and called on Representative Amodei to give this false testimony again in July 18, 2017.

    *“Conspiracies are typically proved by circumstantial evidence. “Since such participation, cooperation or unity of action is difficult to prove by direct evidence, it can be inferred from the nature of the act done, the relation of the parties, the interests of the alleged conspirators, and other circumstances.”(Rickley, supra, 212 Cal.App.4th at p. 1166, internal citation omitted.)

    *“Furthermore, the requisite concurrence and knowledge “may be inferred from the nature of the acts done, the relation of the parties, the interests of the alleged conspirators, and other circumstances. Tacit consent as well as express approval will suffice to hold a person liable as a co conspirator.” (Wyatt, supra, 24 Cal. 3d at p. 785, internal citations omitted.

    Full Committee Markup FY:18 Interior Appropriations Bill
    02:55:48 Stewart Misleading

    “We have been trying to use contraceptives as an answer for 30 yrs. and it simply is impractical.”
    “The repeated inoculations, it just simply hasn’t worked.”
    “I would like to yield 30 seconds to Mr. Amodei, he has more insight on this.”  

    Representative Amodei Misleading
    “BLM has been trying to do a pilot program in Burns Oregon and were sued by an outside group, I don’t know the name, so I’m not pickin on anybody. Just stop it, and so, obviously that is something that needs to be explored, because quite frankly, I don’t think anybody in this room disagrees that the status quo isn’t working. Birth control is something that should be taken a look at and used if appropriate but when you get, outside groups suing a pilot program to see how that works, it’s a problem, so I think there’s room here for leadership in terms of going, we need to weigh in cause quite frankly we’re where we’re at where people were here before us, quite frankly, have kicked it down the road with a can sitting at our feet.” 

    Representative Simpson Misleading
    “PZP beautiful, just hasn’t been working, BLM’s been trying it. That’s why they tried to pilot program in Burns, that’s why they were sued. We can’t seem to move off this but the reality is you think your being kind to horses, you’re not, letting them starve out on the range. Ms. McCullough has gone out and seen em. Some of you that talk about this need to actually go see what’s happening instead of just talkin. It is a problem and we are spending in this bill 80 million dollars. The former BLM director came to me one day a couple years ago and had an idea. You . . .” “Nobody’s adopting these things”. Then Representative Simpson essentially made a very inappropriate joke about a “silver bullet

    These were not “PZP”, “contraceptives” or “birth control” experiments.
    Mare Sterilization Research Environmental Assessment DOI-BLM-O R -B 000-2015-0055-EA, Bureau of Land Management Burns District DECISION RECORD Mare Sterilization Research Environmental Assessment DOI-BLM-OR-B000-2015-0055-EA

  24. Representative Stewart et al. has neither mentioned the National Academy of Sciences Report (NAS) Report in committee hearings where they are lobbying for unlimited sale authority, slaughter, and mass euthanasia of federally wild horses, nor have they called for any investigation as to why: the Department of Interior was not using contraception, why the USDA Wildlife services is spending more annually on the killing of natural predators of the horse than on the entire National Wild Horse and Burro budget or why specifically called on Representative Amodei to cover up a heinous illegal act planned by the BLM on July 18, 2017 in support of his amendment to mass euthanize the federally wild horses.Current Off Range, Fiscally Irresponsible, and Illegal Miss-Management:
    Representative Stewart et al. have also covered up the BLM’s willful lack of management against their statutory duties, while the livestock industry is enriched, in turn gathering, removing and housing these wild horses, inhumanely living in large holding pens, on private property, (at 7 to 8 dollars/day according to Representative Cole) in unnatural familial conditions, unnatural physical conditions, after brutal stampede round-ups akin to putting a baby on a highway and telling it to not get hit and to keep up, while causing animal fighting due to natural hierarchies and extreme chaos, fright, constituting extreme animal cruelty under color of law. Even in these holding pens, the BLM has admitted to a %5 death rate just due to normal handling. Young sick old and pregnant are run in stampede conditions for miles while stallions die trying to free them once in the mass collection chutes. Stallions escape and come back to try and free their families. There are no cameras on these helicopters which swoop cruelly close, sometimes touching them to move/herd these horses by stampede for miles across rough terrain. Much of these stampede runs for miles are not in the viewing area of the public. This is all, unnecessary and does constitute extreme animal cruelty according to the patchwork of animal welfare laws, federal, state, and locally and as according to Dr. Lester Friedlander BA DVM. Again, wild horses are not livestock and are subject to these animal welfare laws which the BLM/USDA Forest Service and Congress have illegally ignored, along with the will of the people, with intent to wipe out this resource belonging to the people.Mares have given birth on the run and babies left behind. Babies have worn their feet off. Wild horses do not normally stampede. Out of view, horses go down, and once corralled, mares give birth to babies that then die. In nature, stallions spend most of their time and energy keeping their family away from other stallions, not pushing them onto a highway at breakneck speeds across rough terrain with young, old and sick underfoot, mixing up and losing their family members. BLM workers say wild horses choose new families all the time, forgetting that routine round ups are the major cause of that.  Wild Horses conserve their energies in case of a predator attack, they do not normally run in this type of group stampede. This is all unconscionable. This is shown by the USGS Ethology referenced in Attachment 1.These are the kind of behaviors that the 1971 Act was passed to stop, but due to special interest pull, ignoring the FACT that these wild horses are not Livestock and are protected by ALL the animal welfare laws, and misuse of appropriations legislation which the House is responsible for, we are now moving from these current abuses to outright killing of these wild horses against statutes and against the will of the people and our constitutional rights to property, thanks to Representative Stewart of Utah et al. Documentation available upon request.

    One woman, Ms. Leigh of Wild Horse Education has spent much of her adult life on the range documenting and fighting these horrendous roundup practices, gaining standing and working to decrease these abuses.

    Many Wild Horse photographers have documented these beautiful and inspirational families of wild horses.

    This writer’s New Mexico non-profit, Wild Horse Observers Association (WHOA), stopped helicopter roundups in NM being done by the USDA Forest Service in 2004, and worked to stop the BLM from re-implementing this from an adjacent BLM property, however reasonably understands that helicopters and other set-ups can be and are used by veterinarians and others for humane and feasible darting, in a humane manner. (Documentation available.)

    Representative Stewart’s own Governor Gary Herbert of Utah has admitted on camera in 2017, to this writer, that helicopters could instead be used (briefly and humanely), for humane darting of contraception. This would take seconds per horse, a very short run, and can be accomplished at 50 meters rather away than swooping down on them in roundup fashion. Documentation available upon request.

    On July 5, 2016 we also sent this information (see Attachment 2) in detail previously to:  Re: Entry into the Federal Lands Subcommittee record: Cost Analysis/Data for the Subcommittee on Federal Lands on Wild Horse and Burro Hearing of June 22, 2016.


  25. Cattle are non-native ruminants.  See data and references in Attachment 1 regarding numbers of Cattle relative to native deer, elk, and native wild horses.

  26. Horses are not ruminants and are indeed native to Northern American and evolved here and only here in North America for over 55 million years, current form about 2 million years old, gone from North America only 7 to 13 thousand years in which time, the grasses did not evolve in any way significantly.  See WILD HORSES AS NATIVE NORTH AMERICAN WILDLIFE: Horses: An Excellent Defense for a Returned Native Species – Ross MacPhee (Curator, Dept Mammalogy, Division of Vertebrate Zoology) – 2012 McPhee – (Excerpt)“It is worth noting that dozens of other species in addition to native horses died out at the close of the Pleistocene, in an episode termed the megafauna extinctions. The only major difference is that, long before 10,000 bp, E. caballus had established itself on other continents (South America as well as Eurasia) by crossing land bridges. There they survived. Reintroduction to North America 500 years ago is, biologically, a non-event: horses were merely returned to part of their former native range, where they have since prospered because ecologically they never left.Whether these considerations should play a role in policy decisions I leave to others. At the same time, it needs to be more widely understood that the horse’s status as a native North American species is beyond serious question, whatever side of the debate over wild horse control one leans toward.

