To the Nevada State Senate Natural Resources Committee:

Senators Ford, Manendo, Segerblom, Settelmeyer and Goicoechea

Re: Senate Joint Resolution #1 (wild horses)

From: Karen Boeger, Backcountry Hunters and Anglers

March 11, 2013

Dear Senators,

I am writing to express my concern about the Senate Joint Resolution #1 as currently written and the unintended consequences should it actually come to pass that the public land agencies cease gathers of wild horses. I assume the crafters of the resolution have the welfare of wild horses as their goal. However, if that indeed is the intent of the resolution, to enact it's prohibition would actually result in exponentially diminishing the health of existing wild horse herds.

My concerns are as follows:

1.The health of wild horse herds, all native wildlife and public range livestock depends upon the health and sustainability of the habitat. The Appropriate Management Levels (AMLs) for each Herd Management Area (HMAs) are set by rigorous science and in a prescribed balance with the needs of native wildlife and range livestock as required by the Multiple Use Sustained Yield portion of FLPMA (Federal Land Policy Management Act) in order to maintain habitat health.

2.Federal law (1971 Wild Horse and Burro Act / WHBA and amendments) mandates that excess horses be removed as needed to maintain ecological health of the land and balance with all other uses of the public lands.

3.The BLM and USFS have been working hard to address the many concerns of wild horse groups. They are currently administering various forms of birth control and re-releasing some of the gathered horses. This is not a total solution yet; the science is still not conclusive as to the efficacy and the cost effectiveness of this approach. (Among other reservations, I have heard anecdotes that a mare's fertility increases after the birth control effect subsides.) The effect-iveness of a wild horse sanctuary in Elko Co. is currently a test model. These tests will all require time and science-based scrutiny.

4.Wild horses have no effective predators and thus, without gathers, their population doubles every 5 years on average.

5.Contrary to livestock management, wild horses graze the range 12 months of the year and they recognize no allotment boundary. Gathers are the sole management tool to avoid the range becoming overgrazed.

6.Wild horse gathers have rarely if ever been to the lower number of the range set in the AML and few if any HMAs are at AML. This means that gathers must happen more frequently at a greater cost to the public and the range is never given sufficient rest to recover to sustainable levels and continues to degrade.

7. Much of Nevada's public lands have suffered drought conditions over the last few years. This year, BLM has already put permittees on notice that AUMs (Animal Unit Months) will need to be reassessed. To maintain the health of our public lands, the AMLs should also be reassessed, as they were set many years ago without considering long-term drought conditions.

8.Without gathers, our rangelands will continue to degrade. Many wild horse herds are already in an unhealthy state. Our wildlife populations have suffered from excessive horse numbers. Sage grouse numbers can be predicted to decline with diminished rangeland health, while an imminent listing threat looms.

9.I have personally witnessed the long term damage to riparian and upland health that an excess of horses over time can cause. My husband and I have a favorite Wilderness canyon we pack into almost every year in the High Rock Canyon area of no. Washoe County. 10 years ago, the creek and meadows were in obvious recovery from previous overgrazing by both horses and livestock. Livestock have long been removed from this allotment, yet over the last decade horse numbers have been increasing dramatically and the land has deteriorated to such a degree that it's hard to believe it can ever recover – creek banks are bare and large areas are completely denuded of any grasses, shrubs or forbs. The health of the horses and wildlife are at serious risk.

10.The numbers of wild horses have increased dramatically since the passage of the WHBA and the taxpayer funded cost of management has equally risen. New solutions must be found to solve both the burgeoning numbers and costs. Eliminating gathers is not a viable solution.

Sportsmen pay for wildlife management. Should wild horse groups devise a way to share more of the financial burden of wild horse management?

For all the above reasons and concerns, I urge you to either let this mis-guided resolution die or reword it to affirm that wild horses are a beautiful and valuable resource of our public lands which require rigorous management to achieve healthy herds and sustainably healthy habitat to support them.

Thank you for your consideration of my comments, Karen Boeger