Dear [BLM]:

I am a small-time cattle rancher, mustang adopter, writer, and board member of the Colorado chapter of the National Mustang Association, and live in Dolores and Disappointment Valley, Colorado. As you know, TJ Holmes and I authored the “Bait-Trapping Proposal” mentioned in the scoping letter, which foreshadows what I am about to say: I fully believe that bait trapping within Spring Creek Basin HMA is possible and would be far easier on the horses, public, BLM personnel, and the government’s pocketbook than initiating further helicopter roundups. But there is another reason I believe it is the wisest course of action for BLM to take.

It’s no news that the West is at war: standoffs between cattle ranchers and BLM personnel. Old-time residents mounting ATVs to ride public lands in designated wilderness areas, claiming roadways where there were none before. Wyoming ranchers suing for the removal of wild horses, and winning. Mustang advocates fighting helicopter roundups with letters and phone calls; activists drawing media attention, and sometimes the law. The BLM has often been on the “wrong” side of these encounters. This doesn’t have to remain so.

It’s old news that BLM has been managing wild horses in herd management areas and herd areas since the early 1970s in response to the Wild Free-Roaming Horses and Burros Act of 1971. Before that, some ranchers “managed” the herds. But in all the years prior, the horses managed themselves, which is why the WFRHB Act specifies that “[the horses and burros] are to be considered in the area where presently found, as an integral part of the natural system of the public lands.”

For well over a hundred years, generations of the Spring Creek Basin herd have survived in the desert lands of southwestern Colorado’s Disappointment Valley, their numbers controlled in part by naturally occurring predator-prey relationships with mountain lions, and by the natural mortality rate of death loss from old age, foal loss, and accidental death. As their range was reduced and they were removed from their natural water source (Disappointment Creek), and their natural predator was hunted to dangerously low numbers, the horses, unbeknownst to them, have had to rely on human participation in range and herd management to maintain range and herd health.

The use of the immunocontraceptive reproductive control vaccine porcine zona pellucida (PZP) in Spring Creek Basin HMA began in 2011. In the following years, the allowed number of mares darted increased, and the PZP darting program in Spring Creek Basin is now as successful as it is in the other herd areas in which it is practiced in Colorado, Wyoming, Montana, Idaho, Utah, and New Mexico. It’s interesting to note that of the eight managed herd areas in those six states implementing PZP by darting, not one has a scheduled removal in 2015—in every HMA in which PZP has been used, the number of years between removals has increased.

It’s also interesting to note that three of the eight managed areas darting their mares with PZP (with no removals scheduled in 2015) are in Colorado. Of the 18 scheduled removals, five will be using the bait-trapping method, and of those five, one is in Colorado (data taken from blm.gov’s “Tentative Fall 2014/Winter 2015 Wild Horse and Burro Removal and Fertility Control Treatment Schedule”). I mention these statistics because they illustrate the fact that Colorado is among the leading states in implementing humane and successful mustang-management methods. Our local herd—our mustangs that have descended from horses first coming into Disappointment Valley well over a century ago—deserves that same best treatment.

Because of the thorough documentation of the Spring Creek Basin mustangs, the successful implementation of PZP, and the committed local advocacy group, bait trapping is the natural next step toward Spring Creek Basin HMA becoming a model HMA in the state of Colorado and the West. To insist on the other alternative—helicopter roundups—would ensure that our local BLM office (Tres Rios Field Office) is seen as living in the uninformed and distant past, when instead it can be a leader of humane and wise contemporary mustang management. There is no viable reason not to enlist bait trapping as the preferred means of removal in Spring Creek Basin.

We thank you for your consideration.