    Ross MacPhee, PhD
    Division of Vertebrate Zoology
    American Museum of Natural History
    New York NY 10024


  27. Wild Horses are not self-limiting as are kangaroos. Wild horses evolved with natural predators in North America.  They unlike ruminants, (bovine/cattle) have upper front teeth and mow rather than pull flora out of the ground. Their digestive system unlike bovine, do not usually kill seeds, but instead spread seeds and cause quicker germination.
  28. Representative Stewart knew what Amodei would say when he called on him see number 24 in the Interior Appropriations meeting because he heard him cover up the Burns Oregon sterilization experiment during the Agricultural Committee meeting on July 12, 2017.
  29. Representative Stewart has specifically called on Representative Amodei to cover up this heinous illegal act planned by the BLM and to also cover up how it was stopped in support of his amendment to mass euthanize the federally wild horses. Again, @ 2:56:09 July 18, 2017
  30. Representative Stewart has specifically called on Representative Amodei to disparage the scientific solution as determined by the National Academy of Sciences when he both supported and covered up the BLM’s heinous plans to illegally vivisect 200 wild mares with 75 of them pregnant in a filthy environment act planned by the BLM and said it was a birth control experiment. @ 02:56:23 July 18, 2017
  31. Representative Stewart has specifically called on Representative Amodei to also claim that an NGO or “outside group” had halted the BLM at Burns Oregon from performing a birth control experiment essentially making the false case that the BLM now had no solutions available outside of KILLING.
  32. Representative Stewart has specifically called on Representative Amodei to also claim that an NGO had halted the BLM at Burns Oregon from performing a birth control experiment essentially making the case that the BLM could not use contraception without further experimentation when in fact, PZP has been in use successfully under the DOI’s National Park Service at Assateague National Park for approximately 30 yrs. (this number referenced by Stewart) with no adoptions and no roundups necessary. This is a 4800 acre area which is remote and well documented. There are other herds, McCullough Peak, Pryor Mountain as well as horses along the east coast, the Corolla herd, Shackleford Banks and more as well as other species.
  33. Representative Stewart knew or should have known what Representative Amodei would testify as he was in the room when Representative Amodei stated this same false statement on July 12, 2017.
  34. Representative Stewart then specifically mislead our entire nation in his Christmas Day Op-Ed to the NY Times entitled, The Hard Truths About the West’s Wild Horse Problem. December 25, 2017. While he had this article published as “Chris Stewart” rather than Representative Chris Stewart, we believe he used his position as a Representative to gain access to the NY Times, and then specifically mislead the Nation as follows:Chris Stewart told the nation falsely that contraception could not possibly work because: 1. You could not use birth control on a pregnant mare and 2. That wild mares are always pregnant. Hence, basically you cannot even use it on wild horses.Mr. Stewart falsely prepared the Nation for the FALSE NEED to STEAL and KILL their wild horses that unify them, inspire them, are a natural resource belonging to them, the people of this Nation. This all to show favor to the two special interests involved in kill industries.
  35. Ms. O’Dowd publicly informed the NY Times of this falsehood on December 27, 2017 and the Times posted an online correction on December 29, 2017. However, the damage was done.
  36. Representative Stewart quietly voted FOR horse slaughter on July 12, 2017 in the Agricultural Committee. However just 6 days later…… in the Interior Appropriations Committee Stewart lobbied then for a second TOOL to KILL the Nation’s horses, mass euthanasia. Here he manipulated, contrary to his own recent pro-horse slaughter for human consumption vote, that:“I do not see horses as Food Animals”, “I see horses as companion animals”, and “I would never eat horse meat”. He even went so far as to say he’s eaten a bunny’s eyeball, fungus, and slugs, but not horse meat.This was his manipulation to gain a second tool for the Secretary of the Interior versus the people, to kill our nation’s wild horses. This committee did pass the Representative’s amendment by voice vote.
  37. Stewart et al. have ignored the BLM’s years of mismanagement and the BLM’s ignoring the recommendations of the NAS study for years, and then later convened at tax payer expense two more panels of experts, the United States Geological Survey (USGS Panel) and the National Research Council Panel (NRC Panel), (from Case 1:16-cv-01570-CKK). Hence, the BLM continued to mismanage for years and to search and spend tax payer dollars, in order to facilitate the evasion of the rule of law, under color of law and perform illegal and inhumane experimentation under the guise of further experts, albeit not in agreement per Case 1:16-cv-01570-CKK.
  38. CKK. Excerpt from Attachment 1-  Representative Cole joins in the manipulation of the House of representatives, falsely, for a complete package to convince the House that these wild horses cannot be managedRepresentative Cole of Oklahoma, who though recognized by Time Magazine as “one of the sharpest minds in the House,” and a registered member of the Chickasaw Nation, astoundingly and sadly ignored his heritage as well as science when he testified that: horses “are not indigenous to this continent”, they have “no natural predators when it’s out there on the plain”, and “It’s the biggest fastest thing out there out there on the plain” (sic). Cole’s testimony was a gross misrepresentation of the simplest of wildlife facts, in order to support horse slaughter of wild horses. Contrary to his erroneous testimony to the House Appropriations committee on July 12, 2017, horses are in fact outrun by all their existing natural predators: mountain lions, bears, wolves and coyotes. And some bears are a larger “thing” than a horse.Natural Predators Outrun the Horse
    Mt Lion-50 mph   Coyote-43 mph   Brown Bear-40 mph   Wolf-37 mph   Black Bear-35 mph

    These natural predators of the horses are also being wiped out by our special interest government, at $100 million/year by the USDA. This is more than the DOI spends on the nation’s Wild Horse and Burro program, at only $79 Million/year Cole’s pro-slaughter vote went directly against the majority of his constituents, of whom 60% are opposed to horse slaughter (Lake Research Poll) as are all Americans at 80%. To his credit, Representative Cole does self-identify as a rancher advocate, on his web pages.

  39. Cattle far outnumber wild horses on public lands by any count, any year, by orders of magnitude. See Attachments.From the House Ethics Manual:General Ethical Standards
    Government is a trust, and the officers of the government are trustees; and both the trust and the trustees are created for the benefit of the people.“That ―”public office is a public trust” has long been a guiding principle of government. To uphold this trust, Congress has bound itself to abide by certain standards of conduct, expressed in the Code of Official Conduct (House Rule 23) and the Code of Ethics for Government Service. These codes provide that Members, officers, and employees are to conduct themselves in a manner that will reflect creditably on the House, work earnestly and thoughtfully for their salary, and that they may not seek to profit by virtue of their public office, allow themselves to be improperly influenced, or discriminate unfairly by the dispensing of special favors. “
     -Henry Clay, Speech at Ashland, Kentucky, March 1829.

These acts, and plans are both unethical and illegal.


  • These three plans/options being promoted by Stewart et al. as well as the cover ups constitute:
  • Unequal Protection under the law and retaliation: The People versus special interests. Moreover, special interests that the people are paying billions of dollars/year to in subsidies already, which then can be used against us.
  • Conspiracy to Defraud – 18 U.S. Code § 371
    If two or more persons conspire either to commit any offense against the United States, or to defraud the United States, or any agency thereof in any manner or for any purpose, and one or more of such persons do any act to effect the object of the conspiracy, each shall be fined under this title or imprisoned not more than five years, or both.”
  • Code of Official Conduct – House Rule XXIII no. 1 – Damaging credibility of the HouseA Member . . . of the House shall behave at all times in a manner that shall reflect credibility on the House.”
  • Code of Ethics for Government Service No.1
    “Any person in Government service should: 1. Put loyalty to the highest moral principles and to country above loyalty to Government persons, party, or department.”Representative Stewart et al. are in government service and should put loyalty to the highest moral principles and to Country (80% of Americans and our American culture) above loyalty to the Secretary of the Interior, party, or department.
  • Code of Ethics for Government Service No.2
    “Any person in Government service should: 2. Uphold the Constitution, laws, and legal regulations of the United States and of all governments therein and never be a party to their evasion.
  • Extreme Animal Cruelty: Horse slaughter, mass euthanasia and unlimited sale authority also constitute extreme animal cruelty, per former USDA veterinarian Dr. Lester Friedlander BA, DVM, with no follow-up ability to ensure safety and responsibility.
  • Unethical and Illegal: These state and local laws are a patchwork and essentially overturns the Burns Act of 2004 passed in the eleventh hour as a rider on an appropriations bill; as well as disallow any current action to slaughter or mass euthanize federally wild horses.These types of policy and public law changes of these magnitude and gravity are a misuse and abuse or underhanded manipulation of: CFR 40 1508.18
  • Not Livestock: Our Nation’s wild horses are subject to state and local animal welfare laws of the states they are in, as well as those of the federal government unlike livestock. Moreover, they are not raised as food animals and are at risk of having others horses in their midst from other areas.
  • Slaughter Poses Environmental Risks including: Horses rejected for slaughter or that have travelled far en-masse to get to slaughter, may pose a health issue to other area livestock.
  • State Law Patchwork: Our state and local animal welfare laws constitute a patchwork of laws making these plans unconstitutional as well as statutorily illegal. Moreover, some wild horses are rounded up in some states and subject to those states laws, and then transported to other states and subject to those laws.
  • Property Rights, Federal and State: It is unconstitutional to take our property, our resources: by voluntary and/or intentional mismanagement, causing a problem, then stealing the resource that is supposed to be protected and preserved. This is tantamount to racketeering by our own government. The amount of disrespect to the people, their resource, government by representation, and their constitution is unfathomable.
  • Regulatory Taking: While these wild horses are not private property, this is a taking nonetheless and we the people take this personally as we know many of these individual horses personally.
  • Arbitrary and Capricious: There has been no scientific study, no associated fiscal study calling for these actions, only speculative, one-sided, and incomplete, fiscal information.
  • Food Safety: These actions are against international food safety, animal welfare, the constitution, our laws, the statutes, our American Culture, and the will of the people.
  • Violation of the Administrative Procedures Act: 5 USC 702
  • Violation of the Wild Free Roaming Horses and Burros Act. Many violations of this Act.
  • Violation of the Antiquities Act. Inaccurate census and insufficient genetic viability studies, human culture affects, aesthetic effects, etc.
  • Violation of National Environmental Policy Act. Insufficient due process, options, alternatives, basis, studies, cause, public input, etc.
  • Lack of Due Process: The government abuses the appropriations process to hold the people hostage and change policies and laws without reasonable due process in complete opposition to the 80% of Americans opposed to horse slaughter as well as in opposition to mass euthanasia and unlimited sale authority, all the comments and petition signatures received.
  • Insufficient Cause/Basis Given: 40 CFR 1508.17 Legislation: There has been no request by Stewart et al. for a legislative impact statement to the BLM or to the Department of Interior. There has been no Environmental Impact Statement on genetic viability, behavioral affects, human effect, cultural effect, animal welfare, feasibility, environmental, etc.
  • Unequal Protection: While the livestock industry is compensated for a bad year, the taxpayer and the wild horse advocates are hit twice, in their taxes, and then in their time, donations and personal concern over this resource and its individuals which we/they photograph, study and aesthetically enjoy.
  • Lack of Leadership: There has been no significant interagency sharing visible between the National Park Service that utilizes wild horses for tourism as well as utilizes Native PZP/Contraception to manage population, and the BLM which are both under the DOI, as well as no sharing between the National Park Service and the USDA FS and the BIA as well.
  • Congressman Stewart has even misused the media which is supposed to be a check and balance in our system of government, to misinform the people on Christmas Day regarding contraception of wild mares. The NY Times correction this writer requested came 4 days late. This Op-Ed, though freedom of speech, was a manipulation and betrayal of his office as a United States Representative.
  • Under Color of Law: Theft and all of the above, and below, under color of law.
  • Due Process/Standing: Congressman Stewart et al. in effect told the “outside group” (CAES) to “STOP”, and told Congress that their “leadership” is needed, rather than that of the people’s. They ask Congress to ignore the will of the people and to allow these most heinous experiments, and entirely illegal and unnecessary killing in any manner possible, our nations unifying force, the wild horse.
  • They abuse the Appropriations process statutorily. They abuse the media, our check and balance. They assist the BLM in its designs to do whatever the Livestock industry wants and are OK with the rogue Bureau of Land Management (BLM) designing its illegal, unwholesome and freakish experiments in a manner to try and ensure that no citizen or group will have standing to oppose them.To wit, only CAES passed the legal test of standing, and once it did, the BLM dropped the most heinous illegal experiment. This experiment and the lengths they have gone to HIDE it and to COVER UP, show that BLM is indeed a ROUGE AGENCY and that this is due largely to conspiracy with Congress, against the people of the United States of America.

WHEREAS CAES requests relief with all due respect which includes the following:  

CAES asks:  Congress itself to “STOP” its illegal pandering to the Livestock industry and START requiring the Bureau of Land Management to respect our nation’s cultural UNITY around it’s wild horses and end its illegal rouge actions and plans.

CAES asks: Congress to STOP the divisive tactics regarding the best alternative to the illegal killing of our wild horses, including allowing our government’s own EPA calling our unifying cultural heritage a “Pest” and hence, then calling the humane, non-toxic, non-hormonal contraceptive native PZP, made only of protein and oil as a immune-contraceptive a “pesticide”, hence promoting fear for usage of this contraceptive or PZP22.

CAES asks: Congress to STOP, any funding for killing our nation’s wild horses.

CAES asks: Congress to pass the SAFE Act HR 113, for food safety and to thereby STOP the hidden dumped horse issues in our border states with Canada and Mexico CAUSED by Kill Buyers dumping of horses rejected at these borders due to pregnancy, etc. which are then politically and dishonestly used to promote horse slaughter.

CAES asks: Congress to REQUIRE on range management per the SPIRIT and INTENT of the 1971 Act.  With the constant round ups and small herd sizes, and refusal to utilize PZP immune contraception though it would be so very easy, (for example BLM at Socorro NM) there is a very low possibility that any number of wild horses, actually live out their lives on the range, in complete ignorance of the SPIRIT and INTENT of the 1971 Act.

CAES asks: Congress to disallow removals from herds protected under the 1971 Act that the BLM states are too small to utilize PZP due to genetic viability as removal of genetics is far worse than stopping births to the point where births equal attrition. Hence, stopping the “need” for removals.

CAES asks: Congress to stop the illegal use of it’s Appropriations process’ to promote the death of America’s wild horses and the slaughtering of both its wild hoses and its owned horses.

CAES asks: Congress to END all off-range management and hence round ups within 1 yr.

CAES asks: Congress to follow the Science and the will of the people and to STOP illegally utilizing the media to manipulate the people on this issue so uniting to our country.

CAES asks: Congress to STOP keeping our First People so poor, in order that Governor Gary Herbert and/or Governor Susanna Martinez can try to scape goat even those who believe them sacred, for the killing of our nations unifying force, the wild horse which the overwhelming majority of First Peoples and their fellow Americans see as spiritually, and culturally sacred.

CAES asks: Congress to STOP allowing the slaughter of ANY horse for human consumption that is not raised as a food animal for slaughter over the borders or on American soil.

CAES asks: Congress to STOP allowing the sale for slaughter for human consumption, of ANY estray animal of unknown origin and unknown food and drug history, and especially any Estray Equine which are rarely if ever raised as a food animal, to be sold as a food animal, as that is the basis for a FOOD SAFETY issue in and of itself, even if sold over our borders. This product can then be sold back to the U.S. as well as to people in other counties.

CAES asks: That Representative Stewart et al. are sanctioned at a minimum and are no longer allowed to “lead” on this issue even behind the scenes, and that all votes following their false testimonies to Congress be stricken from the Congressional record.

CAES asks: That the wild horse be recognized along with the Eagle and the Bison as this Nation’s National Ungulate. The horse is the oldest large mammal of North America and built and defended this nation.

CAES asks: That all executive Orders regarding Tourism be UPHELD.

CAES asks: That all Historic Preservation laws be brought to bear to preserve and protect even the “Fort Polk” horses in the Kisatchie National Forest immediately, as well as all other wild horses near military lands.

CAES asks: Congress to recognize that States own their wildlife including their wild horses even on federal lands and that these horses are wild horses even when they have not been recognized under the federal 1971 Act.

CAES asks: Congress to uphold food safety laws and to uphold the FACT that no wild, feral, or estray horse meets the federal definition of Livestock and hence to cease and desist ALL unrestricted sales of these national treasures, which in fact, are a state and national resource of the people, which of course have in no way, been raised as food animals.

CAES declares: If Congress ALLOWS our healthy wild horses to be killed the very spirit of our American Nation will be extinguished. Congress must not do, what it does not have the ethical, legal, or moral authority to do against our proud nation. This is tantamount to treason, if not actually treason.

CAES asks: For a Congressional Environmental Impact Statement to be performed, by people with no conflict of interest in any of the two kill industries, Livestock or Game, before any act of killing even one of our native healthy wild horses which built our country, protected our families, and their families, and have worked for us whenever, we have ever asked, and are in fact, important for our environmental health as native species, is funded or allowed through this corrupt Appropriations process.

This manipulative plan to kill our nation’s wild horses is an abuse of the very subsidized system of government that Henry Clay promoted.

What can you do?

Please take a moment to call the followig officials and tell them NOT to follow Rep Stewart and to protect our wild horses.

Murkowski, Lisa – 202-224-6665
Cochran, Thad 202-224-5054
Alexander, Lamar 202-224-4944
Blunt, Roy 202-224-5721
Hoeven, John 202-224-2551
McConnell, Mitch 202-224-2541
Daines, Steve 202-224-2651
Capito, Shelley Moore 202-224-6472
Udall, Tom 202 224 6621
Feinstein, Dianne 202 -224-3841
Leahy, Patrick J. 202-224-4242
Reed, Jack 202-224-4642
Tester, Jon 202-224-2644
Merkley, Jeff 202-224-3753
Van Hollen, Chris 202-224-4654


Department of the Interior, Leaked Draft 2018–2022 Strategic Plan

A CAES Report-card on Ryan Zinke

2017 CAES© permission to use any part of this article not in it’s entirety is required.

©U.S. Department of the Interior

In a September, 2017 draft, obtained by obtained by Defenders of Wildlife, the Department of Interior, led by Secretary Zinke outlines the nefarious plan for our public lands.

We’ve done a little scorecard on how this plan weighs when compared to a transparent, receptive, forward-looking Interior Department serving the the majority of American’s by continuing and strengthening  our natural heritage, cultures, treaties, and astute, science-based use and/or protection of our natural resources.


MISSION AREA 1:  Conserving Our Land and Water 
GOAL #1:  Utilize science in land, water, species and habitat management supporting decisions and activities
GOAL #2 Manage DOI water storage and delivery to resolve conflicts and expand capacity
GOAL #3: Foster partnerships to achieve balanced stewardship and use of our public lands
GOAL #4: Inform land use planning processes especially for public use and access

 Teddy: established                                           Ryan: strip protections from 
          A. 150 national forests                                 A. 11.3 million acres of public lands
          B. 51 wildlife refuges                                   B. 218 million acres of marine environment
          C. 5 national parks                                       C. Reducing National Monuments              
          D. 18 national monuments                         D. Dismantling wildlife refuges                                                                                                            E. Gutting endangered and critical                                                                                                         species protections
Teddy Roosevelt, would tell Ryan he needs to he protect our national monuments, institute better protections of our wildlife, land air and water.


MISSION AREA 2 Generating Revenue and Utilizing Our Natural Resources 
GOAL #1 Ensure energy and economic security for America
GOAL #2: Ensure access to mineral resources
GOAL #3: Ensure public receives fair market value for resources; fees are reasonable and recover cost
GOAL #4: Focus timber programs on “healthy forests” lifecycle
GOAL #5: Manage grazing resources


A. Vocabulary error
“Sustainability” is a word that Ryan uses often, but doesn’t appear to have done his homework and looked up the definition.
                        1. Cancelled moratorium on coal leases, while announcing a new round of                                leasing in the Powder River Basin, WY
                        2. Ryan announced offshore oil and gas leases in a 77 million-acre region of                              the Gulf of Mexico, while still recovering from the 2010 Deepwater                                          Horizon disaster
                        3.  Ryan joked to the National Petroleum Council that “fracking is proof that                               God’s got a good sense of humor and he loves us.”
 Ryan demonstrates that his understanding of “sustainability” is that; limited resources (oil, gas, minerals, etc.) will secure a sustainable future for the American people. This misunderstanding will be devastating and possibly irreversably damaging to our evnironment, wildlife, and overall quality of life.


MISSION AREA 3 Expanding Outdoor Recreation and Access
GOAL #1: Expand hunting, fishing, and other recreation on DOI lands and waters
GOAL #2: Enhance public satisfaction at DOI sites
A. Ryan has created trust issues with the majority of Americans
                       1. closed-door dealings and speeches
                       2. refusal to publicly release his national monuments report
                       3. ethically questionable business travel
                       4. suspicious relationships with Political Action Committees
                       5. special attention to special interests
                       6. considering drilling adjacent to and even inside 30 national parks
                       7. ignored stakeholders of planning process for conservation of greater-sage                             grouse and how to balance that with other nultiple uses across the west.                              (A move that promotes continuing decline of the bird and likely putting it                              on the endangeres species list.)
Ryan fails to recognize people outside special interest groups, and does not know how to communicate with those outside his usual group of friends. He has total disregard, and no respect for the hard work of others who contributed work before him, nor how his changes will negatively impact them, the environment or the wildlife. He will also be throwing out not only the work already done, but also significant tax dolaars wasted that were used in developing exisiting protections and plans.


MISSION AREA 4 Fulfilling Our Trust and Insular Responsibilities 
GOAL #1: Support tribal self‐determination, self‐governance, and sovereignty
GOAL #2: Fulfill fiduciary trust
GOAL #3: Strengthen economic and health capacities in the US Territories, and fulfill US compact obligations to the freely associated states
A. Vocabulary error
     “Sovereignty” is a word that Ryan uses as a noun, or a thing that can be supported.             This demonstrates his lack of homework doing with his vocabulary list and looking           up definitions once again.
                          1. Reccomendation to shrink Bears Ears National Monument
                          2. Recommendation will stop protection of Indigenous artifacts
                          3. Recommendation will lift protections of Indigenous sacred sites.
                          4. Recommendation is in opposition to member tribes of the Bears Ears                                      Commission.
On the heels of a new administration failing to hear, respect or honor Indigenous rights, or treaties, Ryan deals another blow to our First People recommending the decrease in size of National monuments such as Bears Ears, and lowering the protections for those very things that ought to be the decision of the tribes based on the sovereignty. If Ryan believes in sovereignty, he must learn the it is the right for our Indigenous Peoples “to make their own laws and be governed by them.”


MISSION AREA 5 Protecting Our People and the Border
GOAL 1: Ensure emergency preparedness & DOI law enforcement staffing addresses public safety risks
GOAL 2: Support securing our southern continental US border
GOAL #3: Manage wildland fire to reduce risk and improve ecosystem and community resilience
GOAL #4: Provide science to safeguard communities against natural hazards
As the Secretary of the Interior, Ryan should be asking for more money for his department right? He is failing this part of his job by recommending cuts during his testimony to the Senate in 2017 for the FY 2018 budget.
          Recommendations made for the FY 2018 budget:
               13% cut for the BLM, USFWS, Bureau of Reclamation & US Geological Survey                               (Nearly half from Office of Surface Mining & Reclamation)
               11% cut for the National Park Service
          Rescinded policy that would make companies pay fair market value for oil, gas and                coal extraction on federal lands (loss of revenue to taxpayers $75 million)
Ryan again seems to be leaning in favor of special interest, profit makong ventures, and not increasing funding to protects our heritage, resources or even our tax dollars. Instead the only way he has made any recommendation that would increas income for the department is the idea to triple fees to be admitted to our National Parks.

MISSION AREA 6 Modernizing Our Organization and Infrastructure for the Next 100 Years 
GOAL #1: Align DOI organizational structure and workforce to improve partnership engagement and mission delivery
GOAL #2: Reduce administrative and regulatory burden
GOAL #3: Prioritize DOI infrastructure needs and reduce deferred maintenance backlog
A clear agenda that is contrary to the job he is in. 
     A. Ryan doesn’t seem to understand that the Deparment of Interior doesn’t oversee                  the Customs and Border Protection, whic is actually acomponent of the                                 Department of Homeland Security. 
     B. Ryan claims conservation, safety and public health policies are “burdensome” on               energy production (oil, natural gas, coal and nuclear) in a report issued in response           to Executive Order 13783. The Dept of Interior feel that protections for wildlife and           habitat, science consultation for critical species and areas deemed areas of critical             concern are among these burdensome things. But that’s not all, he also feels that                 planning & appeals processes (that pesky public involvement component) and of               course all those exhaustive permits to satisfy legislative and administrative                         requirements. These all just get in the way of making “America Energy Dominant”.
     C. The National Park System has a $12 billion maintenance backlog, and the National             Wildlife Refuge System is suffering a $2.7 billion backlog yet Ryan calls for a $1.6               billion budget cut for his department. 
     D. Ryan’s “reorganization” through the reassignment of over 50 top staffers at the DOI            was done involuntarily and often to new positions in which the staffer had no                    expertise. This can never be productive for an organization to function efficiently.
     E. Ryan supports the elimination of about 4,000 jobs at the DOI. Further adding insult           to injury many more will be uprooted with his plans to move 3 DOI agency                           headquarters to Denver from Washington DC, a move that is clearly an attempt to             further keep the states that are not the west out of the loop on western land issues,             such as the push to transfer federal lands to states.
The only issue that hould concern him with the border should be effects of a border wallon wildlife and habitat, including endangered species and several national wildlife refuges. Ryan needs to focus on a fair nd healthy balance between energy development and resource conservation that protects our future, not seeing these protections and policies as burdensome. While we agree that some positions in the Department of Interior could be eliminated, we disagree with moves or eliminations due to retaliation on those who disagree with Ryan and the special interest group he clearly works for. We do not believe moving offices that deal primarily with issues that are western issues to western offices is an appropriate way to represent those public land owners who live in the eastern states. This limits the information and public meetings access, along with contributing to a feeling of secrecy and “good old boy club” atmosphere. Taunting his own staff saying 30% are not loyal is not a professional way to handle human resources, and is not going to breed a healthy work environment, thus furthering the feeling of mistrust and division. 

∑ Overall Reportcard Score –  is that Ryan moved up a grade when he clearly was not ready.
Ryan Zinke’s actions are contrary to his job description, he has a clear dislike and disregard for conservation, preservation and majority interests. We believe it is time for Ryan to change jobs. He is no more qualified for this job than was the scientists he put into an accounting position. We believe that Ryan Zinke cannot achieve the goals of the Department of the Interior when he fails to realize that the goal is to protect and preserve, conserve and respect…not profit.






zinke signs order 16x9

Please remember that CAES and our other branched, National Wild Horse & Burro Administration and Public Lands Truth Campaign are 100% volunteer and we can only do the work we do with your support. Please consider making a contribution or becoming a member through a monthly donation.
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Continue reading “Department of the Interior, Leaked Draft 2018–2022 Strategic Plan”

A Peoples National Wild Horse and Burro Advisory Board meeting (with Poll)

POLL: What would you rather for our Nation’s Wild Horses & Burros?

Choose A or B and Click on the Link Below to Vote:

-Sold to foreign Nations including Russia where they are hammered in the head prior to slaughter.
-Mass Euthanized and MASS composted.
-Sold to poor peoples for food.
-sold to a corrupt tribal government, ignoring their own natural laws and the will of their people.
-sold to Zoo’s for zoo animal protein.

-Managed utilizing natural predators.
-Managed utilizing the recommendations of the National Academy of Science and stated the best solution was PZP immuno-contraception.
-Managed by darting from helicopter IF NEED BE: Keeping each family band together, not separating families, with darting each band in about 5 minutes, on the larger more remote Wild Horse Areas- All helicopters must have live stream cameras on the bottom ( as they ALWAYS should) facing in each direction so that the public can see how close the helicopters are/went, and if any wild horse went down or was separated etc.

Vote Here: Wild Horse and Burro Poll


What are the real choices? (Listen to Video)

What are the choices being discused? (Listen to video)

What is the real reason that the Department of Interior refuses to manage ON THE RANGE in a non lethal manner? (Listen to video)

Why have we been threatened constantly with slaughter AND MASS EUTHANASIA when 80% of Americans are opposed? (Listen to video)


Does Chris Stewart Give Alternate Facts About Wild Horses Or is He Questioning His Own Religion?


chris stewart
The Mormon Congressmen who set 3 world records and writes New York Times best-selling books.

Representative Chris Stewart of UT is a Mormon. He is also one of the most outspoken adversaries of wild horses. He claims they are over-populated, starving, destroying the land, and that they are merely animals that escaped domestication and now live wild on our public lands.

There have been many scientific finds, mitochondrial analysis, fossil finds, carbon dating, and a comparative analysis of the Yukon horse to modern wild horses proves that the genetic markers are so similar that the horses are unlikely to have been extinct during the 10,000 years after the Pleistocene Era.

The one fact that Chris Stewart has never addressed, and one that makes us question not only his moral compass, but also his sincerity in statements made, is that the Book of Mormon, used by the Church of Latter-day Saints, mentions horses several times. This would mean that horses never went extinct on this continent, which proves a constant evolution of Equines for 58 million years.

Several artifacts have been found that are from the period in question. They include fossils, petroglyphs, cave carvings and drawings, and sculptures like the ones in this photograph.

The Book of Mormon speaks of horses in Lamanites (Alma 18:9 – 10; 20:6), Nephites (3 Ne. 3:22). Throughout the book horses are mentioned as an indigenous species. In Ether 9:19 Jaredites had horses. 1 Nephi 18:25 horses are mentioned with other large animals. Enos 1:21 tells us that Nephites had many horses among flocks. Alma 18:9 – 10 says the Lamanite King, Lamoni had horses and chariots. 3 Nephi 6:1 says the Nephites had horses after the Gadianton Robbers. The last mention of horses in the Book of Mormon is from approximately AD 26.

Mr Stewart among many other public figures, repeat the rhetoric we hear frequently. The accepted theory that allow wild horses to be treated as some invasive, unwanted animal. That theory is that all wild horses are descended from European stock. The theory is that after the 10,000 years of extinction horses, that were mostly of Spanish and Portuguese stock, were brought during the Spanish conquistadors expedition.

As with many claims made about our wild horses, there is just no clear, evidence to support this theory. However, there is much historical evidence that would seem to point out the polar opposite of that theory.  The Spanish revered the importance of the horses brought here, they needed them for war, to conquer this new world. Very meticulous records were kept as to the fate of each horse, and in no record do they believe their horses escaped and disappeared into the wild.

We also would need to consider that for them to have populated our continent, there would have to have been a stallion and mare escape at the same time, stay together and reproduce. They would have had to repeat this behavior for centuries which in itself is an unlikely occurrence.

Consideration would then have to be given to whether or not these escaped Spanish horses arrived early enough to account for horses kept by Indigenous tribes, which were documented by early European explorers. There were 4 early expeditions that brought horses, they were the expeditions of Cortes, Narvaez, de Soto, and de Coronado.

Discovery by Europeans of horses found among Native American tribes. Graphic by Daniel Johnson

The chronicles of these expeditions make the claim that our wild horses are descended from these Spanish horses nearly impossible. Narvaez only had one surviving horse, that doesn’t work for being the creator of modern day wild horses. The other 3 conquistadors made Spanish land advances as far as Texas where they were stopped by the Plains Indians who already had horses. Given there is no explanation for how the Plains Indians got those horses, and knowing there was one Spanish horse surviving before they came to the Americas, the theory of modern horses descending from escaped Spanish Conquistadors just becomes fiction.

Sketches of North American petroglyphs found in the Black Mesa area of Cimarron County, Oklahoma.

Mr, Stewart also contradicts some Latter-day Saint authors who mention horses in Mesoamerican artworks. Although these images are rare now and the fact that they are subjective do not in themselves provide any proof that horses were no extinct here, but must be added to the growing proof.

One such artwork mentioned is found at Chichen Itza. It is on the side of a building called the Temple of the Wall Panels. It is interpreted by Latter-day Saint scholars to be a man standing next to a horse. The carving has been dated to the 9th or 10th century AD, long after the last mention in the Book of Mormon, but definitely pre-Colombian. In the image below the wall shows erosion to some degree so the photo has an outline drawn on it to show the remaining details more clearly.


Mitochondrial-DNA analysis, of the Yukon horse bones found recently, found that the modern horse, Equus caballus, is genetically equivalent to Equus lambei.  These fossil records represent the most recent Equus species in North America prior to Equus caballus. Not only is Equus caballus genetically a match to Equus lambei, but no evidence exists for the origin of Equus caballus anywhere except North America.

yukon horse equus lambei

So the science is there to prove that today’s modern horse is at a minimum a reintroduced native species, and there is sufficient evidence to support the theory that horses never went extinct on the North American continent.

Given all of this information we have to wonder why politicians like Chris Stewart have continued to ignore the science, continued to repeat the exaggerated population claims of the Bureau of Land Management, misrepresents truth, misleads federal budget hearing committees and calls for the death of healthy wild horses. Just like the science can prove the origins of modern horse, the records of the Bureau of Land Management can prove the population growth, according to their own census, are also nothing more than myth.

There is a very simple solution to wild horse population management, but less than one percent of the Wild Horse & Burro budget is spent on it. And that is management on the range with PZP, a birth control vaccine.

For more information on ‘On the Range Management’  or any other questions on this publication, please email: or call our office at 541-315-6650.




Sign the petition to let lawmakers know we will not stand for euthanasia, slaughter, or any other means of destruction that results in the death of wild horses and burros!

Time is short, so please sign, share, and ask your friends to sign today! 

STOP EUTHANASIA of U.S. Wild Horses – YES to LIFE!



What it means for wild horses of the West.

Screenshot 2017-07-22 05.49.55

This is what is posted on the House Appropriations page…..doesn’t make much clear does it? Let’s take a look at what the bill said originally and what the change is, and the final, adopted version (by the House Full Committee)…..

Screenshot 2017-07-22 05.45.03

So what does the wording change mean —

The statement – in the original (the first paragraph in the above photo), funds are not available for the destruction of healthy or unadopted horses OR sale resulting in processing or commercial products

The definition – destruction of healthy or unadopted – Euthanasia

sale resulting in processing or commercial products – Slaughter

The statement – in the final version (the last paragraph in the above photo), funds are not available for the sale of…resulting in destruction for processing into products or meat

The definition – sale resulting in destruction for products or meat – Slaughter


So where are we right now?

The House Full committee has voted in the Stewart Amendment leaving us with the last version, which does not allow funds for ‘slaughter’ but has taken out language restricting ‘euthanasia’.

The Bill however, must still be approved by the Full House, and it still has to be heard and approved by the Senate Subcommittee, Full Committee and Full Senate.

Each of these bills goes through a sub and full committee of each the House and Senate, and also must be passed by the “Floor” in each the Full House, and Full Senate. Another way to look at this:

How does a Bill to get to completion?

House (sub)committee A + House (larger) (full) Committee B + House Full Membership (all the Representatives) (sometimes called the Floor) C = Full House Adoption (passing of the Bill by the House of Reps.) D

Senate (sub)committee E + Senate (larger) (full) Committee F + Senate Full Membership (all the Senators) (sometimes called the Floor)G = Full Senate Adoption (passing of the Bill by the Senate) H

D + H = FY 2018 Budget Appropriations Act  (The done deal)

What can we do at this stage?

  1. Call your Representative:  Find My Rep. and let them know you do not want them to pass this bill with the Stewart Amendment which allows funding to be used to euthanize horses (No Slaughter OR Euthanizing healthy or unadoptable horses)
  2. Call the members of the Senate Appropriations Committee (we recommend just making the time to contact the entire committee because they are fast-tracking these bills!)


As always, if these articles, and information are useful to you, please consider helping Citizens Against Equine Slaughter stay in the fight for our nation’s beautiful, majestic equines. You can support us by volunteering or through donations by clicking on the Donate button found on this website. We are all volunteer, and our only mission is to protect the lives and homes of these sentient beings.

Representatives Stewart, Amodei, and Simpson Mislead Interior Appropriations Committee to Vote for Mass Euthanasia of Wild Horses

screenshot-www youtube com 2017-07-19 01-33-22

Representatives Chris Stewart (UT),  Mark Amodei (NV), and Mike Simpson (ID) mislead the Interior Appropriations committee in order to trick representatives into voting for MASS EUTHANASIA of U.S. Wild Horses. (A voice vote was taken so they cannot individually be held accountable.) Video of the Interior Appropriations Committee meeting is posted below.

Watch Video Here:


Contact your House Reps here:

Contact your Senate Reps here:

Read more about Representative Amodei’s violation of U.S. criminal code, Title 18 here: Representative Amodei Violates US Criminal Code, Title 18

Press Contact:
Val Cecama Hogsett

Representative Amodei Violates US Criminal Code, Title 18

CAES letterhead

Press Release: US Representative Amodei testified yesterday 7/12/17 in the House Appropriations Committee illegally “misleading”[1] Congress and the nation, regarding extreme animal cruelty of in field sterilization experiments planned in Oregon.
Per CAES legislative liaison Val Cecama Hogsett, Mr Amodei made a statement to the committee that an NGO had sued the BLM regarding birth control experimentation in Oregon with the result that the government had no alternative to warehousing wild horses outside of slaughter.
The NGO referenced was CAES. The experimentation referenced was in fact not “birth control” but in field sterilization via ovariectomy and colpotomy of 200 wild mares in different stages of pregnancy. This is extreme animal cruelty and was indeed halted by the suit[2] filed pro se by Patience O’Dowd in an administrative Appeal by CAES.
CAES believes Representative Amodei’s statement mislead the Congress and the nation to think that there is no viable alternative to slaughter or euthanasia when clearly CAES and Wild Horse Advocates and scientists are overwhelmingly promoting feasible and humane “On Range Management” by birth control PZP immuno-contraception as recommended by the National Academy of Sciences. Sadly, this esteemed and feasible recommendation was not even mentioned in committee.
The result was a very close vote in this committee of 27 to 25 to allow horse slaughter in the United States. CAES believes Representative Amodei’s testimony clearly is in violation of 18 U.S. Code § 1001 – Statements or entries generally
It is well known that our nation is strongly opposed to horse slaughter[3], hence some of our representatives work in a stealthy manner to re-install this unnecessary abhorrent special interest practice.

Congress must not try to mislead in order to obtain this result so clearly against our national culture.

CAES is submitting a title 18 complaint against Representative Amodei.

Respectfully submitted this 13th day of July, 2017
Dr. Lester Castor Friedlander D.V.M., president of Citizens Against Equine Slaughter

Press Contact:
Val Cecama Hogsett

[1] The House of Representatives Full Appropriations Committee

[2] BLM Motion to Vacate and Remand in Citizens Against Equine Slaughter, et al. 20160909-CAES-IBLA-Motion-to-VR-Mare-Sterilization-Research-EA

[3] ASPCA Press Release, Research Confirms Americans Strongly Oppose Slaughter of Horses


East Pershing Complex Gather Plan Public Comment


NEPA Document Number: DOI-BLM-NV-W010-2017-0009-EA

Location of Proposed Action: Pershing, Humboldt, Churchill, and Lander Counties.

Name and Location of Preparing Office: Humboldt River Field Office, Winnemucca Nevada Subject Code/Case File/Serial Number: 4700

Citizens Against Equine Slaughter finds that the BLM should choose Alternative C, or No Action on this proposed EA for the reasons outlined in this public comment.

Taking a preserve (HA) created by federal mandate and micro-managing herd management areas (HMA)within the HA was never authorized under any Congressional Act.

Micromanagement is defined as: ​to control every part of a situation, even small details. So the entire HA is not managed as a whole ecosystem, therefore cannot achieve a thriving natural ecosystem pursuant to the WFRHBA.

Hence it is not managed like Yellowstone National Park where predators and prey and environment are interacting in a natural manner. It is also not being managed like Assateague National Park. Both of these National Parks are profitable and are both under the Department of Interior. The Department of Interior might ought to “tier” their learning. The point here is that a natural balance can exist and the DOI understands how to do this and how lucrative it is.

WHO CARES about comparing a non-native species such as Bovine from Asia with horses. This is patently ridiculous and irrelevant. What ought to be compared is the fact that cattle are non-native, and their mouths do not contain upper front teeth and hence pull on plants and hence destructive. Of ALL the other grazers being ruminants are lacking in upper front teeth, hence equines are needed and necessary grazers on the range, and moreover, less destructive. The horses act as a lawn mower would for a human maintained lawn, the physical act of mowing promotes healthy growth of the plant. Their roaming activity also promotes biodiversity when paired with their mowing. Livestock such as cows or sheep, wrap their tongue around a plant either tearing it or pulling it out by the roots, both of which do not promote regrowth.

Comparing cattle to wild horses is also ridiculous given the relative numbers. This comparison is clearly unequal protection under the law and is also not scientific.

The EA has been written under current LAW. If the LAWS change the EA needs to start ALL over again.

Crucial information is not provided in the EA to support the actions proposed in the alternatives, including but not limited to:

  • All ungulate numbers must be detailed over the last 50 yrs.
  • Rainfall must be detailed over the last 100 yrs.
  • All grazing permits must be detailed.
  • The BLM must provide the full detail on all and any sterilizations for male or female.

Gearing things principally toward the livestock industry is in fact unequal protection under the law as well as going against the principle use purpose of the WH&B Act.

The BLM hasn’t provided a feasible, humane, safe, transparent, and culturally acceptable alternative to promote a natural thriving ecology providing equal protection under the law.

CAES suggests the following Alternative :

On Range Wild Horse Management via predators or PZP only.

  • Helicopter usage only for application of PZP, one band at a time, in the areas where native predators are unacceptable to the BLM, for reasons which the BLM should detail
  • Bait trapping one family at a time for the purpose of darting is also humane and feasible
  • Addition of predators in the most remote areas where the BLM refuses to utilize PZP
  • Cameras on the bottom of helicopters in all directions
  • Mix 40 darts of PZP at one time
  • Dart one family at a time for a short period
  • Dartable PZP should be used

The FLPMA and PRIA both state that multiple use policies were to be used to determine land uses, however it also stated it would not override any other land use policy.

  • Sec. 101. [43 U.S .C . 1701 note] This Act may be cited as the “Federal Land Policy and​
    Management Act of 1976”. DECLARATION OF POLICY Sec. 102. [43 U.S .C . 1701] (a) The Congress declares that it is the policy of the United States that– (b) The policies of this Act shall become effective only as specific statutory authority for their implementation is enacted by this Act or by subsequent legislation and shall then be construed as supplemental to and not in derogation of the purposes for which public lands are administered under other provisions of law.
  • 43​ U.S. Code Chapter 37 – PUBLIC RANGELANDS IMPROVEMENT ACT of 1978 (a) The Congress finds and declares that— (c) The policies of this chapter shall become effective only as specific statutory authority for their implementation is enacted by this chapter or by subsequent legislation, and shall be construed as supplemental to and not in derogation of the purposes for which public rangelands are administered under other provisions of law.
  • Mountain States v. Hodel found that the 1971 law is in fact a land-use regulation; “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. At the outset, it is important to note that wild horses and burros are no less “wild” animals than are the grizzly bears that roam our national parks and forests.
  • “Herd areas meet the critical habitat criteria set for ACECs. § 1610.7-2 Designation of areas of critical environmental concern or ACEC, is a special designation created by Congress in the 1976 Federal Land Policy and Management Act. That law directed the Secretary of the Interior and the BLM to designate as ACECs: “…areas within the public lands where special management attention is required… to protect and prevent irreparable damage to important historic, cultural and wildlife resources. The horses on our public lands have been determined to be wildlife in many court cases, Kleppe v NM, WHOANM V NMLB and above in Mountain States v. Hodel as well as by Congress in the 1971 Act itself!! Let us remember how many people supported the 1971 Act. Hence these are legally ​wild ​horses.

Many tribes also consider these wild horses as wild, as well as cultural historic properties under both federal and state Historic Preservation Acts.

Just as BLM did not and does not have the authority to micro-manage areas within the Herd Area, it also did not have congressional authority to combine Herd Areas or preserves to create complexes.

The EA speaks to 4 Wilderness Study Areas within the ‘complex’. We realize that as a native species wild horses should be in these WSA’s as an integral part of the public lands and the ecosystems in these WSA’s.

The Secretary must protect herds per the 1971 law. Thriving herds must be genetically viable.This complex is managed for 3 different HMA’s. None of the 3 meet genetic viability at the low end of the AML range. The AML’s need to be adjusted to reflect proper levels to be in compliance with the 1971 law of protecting these herds. ​“It was originally thought that an effective population size of at least 50 was necessary to avoid short-term inbreeding depression, but empirical work suggests that if maintenance of fitness is important, effective population sizes much larger than 50 are necessary. Theoretical studies suggest that the figure could be closer to 5,000 for several reasons….”​ The AML’s must be increased to reflect the base number for genetic viability. In some cases where herds are able to migrate back and forth between HMA’s this is achieved, but again if managed on the entirety of the HA this would happen naturally.

This brings us to the point that migratory routes were not considered in the areas designated in​ the 1971 law. As such many of the herds were cut-off from a natural breeding selection to prevent any inbreeding. This I also an issue with water sources. When the smaller HMA’s were designated within the preserve, horses were often then cut-off from natural water sources. Many times, private landowners were then contracting with BLM to provide water from their own water sources. This is a bit of the fox guarding the hen house. But the entire area or preserved being open to the horse will mitigate, water, forage, land degradation issues.

In the West Douglas Case (COLORADO WILD HORSE AND BURRO COALITION, INC v. Ken​ SALAZAR, DOI pg 8 the Court finds that BLM’s authority to “manage” wild free-roaming horses and burros is expressly made subject to “the provisions of this chapter” 16 U.S.C. § 1333(a), including the provision that “[i]t is the policy of Congress that wild free-roaming horses and burros shall be protected from capture….” Id.§ 1331. It would be anomalous to infer that by authorizing the custodian of the wild free roaming horses and burros to “manage” them, Congress intended to permit the animals’ custodian to subvert the primary policy of the statute by capturing and removing from the wild the very animals that Congress sought to protect from being captured and removed from the wild.

Helicopter stampedes are not what the original intent of the law was. That clearly means the authority given by the Burns Amendment went against the original law to begin with and that amendment needs to be challenged and repealed. In the meantime, helicopters that will cause deaths should not be considered as an option to roundup wild horses. It is not the minimum feasible option nor is it humane. And it also violates the animal cruelty laws of the state of Nevada.

Herd areas relevant to the exemption clause” of the 1976 Federal Land Planning & Management Act. Sec. 302(a) which says; in relevant part, “where a tract of the BLM lands has been dedicated to specific uses according to other provisions of law, it shall be managed in accordance with such laws.” i.e. Such as the intent of the 1966 National Historic Preservation Act. 1971 Free Roaming Wild Horse and Burro Act, and the 1973 Endangered species Act.

The EA speaks to degradation by cattle and horses. It is clear that there are many morelivestock in this ‘complex’ area. And with the entirety of the HA or preserve managed principally for the wild horses, as WAS stated in the 1971 law, there would be one horse per 3,962 acres. That is using the low end of the AML range which is what is left on the range after a gather. This is clearly NOT managing the preserve principally for wild horses. We find that to be an egregious error in management. Right now, the number of acres to one horse, according to the total number of horses on the complex according to the EA, is 1 horse per 856 acres.

The EA also states the WFRHBA Act “mandates management of wild horses in a manner that isdesigned to achieve and maintain a thriving ecological balance…” We assert that a thriving ‘natural ecological’ balance cannot be achieved where there is land degradation from excess livestock grazing. Yet the EA does not provide the number of livestock on the preserve. So therefore, with the number of allotments, and the average number of cows permitted on these allotments, we assert that there is no principle management for wild horses, and the number of livestock permitted deviate from the mandate to have a natural ecological balance.

You also infer that there is a need “to prevent the unnecessary death of wild horses resultingfrom excess, which has not been proven in this EA, lack of water or forage, which would not be an issue if livestock were removed, fences were not keeping horses from natural water sources, and again the area is properly managed, principally for wild horses. If there is not enough water or forage, the livestock must be removed first not only for the wild horses but for all other wildlife in the area as well.

In section 1.4 of the EA we disagree that the No Action Alternative is contrary to the​ requirement under the WFRHBA to remove excess horses, because as stated above, the HA is not managed principally for horses, there is an unequal balance of protection for wild horses and burros that is a problem on all of the wild horse preserves and the BLM must stop favoring special interest corporations that want to use these public lands. We see that because wild horses do not make money they always take a back seat, and that is not in keeping with the intent of the law which was to protect the wild horses because in 1971 there were shockingly few left. BLM mistakenly seeks to manage for just above the population there was in 1971 when Congress was so shocked at the few horses left in the wild that the WFRHBA was passed unanimously. And the fact that there were at one time between 2 and 8 million horses here is never mentioned.

We have provided the House and Senate proof of the lies that we have tens of thousands of starving horses on the range, and not one BLM office, person or even politician supporting that claim have ever provided proof beyond the Cold Creek, human created incident, or an occasional horse that dies. These are wild animals and as such, some will die. The law of nature is that only the strong will survive, so managing for unnatural goals in years of drought could even be questionable, however because the predators have been killed in such mass numbers we believe that ‘some’ unnatural measures now must be in place. However, the foundation needs to be fixed to do that. “Blaming wild horses for the damage done on public lands by livestock, is like blaming people who put ice cubes in their drink for the disappearance of the glaciers.” – Erik Molvar, Executive Director, Western Watersheds Project

We want you to choose the No Action Alternative. Give the entire HA’s principle use for wild horses by adjusting the permitted livestock, even if that means waiting until the next RMP round. The WFRHBA gives the Secretary (and his appointed custodians) the authority to provide supplemental feed and water when needed, so that is the minimum feasible level of management. When livestock are in trouble, the government provides subsidies or assistance to make hay drops.

It is a violation of the Nevada Animal Cruelty laws to even consider spaying of mares, and thatoption will never be acceptable to the American people. When the mortality rate of stallions gelded is higher than average when done by the BLM there is no way spaying of a mare, a much more complicated surgery, should not even be considered.

The EA also stated that wild horses double in size every 4 to 5 years but your own census of these HMA’s does not support those claims. We agree with using fertility control, PZP for the herds, but we also recognize that statements have been made by the agency that PZP doesn’t work (it won’t work if you do not use it on enough mares to achieve the desired population growth reduction) it is too expensive, PZP native is about $27 per mare, and the horses can be bait trapped one family at a time. Doing this will reduce the recompensatory breeding, fighting of stallions, and trauma of breaking up family bands.

Again, you mention sterilization of mares in this via ovariectomy. We find this is violating the Nevada Animal Cruelty statutes. Ovariectomies in wild mares has been highly unsuccessful and resulted in mortality rates that were above the acceptable range of the American Veterinary Medical Association. When we researched this last year during the IBLA appeal on the BLM’s decision to do these types of experiments we found that doing them in non-sterile environments is also not pursuant to the laws. And this action could also cause a veterinarian to have their license revoked.

The EA is also not clear, in Alternatives A and B about whether the horses would be treated with fertility control vaccines, or if there would be geldings or if there would be mares spayed, and needs to outline the number of each of those actions in each HMA. The language pertaining to the specific actions to be taken is vague. Therefore, Alternative C must be chosen and no action must be taken for this and all reasons above.

Thank you for allowing us the opportunity to comment on this plan and provide some insight into what we believe is the best management that can be implemented moving forward to achieve the goal of healthy horses on healthy lands.

Respectfully submitted (as amended) this 12th day of July, 2017
Theresa J Barbour for Citizens Against Equine Slaughter
PO Box 115
Drain, Oregon 97435

Patience O’Dowd or Wild Horse Observers Association
PO Box 932
Placitas, NM 87043

Wednesday, July 12th: The Fate of Horses in this Country Will be Decided Today (Updated)


Update 1:

The Amendment in the Ag. budget failed, and Amodei intentionally mislead the committee….more on this son. We’re listening to the Interior hearing which addresses wild horses before we put out a full account of today’s administration’s results……sickening thus far.

Update 2:
The Interior budget passed the House subcommittee and now moves n the the Senate full committee. This is sickening news again. Not a good day for the EPA, ESA or horses in America. Today, once again I will turn my flag upside down to represent a nation in distress, and it will remain there I fear, until this administration is voted out of office! WE have to vote these people out in 2018. This is OUR country, OUR environment, OUR animals, and WE WILL BE HEARD!

Will they go to slaughter in this country once again?

Will the Bureau of Land Management (BLM) get Congressional approval to destroy 50,000 wild horses that they removed from the lands they belonged on?

Will the protections from all of our equines in this country go backward in time, to a less humane, less civilized place?


At 10:30 EST, the Full Committee mark-up on the Department of Agriculture’s FY 2018 budget hearing will look at the House Draft, that draft removed section 767, and that meant that there can be funding for USDA inspections of horse meat in this country. And removing section 767 also removed the restriction that did not allow BLM to euthanize or slaughter healthy or unadoptable horses.We believe the Roybal-Allard/Dent amendment will be introduced to address at least one of these issues, but we have not yet seen the language, so we will be waiting to hear that. And whether or not it is voted into inclusion in the budget. (This hearing I believe will be audio only) You can open it on the web at the following link:

At 3 pm EST, the House mark-up of the Department of the Interior’s FY 2018 budget will begin. This bill addresses the request of Secretary Zinke, Rep. Chris Stewart and others to make sure NO restrictions are included that stop the BLM from using ALL tools available to them in the 1971 Wild Free Roaming Horses & Burros Act. This tool they speak of includes the possibility of destroying or disposing of excess horses. The bill seeks to make it easier and faster for the horses to be transferred to other agencies, under the guise of work horses, with no limits. The original language in the 1971 law also said sterilization could be a tool used to manage horse populations. Now, we know in 1971 that statement meant gelding a stallion (mare sterilization had never been done at that point) and they still intend to try and twist that to experiment on mares, and do it in filthy, dusty environments, putting the mares at great risk of death. We will be watching and hoping that the bill is simply at a stand still for this reason and MANY others. It seeks to destroy wild lands, wildlife, and so much more to make us ‘energy dominant’ as both Secretary Zinke and President Trump have stated. You can watch this hearing at this link: