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December 5-6, 1975
Naval Weapons Center
China Lake, California
UNITED STATES DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
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12/1975
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NATIONAL ADVISORY
BOARD FOR WILD
FREE-ROAMING HORSES
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CALIFORNIA STATE OFFIC6
CENTRAL LIBRARY COP5fi
Wild
AGENDA
National Advisory Board
for
Free-Roaming Horses and Burros
Naval Weapons Center
China Lake, California
December 5-6, 1975
December 5
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8 a.m. Introduction and Welcome - Commander, NWC , and BLM California
State Director
The Ecological Impact of Wild Horses on the Public Lands -
Thad Box, Advisory Board Member
The Ecological Impact of Wild Burros on the Public Lands -
Roger Hungerford, Advisory Board Member
9:15 a.m. Break
9:30 a.m. Burros on and Adjacent to the NWC - Tilly Barling, NWC,
and Lou Boll, Bakersfield District Office, BLM
10 a.m.
11:30 a.m.
1 p.m.
2 p.m.
3:30 p.m.
December 6
Presentations by
Livestock, and
Conservation, Wild Horse and Burro,
Wildlife Organizations
Lunch
Presentations by Conservation, Wild Horse and Burro,
Livestock, and Wildlife Organizations
Burro Research - Robert Ohmart, Arizona State University
Wild Horses in the Challis EIS - Jim Englebright, Salmon
District Office, BLM
Agency Reports
Public Comment
Advisory Board Discussion and Recommendations to Adjournment
8 a.m. Leave NWC on Aerial and Ground Field Tour of Land Adminis-
tered by the NWC, NPS , and BLM. Return to NWC at 5 p.m.
APPROVED :
BLM Library
Denver Federal Center
Bldg. 50, OC-J21
P.O. Boa 2504V
Denver, CO 80225
Board Members Present - December 3. 1975
Dr. Floyd W. Frank
Dr. Thad Box
Mrs. Velma B. Johnston
Mr. William L. Reavley
Agency Personnel Present - December 5. 1975
George D. Lea, Washington, D. C., Deputy Assistant Director, Resources,
Bureau of Land Management, Representing the Secretary of the Interior
Bill Evans, Washington, D. C., Director, Division of Range Management,
Forest Service, Representing the Secretary of Agriculture
Kay W. Wilkes, Washington, D. C., Chief, Division of Range, Bureau of
Land Management
Don Seaman, Washington, D. C., Forest Service
Robert J. Springer, Washington, D, C„, Bureau of Land Management
Nancy M. Manzi, Washington, D. C., Bureau of Land Management
Betty F. Cullimore, Washington, D, C„, Bureau of Land Management
Edward L. Hastey, Sacramento, California, Bureau of Land Management
Louis A. Boll, Bakersfield, California, Bureau of Land Management
Paul W. Savercool, Bakersfield, California, Bureau of Land Management
Jerry Hanell, Bakersfield, California, Bureau of Land Management
Carl Rice, Sacramento, California, Bureau of Land Management
Jim Englebright, Salmon, Idaho, Bureau of Land Management
F. Hu Joist, San Francisco, California, National Park Service
Terral F. King, Bakersfield, California, Bureau of Land Management
l
Peter G. Sanchez, Death Valley, California, National Park Service
Milton Frei, Denver, Colorado, Bureau of Land Management
"Glenn W. Harris, Bakersfield, California, Bureau of Land Management
Dave Garber, Bishop, California, Forest Service
Jerry Steffend, Lone Pine, California, Forest Service
Janis Bowles, Bakersfield, California, Bureau of Land Management
Milford Fletcher, Santa Fe , New Mexico, National Park Service
Brad Hines, Bishop, California, Bureau of Land Management
B. Collins, Bishop, California, Bureau of Land Management
James Thompson, Death Valley, California, National Park Service
Dick Harlow, Bakersfield, California, Bureau of Land Management
Dick Raynor, Death Valley, California, National Park Service
Tilly Barling, Ridgecrest, California, China Lake Naval Weapons Center
Capt. William Daniel, Ridgecrest, California, China Lake Naval Weapons
Center
Public Appearances - December 5. 1975
Robert Ohmart, Tempe , Arizona, Arizona State University
Jim Deforge, Ontario, California, Desert Bighorn Council
Richard Weaver, Sacramento, California , California Department of Fish and
Game
DeLoyd Sat ter thwa ite , Tuscarora, Nevada, National Wool Growers Association,
American National Cattlemen's Association, Public Lands Council, and
Nevada Wool Growers Association
Lewis E. Carpenter, Fresno, California, Sportsmen's Council of Central
Cali f orn i a
Bud Wiedeman, Los Angeles, California, Society for Conservation of
Bighorn Sheep
Mary DeDecker, Independence, California, California Native Plants Society,
Southern California Botanists, California Natural Areas Coordinating
Counc i 1
Walter B. Powell, Altedena, California, California Wildlife Federation,
Southern Council of Conservation Clubs
Miriam Romero, Monrovia, California
Shirley Moncsko, Ridgecrest, California
Belton Mouras, Jr., Sacramento, California, Animal Protection Institute
Peter Burk, Barstow, California, Sierra Club
Joyce Burk, Barstow, California
Lyle Gaston, Riverside, California
Dean Slaughter, LaCanada, California, Desert Protective Council
Pat Smith, Newbury Park, California, American Horse Protection Association
Mary Ann Henry, China Lake, California
William Blackmore, Los Angeles, California, University of Southern
California
Dell 0. Clark, Sacramento, California, California Department of Food
and Agriculture
People Signing Visitors1 Roster - December 5, 1975
Roy Hines, Fresno, California, California Department of Fish and Game
Philip C. Archibald, Ridgecrest, California, China Lake Naval Weapons
Center
Donald G. Dixon, Riverside, California, California Department of Food
and Agriculture
Larry Zabel, Inyokern, California
Kelly Smith, Newbury Park, California
Sandra Young, China Lake, California
Homer F. Harrison, Bakersfield, California, Sportsmen's Council of So.
California
Mike Davis, Ridgecrest, California, Daily Independent
C. Driussi, Ridgecrest, California, Bakersfield Californian
Charlotte V. Gould, Ridgecrest, California
Donna Luzuis, Highgrove, California, California Archeological Society
William Butler, Tempe , Arizona, Arizona State University
Ray King, Ridgecrest, California, China Lake Naval Weapons Center
Margaret Fernandes, Ridgecrest, California
IV
TABLE OF CONTENTS
Lm
Introduction 1
Proceedings 2
Certification 4
Append ices
The Ecological Impact of Wild Horses on the Public
Lands, Thadis Box, Utah State University and Advisory
Board Member Appendix No. 1
The Ecological Impact of Wild Burros on the Public
Lands, Robert Ohmart, Arizona State Univ. . Appendix No. 2
Burros on and Adjacent to the China Lake Naval
Center, Lou Boll, BLM
Weapons
Appendix No.
3
Burros on and Adjacent to the China Lake Naval
Center, Tilly Barling, NWC . .
Weapons
Appendix No.
4
Statement of Jim Deforge, Desert Bighorn
Council
Appendix No.
5
Statement of California Department of Fish and
Richard Weaver . .
Game ,
Appendix No.
6
Burros in Bandelier National Monument,
Milford Fletcher, NPS .......
Appendix No. 7
Joint Statement of the National Wool Growers Association,
Nevada Wool Growers Association, and the Public Lands
The Other Side of the Burro,
Donald M. Swarthout . . .
. Appendix
No.
8
a 1
. Appendix
No.
9
of
. Appendix
No.
10
. Appendix
No.
11
. Appendix
No.
12
v
Statement of Mary DeDecker Appendix No. 13
Statement of Walter B. Powell, Land Use Committee,
California Wildlife Federation; and Land Use
Committee, Southern Council of Conservation Clubs,
Regarding Feral Burro Management on Public Lands in
California Appendix No. 14
Statement of Miriam A. Romero Regarding the Imple-
mentation of PL 92-195 Appendix No. 15
Statement of Richard J. Vogl, California State
University Appendix No. 16
Statement of Patricia Nelson Appendix No. 17
Burros In Death Valley National Monument,
James B. Thompson, NPS Appendix No. 18
Impact of Feral Burros on the Death Valley
Ecosystem, Peter G. Sanchez Appendix No. 19
Burro Research, Robert Ohmart, Arizona State
University Appendix No. 20
Challis Wild Horses, Jim Englebright, BLM . . Appendix No. 21
Statement of the Animal Protection Institute
of America, Belton P. Mouras, Jr Appendix No. 22
Statement of the Sierra Club Regarding Imple-
mentation of PL 92-195, Peter Burk Appendix No. 23
Statement of Lyle Gaston ..... Appendix No. 24
Statement of American Horse Protection
Association, Pat Smith Appendix No. 25
Statement of Howard and Nancy Green Appendix No. 26
Statement of Mary Ann Henry Appendix No. 27
Statement of Dr. William M. Blackmore, California
State Veterinary Medical Association .... Appendix No. 28
Statement of the National Wildlife Federation,
Bill Reavley Appendix No. 29
v 1
Statement of the California Natural Resources
Federation, J. R. Penny Appendix No. 30
Statement of the California Department of Food
and Agriculture, Dell 0. Clark Appendix No. 31
Statement of the Public Lands Committee, Sportsmen's
Council of Central California, Homer
Harrison Appendix No. 32
Letter from the American Donkey and Mule Society,
V. Dana Allison Appendix No. 33
Call to Meet Appendix No. 34
Notice of Meeting .............. Appendix No. 35
Delegation of Director, BLM, to Deputy Assistant
Director, Resources ... Appendix No. 36
vii
Proceedings of the National Advisory Board
for
Wild Free-Roaming Horses and Burros
Naval Weapons Center
China Lake, California
December 5-6, 1975
The eighth meeting of the National Advisory Board for Wild Free-
Roaming Horses and Burros was held at China Lake, California, the
site of the Naval Weapons Center. The meeting was requested by
Kent Frizzell, Acting Secretary of the Interior, on behalf of him-
self and Secretary Earl L. Butz of the Department of Agriculture,
by memorandum dated October 8, 1975.
The primary purpose of the meeting was to hear the suggestions
and recommendations that various groups representing conservation,
wildlife, livestock, and wild horse and burro organizations might
present for the management and control of wild burros. A field
tour into the north area of the Naval Weapons Center on Saturday
was conducted by Mr. and Mrs. Bob Barling. The tour was open to
the public. In addition to being on portions of the ground tour,
Board members were flown by helicopter over adjacent lands adminis
tered by the National Park Service and the Bureau of Land Manage-
ment. These aerial flights provided the Board with more knowledge
about burro habitat, the number of burros, and related problems in
the region.
The official proceedings were held in the Michelson Laboratory
Building on the Naval Weapons Center. Due to various other com-
mitments or sickness in the family, only four of the nine Board
members were present. The meeting was conducted within the agenda
however, no formal recommendations were made since there was not a
quorum of members present.
Introductio
Proceedings of the National Advisory Board
for Wild Free-Roaming Horses and Burros
China Lake, California
December 5, 1975
The meeting of the National Advisory Board for Wild Free-Roaming
Horses and Burros was called to order at 8:25 a.m. on December 5,
1975, at China Lake, California, by Dr. Floyd W. Frank, Chairman.
The Chairman introduced Mrs. Tilly Barling, natural resources spe-
cialist at the Naval Weapons Center, who was responsible for the
arrangements of the meeting. Mrs. Barling introduced Captain
William Daniel, Public Works Officer, who welcomed those attending
the meeting on behalf of Admiral Freeman. Admiral Freeman received
orders for another commitment which prevented him from being at the
base during the meeting.
Captain Daniel said that historically the Naval Weapons Center has
been conscious of a very strong ethic of stewardship toward the
1,712 square miles of land it administers at China Lake. The
Center command takes a keen interest in the welfare of the Center's
lands and that Acts such as the Sikes Act mandate conservation of
natural resources on military lands. The burros in the area of
the Weapons Center recognize no boundaries and use lands under the
administration of the Navy, Bureau of Land Management, and the
National Park Service. It is because of this, Daniel said, that
persons at the Naval Weapons Center feel that this is a regional
problem extending from Saline Valley on the north to Pilot Knob on
the south and the Navy takes pleasure in extending a cordial wel-
come to the National Advisory Board for Wild Free-Roaming Horses
and Burros and the managing agencies.
The Chairman next introduced Mr. Ed Hastey, Bureau of Land Manage-
ment California State Director, who briefly described some of the
land management problems on the California Desert. California being
v_the most populous State, with more vehicles per capita including
off-road vehicles, than any other State, means the BLM must cope
with people problems in addition to the traditional resource prob-
lems. He stated it had been difficult to inventory wild burros;
the number counted by helicopter or at waterholes he felt was con-
servative. Range conditions in some areas revealed that there were
too many animals. Increasing numbers of wild horses, especially
in the Susanville District, were causing additional range problems.
2
The next item of hunlnenH was tlie preflentnl 1 oiifl to the Board by
the following individuals:
Dr. Th ad Box, Board member
Dr. Robert Ohmart, Arizona State University (two presentations)
Lou Boll, Bakersfield District Manager, BLM
Tilly Barling, Natural Resources Specialist, Naval Weapons
Center
Jim Deforge, representing himself
Dick Weaver, California Department of Fish and Game
Dr. Milford Fletcher, Bandelier National Monument
DeLoyd Satterthwaite , representing the National Wool Growers
Association, the American National Cattlemen's Association,
the Public Lands Council, and the Nevada Wool Growers
Association
Lewis E. Carpenter, Sportsmen's Council of Central California
Bud Wiedeman, Society for the Conservation of Bighorn Sheep,
and representing Dr. Loren L. Lutz and Donald M. Swarthout
Mary DeDecker, representing California Native Plants Society,
Southern California Botanists, and California Natural Area
Coordinating Council
Walter B. Powell, California Wildlife Federation and Southern
Council of Conservation Clubs
Miriam Romero, Representing Dr. Richard Vogl, Chairman of the
Division of Biology at California State University in Los
Angeles; Patricia Nelson of Tujunga, California; and on her
own behalf.
James B. Thompson, Superintendent of Death Valley National Monument
Pete Sanchez, Death Valley National Monument
Jim Englebright, Wild Horse Specialist, BLM, Salmon District
Office
Belton Mouras , Jr., Animal Protection Institute
Peter Burk, Sierra Club
Lyle Gaston, representing himself
Pat Smith, American Horse Protection Association; Mr. and Mrs.
Howard Green
Mary Ann Henry, representing herself
Dr. William Blackmore, California State Veterinary Association
Bill Reavley, National Wildlife Federation and California
Natural Resources Federation
Dell 0. Clark, California Department of Food and Agriculture
Homer Harrison, Sportsmen's Council of Central California
The above presentations can be found in the Appendix.
3
Joyce Burk stressed the people of Los Angeles do not understand the
fragility of the desert. There is a need to educate people to the
fact that the desert does not respond or recover quickly from damage.
The problems the desert can incur from overuse must be shown to
people, especially in urban areas.
Shirly Moncsko spoke on behalf of Charlotte Gould who wanted humane
methods of rounding up horses and burros to take precedence over
economic factors. The most economical method might not be the most
humane way to capture excess animals.
Dean Slaughter of the Desert Protective Council stated that many
animal protection associations would not kill a single animal to
save the range. We must consider the fact that BLM is accused by
many conservation groups as being owned by the commercial interests.
Burro reduction can be brought home on a purely ecological basis.
He suggested that the Advisory Board and agencies heavily involve
the conservation organizations in efforts of publicity.
This concluded the statements presented by individuals from the
aud ience .
The Board also received a letter from Dana Allison of the American
Donkey and Mule Society, Inc., which is included in the Appendix.
One member of the Board suggested that in view of the pending Supreme
Court decision, some definite planning should be done in case the
Act is declared unconstitutional. If the Act is declared unconsti-
tutional, the Federal Government and the States have a great oppor-
tunity to get together and manage wild horses or burros under the
laws we do have.
The next meeting will be handled by the Forest Service and is tenta-
tively scheduled for Oregon. The Chairman thanked the people attend-
ing the meeting and said public support was needed for the positions
expressed at the meeting.
I certify that I attended the proceedings of the National Advisory
Board for Wild Free-Roaming Horses and Burros herein reported, and
that this is an accurate summary of the matters discussed and the
recommendations made.
(Date)
4
- '
Appendix 1, pg. 1
THE ECOLOGICAL IMPACT OF WILD HORSES ON IHE PUBLIC LANDS, BY
DR. THADIS BOX, UTAH STATE UNIVERSITY AND ADVISORY BOARD MEMBER
Currently, as of May 1, 1975, there are 48,658 horses and 5,183
burros using the public ranges and they are scattered over several
States in a number of districts on the public lands and I think it
would be somewhat impossible to discuss in detail the site speci-
fic nature of the impacts. What I would like to do today is to
talk to this population as a population that represents a unique
feature in the management of America's public resources. It's
unique in that it's the first time that a population of exotics
has been protected by law and it is the first time that a popula-
tion of feral livestock has been protected by law so they are out-
side of the rules of management that resource managers normally
work with in that they are not working with wildlife or wild ani-
mals, but really with a feral domestic animal.
This is a population that is increasing rapidly. It has increased
at a rate of about 20 percent per year, you get different figures
from different populations on the public lands, but as a whole has
increased some 122 percent since the Wild Horse and Burro Act went
into effect. I do not want to in any way negate or take from the
fact that each area is site specific and that the resource manager,
in a particular district, has a particular problem to live with,
but the data are really those of the individual districts and I do
not have them available and will not be speaking to site specific
situations. Instead, I will discuss what happens to a plant com-
munity when an exotic is introduced or when one is released from a
relatively stable situation. I'll talk some about the character-
istics of domestic animals, some about the characteristics of
horses, and characteristics of uncontrolled domestic or feral
populations .
At the risk of being somewhat pedantic, I would like to briefly
review primary succession or the evolution of plant and animal
communities. Any time that a community develops, it develops
slowly through time, under control of climate, the geological
materials, and the organisms available to modify that. It may
take literally centuries for a plant community to develop and at
each stage in its development there is a balance set up between
the animals eating the vegetation--the vegetation using the soils.
Appendix 1, pg. 2
So, we get a balance between plants, soils, and the animals using
them. Plant communities, indeed, many times are the result of the
large herbivores that eat these plants and you get succession mov-
ing from one direction to the other depending upon the diets of
the animals eating the plants and the particular plant communities .
Now, this is a nice theory in ecology. We have a lot of documented
cases where plant communities have developed under grazing pres-
sures of the bison in North America or 20 or so large ungulates
in Africa, but it has little use to the resource manager today
because usually the resource manager is working with a situation
that is much more volatile and much more direct. He is working
with a community that may have been relatively stable with only
the ups and downs of native animal populations. He's working with
a community that has the impact of an introduced exotic and that
exotic, in the beginning, was usually domestic livestock and the
animal that we're dealing with today is a feral member of that
introduced exotic. So, the problem of the resource manager today
is different from that of dealing with a wildlife population.
There are some very definite changes that occur when an exotic is
introduced or when an exotic population is allowed to increase
very rapidly in a short period of time such as has happened with
the wild horse population in the United States. The first thing
is that plant communities change in an orderly way when they are
grazed. The particular preferred plants of the grazing animal
tend to lose vigor, little growth takes place, and reproduction
is lowered. Plants decline in population and the animals then
change their diets to a less preferred plant and the whole process
starts over again. The animals start with the plants that they
most prefer then they go to the next preferred plant, and so on.
There are some distinct differences between wild and domestic
animals in this category too. In most cases, wild animals do not
have the ability to switch from one plant to the other very rapidly
There have been experiments with deer, for instance, where deer and
livestock have been put into competition and the livestock changed
their food habits, but the deer did not and usually the deer popu-
lation died off. Even more critical are some of the large ungulate
in Africa which eat only a certain part of the plant, a very narrow
niche, and if you take that niche away from them the population
decreases .
Appendix 1, pg. 3
If we look at the characteristic of domestic animals and their
relationship to vegetation, it is different from that of the wild
animal. For instance, domestic animals are the product of con-
trolled evolution or breeding. They're bred to utilize a wide
variety of forages, they're bred to do a wide variety of work.
Some experiments with cattle on Texas rangelands, for instance,
show that you can take cattle directly off the range where they're
eating native plants, put them in a feedlot eating 9 pounds of
concentrate a day for 6 weeks, and put them back on the range with
very little adverse effects to the animals themselves. Those of
you who own horses know that you can switch them rather rapidly
from one plant to the other or one food to the other. As I pointed
out earlier, native animals cannot shift as rapidly and, therefore,
usually lose out in a competitive arrangement with a domestic ani-
mal. Domestic animals usually outcompete because they have a
wider range necessary for survival.
Now, if we look at the domestic animal that we're considering
today, the horse, they have some particular situations that make
them adapted to the Western public lands. The horse has a jaw and
tooth morphology that allows them to graze very close to the ground.
A horse can graze as close as a sheep; he has two teeth, one in
the top and one in the bottom, that allow him to nip things very
closely. They have an evolutionary build to them that allows
close grazing, they have feet that concentrate large amounts of
pressure in a very small area as far as the weight to hoof ratio,
they have a caecum that allows them to ferment rough forages, and
abilities that allow them to paw through snow and other obstacles
to get to the forage. If you add to these morphological charac-
teristics the ability to switch forages that I mentioned earlier
and an animal that's large enough to resist most of the predators
on the range combined, they represent a harvesting organism with
the potential for destroying the habitat exceeded only, perhaps,
by the donkey, which will be discussed later. What I'm saying is
this harvesting machine, the horse, has the destructive potential
that is probably exceeded by no other domestic animal, sheep and
goats included.
The consequences of uncontrolled populations are well known in
biological circles to the managers themselves. If you get a con-
trolled population, as it reaches carrying capacity, then the
carrying capacity is not reduced at all. You may get some fluctu-
ations around a carrying capacity as you reach the upper level of
the population, but you're able to maintain the basic carrying
Appendix 1, pg. 4
i a pm l Lv of the land I tael f. However, when yon get uncontrolled
populations, either domestic or wild animals that are allowed to
exceed the carrying capacity for any short period of time, the
carrying capacity is actually lowered because some plants are
killed out and soil erosion takes place so that the basic carrying
capacity of the land itself drops and the fluctuations of the ani-
mals are much more dramatic. They drop much lower and before the
land is able to recover, the cycle is extended out much longer
with uncontrolled populations and is much more dramatic.
If we look at the ecological consequences of these uncontrolled
feral animals on rangelands, I think that we can predict, in
general, some rather drastic changes. Again, I don't want to take
away from the site specific nature which you will be hearing about
later from different people. The first thing that we can look for,
as far as ecological impact where horse grazing is concerned, is a
reduction in vigor and destruction of those plants most palatable
to horses. We can certainly predict, and see in many cases, a
change in plant composition of the range for plants less palatable
both to the horse and to other animals as well, and so you get a
change in plant composition. You can also predict, if the popula-
tion is allowed to continue to grow, the removal or crowding out
of wild animals, and I mentioned their more narrow niche segrega-
tion in the community, they will probably be impacted more than
other domestic animals, but eventually you will see a loss of other
domestic animals from the range and finally, soil loss, watershed
deterioration, and eventual die off of the exotic animals them-
selves, in this case the horse. We could end up with a permanently
lowered carrying capacity of the Western range, eventual die off of
large herds of horses themselves, and loss of both the wild and
domestic animals now using much of the public range. This is not
a pretty picture, I'm not trying to scare anybody. The steps may
vary from one place to the other, but in the end, what I'm trying
to point out, in the end the horse has the ability, both from an
evolutionary standpoint and a practical management standpoint, of
doing himself in and doing the range in that he is using.
The ecological effects of the horse now on the Western range varies.
It varies greatly because in some areas where populations are
approaching or have, indeed, increased past the carrying capacity,
this rather bleak situation that I have described is already occur-
ring and in others it may not be discernable, and if there are ade-
quate amounts of their more palatable plants, you see no real change
except a great increase of horses.
Append ix 1 , pg . 5
There is an argument going on in the scientific community the
world over dealing with "to manage or not to manage," "to control
or not to control." This is going on in Yellowstone National Park
with elk, it's going on in a national park in Kenya with elephants
it's going on the world over and you can find very reputable biol-
ogists on both sides of this argument. It depends upon what philo
sophical stance you take. But the point that I want to make is
that even though you have this argument with native animals, this
same argument does not apply to a feral exotic population as we
have seen with the goat in Hawaii, with the feral hog in the
Southeastern United States, and with the feral donkey and camel
in Australia; the chances of habitat destruction and severe soil
deterioration are much greater with a feral domestic animal than
it is with a wild animal.
Appendix 2, pg. 1
THE ECOLOGICAL IMPACT OF WILD BURROS ON THE PUBLIC LANDS, BY
DR. ROBERT OHMART, ARIZONA STATE UNIVERSITY
I might preface my talk by saying that Dr. Hungerford was unable
to make this appearance due to his wife's illness and the observa-
tions that I will be talking about today are solely my own observa-
tions and those of my biologists that work for me and they do not
represent what Dr. Hungerford might have said. I really have no
idea what he might have presented at this meeting because I was
unable to get an outline of his presentation. These remarks that
I will be making today are based solely on our observations and
research information that we have obtained in the last 2 years since
we have been working under contract with the Bureau of Land Manage-
ment on looking at wild burro populations. Also, some of my obser-
vations will come from national park land6 where I have a biologist
doing work on Bandelier National Monument.
Dr. Box has covered a little bit of the information that I had
planned to discuss, but my observations or the observations that
I will be talking about today are based primarily on three areas
of national resource lands--southeas tern California, the Chemehuevi
Mountains in particular; Arizona, the Bill Williams Mountains, the
Kofa Game Range, and various other areas in the State where burros
occur; then in New Mexico in Bandelier National Monument where we
have a little bit of information at present but certainly not enough
to make any concrete statements.
Phil osophically, then, any large herbivore on an area is going to
consume quite a bit of herbage or quite a bit of herbaceous material
on a daily basis. There's simply no way you can get around this
fact. If primary net productivity, in other words, if material
that's present out there is limited, then the carrying capacity of
these large herbivores will probably be reached relatively quickly
if reproductive capabilities and other environmental pressures on
the population are not severely restricting the population itself.
The animal we're talking about today does primarily inhabit, except
for Bandelier, areas which have low primary productivity. In other
words, the plant production part in these environments is very low.
The burro is interesting from the standpoint that we see it in the
fact that it appears that even though it is in an area of low pri-
mary productivity, the populations are continuing to grow which
means that probably and undoubtedly more of the material that's
Appendix 2, pg. 2
being harvested by these animals on an annual basis is more ma
than is being produced on an annual basis which means there is
one source for this material and that's material that has been
over the many years those plants have been growing in the dese
have some slides in a few minutes and I can show you some spec
examples. Dr. Box talked in generalities, 1 want to talk in s
specific areas where we're seeing some of these kinds of impac
and point out to you where these are occurring.
teria 1
only
stored
rt. I
if ic
ome
ts
I have yet to see an ultraextreme case of overutilization. What I
mean by ultraextreme would be total elimination of the plant com-
munity. I have seen one area in the Bill Williams Mountains near
Alamo Lake where paloverdes were highlined a few years ago and
chollas are in the process of being highlined today. Any time you
get cholla cactus being highlined you're obviously utilizing much
more of that plant community that that plant community can eventu-
ally afford which means that vigor of these plants is going to be
reduced. You're going to see major modification of natural ecosys-
tems or desert ecosystems--whether they're notural or not, one can
argue about that. We are, in the near future, going to see major
altercations of the ecosystems. Burro populations are so dense in
this area that it's one of the few areas that I know of where a
burro has actually bitten a Park visitor, This is in the Alamo State
Park. The animals are conditioned to human interactions in this
area and raid the garbage cans and this kind of thing.
About 3 weeks ago we collected two animals from this area as part
of our research efforts in looking at wild burro populations and
our nec ropsy, wh ich took a little over 3 hours for each of the ani-
mals, revealed that both the jenny, about 5 or 6 years old, and
her colt, about 4 weeks old, were in excellent condition. We did
a necropsy on each of the animals. We opened all of the major
arteries and veins of the jenny and of the colt, obviously the
colt was so young that you would expect a very healthy animal, but
the jenny had no indication of sclerotic deposits in any of the
major arteries and veins. All of the organ systems in the body
were in excellent condition, here, again, indicating that these
animals are still surviving and doing quite well off the stored
resources in this desert environment. Three other jennies observed
in the area all had foals, again indicating that energy for main-
tenance of the animal alone plus reproductive energy is still avail-
able in that environment, which means that they are still harvesting
large portions of that environment that were stored over a number
of years ' bui ldup.
Appendix 2, pg. 3
Obviously, if one looks at this environment it's quite altered
and there may well be major alterations in native species' popu-
lations, obviously both plant and animal. This was historic range
of desert bighorn sheep. There have not been desert bighorns in
there during our study so there is no potential problems with big-
horns at present in this particular area around the Alamo Lake of
the Bill Williams.
Over the areas we are talking about today, we are observing between
20 and 25 percent increase in burro populations between 13 and 18
months. I talk of 13 and 18 months as opposed to an annual cycle
because burros do not reproduce greater than 20-25 percent in an
annual cycle because the gestation period is 12 months. There's
a month that occurs before postpartum estrous is undertaken by the
jenny, so the colt has to be at least 4 weeks old before she will
rebreed and, in general, every jenny that we've observed will
rebreed within 13 to 18 months which is only 1 to 5 months after
parturition. It is not uncommon to see a jenny with a 6- to 8-week-
old colt or maybe even a 12-week-old colt beside her, pregnant, and
even having a three-quarter grown animal in company which is a pre-
vious foal also. We see jennies maturing at a year of age. They
usually are bred by the time they're 1 year old, which means they
will drop their first foal when they're 2 and every 13 to 18 months
after that they will drop another foal, again implying and indicat-
ing the tremendous reproductive capabilities of these animals. In
spite of the fact that primary productivity is not adequate to
support them, they're still utilizing stored materials that were
laid down there in years past and some of these may be many years
past because of the erracticness of rainfall in the environments
that we are talking about. Here, again, I exclude Bandelier which
is a very highly productive area compared to desert situations.
Bandelier is a pinon- juniper community and not desert habitat as
we see in Arizona.
In this Alamo population, they're still reproducing at a high rate,
they are certainly altering the plant community, and they are living
off of stored resources.
In the Chemehuevi Mountains in California, we have a herd of burros
in there of approximately 70 to 80 animals and these animals do not
appear to be modifying the desert community at this time to any
great degree. We still see reproduction going on in plant commun-
ities. We see young paloverdes coming in, we see burrobush (Ambrosia
Appendix 2, pg. 4
dumosa) being beaten down at some places, but there are still young
plants coming in, there are still some plants that are not being
altered, but reproduction in burros is continuing at 20 to 25 per-
cent which implies to us that it's not going to be long before
we're going to see this destruction of vegetation unless some con-
trol is initiated fairly soon. Here, again, we're talking about
historical bighorn sheep sites. They were in there but they're
gone now. We saw two when we initiated our study in that area
but it may well be that burros have eliminated them. It's circum-
stantial evidence. I have no evidence to indicate that burros and
sheep are actively competing with one another. I say we have no
definitive evidence. We have some good evidence to indicate that
they are utilizing similar resources which we will look at this
afternoon.
The Chemehuevi area is one where we feel that major modification
of these plant communities has not begun to be apparent.
In the Bill Williams Mountains, which is another area I'm talking
about, we are seeing major modifications of plant communities.
SLIDES
To familiarize you with the area that we will be talking about, you
can see Topok in the upper lefthand corner, the Chemehuevi Mountains
just below that, Trampas Wash, which is an area that we have about
2 years of data from on the California side, then if we drop south
to Lake Havasu City down into the Aubrey Hills, and down in the
righthand corner you can see the Bill Williams Mountains. Unfor-
tunately, Alamo Lake, the area that I'm talking about, is not
included on this map but it would be on down the Bill Williams
River and Alamo Dam and Alamo Lake, so really we'll be talking
about this area and another area just a little further south and
east. We have surveyed this entire area from approximately Topok
south to the Bill Williams River where the Bill Williams and the
Colorado River confluence occurs. It is approximately 500 acres
of land mass in this area and our burro populations at present are
estimated to be between five and seven hundred animals. So, we
have at least one animal per section and in the Bill Williams Moun^
tains we have concentrations of approximately seven to ten animals
per section at certain times of the year.
Appendix 2, pg.- 5
Here are some of the animals in the Bill Williams Mountains. You
can get some idea of the vegetation. You can see the jenny there
that has been color collared. There's approximately 90 plus burros
in this area.
Here is a burro working over a paloverde tree. In this particular
instance, the burro is clipping the cambium from the limbs them-
selves. You can see from this shot the kinds of stored materials
the animals are taking and this removal of cambium is obviously
going to kill these branches that have been clipped in this manner.
Also, you can see branches lying around here that have been pulled
down.
Here's another picture of an animal working on a tree.
Here's a paloverde tree that's been worked over by burros. We
have some in even greater destruction than this where there's sim-
ply just the trunk sticking up. The animals have pulled down all
of the limbs. You can see that they pull the limbs down and break
them off. Paloverdes are simply not adapted for this kind of brows
ing behavior where great pressure is pulled against these limbs.
Paloverde is a brittle tree and simply will not tolerate hard pull-
ing by this exotic large herbivore.
Burros will also eat cholla as you can see by this browsing animal.
The next picture shows you indications where it's removing cholla
stems. There's no question burros have a tremendous capability of
consuming virtually anything in this environment, from creosote to
cholla and the like.
Here's an ocotillo that's been worked on by burros. We have not
seen any ocotillo dying from burro utilization. What happens,
usually, is a little group of ocotillo stems reappear ing--you get
a weird physiogamy of the plant after burros have worked on it--
but usually a few of the seed stalks do make it up to the point of
where you get inflorescences, form, and this kind of result.
Here is a burrobush (Ambrosia dumosa) that's been worked over by
wild burros. You can see the heavy hedging of this plant. This
is one of their favored plant species and, as Dr. Box pointed out,
what we refer to frequently as "ice cream" plants in the environ-
ment of animals. This is one of their "ice cream" species.
Appendix 2, pg. 6
Here are some of the trails that burros are making. This, obviously
is going to have important implications on soil movement, loss of
what little, if any, organic material, but certainly heavy soil
erosion and this result if you are in areas where heavy rainfalls
occur .
Our annual rainfall in this area is about 3 inches a year. Most
of this comes in the winter but is very sporadic in its falling.
If you told a rancher that he had a wonderful ranch out here with
3 inches a year on it, he would look at you rather askance. The
burro can utilize this area very well. He has no problem, at least
as we see it thus far, in finding enough energy to provide him with
maintenance energy plus reproduction. Obviously the first thing
the animal has to take care of is maintenance energy and if there
is enough energy left over, then reproduction will go on and it's
obviously going on in the burro populations that we are examining.
Here is a trail that's come down a very steep slope and you can see
the massive amount of soil that's been removed there to the lower
part of the slope. Here, again, if we'd had a lot of rainfall
these areas would really be heavily eroded and we'd have small
arroyos beginning to form and the like.
END OF SLIDES
As Dr. Box pointed out, there are specific areas that managers are
going to have to examine. In some areas we've seen in Arizona,
there 're detrimental effects underway. In other areas, it appears
that the burro population is not drastically affecting the area
although, unfortunately, some of our native species are absent from
these areas that historically were there. Whether or not the circum
stantial evidence can be based on fact remains to be seen.
There are also other animal species that I think we have to be con-
cerned about. Burros were given the opportunity to prefer grasses.
This afternoon I will point this out from research data we have.
Desert tortoises are dependent upon grass as a species and I think
where desert tortoises and burros occur sympa tr ica 1 ly , you may well
see the elimination of desert tortoises. We're certainly going to
see alterations in small mammal populations and large mammals such
as bighorn sheep may be eliminated by the presence of the burro in
an area. We don't have definitive information yet. We have some
good suggestive information on food habits which indicates that
this could be a possibility. The definitive data is still lacking
in this particular problem.
Appendix 2, pg. 7
Burros are certainly having an impact on areas and unless we can
get some control on some of these areas their populations are going
to drastically alter the native desert ecosystem. This is, then,
a philosophical decision. Do we want the ecosystems preserved in
their natural form or do we want to allow burros to modify them?
This is the management agencies' decision and I think that the data
that are coming forth now indicate that burro populations are going
to have to be managed, controlled by some means or another to pre-
serve not only the ecosystem but to preserve the burro population
itself because it certainly can destroy an area to the point of
where its own populations are going to be heavily hit by disease,
starvation, and lack of reproduction and reduction in the vigor of
the population itself, not only to the point where we would certainly
eliminate native wildlife in some of these areas.
■
Appendix 3, pg. 1
BURROS ON AND ADJACENT TO THE CHINA LAKE NAVAL WEAPONS CENTER, BY
LOU BOLL, BAKERSFIELD DISTRICT MANAGER, BUREAU OF LAND MANAGEMENT
Wc have recently completed a first draft of two very important
documents which will form the basis for our management of wild
burros. Both of these are in the initial review process. One,
the environmental assessment, the E.A.R. (environmental analysis
record) on impacts of burros on national resource lands, and
second, a burro habitat management plan. I'll confine my remarks
to the management plan since this will set the stage here in the
Bakersfield District for the actions we feel we must take to keep
the lid on a potential powder keg.
Let me caution that the hard data for arriving at this first cut
management plan is less than precise. It incorporates current and
aged information gathered by many individuals in the Bureau of Land
Management and it has had the benefit of some general and specific
consideration by adjoining agencies. It has not had much public
exposure as yet. It will. We will not draft the final plan until
we've had public exposure.
You've been provided with some handout material which is some
excerpts from the draft management plan, the top sheet of which is
a map of Inyo County. Our burro population exists in Inyo County
only and on this map we have identified 12 management areas which
are the areas and habitats that we feel certain were inhabited by
burros in 1971. The second page has our estimates of existing
burro populations, a total of 820 full-time resident burros with
another 835 migrating from other ownerships to national resource
lands for at least part of the year. The last page of the handout
material tabulates the areas we feel comprise the herd areas by
various ownerships. A quick calculation reveals that we have about
one burro per two sections of national resource lands or, if we
figure the migrants, one burro per section.
I can almost hear the wheels buzzing, how can one burro or two
burros per section constitute a problem? I'm sure that all of you
realize that these herd areas are the maximum extent possible
inhabited by burros whereas the problem manifests itself at criti-
cal times of the year in critical areas, namely, around and within
1 mile of water during the hot, dry summer months. Data indicates
Appendix 3, pg. 2
that approximately 83 to 90 percent of burro use during July,
August, and September occurs within this 1-mile radius of water.
Our files are replete with photographic evidence of the type of
destruction that you have already seen some slides on and you'll
see more of these concentrations of burros near and around water.
You'll see some more of it tomorrow.
The other two pages are brief management recommendations for each
of the 12 herd units. For the sake of brevity, I will quickly
touch on four areas we consider to be the problem areas.
Number one is the area from Trona north to Water Canyon. On the
map, it's herd unit number 5. Here, we recommend reducing burro
numbers by 50 percent on both Navy and national resource lands and
not authorizing further domestic livestock use in the area.
The second area, Hunter Mountain-South Saline Valley area, herd
area number 10, we recommend reducing burro populations by 40 per-
cent and maintaining cattle use at present levels or less.
The third area, Waucoba Wash-Jackass Flats-Marble Canyon area,
herd area number 11, we recommend reducing burro numbers by 40 per-
cent and maintaining cattle use at present levels or less.
Four, the Sand Spring-Last Chance area, herd unit number 12,
reduce burro populations by 50 percent and, for monitoring pur-
poses, requiring ear tags on all of the livestock using the area
so we have a handle some day of who's eating what.
These are the four of the most critical areas of the largest recom-
mended reductions, 40 and 50 percent. Our initial management ideas
are predicated on the premise that healthy herds and healthy habi-
tats must be maintained during this most stressful period of the
year. We, therefore, feel that the areas within 1 mile of water
must be managed accordingly. This is the critical, suitable burro
range and the burros must be managed to achieve a healthy habitat
within this area.
A short dissertation is probably in order on how we propose to make
these suggested reductions in existing numbers. We will begin with
water trapping where we can set up the necessary facilities. Cap-
tured animals will be impounded and offered to the public under
Appendix 3, pg. 3
proper procedures and with the required strings attached. Where
no water trapping opportunities exist, and I'm not certain none
do, we will have to reduce by direct methods, including shooting.
Tranquilizing methods may also be possible where we can get the
equipment in to transport the drugged animals out. 1 would be
less than honest if 1 didn't think we would have to shoot some
burros. I can guarantee that we will be selective, keeping in
mind the objective of maintaining a healthy herd.
I'll close by saying that the plan that we've put together so far
is probably not as precise as many would hope. I would also sub-
mit that the science of range or habitat management is also not
precise except under the best of controlled conditions. In manag-
ing wild land habitat inhabited by wild burros, which we all know
are next to impossible to count, we must finally arrive at that
ideal management situation, not by collection of tons of data, but
by taking initial action coupled with well designed trend studies
which will show us which direction we're headed and then following
up with subsequent action.
Appendix 3, pg. 4
Appendix 3, pg. 3
TABLE 2: HERD MANAGEMENT AREAS
AREA
ESTIMATED NUMBER (NRL)
No.
Location
Resident
Migratory
1 .
Chicago Valley
5
0
2.
Panamint Range
150
300
3 .
Towne Pass Area
50
75
4 .
Slate Range
100
75
5.
Trona North to
Water Canyon
100
80
6.
Argus Range North
of Slate Range
75
50
7.
Darwin Area
20
0
8.
Centennial Valley Area
15
25
9.
Dai-win PI ateau-Santa
Rosa Hills
15
0
10.
Hunter Mtn. - South
Saline Valley
100
100
11.
Waucoba Wash - Jackass
Marble Canyon Area
Flats-
140
95
12.
Sand Spring - Last Chance
Area
50
35
820
835
NOTE
: The above numbers do
not
necessarily indicate total
numbers within
the Herd Management
Area
since part of the acreage
administered by
another agency may have
resident burros that do not
migrate onto
BLM administered land. However, the sum of the resident and migra-
tory numbers would indicate the approximate maximum burros that
could be found on NRL at any one time.
(26)
&UG ^7?
Appendix 3, pg. 6
INTERIM BURRO MANAGEMENT PLAN
1 . Flat recommendations on all herd management areas,
1. Coordinate with other agencies where necessary.
2. Install photo trend plots to monitor use.
2 . Problem Areas
#5 Trona North to Water Canyon
Recommend :
A. Do not authorize further domestic livestock use in the area.
B. Reduce numbers by 307. on both Navy land and NRL.
#10 Hunter Mtn. -South Saline Valley
Recommend :
A. Require ear tags on Roy Hunter's cattle to facilitate monitoring use.
B. Reduce burro population by at least 5QZ
#11 Waucoba Wash-Jackass Flats-Marble Canyon Area
Recommend :
A. Reduce burro numbers by A 07.
Si„ • .
B. Maintain cattle use at present levels or less.
#12 Sand Spring-Last Chance Area
A. Reduce burro #s by 50Z
B. Require ear tags on Henry Howison's cattle to facilitate monitoring.
C. Periodically check flow at Little Sand Spring, correlate with
precipitation records at Death Valley.
3 . Less Crucial Management Areas
#1 Chicago Valley Herd
A. Do not allow burro population to increase beyond 10 head
#2 Panamint Range
A. Reduce resident burro numbers by 507. on NRL. If the
remaining burros migrate to DVNM then further reduction
may be necessary since DV ' s policy disallows introduced species.
Appendix 3, pg. 7
#3 Towrie Pass Herd
A. Do not allow herd to Increase above eat. 50 present on NRL
as of August 1975. If resident burros migrate to the Monument,
then reduction may be necessary.
9U Slate Range Herd
A. Reduce numbers by 301L on NRL
#6 Argus Range
A. Maintain population at present numbers or less.
#7 Darwin Herd
A. Do not allow burro numbers to increase beyond the present
(August 1975) population of est. 20.
#8 Centennial Valley Herd
A. Reduce numbers to maximum of 10 burros
B. Monitor Thornburgh's livestock, and if necessary make reductions
to allow for a burro herd.
#9 Darwin Plateau Herd
A. Maintain burro population at 15.
B. Develop water for better animal distribution
-2-
TABLE 1: LAND STATUS BY HERD MANAGEMENT AREA
Appendix 3, pg. 8
NOTE: The acreage figures were calculated by using a dot grid.
NRL
NWC
DVNM
FS
P or S
= National Resource Land
= Naval Weapons Center Land
Death Valley National Monument Land.
= Forest Service Land
= Private or State Land
CNI
U
3
00
D
<
Appendix 4, pg. I
BURROS ON AND ADJACENT TO HIE CHINA LAKE NAVAL WEAPONS CENTER, BY
MRS . TILLY BARLING, NATURAL RESOURCES SPECIALIST, CHINA LAKE NAVAL
WEAPONS CENTER
Here on the Naval Weapons Center, we are aware of our regional
position with respect to the public lands, the national resource
lands, and to lands of the Death Valley National Monument. Also,
we have a fairly close relationship in space with two of the
national forests. However, fortunately at the present time, these
particular portions of the forests do not have a burro problem.
SLIDES
Let me orient you as to where we are right now. Those of you who
came in by air last night may feel a little lost, like you're out
in the middle of the Gobi Desert. You're really not, you're right
here at China Lake. We are about 90 miles north of Mojave, about
125 miles north and east of Los Angeles, and about 125 miles north-
east of Bakersfield.
The Naval Weapons Center has two land areas--the China Lake Range
complex, a connecting road, and our Randsburg Wash-Mojave B com-
plexes. These are on the Mojave Desert with some Great Basin
enclosures in the northern portion. As you can see, other than
down here and in the large playa that's called China Lake, we are
a mountainous area. Average elevations in this area are above
5,000 feet. Over here we're a little lower- -average elevation
runs between about 1,400 and up as high at 5,500 here in the Slate
Range .
This is Panamint Valley which is Bureau of Land Management, and
then a few public lands, and over here within a mile of our border
lies Death Valley National Monument.
This is why we feel we have a regional management problem rather
than one that is dependent on local jurisdictions.
This is our general location of the Mojave Desert in relation to
the major desert systems of Southwestern North America. The desert
is a place of great variety, much of it is very austere, much of
it is very dry. It was not always so. Not always did we have the
Append i x 4 , pg . 2
sand dunes drifting toward the bottom of the dry lakes or these
great playas which have dried out over a period of probably about
a million years. We are a part of a large system of drainages
that existed in the Pleistocene era and were the result of a very
different climate and the result of glaciation in the Sierra-
Nevadas and even earlier this area drained to the west rather than
draining to the east. At the present time, the drainage of this
particular system is toward the east, toward Death Valley National
Monument which was the termination of a chain of lakes. I'm not
showing these slides to you to give you a lesson in geology, I'm
showing them to you to give you an appreciation of the type of
evolution that has determined the flora and the fauna of these
desert areas of ours and why they cannot tolerate the intrusion of
exotic species that did not evolve in these systems.
Much of the desert vegetation is very
of it is dead and some of it is quite
Weapons Center three major vegetative
pied by burros--the creosotebush scru
area, and in the higher elevations th
lot of these shrubs take a long time
ment. Our average precipitation here
less than 3 inches a year. Other are
elevations probably go as high as 9 i
areas which probably receive less tha
you an idea of the length of time it
develop--one from a moister climate a
c 1 ima te .
sparse and very dry. Some
primitive. We have on the
communities that are occu-
b, the joshua tree woodland
e pinon- juniper complexes. A
to grow in this desert environ-
at the China Lake Base is
as in the range in the higher
nches a year and we have some
n an inch a year. This gives
takes a common sagebrush to
nd one from a much drier
This is one of the problems in imposing an additional biotic entity
on the desert vegetative systems. The production is simply not
there .
Th is cliffrose is a pretty dramatic example of a plant more than
200 years old. A fairly common shrub in the higher elevations.
If you think for a minute what's happened in the world during those
years, it gives you some idea of the length of time it took that
shrub to develop and mature.
There's 50 years of growth rings.
Appendix 4, pg. 3
It is for this reason that we feel that we have a problem with
the exotic species that exist on our lands. At the present time
the feral horses are not a management problem. The population is
very stable. The areas that they inhabit are fairly restricted,
they seldom come down below 4,000 feet on our ranges. We have
about 200 head. However, we do have imposed upon this very tight
cycle of systems within the Mojave Desert a population of feral
burros. The population on the Naval Weapons Center at the present
time is almost a thousand animals. They are split between our two
areas and I'll point out some of the differences in the populations
as we go along.
I don't mean to give you a lesson in ecology, I simply want to
remind you that there are certain essential facts in relation to
the existence of any species on the desert that one cannot ignore
if we are going to have the diversity of wildlife and the diver-
sity of vegetation that the desert can support as it has evolved.
Atmosphere is very important to all life, of course. Living space
is another and in the desert where the shrubs are few, the compe-
tition for shelter and nesting spaces is very keen between some
species. And food, probably, is the highest level of competition
that these native desert species undertake in order to make a
living.
We have the delicate balance and we have four factors we must con-
sider if we are going to be managers. We must look at the pro-
ducers, we must look at the consumers. We look at the variables
that can affect this and there's one sure thing you can say about
the climate of this upper Mojave Desert, it is erratic. We may
have 3 years with less than an inch of rainfall per year, then we
may have 9 inches the following year and the natural ecosystems
seem to be geared to keep up with this provided they are not inter-
ferred with by human uses, with the introduction of exotic species,
or the invasive pollutants that seem to be spreading out further
and further from the urban areas.
The desert, when it is in full production, is quite a beautiful
place. I wish this were the time and opportunity to show you some
of the beauties of the desert and some of the flowers it produces
in the spring. But they're important not only because they please
our aesthetic senses, but they are important because they are the
very basis of the life chain. They provide the green plant mate-
rial on which young birds and animals must feed and they provide
the seeds on which other species must feed.
Appendix 4, pg. 4
We get some of our precipitation in the form of snow in the higher
elevations. We get about two snow storms a year up above 5,000
feet. A great deal of our precipitation comes from summer thunder
showers --some pass over and some land on us and when they do we
have a little moisture in dry washes that is eagerly used by a
whole variety of wild and feral animals.
People lived in this desert for a long, long time. The archaeol-
ogists are pushing the threshhold of human occupation here as far
back as 10,000 years or more. And they left us some records of
the game and the animals they themselves sought or considered
important to their way of life. The desert bighorn sheep appears
almost invariably in all of the large petroglyph displays. And
they also knew the predators such as the mountain lion. But the
sheep again and again indicate to us that this was a very important
animal to the economy of the early peoples who inhabited these
desert lands. This is true not only of this area, this is true of
almost all of the areas in southern California and Nevada where
this rock art is found.
What's happening here and what has happened? About 1860 the miners
started coming down through the highlands of the Cosos and the
Argus Mountains. They were prospecting for gold and silver. They
were seeking to make a living out West and they brought with them
a style of architecture which we treasure as a historical resource,
and they brought with them some livestock. And when they left,
they didn't take their livestock with them. Many of these animals,
probably, ran away from their keepers, were turned loose, or aban-
doned. It is also recorded that in several areas where the charcoal
industry was thriving, in order to support the mineral industry in
Darwin and some of the larger mining towns, that there actually
were farms where burros were raised in order to supply the trains
for the charcoalers to transport the material from the charcoal
camps into the mining towns.
The burro is a clever animal, the burro is a durable animal, the
burro is a resourceful animal. He is also a very intelligent ani-
mal. One of the problems here on the Mojave Desert is that the
burro has been too successful for its own good and for the good of
the rest of the biotic community. We have them in great numbers
here on the north ranges, the China Lake ranges. We probably have
in the neighborhood of 450 at some time of the year. They wander
back and forth between the Argus Range and portions of the Pana-
mint Valley.
Appendix 4, pg. 5
The Slate Range is an extremely arid range. Springs and water
sources are almost nonexistent. There are two water sources, two
springs, that are 12 airline miles apart in this area. The next
nearest water is some 20-22 miles. This area supports about 400
burros. Let me show you a little bit of what has happened here.
This is one of the waterholes. Peak produc t ion--2 gallons. Here's
the other one and it's very likely to be dry in July or September.
Here's what happens when the animals concentrate on the waterholes.
This is in the vicinity of Amity Spring, the first waterhole that
I showed you. Every hill that you fly over or look at in that
area within about 12 miles of those waterholes shows this kind of
trailing, and the trailings run between the waterholes as well as
both sides of them. I often tell visitors that if they know
desert vegetation at all, they just sort of follow it on a down-
ward size and they can find water if they are in burro country.
I could go on and on with these kinds of slides for an hour and
not repeat myself on the locations where they were taken.
What's happening out there? This is the type of vegetation that
we are finding as far as 2-3 miles out from the water sources. We
performed a study here under contract several years ago and we
found damage to the forage plants as far as 7 miles out from the
waterholes, some plants completely missing from the system.
Here, again, the burros are reduced to eating creosote during dry
years when vegetative production is down. This year they seem to
be eating mostly on cheesebush. Browsing on creosotebush is occur-
ring in some areas because we did not have a good production year
for vegetation.
Another nice habit the burros have when they are not eating the
plants is wallowing and trampling them. They're great loungers.
We have a very hot climate during the summertime--temperatures go
up around 114, 115. The burros shade up in the canyons during the
heat of the day and they mill around and trample. You see here
some old atriplex bushes that are in an area where the burros sim-
ply hang out in order to cool themselves during our hot summers
and this is what's happening to the vegetation there. It is
destroying, of course, cover and food material for native rodents,
it's destroying nesting sites for native birds. It's a pretty sad
pic ture .
Appendix 4, pg. b
Here's one of their wallows. They roll continuously in the dust,
particularly in the hot weather in order to remove external para-
sites from their hides.
Again, an aerial view of the vicinity right around Amity Spring.
Burros don't exist in small batches out here. They gang together.
We see as many as 25-30 in a single bunch. There doesn't seem to
be any particular pattern to the numbers we see together. We may
see one or we may see 40 in the same area.
Here's a picture of a burro coming up to visitors seeking a handout.
This is the kind of problem the National Park Service is having
along the roads in Death Valley National Monument. I was on my
way to a meeting in Death Valley just a couple of weeks ago and
right out on the main highway was a burro that had been hit by a
Volkswagen. After sundown, with their dark coloring, these ani-
mals are extremely difficult to see and they consider they have
the right-of-way once they get on the roadway. Those of you who
make the field trip tomorrow may have some of them contest you for
the right-of-way going up one of our canyon roads.
Starvation problems are not pretty to look at, particularly when
you're looking at managing the entire picture for the benefit of
the native animals and also to preserve such burros as the whole
ecology can support.
This is what we found in the year 1969 when we made application
and attempted to do an intelligent burro reduction program out in
the Slate Range area.
We feel that a reduction and management program from firsthand
point of humanity is a better way to go than this starvation situ-
ation which we are going to inevitably run into as the vegetation,
the food material, becomes almost nonexistent for all wildlife and
for the feral animals out there.
We have some options. We can look at this. . .
. . . and we can llok at this . Burros upon burros upon burros. We
even have white ones out there. As a matter of fact, on our north
ranges, we even have two mules.
Appendix 4, pg. 7
And it's not unusual to see a jenny running with a mare band.
Here's total production of that shrub at the height of the growing
season.
Another picture of total production. It doesn't leave much for
anybody else since the burro is the largest and the dominant ani-
mal out there.
This is the waterhole after the burros have been in there in the
morning.
These are our options. The native predator such as the golden
eagle which nests in many areas because of the remoteness of our
lands and the fact that they are not disturbed.
We have to make up our minds as managers where the tradeoff is
going to be.
The prairie falcon is beginning to be a bird in much trouble. We
happen to have a fairly good population of them and a number of
known active nest sites.
The whole system is disturbed because of the existence of one
foreign animal in this land.
Even the rodents. And when the predator-prey relationship becomes
disturbed, the ecosystem follows when the habitat is destroyed and
the quality of the habitat is reduced to simply barren ground.
Then we know we have a lot of trouble and we must do something and
we do not have a long time to wait to do it.
This is a desert area that is not used by burros and it's quite a
contrast to the barren grounds that I've been showing you.
END SLIDES
This is our story. We feel the problem is a regional one. We
feel that only through cooperation with the Bureau of Land Manage-
ment and the Park Service in this total area can we achieve the
type of desert ecology that the area should be and evolved as.
Appendix 5
STATEMENT OF JIM DEFORGE, DESERT BIGHORN COUNCIL
The Desert Bighorn Council is made up of a group of professional
people for the purpose of promoting the advancement of knowledge
concerning the desert bighorn sheep and the long-range welfare of
these animals. Ever since the Council's formation in 1954, it has
been concerned with the impact which burros are placing on desert
ecosystems .
In 1967, the Council passed a resolution pertaining to the burros'
threat on wildlife; this resolution was mailed to various State and
Federal agencies, including the Department of the Interior. The
resolution says in part: "Responsible resource management agencies
should effect control on feral burros by every means currently at
their command."
In addition, the Council responded to the proposed regulations for
the implementation of Public Law 92-195 by letter of April 5, 1973.
"Public Law 92-195 is a good and desirable law providing for manage
ment as well as preservation. We believe it should be implemented
as rapidly as possible and the necessary funds appropriated to
achieve these goals. Any delay in implementing the law will be
costly to the environment, since burros are seriously damaging the
desert ecosystem."
The Council furthermore feels that burros should be completely
removed in some portions of their range to protect other biological
values. This would also allow for range recovery.
For the Advisory Board's information, I would like to call your
attention to a book just published, The Wild Sheep in Modern North
America . A workshop was sponsored by the Boone and Crockett Club,
the National Audubon Society, and the Wildlife Management Institute
in June 1974. The proceedings published in this book are a result
of some of the most knowledgeable sheep biologists in North America
They recommend (page 113), "Wild free-roaming burros, horses, and
livestock should be removed from desert bighorn habitats."
Appendix 6, pg. 1
STATEMENT BY RICHARD WEAVER, CALIFORNIA DEPARTMENT OF FISH AND GAME
California law gives legal status to and provides protection for
wild burros. Section 1*600 of the FiBh and Game Code reads in part that
"it is unlawful to kill, wound, capture or have in possession any undomesti-
cated burro." Section 1*601 of the Code declares them to be the property of
the State of California. These statutes will remain in effect regardless
of any Federal Court decision pertaining to Public Law 92-195. Both
Federal and State law provide clear mandates that the public wants to
preserve the wild burro.
It is the Department’s position, presented repeatedly over the years,
that burro numbers must be kept at a level where they will not cause further
damage to the ecosystem. We have inventoried burros during bighorn sheep
investigations and documented problems arising from competition between
burros and other wildlife. We contend that State laws on the subject are
workable because they contain provisions for the removal of animals by
nongovernmental employees, which is prohibited under a 1971 Federal law.
Section 4602 of the Fish and Game Code provides that a citizen may obtain
a permit from the Department of Food and Agriculture to capture and possess
a burro for a pet or beast of burden. Section 4887 of the Code provides
that a landowner or tenant may obtain a permit from the Department of
Food and Agriculture to kill a burro that is causing damage. We endorse
the concept of burro sanctuaries where these animals may be viewed by the
public. Outside sanctuaries, burro numbers should be reduced to levels
that the range can sustain, and where burros threaten the continued existence
of plants and other animals they should be eliminated. Management plans
must encompass entire ecological units regardless of jurisdiction and the
entire biota, not merely one species.
Appendix 6, pg. 2
Burro Statement
The Department is anxious to cooperate with public land management
agencies to accomplish plans for burro management. We are ready to discuss
and to work out plans for wildlife in sensitive areas.
Appendix No. 7, pg. 1
BURROS IN BANDELIER NATIONAL MONUMENT, BY DR. MILFORD FLETCHER
NATIONAL PARK SERVICE
My comments will be more in the vein of a st
of you know, the National Park Service has s
lems in a number of areas. I might point ou
not Park Service policy. My comments reflec
the Southwest Region of the National Park Se
or comments will be directed toward that ve i
policy which is nonexistent.
atus report. As many
ubstantial burro prob-
t that my remarks are
t only the thinking of
rvice. Any questions
n, not the national
A year ago, in December, we filed an environmental assessment with
the public and after waiting 60 days and receiving public comment,
we went into Bandelier National Monument, an area of some 29,000
acres in north central New Mexico, and we destroyed some 52 burros
with rifles. We are now ready to take the second step. We have
research ongoing. The research will be finished in June. We
intend to file a complete environmental impact statement in late
summer, in July or August. We will then receive public comment on
the environmental impact statement and, depending on the public
comment, we will then take further management actions to reduce
the impact on these feral animals on a rather fragile environment.
We are very, very serious in trying to manage these lands in accord
with our 1916 Organic Act, the mandate under which the Service
operates. We are not in the livestock business, we are in the
archaeology business at Bandelier. We don't feel that that Monu-
ment can sustain or should have any substantial population of
feral animals. It wouldn't make any difference if it's goats,
or elephants, or a gemsbok, or anything. We haven't got anything
against burros, it's just any feral animal in that area. Those
are our intentions depending on the public input that we get.
Our response to date has been very, very good, in our eyes,
because the public is literally demanding that we do something
about this problem.
We're losing up to 70 , 000 pounds of soil per acre per year. There
are renewable resources and there are nonrenewable resources and
the soil is a completely, totally nonrenewable resource. Once it's
gone, you're out of business for a thousand years. We can't take
that kind of damage.
Appendix 7, pg. 2
Since between late
of a population we
we shot 52 of them,
lation, those 52 we
February and September, we've had 28 births out
thought was 130. We thought we had 130 animals,
we've had 28 births in 7 months, and that popu-
shot, will be replaced by next summer.
Appendix 8, pg. 1
JOINT STATEMENT
of the
NATIONAL WOOL GROWERS ASSOCIATION
and.
NEVADA WOOL GROWERS ASSOCIATION
and the
PUBLIC LANDS COUNCIL
BEFORE THE
NATIONAL ADVISORY BOARD FOR WILD
FREE-ROAMING HORSES AND BURROS
at
CHINA LAKE, CALIF,
by
DELOYD SATTERTHWAITE
VICE PRESIDENT
of
NATIONAL WOOL GROWERS ASSOCIATION
Appendix 8, pg. 2
WILD HORSE PORUM
CHINA LAKE, CALIFORNIA
Today I represent the National Wool Orower Association,
the Public Lands Council and the Nevada Wool Qrowars Associa-
tion, and I appreciate onfee again the opportunity to tsstify
before this National Advisory Board*
During the past year many important events have happened
concerning wild horses and burros* One very important step
towards control and management of the horse population was
taken in Nevada* This was oalled the Stone Cabin Valley
Gathering Program* The total cost of the program up to Oct-
ober 31, was $59 , 142. 15 » with the largest cost being salaries 9
and this figure was f 34, *55. 98. The next figure of $16,819*03
was the oost after the animals were rounded up* All of these
costs are still increasing because of the fact that many of
the horses are still being held in the oorrals*
There was a total of 230 horses gathered and 112 taken by
custodians* This leaves 4 head that were turned back, 12 from
death loss, 9 branded and 93 still remaining in B.L.M. care*
So the oosts will continue to increase after the horses
are gathered* This is where the major expenses are going to
be* The expense of capturing the animals is minimal relative
to the expense of boarding the animals after capture*
A few of the problems encountered were:
1* To date it has been difficult to find custodians
willing to take older studs* This was partly overcome by an
intensive publicity drive appealing for custodians for these
horses*
2* These has already been an Instance of a custodian
giving up a wild horse because it cannot be controlled or
broken* The BLM anticipates this will occur often because of
the inexperience of many of the people in handling wild animals,
3* Many people who arrange to pick up a wild horse
do not arrive at the prearranged time and date* Often no notice
is given, wasting BLM time and manpower, and due to this fact
it is sometimes impossible to have a State Brand Inspector there
when he is needed*
4. Well over half the applicants contacted do not accept
the opportunity to take custody of a wild horse and many have to
Appendix 8, pg. 3
be contacted several times before they reaoh a decision, A
significant number has made definite arrangements to pick up
a horse only to decline at the last minute,
5, There has been one instanoe where a stud has pul-
led away from his handler and returned to the mountains, but
in a different part of the state,
6, BLM regulations require an animal report from
custodians certifying their good care of the horses, the
animals condition and so on. Suspected or actual violations
are impractical to investigate after the horses have been
taken over by custodians, especially those going out of state.
These are just a few of the problems confronting the BLM
on their attempts to capture and give away the wild horses.
The major problem beems to be finding enough people to accept
the horses under the conditions prescribed by the law.
The Nevada BLM Director, Mr, Ed Rowland, made the state-
ment that the State of Nevada is in serious trouble. He es-
timates that 8 to 10,000 horses should come off the range
each year. Now, try and find 8 to 10,000 people each year
who want to claim a wild horse under the conditions of the
present law. In fact, I believe that even if you gave owner-
ship, it would be very difficult to find that many homes for
a wild animal,
Mr, Rowland also stated that the Act. says, as you very
well know, that forage must be provided for them. Eventually,
if we do not control the horse population it could wipe out
all grazing.
We, as eui industry, believe that people that are know-
ledgeable about horses on the open range will tell you that
the most humane way to gather those horses is through the use
of helicopter and aircraft. We know from practical experience
that it is almost impossible to gather wild horses on horse-
back. Then it is dependent on a particular season if you use
water-trapping.
At this time, through the organizations that I represent,
we strongly urge that we quit talking about the problem, which
has been talked to death, and support the proposed legislation
that will solve the problem. We believe that a strong, unamimows
Appendix 8, pg. 4
recommendation from this board supporting the use of helioopter
and aircraft for the management and oontrol of wild horses and
burros is needed and also for the amendment of the Federal Law
to permit a transfer of title to those people willing to take
a wild horse or burro.
If this wild home act is not amended now to give range
managers an adequate means of control there is going to be
a classic example of a disaster, especially in Nevada where
the majority of the horses are.
Surely we as people of this great nation can work together
instead of against one another for the benefit of all.
Thank you.
STATEMENT OF LEWIS E. CARPENTER
Appendix 9, pg. 1
S
Sportsmen
FnesNO - Kern - kings
AFFILIATEO WITH
alifornia Wildlife Federation
National Wildlife Federation
J C^ounci
( of CenlrJ CJif
orma
REPRESENTING THE COUNTIES OF
Madera - Mariposa - Merced - Momerey - San Benito - Tulare - Stanislaus
San Luis Ohispo Santa Barbara - San i a Cruz
815 West Gettysburg Avenue,
Fresno. California 93705
2 December 1975
Dr. Floyd W. Frank, Chairman
National Advisory Board for Wild Free-Roaming Horses and Burros
Chairman, Department of Veterinary Science
Idaho Uni vers I ty
Moscow, Idaho.
Dear Doctor Frank and Members of the Board:
The Sportsmen's Council of Central Calif'-
ornia has on many occassions discussed the conflict between native wildlife on our
National Resource Lands and the domestic and feral livestock which have been
introduced onto these lands.
The native wildlife of the American Deserts had arrived at an equilibrium
long before the advent of the white man to Ncrth America. With the importation of
domestic livestock this balance was severely disrupted and native wildlife suffered
great losses In numbers. Many species were forced into, at best, marginal
habitats of scanty vegetation and scarce supplies of needed water. The encroach-
ment of the feral burro, a large and aggressive herbivore, has placed anothar
very heavy burden upon the already stressed environment. This disruption of the
precarious balance of a natural ecosystem, already in trouble because of domestic
livestock has been further disrupted by the importation and protection of an
exotic specie. This has further jeopardized trie continued existence of many
reptiles, birds, rodents and other mammals that have co-existed on these desert
lands for eons of time.
Theerefore, the Sportsmen's Council of Central California has adopted the
position that in order to protect the natural ecosystem of the North American
Deserts it is imperative that the numbers of feral burros be reduced to such
numbers that t!wy do not jeopardize the present or future existence or well-being
of the desert ecosystem and it's flora and fauna and may also give this badly used
environment an opportunity for improvement.
The Sportsmen's Council of Central California has therefore sought and
obtained the assistance of the Honorable G. William Whitehurst of Virginia to
introduce into the U.S. Congress, during 1975, the House Resolution H.R. 2935
which will, if enacted, amend Public Law 92-195 and give the management of the
feral burro back to the Agencies charged with the management of our National
Resource Lands.
H.R. 2935 states, "(a) subsection (a) of section 3 Public Law 92 -195
the Act of December 15, 1971 (16 U.S.C. 1333), is amended by adding "Not-
withstanding any other provision of law, the Secretary Is authorized to use
aircraft and motorized vehicles to provide for the protection, management,
and control of wild free-roaming horses and burros, such use to be in accord-
ance with humane procedures prescribed by the Secretary."
— more —
In Unity There Is Strength to Better, Propagate, Conserve, and Harvest Our Fish, R'ildlife, and Natural Resources
Appendix 9, pg. 2
SPORTSMEN'S COUNCIL OF CENTRAL CALIFORNIA
"Section 3 Is further amended by adding a new subsection (e) , as follows, The
Secretary is authorized to sell or donate, without restriction, excess horses
or burros to Individuals or organizations end quote.
The preceding language also appears In Section 3 1 3 » page 58 of the Sub-
committee print of August 13, 1975 of the PUBLIC LAND POLICY AND MANAGEMENT
ACT -- print number 2. A copy of this bill was furnished to the Council
by the Honorable John Melcher, Chairman of the Subcommittee on Public Lands,
Committee on Interior and Insular Affairs, the House of Representatives, 5^th
Congress, First Session.
The Sportsmen's Council of Central California urges the enactment of
the foregoing legislation.
The Sportsmen's Council of Central California further recommends that
the initial management efforts of feral burros be directed to those National
Resource Lands comprising the Death Valley National Monument; the U.S. Naval
Weapons Center at China Lake; and those other National Resource Lands
adjacent to and between them.
Respectfully yours,
Lewis E. Carpenter,
Legislative Secretary
cc: Superintendent, the Death Valley National Monument
Commander, the Naval Weapons Center
Bureau of Land Management,
U.S. Forest Service,
Honorable John Melcher,
Honorable G. William Whitehurst
Cngressmen and Senators of California
Appendix 10
SOCIETY FOR THE CONSERVATION OF BIGHORN SHEEP
STATEMENT OF BUD WIEDEMAN
■10 1 Noi III < i;ii I'ielil
Alli.imhi.i, ( '.ill l\ >i 'ilia I SO I
Non-l'iotil Oru.im/.ilion
OFFICERS
i\.\ :s4-si 1 1
»•»» % lO*. N »
11.1 VII » i‘KI nlKNl
,'Nl'VM FlUviDINI
INOVU »
T ft I A*IUHI FI
ADVISOR
I ONI N i IIIW C»l» *»
IIONAIOM >VS AMl lU'U I
NO N t W I » 'OllNVON
MARVIN WOOD
IOMN |. O | ANHONl’I
I AMI ft Ml IN O O *
JUOV.lt MNNIIMNIHIAMH
BOARD MEMBERS
WA i Nl OH M.l.f)
I A M | • N Hi hlHiil
I AIM If Ml iff ll |l t.
wiMO ni a liniMMili
JOHN F • ) I AfHMiNUI
l out N I nil/ I ' U ri
MU HABIJI f HUMP son
POSITION ON HORSES AND WILD BURROS
The enclosed papers reflect the attitude of the Society
regarding horses and burros.
The following propositions dhould be implemented*
1, Areas of moderate or hiqh native wildlife habitat
should have no burros and few horses,
2, Areas of historic sheep range should have no
equine populations,
3, Mechanized equipment must be allowed to be used
as a management tool,
4, Ownership of animals for work or pleasure should
be transferred,
5, The niche occupied by feral animals must not be
transferred to domestic stock,
6, Under strict management^ areas should be set aside
for both wild horses of historic ancestry and burros,
7, State Fish and Game Departments should be the
authorities defining wildlife habitats.
Appendix 11, pg. I
BURROS AND BURROCRATS, BY DR. LOREN L. LUTZ, PRESENTED BY BUD WIEDEMAN
The environmental pendulum has swung so far in the wrong direction
that it is now a 52,000.00 offense to harm a burro.
In 1^71 the United States f.onqress passed Public Law 92-195, protecting
wild horses and burros on public lands, and making it a federal offense
to harass, capture, kill, sell, or process into any commercial product
these animals.
The State of California "led" the way for this kind of 1 en i s 1 a t i on .
In 1959 it was made illegal to convert burros into pet food. In 1955
and 1955 killing, uioundinp, capturing and possessing was made illegal
for two-year periods. In 1957 this legislation was made permanent.
Burros are hardy, self-sufficient animals which have superior abilities
to compete for water and forage in arid regions with other forms of
life. They were introduced into the Western deserts by Spaniards
exploring the f\Jew World, and later by prospectors and sheepherder s .
By being such efficient foragers and being able to survive under
marqinal conditions, burros offer unsurmoun table obstacles to native
wildlife survival. They put such tremendous pressure on the vegetation
that the most desirable forage plants are eliminated, and Bighorn
sheep and other mammals and birds such as quail have little left
for food. Very few perennial grasses are left in high-density burro
population areas.
Burros also cause severe soil problems. In the Granite mountains of 5an
Bernardino County, California, burros have just about destroyed Bighorn
Basin with heavy trailinq and rolling areas. Soil erosion is quite
heavy, vegetation propagation is severely limited in areas of this
type. The change in the character of the watershed and the amount
of wildlife is directly proportionate to the amount and kind of plant-
life. Burros will eat virtually anythinq, even eat creosote bush.
Once the vegetation is qone, and consequently the life that fed on it,
decades are needed Cor vegetative regeneration.
Burros also usurp water sources and drive away other animals. Don
Swarthout (l/ice President of the Society for the Conservation of Desert
Bighorn Sheep) recounts burros driving sheep away from a spring he was
watching for several days. They have also been known to kill calves,
fight off horses, and harass range cattle at water holes.
Areas around waterinq devices generally have no vegetation because
of the feedinq and rolling activities of burros, thus negatinq their
use by birds and small animals for food, breeding and protection.
People counting sheep and other forms of wildlife at desert water
sources generally find that in high burro population areas^few sheep,
quail, and chukar are found.
Burros range from below sea level in Death \y alley and Imperial U alley
to above 11,000 feet in Inyo county. They come down out of the
mountains at night and feed heavily on the farmers' crops.
Appendix 11, pg . 2
Attempts have been marie by concerned groups to have sensible management
plans made for these animals. In California this legislation was
killed by legislators poking fun at the Bill through cries of killing
off the symbol of the Democratic party, to pointing out that this was
the beast of burden of Jesus Christ, and also a part of the heritage
of the old West. True enought statements, but somewhat emotional claptrap,
Eco-freak environmentalists have persuaded State and federal legislators
to ignore the dictates of common sense in the management of wildlife
resources. The abrogation of respons ibl i ty by these representa ti ves;
bodes ill for the wildlife of the desert.
I^an has usurped the water, divided the desert ranges with highways,
despoiled the slopes with mines, over-grazed the ranges with sheep
and cattle, introduced diseases, noxious weeds and grasses, put houses
and people where they don't belong, and now as a probable final blow,
man is trying to protect coyotes, bobcats , mounta in lions - and burros -
and then some say " Let Nature take its course."
Burros do have their place. I used to pack them into the Sierras,
Some make fine pets and kids can ride them. There may be a place
for them in the desert, but that should not be determined by emotionalism,
but on a basis of rational judgement by qualified field biologists,
with a manaoement program in view.
By Dr. Loren I,. Lutz
Appendix 12, pg. 1
THE OTHER SIDE OF THE BURRO
Donald M. Swarthout
Presented by Bud Wiedeman
Burros were a part of the working force, along with cowboys and
horses, on our Heart Bar Cattle Ranch for more than k$ years. During that
time we all became well acquainted, to say the least. The burros had a
special job to do and we came to know than, admire and curse them — all in
the same breath.
Burros inherited unique qualities from their ancestors, the wild
asses on the deserts of Asia and North Africa. These forebearers were born
and raised under temperature extremes— intense heat in summer, freezing
temperatures and cold winds in winter— plus the poor grazing associated with
persistant drought. Survival under these conditions, over the centuries,
developed an animal that found our Mojave and Colorado Deserts much more
"desirable" than their native home on the Sahara or Gobi Deserts.
Burros are strong, tough, surefooted, methodical, possess keen eye-
sight and hearing and can put on a real burst of speed if needed. Above
all, they are past masters at conserving energy and taking care of themselves
whatever the conditions may be.
To illustrate* A severe drought occurred on the Mojave Desert winter
range in 1922 and 1923. Cattle losses were 6$%, horses nearly £0$, but
burros no loss! Cattle and horses on the open range often become sore-
footed, burros never. Having excellent feet, they can travel farther from
water to better grazing and can stay longer because their water requirements
are less— a life saving advantage when food is scarce and water holes far
apart or dried up.
Appendix 12, pg. 2
The question naturally arises, why were burros used on our ranch and
not generally on others? The answer is absence of roads. In the spring
cattle were driven 75 miles from their winter range on the Mojave Desert to
their summer mage at the headwaters of the Santa Ana River in the San Ber-
nardino Mountains of Southern California. (This area is now the Heart Bar
State Park.) Burros were used to pack grub, bed rolls, pots, pans and grain.
They were ideal for this job, since they traveled slowly and stayed with the
herd. When close to camp, they would leave the cattle and wait at the trail
shack to be unpacked. They needed watching, however, because most of them
had mean streaks, and if given a chance would stomp and cripple or kill a
young calf. The old cow usually took care of this, but sometimes cow and
calf became separated, so a wary eye was kept to prevent trouble. Burros
also had a disconcerting idea of fun— turning a pack and scattering grub,
pots and pans over the landscape was a pleasurable sport to them. Admitted-
ly it does have humorous aspects, but only much later in retrospect.
For many years the general public has built up an ever growing
romance around the exploration of the desert by the lonely prospector and
his ever- faithful burro. That romance, in fact, never existed. Many pros-
pectors and their burros came to the Heart Bar winter headquarters at Old
Woman Springs on the Mojave Desert, This spot was virtually a mecca for
the "single blanket jackass prospector. '• Here he found ample space to camp
under big cottonwood trees, plenty of good water, free feed for his burros
and an occasional home-cooked meal. The prospector relaxed, because he
knew his burros wauld be there in the morning. However, when prospecting
over desert areas, the burros would be turned loose to graze and the first
job in the morning was to find them. Even when hobbled, burros soon learned
to travel nearly as fast as they normally would. They might be close to
Appendix 12, pg. 3
camp or a full day would be needed to track them down, It wes quite common
tor these burros Just bo take off and leave the prospector afoot and I4O
miles from nowhere.
Around World War I the Model T Ford or "Tin Lizzie1* became available ,
much to the prospector's delight. He gladly turned his burros loose without
even shedding a tear or kissing them goodbye. He just piled his grub* water,
pick and shovel in his Model T and took off. He now carried plenty of water
for dry camps, and could prospect waterless areas otherwise inaccessible
with burros. His burro hunting troubles were over, because he knew "Tin
Lizzie" wasn't going to run off during the night and leave him stranded.
This old prospector of fifty and more years ago has faded out, but his way
of life, hardships, privations, and riches found and lost will forever be
held in tradition. The burro he so happily abandoned has now been sentiment-
ally placed on a pedis tal beside him.
The abandoned burros, on the other hand, have not faded away, but have
multiplied many fold and spread over the desert until they completely dom-
inate many areas. The attributes that once made him valuable to man in the
conquest of the desert have now become deadly forces against all native wild-
life, and especially against the majestic and endangered Bighorn Sheep.
The burro, an import, eats the same feed as native Bighorn Sheep.
Why are these burros exempt from any and all controls and allowed to despoil
the land and crowd native wildlife out? Because well-intended and sympa-
thetic groups of conservationists--who were not fully informed— were instru-
mental in having the present laws passed by Congress. Emotion and sentiment
do not enter into the handling of domestic cattle, sheep or horses on public
lands— the number allowed depends on the available feed and impact on native
flora and fauna. By all that's reasonable, the feral burro should also be
Appendix 12, pg. 4
under complete control of the U. S. Forest Service and the Bureau of Land
Management. The overnight guest is now taking over the household!
In mid-July of 1969 a four day sheep and burro census was made for
the California Department of Fish and Game at Sheep Spring in the Providence
Mountains of San Bernardino County. This study showed that 29 sheep and 1*7
burros came to water. The 197U census at the same Spring recorded 17 burros
and 12 sheep. What happened? A survey of the area showed extreme over-
grazing of annual, perennial bunch grasses and browse. The burros had taken
over this rugged mountain area, the natural home of Bighorn, and grazed it
down to the point where even they (the burros) were leaving. Sheep skulls
and skeletons were found throughout the area, but rarely were burro remains
seen. The burros had left the desert floor when it became over-grazed and
had moved up to this rugged desert mountain where the feed was better. But
the Bighorn Sheep will not leave their desert home. They die first.
Over-grazing: Any given area of range or desert land will produce
a definite amount of feed each year, the amount governed largely by rain-
fall. A portion of this feed can be harvested by grazing without damage or
reduction of future growth; this is known as carrying capacity. The cattle-
man or sheepman who allows over-grazing by over-stocking soon goes out of
business, but leaves behind a grim legacy of damage to land and forage
crops. Over-grazing also occurs in nature; the end result is generally
death by starvation or disease caused by a weakened condition. Lemmings
solve their problem by self destruction. The Yellowstone elk heard, has in-
creased beyond the carrying capacity of their winter range, and the feeding
of thousands of tons of hay (by man) has not solved the problem.
The Sheep Spring area is one example of range destruction by the feral
burro and his grazing habits. Here the annual native grasses are gone
Appendix 12, pg. 5
because the seed stock has been eaten clean. Native bunch grasses have
lasted longer, because new growth will come from the roots for a limited
time, but again the grass is eaten before any seeds can mature. These fine
forage grasses are practically gone in the Sheep Spring area. The sure-
footed burro will slowly and methodically graze over extremely rugged terrain
where nothing else but mountain sheep can go. This must be seen to be be-
lieved.
Here is a classic example of the natural ecology of our desert lands
being disrupted by man's introduction of a foreign animal, the feral burro,
and then giving that animal full protection under Federal law. Fully pro-
tecting the burro is wiping out the desert Bighorn Sheep and other native
wildlife by destruction of the natural flora. When water is limited the
burros drink first and patiently guard the meager supply until their thirst
is quenched. Soil erosion and over-grazing go hand-in-hand.
Sheep Spring is just one of many desert areas where burros have dam-
aged both flora and fauna. Only many years of complete rest from grazing
in any form by burros or domestic animals can the original forage be re-
established.
Congressional action is needed now.
Appendix 13, pg. 1
STATEMENT OF MARY DEDECKER
Statement made at the meeting of the National Advisory Board' for
Wild Free-Roaming Horses and Burros at China Lake, 12/5/75.
I have lived in Independence, Owens Valley, since 1935. Because
I am familiar with the region, I have been asked to represent the
California Native Plant Society, the Southern California Botanists,
and the California Natural Areas Coordinating Council.
Having observed the rapid deterioration of environmental and
aesthetic values where burros occur, I urge that
(1) All the agencies involved, the National Park Service, the
Bureau of Land Management, the National Forest Service, and the
Naval Weapons Center, coordinate their efforts in a program of burro
elination. Regional problems must be handled on a regional basis.
Burros recognize no agency boundaries.
(2) No time be lost in attacking the problem. The acceleration of
their abuse of the land is truly alarming.
In support of the above, I present some of my own observations.
In 1967 burro trails were already furrowing the walls of Cotton-
wood Canyon in Death Valley National Monument. In 1970 I found a
population of Mlmulus parishil at Goldbelt Springs, up from
Cottonwood Canyon. Since this species had not been known north
of the San Gabriel and San Bernardino Mountains, it was an exciting
discovery. In 1971* I revisited Goldbelt Springs, but there was no
Mimulus--only a mudhole at the site. The burros had moved in
within the year.
In April 1975* on a 5-day back-packing trip along the crest of the
south half of the Panamint Mountains, we found numerous burro trails
throughout. Bighorn sheep tracks In the snow pointed out one of
the conflicts here. This crest is the boundary between Death Valley
National Monument and Bureau of Land Management lands.
On my first visit to Waucoba Spring some years ago, I found aquatic
vegetation bordering the pool. Several years later I found burro
trails converging on the spring from all directions. The pool
borders were completely barren. This spring overlooks Saline Valley
near the north end. Burros watering here are now heavily using the
Whippoorwill Flats area where Bureau of Land Management and Forest
Service lands come together. It includes the proposed Forest
Service Pinyon-Juniper Research Area. Selective use of the bunch
grasses here is already evident. A rare plant. Astragalus clmae
suf flatus , is endangered.
In 1974 a reconnaissance of the Inyo Mountains south of Waucoba
Spring revealed that burros from Saline Valley are following
canyons up to streamlets above. Here they are destroying valuable
habitats and muddying the water. This extends into the bighorn
sheep range, probably already having pushed the bighorn back. At
Appendix 13, pg. 2
the head of these canyons, along the crest of the Inyo Mountains,
is the proposed Paiute Wilderness Area. If burros reach that, the
following rare and relatively rare plants would be endangered or
wiped out.
Abronla nana
Astragalus kentrophyta var. elatus (a disjunct population)
Astragalus platytropis
Eriogonum rupinum
Erlogonum esmeraldense
Cryptantha rooslorum (endemic)
Lomatlum inyoense (endemic)
This is a brlstlecone pine forest which has an unusually rich under-
story of limestone-tolerant plants.
On the Naval Weapons Center I visited Renegade Canyon in 1973 and
was dismayed to find burro trails cutting into any breaks in the
canyon walls. In the same canyon in 1975> the trails were deepened
find had destroyed much vegetation on the access routes along the
canyon walls. The canyon bottom looked and smelled like a stable
in many places. This was offensive to aesthetic values in the
petroglyph area, as well as being destructive to that ecosystem.
These are only a few examples of burro degradation of valuable desert
water sources. The great amount of vegetation destroyed on water
borders and on trails lacing the slopes is equally serious. The
rapid acceleration of this damage is frightening because much of it
is a permanent loss. Complete elimination of burros is recommended
for most of the southwest. They can be Justified only in sacrifice
sites where limited numbers might be maintained for public interest.
It is a sad sense of values which allows such abuse to the specialized
habitats of this arid land.
P. 0. Box 506
Independence, Ca. 93526
Appendix 14, pg. 1
STATEMENT OF WALTER B. POWELL, CHAIRMAN, LAND USE COMMITTEE, CALI-
FORNIA WILDLIFE FEDERATION, AND CHAIRMAN, LAND USE COMMITTEE,
SOUTHERN COUNCIL OF CONSERVATION CLUBS, REGARDING FERAL BURRO
MANAGEMENT ON PUBLIC LANDS IN CALIFORNIA
The California Wildlife Federation and its member Councils, including
Southern Council of Conservation Clubs, are comp sed of sportsmen-
conservationists who value our resources of land, water, vegetation,
and wildlife, who are concerned that these resources be conserved and
enhanced and soundly managed on a long-term basis, and who support
the right of sportsmen to participate in compatible recreational use
of these resources.
We are here expressing our particular concern with the impact of
feral burros on the desert areas of southeastern California.
We view with frustration and a growing deep-seated anger the contin-
ued devastation of our land by the politically protected burro, a
devastation that has continued unchecked for years after the serious-
ness of the problem had been officially and publicly noted.
The competitive and destructive potential of the burro was not
unknown in 1971. It had been testified to much earlier. Viewed
from the ecological aspect in this light, the imposition of the
present State and Federal laws restricting management of the burro
in the southeastern desert ranges of California was a completely
irresponsible act. Those who took part in it or supported it can
never begin to pay for the damage that they have caused. But it is
time that they were called to account. Some of these people are
here today--they should be ashamed.
Ecologically sound management of our land, water, vegetation, and
wildlife resources requires that they be managed as a comprehensive
whole, with each part relating in a balanced manner to each other
part. Inflexible one -anima 1 -biased management is ecologically
unsound and, in the case of the feral burro on our desert valleys
and mountain ranges, clearly destructive to our other resources.
The absolute protection now given to the burro by both State and
Federal law is one of several examples of emotionally motivated,
politically imposed, unbalanced, unsound, and destructive wildlife
management practices existing in our State today. This situation
must be corrected.
Appendix 14, pg. 2
We prefer that all wildlife be managed by the State Fish and Game
Commission and the Department of Fish and Game, working in conjunc-
tion with the various landowners. Management by professionals can
be flexible in its response to changing conditions, and flexibility
rather than rigidly legislated procedures is a necessary basis for
sound management of our wildlife resources.
Once the political and legislative restraints are removed, what
should be the elements of a sound overall management program for
the land and outdoor resources of the desert valleys and mountain
ranges typically now used by the burro? First, the ecological con-
s iderat ions :
1. The land and native vegetation which have been ravaged and the
native wildlife populations which have been damaged and dis-
placed will have to be restored.
2. Burros will have to be completely eliminated or strictly con-
trolled in many areas for a considerable period of time in order
to enable restoration of the land, vegetation, and wildlife.
(A few areas should be left (or abandoned) where a controlled
population of burros could continue to exist.)
3. Control, and perhaps temporary elimination, of grazing by domes-
tic animals will also be required.
4. After restoration of the land, vegetation, and native wildlife
has been achieved (and this will take many years in most desert
environments), then qualified biologists and wildlife managers
should be allowed to determine what controlled level of use
(if any) of these lands by feral burros and/or domestic livestock
is compatible with maintenance of the natural resources in a
productive state.
Second, what are the physical considerations involved in controlling
or eliminating burro populations?
Burros typically inhabit the rough and rocky desert mountain
ranges and the adjacent valley floors. They roam widely.
Experience has shown that some burros can be trapped in some
areas, but trapping alone is inadequate for control or elimina-
tion. Similarly, roundup techniques in conjunction with trap-
ping or corraling are useful only in certain types of terrain.
Appendix 14, pg. 3
Careful consideration of the problem by qualified experts has
led to the conclusion that "instant recycling must play an
important part in any burro control or elimination program.
"Instant recycling" is a euphemism for shoot-and-let-lay .
Many burros will be found in rugged and isolated terrain. The
only way to find them is to seek them out on foot, on horseback,
or by helicopter. The only thing that can be done with them is
to shoot them on the spot and leave the carcasses for natural
recycling, via predators and other organisms, of their elements
to the soil and vegetation. The helicopter and the rifle are
by far the most efficient equipment for the task that must be
done .
Finally, what economic, political, and sociological constraints
should be imposed on burro control or elimination procedures? The
answer is: no unnecessary constraints.
The existing laws should be changed to allow motor vehicles and air-
craft to be used for management activities involving wild free-
roaming burros.
Present laws prohibiting unconditional transfer of ownership of
burros, and prohibiting any economic use of burros or burro parts
should also be changed. The burros do represent a "resource" on
our lands, and this resource should be used as constructively as
possible for the benefit of society and its citizens.
If trapped burros must be removed from the land, and there is no
other land to which they can be transplanted, and no agency or indi-
vidual is willing to undertake the responsibility of care and owner-
ship, then humane destruction and economic utilization of the remains
should be permitted.
If burros are to be shot and left to recycle on the ground because
they are too big to retrieve from difficult terrain, then there can
be no objection to shooting and retrieving only 10 or 20 pounds of
choice meat, depending on what can be carried from the site and used.
Appendix 14, pg. 4
If individual sportsmen wish to take part in a controlled hunt
which is part of a burro management plan, then there can be no
objection to this "recreational" use of the burro resource;
besides fulfilling the management objectives, such a hunt would
provide outdoor exercise and possibly meat for the sportsman, and
it would be economic in that it would relieve the management agency
of the expense of hiring "professional" hunters to perform the con-
trol task.
To summarize:
1. Burros must be eliminated in many areas to enable the soil and
vegetation to be restored, and the native wildlife to become
reestabl ished .
2. Shooting and recycling on the spot is a necessary, feasible,
effective, and ecologically sound control/elimination technique
3. The use of motor vehicles and aircraft by management agencies
must be permitted.
4. Unrestricted transfer of ownership and economic utilization of
burros must be permitted.
5. A complete burro management program would allow for controlled
participation by sportsmen and for beneficial consumptive use
of all or part of the burros taken in this activity.
We would like to see some immediate action. Why is it that the
Regional Directors of the U„S„ Park Service and the BLM, and the
Commander of this Navy base cannot sign a Negative Declaration and
start shooting tomorrow? Why do they delay while the land that
they manage in trust is being destroyed. We do not mean to imply
that shooting is the whole answer to the problem, but it is a neces
sary part, and a good start, while other programs are being planned
and implemented.
The California Wildlife Federation and the Southern Council of Con-
servation Clubs stand firmly in support of the need for burro con-
trol. There must be a return to balanced, ecologically sound
wildlife management under the control of the State Fish and Game
Commission and the Department of Fish and Game.
At tachment :
Resolution re MANAGEMENT OF FREE-ROAMING HORSES AND BURROS
adopted by the California Wildlife Federation, April 13, 1975
Appendix 14, pg. 5
CALIFORNIA WILDLIFE FEDERATION
P. 0. Box 9504
Sacramento, CA 95823
RESOLUTION
MANAGEMENT OF FREE -ROAMING HORSES AND BURROS
WHEREAS the feral free-roaming horses and burros are neither a
rare, threatened or an endangered species, and
WHEREAS these animals are rapidly increasing in numbers and are
causing ever increasing competition between themselves,
domestic livestock and native wildlife for the scarce
available forage and water of the lands they occupy, and
are damaging such habitat, and,
WHEREAS the land management agencies (National Park Service, Bureau
of Land Management, U.S. Forest Service, and the States'
Departments of Fish and Game) have determined the areas
where such competition and damage to wildlife habitat is
presently occurring, and
WHEREAS in order to protect the habitat of the native wildlife it
is essential that the numbers of such feral free-roaming
horses and burros be reduced in numbers to permit the
habitat of the native wildlife to recover, and
WHEREAS PL 92-195 does state in part, "Management activities shall
be carried out in consultation with the wildlife agency of
the state to protect the natural ecological balance of all
wildlife species,"
NOW THEREFORE BE IT RESOLVED that the California Wildlife Federation
does lend full support to enactment of H.R0 2935 introduced
by Congressman C. William Whitehurst into the House of
Representatives on February 5, 1975, and which will amend
the Federal law relating to the protection, management, and
control of wild free-roaming horses and burros on public
lands in order to provide the authority needed to properly
manage wild horses and burros in harmony with wildlife and
other uses of the national resource land. By stating:
"Be it enacted by the Senate and House of Representatives
of the United States of America in Congress assembled,
that (a) subsection (a) of Section 3 of Public Law 92-195,
Appendix 14, pg. 6
the Act of December 15, 1971 (16 U.S.C. 1333), is amended
by adding, "The Secretary is authorized to use aircraft
and motorized vehicles to provide for the protection,
management, and control of wild free-roaming horses and
burros, such use to be in accordance with humane procedures
prescribed by the Secretary." (b) Section 3 is further
amended by adding a new subsection (e), as follows: "The
Secretary is authorized to sell or donate, without restric-
tion, excess horses or burros to individuals or organiza-
tions," and
BE IT FURTHER RESOLVED that other conservation organizations be
asked to assist in the enactment of H.R. 2935, and that
Congressional delegation from the area of such conservation
organizations also be asked to assist in its enactment.
Adopted this 13th day of April, 1975
West Sacramento, California
Appendix 15, pg. 1
STATEMENT OF MIRIAM A. ROMERO, P. 0. BOX 394, MONTROSE, CALIFORNIA 91020
REGARDING THE IMPLEMENTATION OF PL 92-195 AS PRESENTED TO THE NATIONAL
ADVISORY BOARD FOR WILD FREE-ROAMING HORSES AND BURROS, AT CHINA LAKE,
CALIFORNIA ON 5 DECEMBER 1975.
As many members of the Board are aware, I have been studying the burro
situation in the American Southwest since the spring of 1973. Both my
husband, Ben, and myself have traveled thousands of miles looking at
burro habitat, interviewing scientists, government agencies' personnel,
conservationists, and animal protectionists. In addition, we took a
large number of slides on burro ecology and burro habitats and problems;
our impressions were incorporated into a slide show and lecture called'
"The Jacks are Wild" which we have shown some 30 times to various groups this
last year or so. I have studied closely all the data and information
available on the burro, and also have studied closely the concepts and
information on range ecology that would be pertinent in the matter of
burro management. We are very familiar with the desert areas of the
Southwest and with the concepts of desert ecology.
My degree is in geography and my graduate work was in desert ecology and
resources management. I am currently employed at the California Institute
of Technology, Geology Division, Pasadena, California. My husband is
an employee of Lockheed Aircraft Corp. He worked and lived in Death
Valley from 1937-1942 and both of us visit the Monument several times
annually.
I am convinced that the burro situation has reached crisis proportions
in the Panamint Range in Inyo County, California. To delay control of
burros in this mountain range would cause severe overgrazing to the
extent that the land will take centuries to come back to normal, if
indeed, it ever can again. While the National Park Service is moving
ahead on plans for burro management, and the Navy has conducted environ-
mental studies on burro habitats in the Naval Weapons Center, the BLM
has not been implementing P192-195 in this area. While we do recognize
the problems of manpower and funding, nonetheless, something must be done
to eliminate the burros in the Panamint Range which are causing the
ecosystem degradation. I strongly recommend that the Board advise the
Department of the Interior that management and control of burros in the
Panamint Range must begin promptly. There is, also, a great need for a
cooperative agreement for management with the Park Service, the Navy , and
the BLM.
The burro has an extremely wide ecological niche and it does, indeed, overlap
with that of the Nelson bighorn sheep. The burro does compete with the
bighorn for forage, water, shade, and escape area. There are many areas
in the Mojave desert where burros have invaded bighorn habitat. I recommend
that the BLM begin to clearly identify these areas and then begin planning
for removal of burros from bighorn habitat areas.
And, finally, PL 92-195 says that where the burro is that this land should
be used "principally, but not exclusively" for burro habitat and protection.
I object to the word "principally". I do not think that the principal use
of bighorn habitat should be for burros; nor do I think that the principal
use of land where endangered species of native flora and fauna exist, or where
Appendix 15, pg. 2
there are sites protected under the Antiquities Act should be for burros.
It is evident that the authors of the law did not know nor understand the
geographical distribution of burros, nor the problems that the wording of
the law would cause insofar as it deals with burros. There is not adequate
protection for fragile ecosystems, endangered species of flora and fauna,
or protection for rare and fragile archeological sites in the law.
I would recommend that the Board define what the word "principally"
means in the law, especially in those areas where the uses are non-
compatible.
I would also like to go on record as supporting the use of motorized
vehicles and helicopters in the management of burros and should be used
as access to areas or for censusing purposes.
I would also support the private ownership of burros which have been donated
to individuals from the public lands. However, I would like to see those
animals branded in some way so that if the owners turn them loose again
on the desert, that they then fall under the estray laws.
I am grateful to the Board for the opportunity to present this statement.
During the times we have presented our slide show to the public, we have
had opportunity to talk with hundreds of people and I feel that their
comments are important. If at any time, any member of the Board wishes
any help or discussion with cither my husband or me on the matter of the
burros, we urge you to feel free to call on us at any Lime. The burro
situation is very serious and time is running out in many of the ecosystems
they inhabit.
Appendix 16, pg. 1
STATEMENT OF RICHARD J. VOGL, CALIFORNIA STATE UNIVERSITY
I am opposed Co the presence of wild or feral burros on public lands (both state
and federal) in Nevada and California because they are causing irreparable damage
to the native grasses, the soils, the watersheds, and the natural watering places
of blackbush scrub (Coleogyne ramosissima) and Joshua tree woodland (Yucca brevifolia)
communities in eastern California and Nevada. Most of the remaining native grass-
lands which contain an irreplacable variety of perennial bunchgrass species are
being destroyed by the unrelenting burro grazing; unnecessary grazing and browsing
that is being added to ranges which already exceed livestock carrying capacities.
I believe that prior to excessive heavy grazing of all types, the widespread black-
bush scrub and Joshua tree woodland communities were co-dominated by grass species,
and the continued elimination of these species by burro grazing cannot be tolerated
because it is only leading to further deterioration of these ranges and their
reduced productivity.
As an ecologist (see attached resum£) , I also oppose the presence of burros on public
lands because it violates the inviolate principle that states that "the introduction
(or perpetuation) of alien species is to be avoided", because such introductions
often lead to competitive exclusion, whereby two species with similar or overlapping
amplitudes of tolerance such as burros and desert bighorn sheep come into direct
competition with only one species surviving.
As a citizen, I also oppose the presence of burros on public lands and recommend
their removal because, in my opinion, I find them to be totally unacceptable
aesthetically, (even if they are animals), because they are unhappy reminders of
California's first plundering pioneers, the miners, who have already done more than
their share of raping and permanently scarring the West, without having their
Appendix lb, pg. 2
prolific burros continue their destructive impact. I feel that the early miners,
"the fortyniners" , and their burros, represent a mentality that should be
forgotten and not perpetuated.
b<LJL l
Richard J. Vogl
Wildlife and Plant Ecologist
Professor of Biology
California State University
Los Angeles, California 90032
Appendix 17
STATEMENT OF PATRICIA NELSON
Dec. 3, 1975
663$ St. lCstaban
Tu junga, Calif.
Natl. Advisory Board on
Free-Roaming Horses and Burros
f
Ladies and Gentlemen:
For many years my family and I have been
visiting Death Valley and the surrounding mountains.
Over the years it has become very evident that the
burro population has mushroomed to the point of
absurdity .
They are very non-sel ec t ive in their eating
habits. Consequently, they destroy all vegetation
they come upon. The erosion caused by their wander-
ing back and forth over the areas they inhabit most
frequently, Wildrose Canyon, is very evident and
unsightly. But above all, the burros are destroying
the few springs and watering holes that the native
bighorn sheep frequent.
The burros have become a major problem in
many areas, but I believe that they should be culled
out especially in the Fanamint Kange and Death Valley
National Monument. This could be accomplished by
close cooperation between the BLM and the Park Service.
Sincerely yours,
/ 'N ,y —
( 'S/z£ Ax...
Patricia Nelson
Appendix 18
BURROS IN DEATH VALLEY NATIONAL MONUMENT, BY MR 0 JAMES B. THOMPSON,
NATIONAL PARK SERVICE
Death Valley National Monument la the fourth largest area In the
National Park System and the largest area in the Southwestern
United States in the National Park System. It consists of a
little over 2 million acres. This National Park Service area is
fortunate in being a nearly complete ecosystem, a valley between
two mountain ranges almost completely within the boundaries of the
National Monument. It is the hottest, driest, lowest place in the
North American Continent. This unique geography and climate have
resulted in a number of significant biological situations. There
are, in fact, over a dozen species of plants that occur no where
else in the world. Several rare and endangered species of fauna
are within Death Valley's boundaries and within the habitat manage-
ment responsibilities of the National Park Service.
I think that no where else, at least in this continent, does life
balance so precariously on the thin edge between survival and dis-
aster than it does in Death Valley, and no where else are ecolog-
ical principles and dynamics so starkly apparent to the American
people as they can be shown in Death Valley, and that, in fact, is
what the purpose of Death Valley National Monument is.
Our objectives and our policy in Death Valley National Monument are
to, insofar as the resources are concerned, establish and maintain
conditions which are conducive to the perpetuation of the natural
processes and the ecological systems as they operated prior to the
introduction of technological man into the earth, that is, around
1849 and subsequent years. During those years, burros were intro-
duced into Death Valley National Monument. The eastern ranges,
the Armagosa Range in Death Valley, had at one time about 1,500
burros. Thirty-eight hundred of those 1,500 were removed over the
course of years and they no longer exist in those Armagosa Ranges
except in one area where they have become reintroduced near the
Ca li fornia-Nevada line. We have a pretty good count of the number
of burros and you will get to see a little bit of what the impacts
of what we have seen from those burros and what those impacts are.
We are planning to introduce an environmental assessment for public
review on our total resource management objective which includes a
number of subjects related to water management and management of a
number of exotic species, both plants and animals. We hope to have
this document ready for public review by the end of February or
early March. There will be public meetings held immediately
following its availability and we hope to have a resource manage-
ment plan developed from those public meetings by early or mid-summer.
Appendix 19, pg. 1
Cal-"eva Wildlife 1974, Trans. Calif .-Nev. Sect.,
Wildly© Soc., 1974, p. 21-34.
IMPACT of feral burros on the death
VALLEY ECOSYSTEM
Peter G. Sanchez
National Park Service
Death Valley, California
Abstract. Man introduced non-native burros into a desert ecosystem in the
late 19th century. Burros have successfully filled the vacant niche.
Burro population size now numbers approximately 1,500 animals and is in-
creasing. Field evidence indicates feral animals have seriously affected
native flora and fauna of the region and threaten the viability of Death
Valley National Monument as a natural area of the National Park System.
Environmental damage includes soil damage and accelerated erosion, vegeta-
tion destruction, spring and waterhole disturbance, and competition with
native wildlife for food, water and space. Habitats of rare or endemic
plants and animals may be threatened. National Park Service management
problems and efforts to control burro impact are discussed.
INTRODUCTION
Feral burros were introduced in the Death Valley region perhaps as early as
the early 1870's. Later introductions occurred in the late 1800's and con-
tinued into the early 20th century. Most of the free-roaming burros were
escapes or abandoned burden and pack animals owned by prospectors and miners
during the heyday of mining activity in the desert (Hansen 1973) .
Through the last century burros have successfully occupied their ecological
niche. Their numbers grew and they expanded their range into much of the
upland areas where suitable forage and sufficient water was available. By
1933 when Death Valley National Monument was established, burros were long
established in all of the mountain ranges bordering Death Valley. In a num-
ber of areas damage caused by burros wets already severe. Dixon and Sumner
(1939) reported vegetation deunage, competition with and displacement of
native wildlife in the mid-1930's. Numerous later reports document further
competition and damage (Sumner 1959 ; Welles and Welles 1961; McKnight 1958).
The Death Valley burro population now numbers about 1,500 animals and is
Increasing (Hansen 1973). Most of the burros range within Management Units
1 through 5 on the west side of Death Valley. The Monument, Figure 1, has
CAl-NEVA WILDLIFE 1974.
Appendix 19, pg. 2
Place Names Key
1 Ibex Hills
2 Cottonwood Mts
3 Hunter Mountain
4 Quartz Spring S'
5 Goldbelt Spring
6 Eagle Spring / //
7 Telescope Peak
8 Wildrose Canyon
9 Butte Valley
10 Eagle Borax
.jf -
'..O'/,
A
• - j, '1
10 15 20 miles
. S\
FIGURE 1.
DEATH VALLEY NATIONAL MONUMSNT TOPOGRAPHIC FEATURES AND PLACE NAMES.
2 2
CAL-NEVA WILDLIFE 1974
Appendix 19, pg. 3
been divided into 11 management unite, Figure 2.)
The largest concentration of free-roaming burros in California occurs in
the Death Valley region, on and adjacent to Monument lands. More than 40%
of the wild burros in California range within Death Valley National Monument
(Weaver 1972). Burros ranging on public lands in Nevada also enter the
Monument, but their numbers are smaller. The present distribution of burros
is shown in Figure 3. Recent range extensions noted since the burro census
of 1972 have been included. The broken Him on the map shows potential
range expansion and is based cm the availability of suitable terrain, water
and forage. Burros presently range on 777 squar© miles (497,000 acres) or
25.6% of Monument land®.
Topography and Vegetation
Elevations within the Monument rang© from more than 20© feet below sea
level to over 11,00© feet. North-south trending mountain ranges border 154
mile long Death Valley on the east and west. The Amargosa Rang© rise®
steeply on the east side of the valley to average elevations ©f about 5,000
feet and a maximum of just over 8„700 feet in th© northern section. To the
west of Death Valley lie® th© higher Panamint Rang© having average eleva-
tions about 8,000 fe@t and an extrema of 11,049 feet. The terrain utilized
by burro© includes broad alluvial fan® and hajadas, crayons, intermont&ne
valleys, and rolling upland®.
Vegetative cover is divers© a® may fo® expected in an area of great relief.
The flat floor of Death Valley is barren of vegetation and encrusted with
salts except in low to moderately saline areas where phreatophyte® exist.
Desert shrubs cover much of th© land between sea level and 6,000 feet. The
desert shrub community can be divided ©levafeion&lly into several associa-
tions having discontinuous, gradational ©r overlapping boundaries.
Creosotebush-saltbush (Larrea-Atriplex) sparsely covers the lower eleva-
tions, mainly on the rocky' alluvial 'fan deposit®. Creosotebush-burrobush
(Larrea-Franseria) covers middle elevations. Stands of hop-sage (Grayia) ,
blackbrush' TColeogyna) rad associated shrubs comprise the cover afc""feh©
higher elevation®, fhe latter association® appear to fo@ favored by burros.
Piny on- juniper woodland occurs between 6,000 and 9,000 feet. Limber pine
and bristlecone pine woodland i® found at elevations above 9,000 feet.
Shrub cover in and between stands of coniferous woodland is principally big
sagebrush (Artemesla tridentata) .
Wildlife
A diversified fauna exists in the Death Valley region which lie® near the
indistinct boundary between the Mojave and Great Basin deserts. Fifty-one
species of native mammals, 36 reptiles, 3 amphibians, and 6 fishes have been
recorded from the Monument (DVNHA, 1973) .
The desert bighorn sheep ranks high among animals requiring special manage-
ment attention because their numbers and habitat are declining. A 1972
census indicated a bighorn population of 583 (Hansen 1972) . In 1961 counts
estimated 915 bighorn in the same area (Welles and Welles 1961) . Range
studies by Hansen (1972) have placed the pre-pioneer (pre-1850) bighorn
population at as many as 4,800 animal®. Table 2 shows the present and pre-
1850 distribution of bighorn by management units.
Areas presently occupied by bighorn total 384 square miles and appear as
non -contiguous enclaves (Figure 4) . Former range totalled about 1,400
Square miles rad included nearly all mountainous areas of the present Monu-
ment. Only the Ibax Hill® in the southeastern portion of Death Valley
CAL-NEVA WILDLIFE 1974.
Appendix 19, pg. 4
FIGURE 2.
MANAGEMENT UNITS, DEATH VALLEY NATIONAL MONUMENT.
2 4
CAL-NEVA WILDLIFE 1974
Appendix 19, pg, 5
received transient use as animals moved between the southern Amargosa Range
and the Avawatz Mountains farther south (Hansen 19 72) .
The decline of bighorn has been attributed to many factors,, Natural causes
for decline include predation, respiratory diseases, parasites, natural
accidents, and extended periods of drought. The decline has been hastened
by roan (Weaver 1972a). The proximity of man in large numbers, mining
activities, usurpation or occupation of water source®, highway construc-
tion, fencing and other barriers, and poaching have adversely affected big-
horn. In Death Valley mining activity and the modification of water sources
have had the greatest impact. The impact of burros must be added to natural
and man -induced causes for the decline of bighorn. It is the sum of all
these factors which has depressed bighorn numbers and their range. The
presence of burros, however, results in impacts which reach beyond those
affecting bighorn.
Burro Impacts
The fundamental problem is that burros have been introduced into an eco-
system operating since the Pleistocene under nominally natural conditions
characterized by normally marginal water supply, low annual forage produc-
tion, severe climate (even for arid regions) , and infrequent but sometimes
devastating erosive forces, such as wind deflation and flash-flooding. The
system is unable to absorb the addition of a new, large herbivore without
large scale adjustments, h new equilibrium has not yet been reached.
The adjustment toward a new equilibrium has been observed for several
decades. Pour problem area® have been identified! competition with native
animals, vegetational change®, damage to soils, and impacts at springs
(Hansen 1973).
Competition with native animal®
Surveys conducted since the 1930 "s hav® recorded the changes in bighorn dis-
tribution and have shewn that competition exists between burros and bighorn
for forage, water, and ©pae® (Sumner 1959; Hansen 1973; and others).
Bighorn regularly us@d three key springs in the Cottonwood Mountains in
1939. As burro numbers and use in th® are© iner@ased, there 'has been no
significant us® of these spring® by bighorn in the last 25 year® (Sumner
1959). Bighorn and burros, however, @har@ nearby Quartz Spring. A similar
situation of reduced bighorn us© exist® in Cottonwood Canyon (in the same
mountain range) and is worsened by th© seasonal presence of trespass cattle.
Bighorn were known t® utilize Eagl® Spring in the Panarainfe Mountains in
1935. Burros entered th® are® in 193® and bighorn us© terminated. Bighorn
fed and watered in Butt© Valley in th© early 1930 "s; by 1935 bighorn were
replaced by herds of burros (Sumner 19 59)'.
Competition between burros and smaller mammals, especially rodents, has not
been studied. However, field observations suggest that an adverse impact
may exist (Hansen, per©, coirnj. Further study is desirable to determine
the effects of habitat disturbance, ©specially in such areas as trampling
of animal burrows, and possible effect® of reduced forage and seed produc-
tion. Impacts upon herpetofaun®, a major ©lament of the desert ecosystem,
is totally unknown.
Vegetation changes
Desert shrub-grassland associations support a greater number of burros than
do other habitats. Both browse and grass species are utilized by burros,
but where equally available, grasses are preferred (Browning 1971). It is
significant that areas heavily grazed by burros are now shrubland instead
CAL-NEVA WILDLIFE 1974.
Appendix 19, pg. 6
FIGURE 3.
BURRO DISTRIBUTION. BROKEN LINE SHOWS POTENTIAL
BURRO RANGE EXPANSION. (AFTER HANSEN, 1973)
CAL-NEVA WILDLIFE 1974
»
2 6
Appendix 19, pg. 7
of shrub-grassland. Un-utilized portions of Unit 3 are shrub-grassland,
believed to be remnants of the native (unmodified) vegetative cover (Hanson
1973) .
Data from transects within and adjacent to a burro exclosure at Wildrose
Canyon were gathered in September 1973, after the exclosure had been in
operation for two seasons during which time rainfall was above normal.
Within the exclosure there is a marked increase in the volume of shrubs
favored by burros. Only blackbrush (Coleogvne) , a species utilized lightly
by burros, is more abundant outside the ex closure (Fisher 1974). Burrobush
(Franseria dumps a) , a species favored by burros (Browning 1960) , is more
abundant within the exclosure and individual plants within the exclosure are
larger (Fisher 1974). Other species of woody perennials also show increased
vigor within the exclosure. Shockley goldenhead (Acamptopappus) , indigo
bush (Dales), Mormon tea (Ephedra), hop-sage (Grayia) , Haplopappus , and box-
thorn (Lvclum) all appear In the "diet of burros ~( Browning I960 ; Hansen 1973).
Perennial grasses are more abundant within the exclosure, but despite favor-
able growth conditions, remain depressed on burro range (Fisher 1974).
Annual grasses and forbs show a significant difference in abundance within
the exclosure (Table 4). Some species, such as fiddleneck (Amsinckia) and
ricegrass (Oryzopsis) , not recorded in the outside transect , have become
reestablished inside the exclosure (Fisher 1974) . Amsinckia tessellata is
known to receive moderate use by burros in the spring (Browning 1960) . The
density of annuals within the exclosure was 73. 8 plants per square meter;
density outside was 26.7 (Fisher 1974).
In areas of heavy burro occupation the density and sizes of plants , espe-
cially shrubs, are much reduced. Damage is greatest in the vicinity of
water sources. Mis-shapen shrubs and abnormally numerous dead shrubs
result from repeated cropping (Hansen, Weaver, others). The ratio of dead
shrubs outside vs inside the Wildrose exclosure was 27:1 (Fisher 1974).
Vegetation whicE~”is not eaten often is damaged by trampling or uprooting
during feeding (McKnight 1958). Though not quantified it is obvioui that
flowering and seed production has been reduced at least locally. Three
areas within the Monument are especially hard hit: Butte Valley, Wildrose
basin, and the Hunter Mo un tain -Goldbe It -Cottonwood Canyon region. Creosote-
bush (Larrea divaricate) has been browsed in these areas of heaviest burro
use. This plant is rarely eaten by any animal (McKnight 1958) .
Relict plant communities may be affected by burros. Recent studies suggest
burro damage, principally by trampling, as probable cause for the low
reproduction of bristlecone pine (Pinus longaeva) above 10,000 feet on
Telescope Peak in the central P an ami nt Range (L.' Johnson, written comm.).
At the opposite elevation extreme, formerly abundant alkali sacaton grass
(Sporobolus airoidas) at Eagle Borax, a site below sea level, has been
grazed so heavily by burros that many plants are now dead. This has
occurred since 1969. Mesquite, saltbush, and Death Valley goldeneye
(Viguiera reticulata) , a local endemic species growing on adjacent alluvial
ferns, is~also heavily utilized (Hansen 1973).
The existence of introduced burros exerts added stress on a natural ecosys-
tem unadjusted to the presence of burros or similar animals. One conserva-
tive estimate of plant utilization is as follows: using 318 lbs. as the
mean weight of a burro and 9.7 lbs. daily forage consumption, the 1,500
burros in Death Valley consume 14,500 lbs. (7.27 tons) of food per day or
about 5,310,000 lbs. (more than 2,650 tons) of food per year. Weight and
daily consumption values believed comparable to Death Valley conditions were
selected from Maloiy (1970).
CAL-NEVA WILDLIFE 1974 .
Appendix 19, pg. 8
FIGURE 4.
BIGHORN RANGE (AFTER HANSEN, 1972).
2 8
CAL-NEVA WILDLIFE 1974
Appendix 19, pg. 9
Soils
Tracking and trampling diminishes vegetative cover and hastens erosion
especially during infrequent and often severe storms. Bare soil between
plants is normally protected from wind deflation and water erosion by the
development of a gravel cover of desert pavement, often one pebble thick,
which retards movement of underlying eilfe- and sand-aistod fractions (Thorn-
bury 1960) , Tracking disturbs th® pavement and exposes the finer soil
particles. Where pavements are absent or poorly developed soil is retained
by the development, following rains, of a thin, porous mineral crust
(Hansen 1973). Fungal mycelia also serve as ©oil binders (F. Went, pers.
comm.). Though both mineral and fungal structures are repaired after rains,
tracking soon destroys them.
Tracking in the Wildrose area has disturbed 97-100% of the bare soil areas
within one mile of the sampled water source (Hansen 1973). Up to 5 miles
from the water, 20-25% of the bare soils are disturbed (Hansen 1973). In
the Goldbalt Spring area of the Cottonwood Mountains, 80-100% of the bare
soils are disturbed.
A pronounced effect of tracking is readily visible on hillsides where burro
trails tend to be numerous. Soils removed from trail treads on steep hill-
sides are displaced outward and downward through repeated trail use (Weaver
1972a) . During storms greater amounts of soil are removed by sheetf lood
and rillwash erosion. Locally (Rogers Peak, central Panamint Mountains,
for example) ,. thin soils have been removed to bedrock. Thicker soils are
sub ject to gullying (Hunter Mountain) •
Springs
Environmental alteration i® sever© at and near water sources because burros
tend to congregate around waterholes and repeatedly move to and from them.
Unless food is scarce burros generally do not travel more than 5 or 6 miles
from water (McKnighfc 1958 ? Hansen 1973)'.
Ponded springs are polluted with urine and feces (Weaver 1972a) . Though it
was formerly thought that bighorn would abandon a spring used by burros , it
is known that wildlife and burros regularly do use the same springs. Con-
tamination of water by burros does not preclude use by large animals . Pol-
lution, however, remains an issue. Pollution is unquestionably objection-
able to humans and preclude® hikers5 and backpackers® use of affected
springs (Weaver 1972a) .
Burros cam and do usurp available water at the expense of native wildlife.
Many springs in the Monument do not have flew volumes large enough to supply
the needs of both burros and native animals (Weaver 1972a; Hansen 1972).
Flows of many springs are measured in gallons per day and have no flow dur-
ing summer. Other water source® are small potholes (tinajas) capable of
storing a few tens of gallons of water. Though adequate during winter
months, wildlife water supply in summer is often tenuous. As summer tem-
peratures climb to and above 120® F. in Death Valley, daily evaporation
often exceeds 1 inch. Though the 90:1 evaporation/precipitation ratio
(Hunt at al. 1966) is less at elevations above the valley floor, small
springs go dry early in the summer. Tinajas then store water for only a
short time after infrequent storms. Unlike other deserts there is no sum-
mer rainy season. The amount of available water is the most important fac-
tor acting to limit bighorn herd distribution. Man has aggravated the
situation by usurping and altering many springs. Add the feral burro and
bighorn survival in some locations has become critical (Hansen 1972; Weaver
1972a) .
2 9
CAL N12VA WILDLIFE 1974
Appendix 19, pg. 20
Table 1. Burro Distribution In Death Valley
by Management Unit
(Hansen 197
Unit
Burros
1
125
2
600
3
100
4
455
5
220
6
0
7
0
8
occasional
9
0
10
20
11
0
Table 2. Present and Past Bighorn Population
by Management Units (Hansen 1972)
Bighorn
Population
Unit
Present
Pre-1850
1
90
1,000
2
125
800
3
80
300
4
33
900
5
20
500
6
0
Transient
7
110
250
8
65
150
9
0
0
10
60
900
11
0
0
Totals 583
4,800
CAL -NEVA WILDLIFE 1974 .
3 0
Appendix 19, pg. 21
Burros affect springs and aquatic habitats in other less direct ways.
Destruction of vegetation around springs has reduced cover for birds and
small mammals (Weaver 1972a). Less visible is the throat to invertebrates .
Of the near 300 springs in Death Valley National Monument, less than 20 of
the more accessible springs have been inventoried. To date 15 species of
aquatic molluscs have been found. Most are new, endemic species. The area
may contain twice the known number of molluscs (D. Taylor, pers. comm.).
Water turbidity, changes in chemistry due to the presence of excreta, and
repoated disturbance of pond substrates are factors affecting the survival
of some invertebrates.
Burro Control Activities
A burro control program began in 1939. At that time the population was
approximately 1,500 animals and the range included the mountainous areas on
both sides of Death Valley. By 1942 all burros were successfully removed
from the mountains on the east side of the valley. The complete removal
from the Amargosa Range reduced the Monument population to about 700 burros
(Hansen 1973) . Control and removal activities continued but varied with
fluctuations in available personnel and funding levels. Efforts in the
Panamint Mountains were directed toward cropping population increments and
did not attempt a systematic removal of burros from a given area. Removal
activities centered mainly in the Wildrose and Butte Valley areas. Between
1939 and 1968 official records show that 3,578 burros were removed from
Death Valley and may have been as high as 4,130 if unrecorded trapper
reports are added. Burro control activities were curtailed in 1968 (Hansen
1973) . The National Environmental Policy Act of 1969 required the prepara-
tion of an environmental impact statement (EIS) prior to initiation of a
major or controversial federal project. Additionally several wild horse
and burro protection bills were introduced in Congress. (The Wild Horse
and Burro Act, Public Law 92-195, became law in December 1971.) The odds
for successfully completing an EIS were low, especially because the outcome
of pending legislation to control burros was uncertain.
By 1972 the burro population had again risen to 1,500 with the animals
occurring in greater densities on a smaller range (Hansen 1973) . Live
trapping resumed in July 1973 as an interim control measure. To date 45
burros have been trapped by the National Park Service and removed by permit
holders for pets.
Management Considerations
The National Park Service recognizes the burro as an exotic animal. The
basis for planning and management actions is the National Park Service
Resource Management Policy (1970) for natural areas, which states in part:
"Management will minimize, give direction to, or control those
changes in the native environment and scenic landscape resulting
from human influences on natural processes of ecological succession.
Missing life forms may be reestablished where practicable . Native
environmental complexes will be restored, protected, and maintained,
where practicable, at levels determined through historical and eco-
logical research of plant-animal relationships. Non-native species
may not be introduced into natural areas . Where they have become
established or threaten invasion of a natural area, an appropriate
management plan should be developed to control them, where feasible."
In compliance with this policy and the provisions of the National Environ-
mental Policy Act of 1969, a management plan and draft environmental impact
statement are being prepared.
3 1
CAL-NEVA WILDLIFE 1974.
Appendix 19, pg. 22
Table 3. Shrub Volumes Inside and Outside of the Wildrose
Burro Exclosure (from Fisher 1974)
Shrubs
Plant Volume
INSIDE
( cm3)
OUTSIDE
Acamptopappus schockleyi
Coleogyne ramosissima
Dalea fremontii
Ephedra sp.
Franseria dumosa
Grayia spinoaa
Haplopappus sp.
Lycium andersonii
3,210 ,737
120,511
230,476
3,757,474
50,307
1,810 ,034
266,774
10,741,674
317,678
1,678,862
230,938
1,780,056
14,155
330,010
145,450
601,203
Table 4. Annual Grasses and Forbs Recorded in Vegetative
Transects Inside and Outside of the Wildrose
Burro Exclosure (from Fisher 1974)
Annual Grasses and Forbs
No.
INSIDE
Individuals
OUTSIDE
Aina i nek! a tessellata
4
0
Grass spp.
74
0
Broraus rubens
1160
461
Chaenactis sp.
11
2
Chorizanthe brevicomu
3
0
Cryptantha sp.
7
0
Descurania pinnate
11
2
Eriastrum ereraicum
24
19
Eriogonura sp.
0
1
Er odium texanura
4
0
Gilia can a
69
9
Ipomopsis polycladon
12
7
Lepidium dictyotum
12
5
Oxy theca sp.
9
1
Streptan thella longirostris
2
1
Table 5. Estimated Burro Populations, Death Valley National
Monument (from Sumner, 1951; Hansen, 1973)
Year
Burros
1939
1,500
1942
700
1951
800
1967
1,000
1969
1,350
1972
1,500
CAL-NEVA WILDLIFE 1974
Appendix 19, pg. 23
The plan proposes exclusion of burros from Death Valley. The plan also
provides for the exclusion of trespass livestock as wall. Elements of the
plan are as follows:
1. Continuing research adding to present knowledge of vegetative systems
and the animals therein. Studios of new management and control technique**
is also recommended.
2. Implementation of a public information program to inform the public of
the environmental effects of feral animal problems and to apprise the public
of the progress of the project.
3. Fencing permanently portions of the Monument boundary to preclude entry
by animals ranging on lands adjacent to the Monument. Burros ranging on
surrounding public lands are protected by federal law and populations there
will be managed as a public resource.
4. Removal of burros within the Monument by live trapping and direct reduc-
tion as required.
5. Construction of temporary barrier or drift fences as required within
the Monument to prevent repopulation of areas where animals have been
removed, to protect springs and other water sources from damage by feral
animals, and to reduce competition with native wildlife species.
6. Monitoring of vegetative recovery following exclusion of animals to
determine the need for restorative projects and control of exotic plants.
Conclusions
Damage by feral burros is one of a number of man-caused problems affecting
the integrity of a natural ecosystem in Death Valley. To be effective,
other habitat management projects such as restoration of former wildlife
habitat, rehabilitation of old mining scars, relief of human impact by
recreational activities, and others, cannot be successful if destructive
influences remain. For example, it is of no benefit to bighorn to rehabili-
tate a spring formerly used by them if burros will move in. It is imprac-
tical to ravegetate an abandoned mining road if burro impact negates
management's efforts. For restorative actions to be assured reasonable
success, such actions must be delayed until a primary destructive force is
rendered inoperative. If burro control is unacceptable, the public must
accept the ecological fact of life that the Death Valley ecosystem will
continue to alter until a new equilibrium is reached and native populations
will continue to decline significantly. In the long term, the disappear-
ance of some native species can be expected.
Acknowledgements
A paper on this subject should and probably would have been presented by
Charles G. Hansen, National Park Service Research Biologist, had he not
bean killed in a plane crash in the line of duty on May 2, 1973. This
paper is dedicated to Dr. Hansen in commemoration of his dedication to
wildlife and related studies in Death Valley. Much of the information con-
tained in this report was taken from his writings and the many lengthy dis-
cussions we had together. Special thanks are due Lewis Nelson, Jr. and
Charles L. Douglas for particularly constructive reviews of the manuscript.
CAL -NEVA WILPLIFE 1974.
Appendix 19, pg. 24
Literature Cited
Browning, B. , 1960, Preliminary Report of the Food Habits of the Wild
Burro in the Death Valley National Monument: Desert Bighorn Council
Trans . , p. 88-90 .
f 1971, Food, in The Desert Bighorn, Its Life History, Ecology and
Management, Chapter-!”, p. 4-1 - 4-99 (in press) .
Death Valley Natural History Association, 1973, Fishes, Amphibians, Rep-
tiles, and Mammals of Death Valley National Monument: 8 panel check-
list folder, undated.
Dixon, J. S. and L. E. Sumner, 1939, A Survey of Desert Bighorn in Death
Valley National Monument: California Fish and Game 25:72-95.
Fisher, J. C. , Jr., 1974, Plant Transects from Inside and Outside Two Burro
Exclosures in Death Valley National Monument. National Park Service,
Death Valley, Calif., typed report, 4 pp.
Hansen, C. G. , 1972, The Evaluation of Bighorn Habitat in Death Valley
National Monument: National Park Service, Death Valley, Calif., typed
report, 84 pp.
, 1973 , Evaluation of Burro Activity in Death Valley National
Monument: National Park Service, Death Valley, Calif., report, 43 pp.
Hunt, C. B. , T. W. Robinson, W. A. Bowles and A. L. Washburn, 1966, Hydro-
logic Basin Death Valley, California: U. S. Geological Survey Profes-
sional Paper 494-B, Govern. Print. Office, Washington, D. C. , 138 pp. ,
maps .
Maloly, G. , 1970, Water Economy of the Somali Donkey: J. Physiology p.
1523.
McKnight, T. L. , 1958, The Feral Burro in the United States: Distribution
and Problems: J. Wildl. Manage., 22 (2) :163-173.
National Park Service, 1970, Compilation of the Administrative Policies for
the National Parks and National Monuments of Scientific Significance
(Natural Area Category): U. S. Government Printing Office, 147 pp.
Sumner, L. , 1951, When Desert Bighorn Meets Burro: National Park Service
mimeographed report, November 1951.
, 1959, Effects of Wild Burros on Bighorn in Death Valley, Desert
Bighorn Council Trans., p. 4-8.
Thombury, W. D. , 1960, Principles of Geomorphology: John Wiley and Sons,
Inc. , N . Y. , 618 pp.
Weaver, R. A., 1972, Feral Burro Survey: California Department of Fish and
Game, no. 1-5, Project no. W-51-R-17, July 1, 1968 - June 30, 1972,
Sacto. , Calif., mimeographed report, 14 pp. and map3 .
, 1972a, Desert Bighorn Sheep in Death Valley National Monument
and Adjacent Areas: California Department of Fish and Game Wildlife
Management Administrative Report No. 72-4, Sacto., Calif. (March 1972),
20 pp.
Welles, Ralph E. and Florence B. Welles, 1961, The Bighorn of Death Valley:
U. S. Government Printing Office, Wash., D. C., 242 pp.
CAL-NHVA WILDLIFE 1974
Appendix 20, pg. 1
BURRO RESEARCH, BY DR. ROBERT OHMART, ARIZONA STATE UN I VERS 117
Our burro research has been in progress for approximately 2 years
when we started looking into the Chemehuevi Mountains in California
and then shortly after that initiated studies in the Bill Williams
Mountains in Arizona. Since then, about 2 months have passed since
we've initiated studies in the Kofa Mountains on the Kofa Game
Range in Arizona. In the 2 years of information that we've had in
the Chemehuevi Mountains, in this herd of 70 or 80 burros, we see
definite movements in these animals. When we initiated these
studies in late 1973, we found that from the winter of the preced-
ing year there had been a tremendous amount of rainfall, compara-
tively, for that period. As a result of this, for the last couple
of years and until a year ago, burros and all other animals were
utilizing a large portion of an annual that has grown 1 or 2 years
ago. I think if we look at some of the food habits data you'll
see that indeed this annual, desert wheatgrass (Plantago insularis)
plays a very important role when it's available in the areas.
In the fall of 1974, we viewed not too much movement displacement
in the Chemhuevi herd toward the south. I have a map and in a
minute we'll look at our study areas. In 1975, we were viewing a
much greater herd displacement south toward the Havasu Landing.
SLIDES
This, again, is the map I referred to earlier. We're looking into
the Chemhuevi Mountains, some of the data we're talking about in
this area, trampas Wash which allows us to go from Highway 95,
which is out in here, all the way back and penetrate to the river
just above Blankenship Bend, Topock Gorge being right here, just
west of the Mojave Mountains,, In the winter of 1974 we saw very
little displacement of animals from this area south to here
although we did see some. The burros moved out into the flats
in the fall after the mesquite beans had dropped and been elimi-
nated from the riparian communities along here, the animals moved
into this area and utilized Plantago and other plant species in
there, then in the spring they returned back to the Trampas Wash
area. Home ranges varied from 6 square miles up to 36 square miles.
A jenny had the smallest home range and a jenny had the largest home
range. There was no significant difference between jacks and jennies
Appendix 20, pg. 2
as far as home range size. Our home ranges were slightly larger
than those reported by Patty Moehlman in Death Valley. Interest-
ingly enough, home ranges were not perpendicular to the river, but
were more or less parallel to it in some instances, but perpendicular
to it in others.
The animals tended to spend, in the summer periods, a lot of their
time along the river edge utilizing the riparian communities as a
water source and as a food source and in the wintertime tended to
move away from it and utilize the mountain ranges for food sources,
feeding on the interfluves or between the drainages where annuals
and the like were present.
Also, some of the data will be from the Bill Williams Mountains.
Here we have bighorn sheep sympatric with burros. Unfortunately,
the food habits data from this mountain range is not completed.
I have the bighorn sheep data with me which just came out of the
laboratory and I have the burro data from the Chemhuevi Mountains.
You can see these areas are maybe 20 miles apart, separated by the
Colorado River. We will look at these two sets of data.
The burro fecal analyses, or food habits data, are being completed
and hopefully will be in our semi-annual report to BLM when we
turn in the January report. The food habits data from the Cheme-
huevi Mountains for burros is present in our last annual report.
I might comment on how we are getting at the food habits informa-
tion. Only fresh fecal material is picked up. In other words, we
watch an animal defecate and after the animal moves away, the biol-
ogist moves in and picks up a fecal sample. This way we know we're
talking about annual food habits, or monthly food habits, and not
leaving it to chance as to a fecal group being from January or
February and going out and saying, "Aha, this represents an annual
food habits picture." We feel we have to collect monthly samples
from animals, freshly dropped, otherwise we really are not sure
what we're viewing in the way of food habits.
These are composite samples that I'll be talking about. Samples
of 10 droppings of 10 different animals are taken per month. We
take a tenth of these, they're ground up, mixed, washed, then we
take a sample from those and make 20 slides of that. On each slide
we read 20 fields randomly, so there's 400 fields read with plant
parts being identified in these fields. The technician that reads
these plants wouldn't know one plant from another, has no idea what
Appendix 21, pg. 3
i
burro biology or bighorn biology is involved, she's simply a plant
technician who can recognize a plant from a microscopic standpoint,
but many of the plants she's never seen before in her life or If
she has, she doesn't know what they are. We feel that this helps
insure that we're getting an unbiased bit of information from this
young lady in the fact that she's providing us with simply what she
identifies in these slides.
We might run through some of the other slides I have here and dis-
cuss a little bit of the other information that we've seen in the
study areas.
This is Plantago insularis, or desert wheatgrass. The three plants
on the left are growing plants. This annual herbaceous plant is
stimulated to grow during the winter. It's a cool season grower
and when rain falls in the winter, Plantago insularis germinates
and matures throughout the wintertime. Once spring comes, it starts
to dry up and cure. The plant on the left is a cured plant. Depend-
ing on the amount of rainfall, this is the difference in size in
these plants. The one on the right is one of the plants that was
grown during one good winter season. The three on the left are
maximum size we found in 1975 when there was very little rainfall.
You can see that the size of the plant is related to the amount of
rainfall and obviously availability of the plant is directly related
to winter rainfall. Once this plant grows, sets seed, then it dies
and remains as a cured annual out on the area where it's used by
bighorn sheep and burros and the like.
Here's a picture of Plantago insularis. You can see the brown
material covering the soil site here and burros are utilizing
Plantago insularis here. Plantago is utilized heavily when it's
available. When it's not available, then obviously some other
plant species takes on the brunt of removal by all animals.
Here's a picture of desert bighorn sheep utilizing Plantago insu-
laris. You can see the one ewe in the upper left hand corner has
a radio collar on her. That's her lamb with her. You can see
another ewe there that has a lamb. We had three lambs born in the
Bill Williams this year. After about 3 months of age, all three
of them disappeared. We're not exactly sure why they disappeared,
but we strongly suspect it was not predators, but it was the tran-
sition from weaning to a solid food source. They're certainly more
vulnerable to predators during the time that they're 1, or 2, or
Appendix 20, pg. 4
3 weeks old than they are when they get to be 3 months old. We
suspect that this food problem may be much more acute than the
data in the past has shown. The data in the past has been very
scanty. It's not very well documented.
Here's also a picture of bighorn sheep utilizing the inflorescences
of brittlebush (Encelia farinosa). This comprises another important
component of their diet as well as paloverdes (Cercidium) which is
another important component of both bighorn and burro diets.
Here's a ewe which had a lamb a couple of months after we captured
here and radio collared her. The lamb lived approximately 3 months
and then disappeared. We never saw the lamb again.
Here's another picture of the ewe and the young lamb. You can see
the lamb is maybe 2 or 3 weeks old there and the radio collared
ewe. You can see again the dearth of Plantago insularis. This
was this last winter, in January or February. Very little, if any,
Plantago on the slide which means we didn't have good winter range.
Here's a picture of the ewe a few months later. See the radio
collar on her? She's coming in to water without her lamb.
We've heard a lot of stories of burro and bighorn interactions.
We have seen a number of burros and a number of bighorn sheep in
relatively close proximity. Here the animals are 10 or 13 yards
from one another and neither appearing to pay much attention to
the other. Like I say, we have a number of these observations.
This does not negate anyone else's story that they've seen bighorns
kill burros or burros kill bighorns. All we can say is that in the
instances that we've observed we have not seen interactions between
bighorns and burros in close proximity. In these two areas we're
talking about, water is not a limited resource. There's the Colo-
rado River running through each of the study areas, there's the
Bill Williams River running through there, and there's the Planet
Ranch which has domestic livestock on it and provides a food source
for livestock in the form of Bermuda grass and the like. So
water's not a limited resource, no one would be defending a water-
hole or the like, but in the interactions that we've seen there
have never been any physical interactions between bighorns or
burros or bighorns and deer, bighorns and domestic livestock, or
any of the other possible combinations.
Appendix 20, pg. fJ
Here's another slide of bighorn sheep. You can see a ewe and a
lamb to the right of the burros. You can see another ewe up above
them. They're probably within 6 to 8 yards of one another, the
ewe and the lamb, and no apparent interest displayed by either
species. Here, again, this does not negate anyone's observations
on seeing one animal attacking the other or the like. We have just
never seen this. Here, again, you can see large amounts of brittle-
bush in there, (Encelia farinosa) and a number of other shrubs which
are important in both of these animal species. Here, again, they're
browsing or feeding together and this is something in the past most
people have said bighorns are in the rough, rocky areas and burros
are in the flats. This is not true. They both utilize to a great
extent common situations and I think one of the reasons why the big-
horns are in the rocky areas is because they saw you long before
you saw them and they have gone there for protective cover. When
they are out foraging and grazing, they're utilizing the entire
habitat and not just the rough, rocky areas of which the burros can
penetrate just as nicely as can bighorn sheep. Not quite as agile,
but certainly as capable.
We have gone into a collection program where we're looking at burros
and trying to get some assessment of biological parameters about
these animals. This is a jenny that I shot 2 weeks ago. She was
5 to 6 years old and had a colt with her. I collected both animals.
We wanted the blood samples from these animals as well. They were
shot in the neck with a 7 mm magnum, of which I do the shooting,
and then we get blood samples to compare with the 120 odd blood
samples that we have from drugged burros to see comparisons between
the drugged versus this. It took about 6 hours to necropsy this
animal. Every major artery and vein were opened, all organs were
weighed and measured, tissue samples were taken for histological
evidence, skin weights were taken, parts of the brain, the entire
system was gone through as well as the lymphatic system on these
animals. It's a tremendous amount of work.
Here's the colt which is about 4 weeks old. As I said before, they
were all shot in the neck. We don't want any organs disturbed, we
want weights and measurements on these, but it's done as humanely
as possible. We take them by jeep to the field base. Here are
Dr. Ed Bicknell, a veterinarian who aids us on this necropsy work
and Mr. Glen Martin with BLM. Body weights are taken, organ weights,
Appendix 20, pg. 6
the entire system is worked over; we skin out the animal, work it
down, and eventually then the material is all taken back and
incinerated .
I have some overhead projections I would like to show you relative
to some of the information we're finding in some of our burro studies.
In the Chemehuevi Mountains this gives you some idea of where a
burro spends its time during a 12-month period. As you can see,
the interfluves are the areas between washes which, in January,
February, March, April, and May, constitute where the majority of
the burros' time is spent. By May, we're running ambient tempera-
tures close to 120° to 125° F. The animals then begin to spend less
time on the interfluves and more time is spent in the riparian com-
munity where shade and water are available. You can see that during
this time, also, they're spending more time in the washes. This is
where they're primarily feeding during this period. The food data
that we have substantiates the changes in these different environ-
ments. This would be primarily Plantago feeding time, this would
be primarily mesquite bean feeding time, then back to Plantago or
whatever is available in the washes and the interfluves. You can
see that they're sharing about the same portion of the time here.
So, in a 12-month period, on a percent frequency basis, scoring
each animal as a hit, one gets an indication of where these animals
are spending their time in these desert ecosystems.
Here's a slide showing the four primary food items of burros in the
Chemehuevi Mountains in 1974 and part of 1975. You can see that
Plantago insularis forms a very important part of the diet from
January through June and July. Here, again, this plant is primarily
on the interfluves. That's where these burros are getting it. In
June and July, Cercidium occurs in the washes. Remember, that's
the time they're spending in the washes. Cercidium, or paloverde,
becomes an important component. You can see that they are utilizing
Prosopis, which is the long dotted line, in July and August when
bean drop and bean set are beginning. As they become reduced in
availability, the burros then shift back to paloverde and Pluchea
(arrowweed) forms a very important part of the diet in the Cheme-
huevis at that time. You can see that two major components in the
desert in the burro diet is Plantago insularis, which is a herbaceous
form, and paloverde.
Appendix 20, pg. 7
Here, again, this is not a valid comparison because we're looking
at two different mountain areas, but we're looking at bighorn sheep
diets in the Bill Williams and burro diets in the Chemehuevi Moun-
tains. We'll eventually have our burro diets in the Chemehuevis and
I think they'll show virtually the same thing. But you can see that
Plantago insularis plays a very important role in both of these
species' diets. Bighorns will take it when it's available as will
burros. You can also see that Cercidium, this is paloverde, is
another important diet in bighorn sheep as far as energy availabil-
ity. In June, July, August, and also October, you can see that
paloverde plays a very important part, then in January Plantago
begins to become important, and also in here Cynodon dactylon,
which is Bermuda grass, produced by Planet Ranch, is also a very
important component of the bighorn sheep diet, especially in the
spring months when it is available. We feel that this may well
be one of the reasons why bighorn possibly have done as well in
the Bill Williams Mountains as they have although we don't have
enough data base yet to make any concrete statements relative to
that. I think that once we get the burro data superimposed from
the same habitat, on the same time frame with the same food avail-
ability, we will see definitely heavy overlaps in burro use of food
sources such as bighorns use.
This is another table showing you the major diet of desert bighorn
sheep in the Bill Williams. You can see that Plantago insularis
plays a very important part, paloverde, Hyptis, Bermuda grass,
Cryptantha, some of these things do not have common names. Burro-
bush also became an important parameter in here, creosotebush form-
ing almost 4 percent, and, of course, mesquite coming into the diet
as well. Frequency, the number of times they appear every month,
is 100 percent for a lot of these plant species.
One of the problems in trying to document any kind of competitive
interaction with two animals like the bighorn and the burro is the
fact that it takes a number of years of simultaneous data in some
of these habitats to document when the bad year comes because it's
probably going to be the bad year where the real tough competition
is going to occur. When the food resources have been depleted,
there is no Plantago available for either species. It may well be
it's going to be such a subtle thing that you may not be able to
see it there. It does appear that both of these forms are utiliz-
ing virtually the same kinds of plant material, the burro having
Appendix 20, pg. 8
even the greatest versatility. In our Chemehuevi data, we find
that if you get a month with a little rainfall in it, the next
month the diet of the burro will include as high as 39 species of
plants, whereas a month preceded by a dry month, the diet usually
includes only about 10 or 11 species of plants with Plantago and
Cercidium, some of these species being the most important components
during that time.
I think our data are beginning to be quite revealing with respect
to some of the potential problems that may be existing between big-
horns and burros.
In the Kofa Mountain range, we have even a more interesting situa-
tion in the fact that we have domestic livestock, burros, bighorn
sheep, and mule deer. In the Bill Williams Mountains, we do not
have very many mule deer. They're mostly confined to the riparian
community and not in the Bill Williams Mountains themselves.
Recently, my research has caught the eye of a Senator back in Dela-
ware. Senator William Roth has nominated the study we're doing on
burro movements and behaviors and the like as being one of the
frills of the year awards. In other words, one of the types of
research where governmental agencies are spending their money for
a nonpublic demand type of information. I've written to Mr. Roth
pointing out to him the importance of this, the passage of Public
Law 92-193, and the like. Also, I point out to him that if he has
no concern for the preservation of desert ecosystems or the poten-
tial welfare of native plants and animals, then I could understand
how he could make these allegations. In a recent phone call to him
by a Phoenix newspaper, he points out the fact that he is concerned
about Government spending and he sees no reason why these problems
should be looked into and that there is an Advisory Board set up to
advise the Secretary of the Interior. Obviously, he really has no
idea of what the Advisory Board's capacity is, they're not a
research agency. So, I would recommend that the Advisory Board
inform Mr. Roth of their responsibilities in these problems. Also,
people who are interested and concerned about the burro problem,
about the bighorn problem, about desert ecosystems, possibly even
write Mr. Roth, not for myself or anyone else, but simply to make
him aware that there are problems such as this and that he is cer-
tainly not helping by singling out these kinds of research prob-
lems. Bill McClellan from the Phoenix paper summarizes by saying,
"Hell hath no fury like a Senator running for reelection." Mr. Roth
is running for reelection and I'm sure that he's showing to his
constituents he's concerned about governmental spending, but unfor-
tunately, I think he's chosen some of the wrong projects, at least
one of the wrong projects, to criticize.
Appendix 21, pg. 1
PRESENTATION BY JIM ENGLEBRIGHT, BUREAU OF LAND MANAGEMENT
CHALLIS WILD HORSES
For presentation at the December, 1975 meeting of the National Advisory Board
on Wild Free -Roaming Horses and Burros.
SLIDE
NARRATIVE
1. Challis Wild Horses
Good Afternoon. My specific job for the past
2\ years has been to study and write a manage-
ment plan for the Challis Wild Horses. We
feel that we now have some good basic data
on this particular herd.
2. Map of Idaho
The horses are located near the town of
Challis, Idaho. Challis is a small town
in eastern Idaho.
3. Wild Horse Boundaries
This slide shows the approximate boundaries
of the Challis Wild Horse Area. This area
is just south of Challis. Exact boundaries
were established by the B.L.M. which consist
of approximately 168,648 acres, and are
roughly 24 by 13 square miles.
4. Topography
Topography is varied in the wild horse area.
The peak in the background is Lone Pine Peak
which is about 9,600 feet. However, most of
the area is rolling sagebrush
5. Topography
grass foothills. The lowest elevation is
in Bradbury Flat which is around 5,400 feet.
6. Spar Canyon
Vegetation and soils vary in the area from
this in Spar Canyon . .
Appendix 21, pg. 2
7. Bluebunch
Stand
8. Cattle
Wheatgrass . . To this in some of the higher country.
The wild horse area is used by a variety of
animals. Currently 14 different operators
have grazing privileges in the wild horse
area and collectively run 3,974 cattle and
100 sheep.
As you may have heard, the Challis Planning
Unit is currently drawing national attention
by being the first planning unit administered
by the B.L.M. to have an Environmental Impact
Statement prepared on livestock grazing.
The wild horse area comprises about 45 7a of
the Planning Unit and therefore, wild horses
are a major consideration in the E.I.S.
The statement is a result of a suit filed
by the Natural Resource Defense Council and
others, challenging that the Bureau's
bureau-wide programmatic statement did not
comply with the National Environmental Policy
Act in connection with the grazing program.
The court agreed with the plaintiffs and
the Challis Planning Unit was chosen to
serve as the initial statement on a planning
unit basis. The statement should be ready
for public review in April of 1976. I'll
2
Appendix 21, pg. 3
discuss the statement and how it relates to
wild horses a little later on in the program.
Antelope
Wild animal* ate plant i tut in the wild hotae
area. About 300-350 antelope . . .
10. Elk
100-150 elk . . .
11. Deer
and 600-800 deer call it their home during
some portion of the year (numbers estimated).
Elk and deer primarily use the area as
winter range.
12. Salmon
The headwaters of the East Fork also provide
major spawning grounds for anadromous fish.
As you can see, management considerations in
the Challis Unit are complicated.
13. Stallion gathering mares
Currently there are 407 horses and three
burros in the Challis Unit.
14. Mares in flight
These horses have a little better size and
conformation than most wild horses. The
average weight of a mature adult horse is
estimated to be 900 lbs.
15. Lone Gray Stallion
Band size varies from one individual horse
such as this (note his size) . . .
16. Large Band in Movement
To this band with 21 members. The gray
colors you are seeing are a characteristic
color in the herd. Dominant colors are bay,
black and gray.
17. Burro with White Nose
Three burros run with the wild horses. This
burro and this young stallion are pals; wherever
you see one, you will find the other.
3
Append ix 21, pg . 4
18. Burro with grays
Another burro. Note the gray horses, how
they resemble horses with Arabian breeding.
19. Gray Stallion
Another stallion showing characteristic gray
color of Challis horses ....
20. Band of horses
. . . and this is his band of mares.
Characteristically there is one stallion per
band, however several bands have two stallions
per band, some have more than two.
21. Young Colt
The Challis horses have grown rapidly since
1971. Our best count in 1971 indicated 150 horses
and 1 burro. Today there are 407 horses and
3 burros, representing almost a 2707, increment.
In 1973 and 1974 the horses increased at 287,
a year. This year, they only increased by
187«. Our spring this year was late with
heavy snow and cold weather prevailing. This
likely affecting foal mortality. By our best
estimates, a 287. increase in 1973-1974 would
indicate about an 857. colt crop.
22. Dead Horse
Mortality until this year has only been
approximately 2-37o ....
23. Sick Mare
. . . which could mostly be attributed to
natural causes and parasites. This mare was
found dying of what was believed to be
parasite infection. Fecal analysis by
veterinarians indicate that the horses have
high levels of strongyles (a blood worm
4
Appendix 21, pg. 5
affecting the digestive system).
24. Stud Pile
We have been working with Dr. Richard Hansen
of Colorado State University to determine
forage preference of the Challis horses.
We send in random samples of fecal material
during different seasons of the year, and
he examines them microscopically to determine
what the horses have been eating. We also
have done the same for deer, elk, antelope
and cattle. After it was determined what the
various animals are eating, a diet similarity
index was calculated to determine how similar
their diets are. The results of that study
are available and included in the report
that was handed to you.
25. Marker Band -
Roach Back Band
Marker bands such as this one have been
studied for band stability, seasonal movement,
and home ranges. Normally the horses do
not move much over 5 sq. miles anytime during
the year.
26. Cattle and Horses
Feeding Together
We have found in the Challis area that the
greatest competition is between horses and
cattle. Horses under current livestock
management have in essence a competitive
advantage because they are able to use,
and . . .
5
Appendix 21, pg. 6
27. Horses in High Country . . . seem to prefer, much of the steeper,
rougher country. They also are able to
graze farther from water than cattle.
28. Wet -Meadow Area However some areas such as wet -meadow areas,
areas near water, and early spring ranges are
used extensively by both horses and cattle,
and a variety of wildlife species. Some of
these areas are in poor condition as a result
of this combination of use.
29. Fences Fences and wild horses are a continuing
problem. Currently the wild horse area is
not intensively fenced and the horses seem
to have adjusted to the existing fences
rather well. Where gates are open they
consistently go through them - where fences
are open ended, they know their way around.
Since the fences are barb wire, potential
exists for serious damage to horses
especially when they are under stress.
30. Horses on Winter Range We feel that the limiting factor on horse
numbers in the Challis area is winter range.
A range survey recheck was made in the
wild horse area in 1974-1975 to determine a
carrying capacity for wild horses. We found
that the area could support some 582 horses.
However this was based on summer conditions
and all of the country being available to
6
Appendix 21, pg. 7
horses. Much of the horse range becomes
unavailable during the winter because of
deep snow. The late winter and early spring
of 1975 gave a good indication of the country
that was potentially unavailable to horses
during the winter because of deep snow.
This country was mapped and it was concluded
that only 54.3% of the horse area may be
unavailable to horses during extreme winters.
Therefore, under existing conditions it
is our assumption that the area will support
somewhere near one -ha If the number that can
be supported during summer conditions, or
approximately 300 horses.
31. Horse Trap Our recommendation will be to manage the
horses for a minimum of 150 and a maximum
of 300. Currently some gathering facilities
are being prepared to reduce horse numbers.
Possibly next summer a gathering will be
initiated.
32 . The End
7
■
.
Appendix 21, pg. 8
PRESENTATION ON WILD HORSES IN RELATION TO THE E.I.S.
Now in relation to the wild horses and how they are handled in the Environ-
mental Impact Statement; Realize of course that the statement is only in draft
form and may be subject to change.
Basically here is how the statement was handled. The Bureau brought in a team
to write allotment management plans for the various allotments in the Challis
Unit. In the wild horse area, four three pasture rest-rotation systems and
one two pasture rest -rotation system were proposed. The statement then is
an evaluation of the proposed allotment management plans and the effects
they will have on the various resources in the area, such as wild horses.
The impacts on wild horses are many. Whereas an entire allotment was normally
grazed every year by livestock for approximately the same period, now each
allotment will be sub-divided into smaller areas or pastures. Livestock
grazing by pastures will be more concentrated, but for a shorter period of
time. For example in a typical three pasture system:
Pasture 1 - Grazed for livestock production 5/15 - 7/20.
Pasture 2 - Grazed at seed ripe of desirable plants for livestock pro-
duction and seed trample 7/21 to 8/31.
Pasture 3 - Rested yearlong to allow plants to meet their physiological
requirements .
To initiate this kind of proposal, several new fences will have to be con-
structed in the wild horse area. Here is how we have recommended that the
fencing situation in the Challis area be handled -
a. All fences, except fences on the wild horse boundary, should be open-
ended wherever possible to permit free horse movement. This usually
Appendix 21, pg. 9
can be accommodated by tieing fences into areas that are natural
barriers for livestock, or by using let down fences. Let down fences
should not be constructed of barbed wire. Rather smooth wire should
be used to prevent the possibility of horse entanglement.
b. Pole fences and electric fences are not economically feasible.
Maintenance and labor costs are prohibitive. If wire is used, the
first preference should be a three or four-strand smooth wire fence.
Barbed wire should be used as a last alternative.
c. Visibility and contrast are important in building horse fences. The
following recommendations should improve these two aspects of fences
in a horse area.
1. No environmental fence should be used.
2. Wooden stays should be used to add contrast.
3. Wooden posts should be used more liberally. One wooden post every
other post where terrain permits; and one every five posts in steep
rocky terrain.
4. Fences should be kept to ridgetops as much as possible. Canyon
bottoms and draws should be avoided wherever practical. This
gives a "skyline" effect to fences for more visibility.
d. Fences should parallel horse movement patterns as much as possible.
e. All gates should be left open after livestock have been removed to
permit free horse movement.
Basically the rest-rotation systems as proposed will impact the horses in the
following manner:
Induced Horse Movement - It may be expected that induced wild horse movement
will occur from the pastures being grazed, even after mitigating measures are
applied. Because of a greater concentration of livestock per unit area, horses
will move because of their intolerability for cattle and for the human element
2
Appendix 21, pg. 10
involved with managing the cattle.
As horses move into rested pastures, total living space would be reduced and
the density of wild horses per unit area would increase. This may result in
potential for (1) band structure changes resulting from increased contact
between bands; (2) more stress and competition among bands - (i.e. increased
stress among stallions, increased competition for available forage, cover,
water, living space, etc.,); (3) magnification of disease and parasite problems;
(4) change in foaling areas and a variety of other possible factors. The total
ramifications of these impacts are not completely understood.
Reduced Competitive Advantage * It is expected that pastures being grazed by
livestock will result in a reduced competitive advantage for horses in these
pastures. Horses in the past have had the advantage of using some of the rougher,
steeper country that cattle were not using because of steepness of slope and/or
a lack of water. A combination of new water developments and increased
concentrations of cattle per unit area will permit cattle to use some of this
country that was previously unavailable to them.
Horse Winter Ranges - Since winter range is the limiting factor on horse numbers
in the Challis area, use of these winter ranges is critical. Use on horse
winter ranges will continue so long as cattle are in the unit. This is un-
avoidable. Some treatments may result in 70-90 percent utilization of the
available forage.
How this will affect the horses is not quantifiable and will warrant further
study after initiation of the proposal. The impact of the lack of quality
forage for wintering horses is dependent upon the severity of livestock use.
Secondary Impacts of Horses Grazing Rest Pastures - Horses will tend to move
into rested pastures. It has been estimated that 70 to 90 percent of the horses
3
Appendix 21, pg. 11
will be in these areas, depending on the intensity of livestock use in other
pastures, thus use in these areas may be substantial even if mitigating
measures are applied.
It can be expected that horses would graze desirable forage species during the
growing season. This would reduce seed stalks, vigor and litter accumulation
of these species. The impact could be significant and definitely reduce the
desired response of the proposal.
*
4
Appendix 22
STATEMENT OF BELTON P. MOURAS, JR., ANIMAL PROTECTION INSTITUTE
OF AMERICA
Mr. Chairman, I am Belton P. Mouras, Jr., Field Service Director
of the Animal Protection Institute of America, national headquarters
in Sacramento, California.
We again appreciate being invited to attend your meeting--the last
time being at Lake Havasu two years ago.
Let me say to begin with that we are not opposed to the establish-
ment and implementation of a good controlled conservation program
for the burros, but only if the need is very strongly established
and the program is humanely conducted.
If a control program or part of a control program of shooting is
adopted, then we must urge the Board to assure us that the shooting
will be done by professional marksmen, and not by specially-licensed
hunters. We feel humane and other public-interest groups should
also be allowed to monitor the program.
Again, Mr. Chairman, above all, if the need for a control or conser-
vation program is firmly established, we again ask that it be humane.
I thank you for inviting us here today.
.
'
Appendix 23, pg. 1
STATEMENT OF PETER BURK, SIERRA CLUB, REGARDING IMPLEMENTATION OF
PL 92-193, THE WILD FREE-ROAMING HORSE AND BURRO ACT, AS PRESENTED
TO THE NATIONAL ADVISORY BOARD FOR WILD FREE-ROAMING HORSES AND
BURROS, AT CHINA LAKE, CALIFORNIA, 5 DECEMBER 1975.
Attached to this statement is a copy of the Sierra Club policy on
feral burros which should be inserted in the proceedings of this
Board meeting along with these remarks.
The Sierra Club has expressed its policy on the matter of the feral
burros in the Southwestern United States quite clearly in the attached
document. At this time, the Club would like to make tv/o recommendations
regarding the implementation of PI 92-195. The recommendations are made
within the framework of the existing Club policy on feral burros.
(1) Recommendations relevant to the burro situation in the Panamint Range,
Inyo County, California:
Because the numbers of burros in the Panamint Range exceeds
carrying capacity; and
Because these burros exist in habitats and ecosystems which
are administered by three agencies, namely the National Park
Service in Death Valley National Monument, the United States
Navy in the Naval Weapons Center, China Lake, and the Bureau
of Land Management under the jurisdiction of the Bakersfield
and Riverside Districts (although primarily the Bakersfield
District ) ; and
Because these burros freely roam and migrate across jurisdictional
boundaries; and
Because PI 92-195 does not clearly define which agency
would have the jurisdiction over those burros which utilize lands
administered by several agencies; and
Because none of t he above-named agencies can by itself manage
these animals without the cooperation of all agencies involved; the
Sierra Club recommends that the three agencies involved enter into
a cooperative agreement for the management and control of burros
in the Panamint Range; and the Club further recommends that
The control of burros in the Panamint Range should be the Number
One Priority for burro management in the Mojave Desert.
(2) Recommendations relevant to the burro populations in desert bighorn habitats.
The Sierra Club recommends that the BLM promptly inaugurate burro
management and control programs for those areas of the Mojave Desert
in California that are bighorn sheep habitat. The bighorn in California
are a threatened species and are fully protected in the State of
California. There is no hunting season on this increasingly rare
animal in the California desert. The Sierra Club recommends that, the
BLM enter into cooperative agreement with the State of California
Department of Fish and Game in this matter. The Sierra Club refers
the Board to those sections of the Feral Burro Policy which deal with
bighorn habitat and needs of native wildlife.
Appendix 23, pg. 2
The Sierra Club calls for control of feral burros in a manner which protects
native fauna, flora and soils. In addition, the Sierra Club adopts as suggested
guidelines for this policy, the proposed "Sierra Club Feral Burro Policy" prepared
by the SCRCC Desert Subcommittee and the Wildlife Committee of the Angeles
Chapter on April 15, 1975.
(Policy and guidelines adopted by unanimous vote of National Board of Directors,
Sierra Club, San Francisco, California, Annual Board of Directors meeting,
May 3, 1975.)
Guidelines:
INTRODUCTION
Over the years, burro populations have dramatically increased in western a
arid regions to the point where they now constitute a eerious threat to native
habitats. Native wildlife, including the endangered desert bighorn sheep,
cannot compete with burros. Burros have no natural predators, are prolific
breeders, and are rapidly extending their range. Although burros exist in a
"wild" (Feral) state, they are not in the true essence "native wildlife." Burros
Burros are an exotic species which occupy an extremely wide ecological niche
at the expense of native flora and fauna.
The Sierra Club recognizes that many people have an aesthetic and historical
interest in the feral burro.
It should be emphasized that the existing burro herds are the results of
man's action, and are a man-made problem. Therefore, man must control burro
populations and burro-related impacts on native biota, soils, and cultural sites.
The Sierra Club feels strongly that priorities should be given to native
wildlife and the land they utilize over the total preservation of an introduced
species. This is in accordance with Sierra Club National Wildlife Policy which
states:
(Under "Wildlife Conservation Management")
"The Sierra Club believes the goal of wildlife management should be to
insure a natural diversity within natural ecosystems by means that
involve a minimum of overt human interference."
(Under "Introduction and removal of Wildlife")
"The introduction of non-native species of animals and plants into
natural ecosystems where native wildlife may be displaced or destroyed
is inconsistent with sound conservation principles. It should be assumed
that such introductions would have a damaging effect on existing natural
ecosystems unless clear evidence to the contrary exists."
RECOMMENDED SIERRA CLUB FERAL BURRO MANAGEMENT POLICY
Part 1: Recommendations: Species recognition.
1) The Sierra Club recognizes that feral burros and feral horses are two
distinct species. Ecological niches arc dissimilar.
Appendix 23, pg. 3
Part If: Recommendations: Management and Control;
1) The feral burro must be strictly managed and controlled.
2) Federal and State agencies must Insure that burro management methods
are humane.
3) The Sierra Club recognizes the necessity of utilizing mechanized
transportation (helicopter) for management purposes, l.e., for censuslng,
reconnaissance, and access to habitat areas.
4) The use of firearms by competent Federal agencies or their appointees is
a humane method of direct reduction of feral burros.
5) The Sierra Club endorses the concept of private ownership of feral
burros as pets or pack animals.
6) The Sierra Club opposes the utilization of feral burros for sporting
purposes, including wrangling or mustanging of herds, burro racing,
or for any similar activity.
7) The Sierra Club suggests that, when feasible, carcasses resulting from
burro reductions be donated to government institutions.
Part III: Recommendations for Protection of native ecosystems and fragile resources.
1) Burro herds must be culled in areas where native habitats have become
impoverished because of overpopulation, and where overgrazing is evident.
Burro herd numbers should be maintained at a level which would minimize
impact on native habitats.
2) The burro must be eliminated from all Federal and State lands where
they would pose a threat to habitats in which rare, endangered, threatened,
or endemic species of flora and fauna exist.
3) The feral burro must be eliminated from all areas which are protected
by the Antiquities Act.
4) The feral burro must be eliminated from all National Parks and Monuments.
5) Burros must be managed and controlled in National Recreation Areas, and
removed from those sections of the N.R.A. in which they would pose a
threat to rare, endangered, threatened or endemic biota, or to cul-
tural sites protected under the Antiquities Act.
Part IV: Recommendations for Congressional Action.
1) The Sierra Club recommends that PL 92-195 (The Wild Horse and Burro Act)
be amended so as to apply only to wild (f eral)horses .
2) The Sierra Club recommends that a Feral Burro Management bill be introduced
in Congress which would delineate burro management concepts, and which would V
establish sanctu arics in areas wlieru it has been determined, through
proper scientific studies and environmental impact statements, that there
is sufficient forage, water, annual primary productivity, and soil conditions
to maintain burro herds, and which would have minimal effect on native wild! if
Appendix 24
STATEMENT OF LYLE GASTON
I have lived on the desert for the last 20 years. I have become
concerned about the destruction of the desert, particularly by
off-road vehicles. These are destroying the plant cover. There
are creosotebushes that have been dated as being five to seven
hundred years old. Some may be 1,000 years old. It is disastrous
for the desert when these plants are removed. The slides that
Mrs. Barling showed of burro damage and my slides of ORV damage
were almost identical. One idea I want to leave with the Board
is that everything that has been said today where the word "burro"
occurs, you can put off-road vehicles in that place and you would
have almost 1:1 correspondence.
I would like to suggest that the Board recommend, within southern
California, that one wildlife biologist be solely committed to
management of burros. He would work with the interagency commit-
tes to formulate plans and see that they are implemented in a time
frame that will permit restitution of some of the habitat that has
been destroyed out here.
We have to get around the problem of writing more and more reports.
The Bureau can write a one-page environmental assessment for a
motorcycle race that's 150 miles long involving 1,000 motorcycles,
using three sentences to justify no EIS, and to permit the race to
go on. I wish we could do the same for some of the burro damage
here .
'
Appendix 25, pg. 1
STATEMENT OF PAT SMITH, AMERICAN HORSE PROTECTION ASSOCIATION
Public Law 92-195 created this Board and charged it with the
responsibility to advise the Secretaries of Agriculture and the
Interior on any matter relating to wild free-roaming horses and
burros and their protection and management. Inherent in the concept
of advice, however, is an independent and honest review of the
programs and policies of the BLM and Forest Service. To properly
fulfill its statutory function, the Board was not meant to become
a rubbers tamp to sanction government activities, regardless of their
wisdom, legality, advisability or efficiency.
But the Board's discussions so far have fallen short of inde-
pendent review. Rather than approach the problems of protecting
and preserving wild horses and burros in accordance with the preamble
of the Wild Horse Act, the Board has accepted the BLM's policies
wholesale. The Board has, for example, made much of the point that
wild horses should be classified as "exotic" animals that are neither
wildlife nor native to the American ecosystem. This is about as
relevant to the values of our Western heritage as classifying the
American Indians as Mongol immigrants who came to North America via
the Bering Straits.
Similarly, the Board has accepted uncritically the BLM's estimate
of wild horse population growth, without demanding hard scientific
Appendix 25, pg. 2
evidence about the growth rates of wild horses in general or those
of individual herds in particular. Figures such as 25 or 30 percent
increases per year are bandied about in an attempt to demonstrate
the supposed threat of too many horses. But no one really knows
how fast horses reproduce, how much of a burden they place on range
resources, or to what degree they compete with other animals for
those resources. More important, no one on this Board has demanded
the studies that would provide answers to these crucial questions.
Because its review has been superficial and unquestioning, this
Board has ratified a "management" policy that is in reality a shorthand
for wild horse extinction. All that we really know about wild horses
is that their numbers decreased drastically in the last 100 years as
range uses increased. The fact that a federal law forbade private
individuals from harassing, gathering or killing the horses suddenly
has created the wild horse "problem". Wild horses became conspicuous
because they were Federally protected.
But the BLM policies so blithely applauded by this Board are in
reality the policies that the Western ranching interests have always
held -- to remove 8,000 or 10,000 or as many horses as necessary each
year to keep wild horse numbers at their low 1971 levels before Federal
protection started. This is the level to which wild horse numbers
were reduced by the ranchers themselves -- the horse population that
the ranchers could live with and keep cattle and sheep grazing on
public land at a maximum.
This program is costing the taxpayers hundreds of thousands of
dollars each year. It not only is picking the taxpayers' pockets,
but it is removing from their public lands horses which these same
taxpayers got Congress to protect and to declare a part of the Nation's
Appendix 25, pg. 3
heritage. They are animals which belong to the people of the United
States, and which were enti*usted largely to BLM. BLM's policies
violate that trust, Using taxpayers ' money to fund programs which
achieve goals which are identical to the pre-1971 poaching, selling
and killing by ranchers is like supplying a burglar with the combina-
tion to the vault and a police escort while he escapes.
The Board's indifference to independent review has been responsible
for a "management" policy that, if left unchallenged, will eradicate
the wild horse. The BLM has turned the Wild Horse Act into a weapon
against the animals that the Act was meant to protect. In the past
two years BLM has authorized the removal of over 2900 wild horses
from the public lands. Removals of 8,000 to 10,000 each year are
desired by BLM. Few, if any, of these actions have been prefaced
by adequate study of alternatives to wholesale wild horse removal.
No environmental impact statement has ever been prepared, despite
the fact that the gatherings are clearly expected to have a direct
and significant impact on range environment. The costs of removal
in dollars are ludicrously high -- from $300 per head (according to
a November 11, 1975, BLM press release from its Oregon State Office)
to $1200 per head (Lakeview (Oregon) Examiner, October 2, 1975). The
cost in terms of permanently depriving Americans of a legislatively
protected heritage by removal or destruction is even higher.
No one can say how many wild horses have been killed as a result
of gatherings. AHPA can count at least 24 that died at BLM-sponsored
roundups. The total number of actual deaths will never be known,
because for many roundups public data on horse deaths is unavailable.
Nor can AHPA estimate how many horses were destroyed when foster homes
Appendix 25, pg. 4
could not be found for them. But the Board has made no comment.
In fact, several members of the Board apparently favor outright
destruction of horses as the best "management" plan.
The brutality and cruelty with which the gatherings are conducted
is horrible. With few exceptions, the BLM employees conducting the
roundups have not been experienced horsemen. Their roundup techniques
do little to alleviate the fright of captured horses. Instead, the
carnival atmosphere and incessant shouting, banging, hat-waving and
hazing excite the horses to a panic. It is little wonder that many
are killed or injured. The Board has never challenged these tech-
niques or investigated the killings, nor observed roundups or set
standards for them.
Moreover, the conduct of the gatherings sometimes just doesn't
make any sense. In the Pryor Mountains this March, 81 horses were
gathered but only 23 removed. Six were killed in the meantime. Why?
In East Kiger Gorge in September 1974, 96 horses were corralled,
20 were later released, and 59 were given to foster homes. Why were
96 gathered in the first place? What happened to the 17 horses that
cannot be accounted for? The Board has not asked these questions.
The history of BLM stewardship of the Wild Horse Act since its
passage in 1971 has been dominated by one theme -- keep livestock
interests happy. The livestock growers obviously don't like the
fact that wild horses are protected by Federal law. The BLM obviously
doesn't like the law. BLM, with Board acquiescence, has ordered that
wild horse populations be maintained so that there will be no dis-
ruption of range allocations on the public lands for cattle and sheep.
Despite wholesale reductions of wild horses this year in Tonopah,
Appendix 25, pg. 5
Nevada, and more recently in Bible Springs, Utah, no concurrent
mandatory livestock use reductions were made. This pattern likely
will be repeated. And once management plans for public lands are
developed, the result is no different: in two areas near Vale,
Oregon, the new management plan calls for an immediate removal of
nearly 500 wild horses -- about two-thirds of the total herd population.
The moral of this dismal history is clear. Despite legislation
intended to protect wild horses, and despite a congressional mandate
that they be preserved, wild horses are doomed to a perilous existence
under the BLM's administration of the law and this Board's advice.
From every BLM spokesman, AHPA hears of the threats wild horses pose
to ecological balance and economic prosperity. (The saving grace of
cattle and sheep, of course, is that they enrich someone's pocket,
despite the fact that they are "exotic".) In the din that the BLM
and livestock interests have created, the voice of the people of the
United States has been lost. So, too, have historic, aesthetic, and
cultural values. But the Board remains silent.
The BLM and this Board have ignored the spirit of the Wild Horse
Act and have used a parsimonious reading of its provisions to accom-
plish almost precisely what would have occurred if the Act did not
exist. The only change is that the persons usually planning and
conducting the roundups are BLM employees, not ranchers. The philosophy
is the same. The 1973 roundup and massacre of wild horses by ranchers
with BLM acquiescence and encouragement is stark testimony to the
nature of the BLM- rancher alliance, which flourishes without challenge
from the Board.
Appendix 25, pg. 6
AHPA submits that the Board must do more, if the BLM will not.
The Board is meant by law to act as an independent advisor. It must
assess BLM policies and programs in light of the purpose of PL 92-195.
It must challenge those policies, demand proof of BLM's assumptions,
and insist that BLM examine alternatives to wild horse roundups. The
Board must approach the problems of protecting wild horses and burros
in a humane and compassionate manner, and develop alternative policies
of its own initiative. If it continues on the rubberstamp path it has
followed so far, the Board will be a guilty participant in the
systematic nullification of a Federal law and the destruction of
a national heritage.
Appendix 26, pg. 1
STATEMENT OF HOWARD AND NANCY GREEN
IUMBOLDT STATE UNIVERSITY Areata, California 95521
HOOL OF NATURAL RESOURCES
•PARTMENTOF WILDLIFE MANAGEMENT
December 2, 1975
Chairman, National Advisory Board on
Wild Free -Roaming Horses and Burros
c/o Mrs. Robert Barling
Director of Natural Resources, Code No. 70309
Naval Weapons Center
China Lake, California 93555
From June through September, 1975# we studied the population dynamics,
behavior, and ecology of wild horses in the Stone Cabin Valley, Nye
County, Nevada. Additional data will be collected this winter and in
the spring of 1976. We hope that the information yielded by our study
will be helpful to the Bureau of Land Management in their management
of wild horses, especially in the Stone Cabin Valley area.
Our work last summer included a survey of forage availability in the
valley. We completed 100 vegetation transects for a total of 10,000
toe points and 2,500 sample plots. We also collected data on habitat
utilization, movement patterns, and the horses' home range size.
Fecal samples from cattle, horses, pronghorn, and rabbits were collected
for food habits analysis. Samples of all forage plants will be analyzed
for caloric value, crude protein and fat content.
Over 250 hours of behavioral observations were made and we have sex
and age data for over 100 bands of horses. We are in agreement with
the ELM estimate of approximately 950 horses in the valley. Our data
shows a relatively low foal crop of 9-10^ for 1975* In almost all
cases, mares with yearlings did not have foals, indicating that the
mares are producing a foal once every 2 years. We found many bands
which contained 2 or more adult males, as well as some all-male bands.
The low foal crop, low mortality rate, and relatively large proportion
of males are indicative of a slowly growing population. These data do
not indicate that the population is expanding rapidly at this time.
The last ELM range survey of the area was conducted in 1959* A pre-
liminary comparison of our data with that collected in 1959 does not
indicate a major decline in range quality during the last 16 years.
The poor condition of the range is due to chronic overgrazing and
cannot be attributed to an expansion of the horse population in the
last 4 years.
(707) 826-3954
|he California state university andcollicis
Appendix 26, pg. 2
Attached is a summary of our percent composition data for two habitats
which received extensive horse use last summer. While these areas
amount to only 20,621 acres they do demonstrate that drastic changes
in percent composition, especially of the species with high forage
values, have not occurred between 1959 and the present. We also
found that the average density values for the 2 areas were essentially
the same as they were in 1959*
We are greatly concerned that so little data has been collected by HLM
upon which to base their management decisions concerning wild horses in
the Stone Cabin Valley. To our knowledge no data, other than an aerial
survey of the population, have been collected. Without data on food
habits, sex and age ratios, birth and mortality rates, current range
forage availability, habitat utilization, etc., it is not possible to
develop sound management options and plans which would best suit the
range and the animals which use it. We urge BLM to gather these types
of data in all areas which have wild horse populations, and that extreme
caution be taken in management practices until such data is available.
We expect to complete the final report on our data in summer, 1976, and
a copy will be made available to the Bureau of Land Management.
We would appreciate receiving a copy of the proceedings of the National
Advisory Board meeting at China Lake.
Yours truly,
Howard and Nancy Green
Graduate Students, Wildlife Management
Appendix 26, pg. 3
BLM Habitat Number: 43Z
Acres: 17,^56
% Compos i ti on
Grass Species
1959
1975
*Hi lari a James i i
12
9
*Oryzopsis hymenoides
5
8
>v$tlpa comata
trace
2
*Sporobolus contractus
--
2
Sitanion hystrix
trace
trace
Sporobolus cryptandrus
trace
—
Forb Species
Annua 1 s
3
13
Sphaeralcea spp.
l
2
Browse Species
Chrysothamnus vi scidi f lorus
60
50
Grayia spinosa
9
3
Artemisia spinescens
5
2
*Atriplex canescens
2
2
*Eurotia lanata
1
2
Ephedra nevadensis
1
2
Atriplex conf ert i f ol ia
1
trace
Artemisia tridentata
trace
2
Tetradymia spinosa
trace
--
Tetradymia canescens
--
1
Artemisia nova
trace
trace
Chrysothamnus nauseosus
trace
--
‘-Preferred plants with high forage values.
Appendix 26, pg. 4
Grass Species
*H 1 1 a r 1 a jaroes 1 (
S I tanion hystTTx
*Qrysops i s hymenoi des
**Bki
BLM Habitat Number: 35 Z
Acres: 3165
% Compos! tl
i on
..-12Z5-
10
10
2
trace
3
trace
3
--
Forb Species
Annuals
Sphaera l cea spp.
Browse Species
Atri plex confert? fol ia
Chrysothamnus vi scidi f lorus
Artemi s i a sp i nescens
ftEurotia lanata
Ephedra nevadens i s
Kochi a sp.
Sarcobatus bai leyi
Gray ia spi nosa
Artemi sia trl dentata
*A triplex canescens
Artemi sia nova
Tetradymi a spi nosa
2
trace
40
25
10
2
1
1
1
trace
trace
trace
4
trace
35
20
10
4
4
trace
trace
4
7
2
^Preferred plants with high forage values.
**Bki - this code was un- i dent i f i ab le by us or BLM Range Conservationists; it
was not given a high forage value on the BLM data sheet.
Appendix 27
STATEMENT OF MARY ANN HENRY
I wish to support Bureau of Land Management in efforts to reduce
burro populations by direct methods--right now--not next year or
later .
I wish to support the Naval Weapons Center in their concern for
damage to plants and land by large burro populations. NWC needs
to use "direct methods" to reduce or eliminate the feral burros--
right now.
From 1947 up until the past few years it was a real event to see
one feral burro when traveling Mt . Springs Canyon to the north and
on to Little Petroglyph Canyon. No more! Herds of 4-30 are a too
common painful sight each time we go to the Petroglyphs.
In Little Petroglyph Canyon last spring the buckwheat shrubs had
been eaten down to nubbins. Introduced weeds were prevalent in the
Canyon. Weeds are opportunists and grow where native plants have
been destroyed by exotic species of animals.
The floor of Little Petroglyph Canyon is sand and can be a water
reservoir at various depths. The feral burros dig down with their
hoofs to expose water. They then foul their own water supply as
well as the temporary water supply for native animals.
Last winter, January 1975, on the flat valley west of China Lake,
the salty lake to the north, there were repeated burro droppings.
Were the burros hard-up for food in the hills because the hills
cannot support large bands of exotic animals and they come to the
very arid valley of creosote bush and atriplex for food?
I support any efforts to eliminate the feral burros and horses by
direct methods--right now.
Appendix 28
STATEMENT OF DR. WILLIAM M. BLACKMORE, CALIFORNIA STATE VETERINARY
MEDICAL ASSOCIATION
The CVMA concurs with the National Park Service, the California
Fish and Game Service, and the Naval Testing Facility that the
feral burro should be removed from all areas where the burro is
in competition with the endangered species native to the State of
California. We also feel that the burro should not be eliminated
completely from the China Lake Facility. At least one area should
be preserved where the burro could live in harmony with the desert
ecological system and could serve the public need to view this
very appealing animal.
Appendix 29, pg. 1
STATEMENT OF WILLIAM REAVLEY, EXECUTIVE REGIONAL DIRECTOR, ON
BEHALF OF THE NATIONAL WILDLIFE FEDERATION BEFORE THE NATIONAL
ADVISORY BOARD FOR WILD FREE-ROAMING HORSES AND BURROS, CHINA
LAKE, CALIFORNIA, DECEMBER 5, 6, 1975.
Mr. Chairman, I am Wm L. Reavley, Regional Executive
Director, National Wildlife Federation. I am in charge of the
Western Regional office, located In Sacramento which is a branch
of our headquarters in Washington, D.C.
Ours is a private organization which seeks to attain
conservation goals through educational means. Affiliates of
the National Wildlife Federation are located in all 50 states,
Puerto Rico, Guam and the Virgin Islands. These affiliates, in
turn, are made up of local groups and individuals who, when
combined with associate members and other supporters of the
National Wildlife Federation, number an estimated three million
persons .
We welcome the opportunity to appear before this board to
comment upon the dire need to properly manage wild and free
roaming horses and burros wherever they may exist. We recognize
at the outset that these animals are in no way indigenous to
the American continent and are a part of the tremendous influence
man exerts on a fragile environment. Parallel is the fact that
man's survival and amenities are derived in part from these
same lands. Therefore It is imperative that man must use his
intelligence to manage these lands to retain the basic elements
upon which the renewable resources depend. Proper management
must be based upon scientific fact and not upon prejudiced
information or emotion.
Undoubtedly the technology and administrative ability exists
to manage populations of wild horses and burros. It is possible
to maintain herds of these animals for public enjoyment, to manage
them in a humane manner, to utilize the protein and other products
Appendix 29, pg. 2
these animals can produce and to provide those Individuals
who wish ownership of such animals. To do this will require
changes In federal laws, and the expenditure of the necessary
funds to do the job. It Is a relatively simple matter. The
small number of wild horses and burros removed from the range
since the passage of the act clearly indicate the
Federal law is much too restrictive. In addition, there has
been Insufficient personnel and funds assigned to this project.
As a consequence range deterioration has already taken place
and destructive effects are inevitable.
National Wildlife Federation passed a resolution on this
subject at its 1975 annual meeting in Pittsburgh, a copy of
which is a t tached .
Thank you for allowing National Wildlife Federation to make
these rema rks .
Appendix 29, pg. 3
Resolution Mo. 26 ,
MANAGEMENT OF WILD HORSES AND BURROS
WHEREAS, wild horses and burros compete with native wildlife and domestic
livestock for forage and water and create serious problems of erosion; and
WHEREAS, wild horses and burros must be managed and maintained in numbers in
harmony with the ability of the environment to support them and other desirable
forms of wildlife and livestock; and
WHEREAS, current restrictions Imposed by Federal law virtually prevent any
• *
practical management of wild horses and burros or controls over their numbers;
NOW, THEREFORE, BE IT RESOLVED that the National Wildlife Federation, in
annual convention assembled March 14-16, 1975, in Pittsburgh, Pennsylvania, hereby
endorses the principles expressed by the National Wild Free-Roaming Horse and
Burro Advisory Board: 1. that the use of properly supervised aircraft be authorized
for the effective management of wild horses and burros; and, 2. the administering
Federal agencies be permitted to dispose of title to surplus animals through sale
or donation*
'
Appendix 30
STATEMENT OF THE CALIFORNIA NATURAL RESOURCES FEDERATION
BEFORE THE NATIONAL ADVISORY BOARD FOR WILD FREE-ROAMING
HORSES AND BURROS, CHINA LAKE, CALIFORNIA, DECEMBER 5, 6,
1 975 .
California Natural Resources Federation is the state
affiliate of the National Wildlife Federation. Incorporated
earlier this year, we are in our formative phase of operation.
Our Executive Committee has unanimously decided to strongly
support a vigorous program calling for sensible management of
the wild horse and burro population.
California Natural Resources Federation therefore has
adopted a position that supports the maintenance of a wild
horse and burro population for aesthetic and historical values,
but strongly holds that these numbers should be held in
balance with the ayailable habitat, recognizing the need to
protect the soil and vegetation as well as the habitat of
native wildlife, forage for livestock and to provide for other
legitimate uses on these lands. To meet these goals management
agencies must have whatever authority and funding is necessary
for the control, management and disposition of horses and burros in
a practical humane manner.
We believe an emergency exists and will become increasingly
severe until such time as authority and funds become available
to perform a proper management job.
We support the position of the National Wildlife Federation
in this matter and wish to thank you for the opportunity of
making this statement.
J . R . Penny
President
Appendix 31, pg. 1
STATEMENT OF DELL 0. CLARK, CALIFORNIA DEPARTMENT OF FOOD AND AGRICULTURE
U All undomesticated burros are the property of the State of California and no
one may possess an undomesticatod burro except for the purpose of domesticating
it and possessing it as a pet or for use as a beast of burden*
3* Any person who desires to capture undomesticated burros v which will be held for
the purpose of domesticating them and possessing them as pet3 or for use as
beasts of burden, may apply to the Department of Food & Agriculture for a permit
to capture undomesticatod burros* Authority for the issuance of burro permits
is in the Pish & Game Code, Chapter 6, Burros, Sections 4600-4606*
3* Burro Depredation - Legislation Passed in 1957
1* Any owner or tenant of land or property that is being damaged or destroyed
by burros may apply to the Department of Food & Agriculture for a permit
to kill such burros* (Pish & Game Code - Section 4137, Legislation pasjed
in 1957.)
a* 1939 - State Legislature passed law prohibiting the use of burros
for pet food*
b« 1953 - Legislature passed another law prohibiting the killing of
burros for two years*
o* 1955 - Legislature renewed the above law for two years* Provision was
made to issue 12 oormits per year to capture a burro by Department of
FOod & Agriculture*
d* 1957 ~ Renewed above, but dropped 12 permit requirement*
D* Burro Permits Issued
1* 1957 to October 1975 - 3,450 permits issued*
2* 1957 to October 1975 - 454 burros were reported taken under permit*
3* Permits issued to 10-3-75 since passage of Wild Horse and Burro Act (PL92-195).
a* 211 permits issued for 492 burros*
b* 64 burros received under permit*
4* 1953 to 1971 - 20 depreciation permits were issued to take 903 burros and
9 permittees reported that 352 burros had boon killed*
5* 1973 - Depredation permit issued to China Lake Naval Weapons Center for
200 burros — none taken*
Hotel Since passage of PL92-195 no permits have bean issued to capture wild
burros except in cooperation with Death Valley Nat '1* Monument where
permittees may obtain a burro trapped by Nat'l* Parle Service personnel*
Appendix 31, pg. 2
E* The Department of Food and Agriculture entered Into a cooperative agreement
on Feral Durro Management In California with the Department of Fish A Ckune,
Fish A WlldLLfOf and Duroau of Land Monagooant In 1969#
1« Our Dopartmont agrees tot
a* Provide a semi-annual Ust of permits issued to capture burros to the
CDFG, B3FW and BLM for their iiiformatlou. Also provide a copy of all
applications to control burros to these agencies for their consents
and rococxoendatlons«
b* Assist In developing and maintaining current inventory information on
burro numbers and locations*
c* Workf in cooperation with the other three agencies , on burro control
operations as may be needed for proper resource management*
d* Assist BUI in developing management plans for burro 3.
F* Public Law 92-195 (Wild Horse and Durro Act) applies only to federal lands
administered by the Secretary of Interior through the Duroau of Land Manage-
ment or the Secretary of Agriculture through the Forest Service* Durro3
found on other federal lands such as Death Valley National Monument and the
China Lake Naval Weapons Center are not covered by PL9 3-195 •
Appendix 32, pg. 1
STATEMENTS made BY HOMER HARRISON
Ch AIRMAN OE THE PUBLIC LANDS COMMITTEE
HUH THE SPORTSMEN'S COUNCIL OE CENTRAL CALIFORNIA
AT THE
NATIONAL ADVISORY BOARD MEETING
E OR WILD-FREE (OAMING HORSE AND BURROS
CHINA LAKEj CALIFORNIA
I am Homer Harrison, representing the Sportsmen's Council
of California-- a large sportsmen, organization in the state.
I am a former renresenta tive from California who served
on the National Advisory Board Council to the secretary of the
Interior, and also served many years on the California State
Bureau of Land Management Advisory Board as a wildlife reoresent-
ative .
Having served on these different Grazing Advisory Boards
for years along with being affiliated with conservation, wild-
life, and sportsmen's organization, and attending meetings,
conferences, syniDosiums, field trips all over the State of
California as well as other western states in observing,
studying our natural resources condition such as range use
and trends, wildlife pooulations and habitat conditions, we
feel like many other organizations in this 3tate that there is
a great need to scientifically manage and control the numbers
of Wild— Eree Roaming horses and Burros that run unon our nubile
lands .
We urge end supnort the Department of the Interior in
instituting and activating a orogram that will scientifically
rmid humanely reduce and control the pooula t ion -growth of our
V/i id -Eree Roaming Horses and Burros where the herds number
Have grown nut of balance with t) e forage, range, habitat,
Appendix 32, pg. 2
'and have become a threat to the other wildlife that shares
and depends upon our public lands for a home and a place to
live for years to come.
^
Homer Harrison
1700 Los Robles Drive
Bakersfield, California
93306
Appendix 33, pg. 1
C
0
P
Y
AMERICAN DONKEY AND MULE SOCIETY, INC.
2410 Executive Drive
Indianapolis, Indiana 46241
December 1, 1975
P. D. Lombard, Acting Director, Division of Range
Bureau of Land Management, Department of the Interior
c/o National Advisory Board for Wild Free-Roaming
Horses and Burros
Naval Weapons Center
China Lake, California
Re: File # 4711.1 (330)
Dear Mr. Lombard:
Although we would very much like to attend the meeting of
the Wild Free-Roaming Horse and Burro Advisory Board, it is
impossible. This letter will have to suffice and we all would
appreciate its being read into the minutes.
I notice that most of the agenda will deal with discussions
about the impact of the species, Equus Asinus Africanus. on the
western lands. If reports and news releases in the past are valid
indications of presentations to be made at this next proposed meet-
ing, participants and observers will conclude that this equine has
too many enemies among the Species Homo Sapiens.
We shall concede that over population in any locale, regard-
less of the plant or animal species is not desireable, and we shall
remind members of the Bureau of Land Management that many times
The American Donkey and Mule Society has offered to help find new
homes for this species, to work out programs for the re-socialization
which would enable these noblest of equines to re-enter co-existance
with people who would like to have one or some. Either we have
received no reply, or an offer from Mr. Kaye Wilkes to let us have
as many as we wish. Just come and get 'em!
The deal offered is poor. Title will not pass to the possessor.
The possessor will have to be under the direction of the Bureau of
Land Management, and the animal must not be converted to the pos-
sessor's own uses. The animals must be kept in a wild state. It
is little wonder that there are not takers.
Appendix 33, pg. 2
Very little publicity is utilised to let people know that
surplus animals are available, yet many people across the country
would like to have one or some if they could have title to the
anima 1 .
Members of the American Donkey and Mule Society would like
very much to see the surplus animals put up for "adoption", would
like to see the United States Government undertake publicity cam-
paigns to teach people about the intrinsic virtues and values of
the noblest of equines. Much more use must be made of the mass
media to attain this end. This organization has a considerable
amount of information, expertise, experience, and people who would
be willing, very willing to work with the Bureau of Land Management
toward this end.
We also realise that a round up would be necessary. However,
I personally would prefer that means other than air craft be used
for this round-up. The expense of air craft usage is one factor.
Another is that there would be an increased demand for fuel to power
that craft, fuel which, if the demand were not present, should have
been made into fuel to heat homes. Petroleum has finally become
more precious than platinum and should be used far more judiciously
than it has been in the past. Round ups via ground forces would
be the most expedient method, and it would enable several people
to pick up a few dollars.
Removal of any of the equines from western lands should not
be undertaken just so that ranchers can put cattle and sheep in
their places. Land that feral animals have been removed from
should, itself, remain or become feral. Even people should be
prohibited from using that land in any manner if the land is to be
as it was found during the original conquests. The only acceptable
exception being that Indians be allowed to use it as their ancestors
did at the time of the conquest. This means that non-native species
such as sailors also should be removed. Can't the Navy find dry
docks at the oceans' edges? Are the sailors so hard up for asses
to chase so that the federal government must provide them with a
desert for their pursuits in that heat?
It must also be remembered that Mother Nature has all sorts
of ways of dealing with surpluses of any sort--very harsh ways.
Much has been made of animals starving, a horrible thought, but
vivdly real. Much is made over the assumption that dead flesh is
a haven for deleterious vermine and disease producing entities.
Yet, it must be remembered, that we are attempting to save displaced
birds and mamma Is --be ings displaced by highly developed cities and
golf courses, recreational areas. Carcasses left on the open ranges,
regardless of the species, provide food for other animals and in
their own way can be a contribution to the preservation of other
species. Some beings must die for other beings to live.
Appendix 33, pg. 3
One woman in California who is very upset over feral equines
on desert lands called me up about a year ago and suggested that we
use the surplus equines to feed starving Mexicans so that the desert
could revert to the way it was. Apparently, equine flesh is quite
nutritious. This might be a valid way of disposing of surplus ani-
mals no one takes if cultural taboos do not get in the way. How-
ever, there should not be a wholesale slaughter just for that purpose.
In conclusion we offer the following suggestions: Make the
surplus equines generally available for "adoption" by interested
parties. Make it possible for title to the animals to pass to those
who want them. Do not use air craft for the round-ups. Work with
the various and varied equine organizations to help teach interested
persons, the public at large, about living and working with the
re-socialised equines. Make far better use of the mass media in
this endeavor. Find ways to establish funds to pay for round-ups,
care, feed, and transportation to new homes --for instance clubs
and organizations could be inspired to conduct fund raising projects
at various locales within this country so that federal tax money
is not tapped. Personal involvement by individuals toward positive
ends will circumvent the taking of animals by persons not truly
interested in their welfare or in positive usages of them. Institu-
tions of many kinds could make use of equines and there are many
people over the country who would be interested in showing how this
can be done.
Instead of spending vast sums of money to compile negative
reports about the impact of equines living ferally on western
desert lands, why doesn't the Bureau of Land Management and the
Wild Free-Roaming Horse and Burro Advisory Board press for changing
the laws so that surplus animals can be given away--inc lud ing pas-
sage of title to the animals? Not every potential new owner is
intending to turn those animals into dog food or voo doo dolls,
nor is every potential new owner going to reneg on a deal as has
happened in a few cases. It is time to stop sitting back and crab-
bing about non-native species eating up the environment, crapping
in water holes, walking over golf courses in the desert. The ques-
tion must be answered, "Are the detractors truly interested in the
welfare of the equines under fire?" If so, solutions are there,
have been proposed but not truly utilised effectively. Be positive
in your recommendations and strong in urging following up, then,
pursue the cause which will establish a desired equilibrium. Uti-
lize abilities and knowledge possessed by many people all over the
country, and make use of the mass media to teach about re-socializa-
tion of equines, and to inform that such animals are available for
adoption.
Thank you
/ s / V. Dana Allison
Director, Members Services
P. 0. Box 180
Mapleton, Maine 04757
Appendix 34
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D C. 20240
OCT 8 1975
Memorandum
To:
Members, National Advisory Board on Wild Free-Roaming Horses
and Burros
From: Acting Secretary of the Interior
Subject: Call to Meet
Secretary of Agriculture Earl L. Butz and I have called a meeting of the
National Advisory Board for Wild Free-Roaming Horses and Burros at the
Naval Weapons Center in China Lake, California, on December 5-6, 1975.
You will be advised of further details by the Director, Bureau of Land
Management.
Save Energy and You Serve America!
Appendix 35
notices
NATIONAL ADVISORY BOARD FOR WILD
FREE-ROAMING HORSES AND BURROS
Notice of Meeting
October 29, 1975.
Notice Is hereby given that the National
Advisory Board for Wild Free-Roaming
Horses and Burros will hold a meeting
on December 5 and 6, 1975, at the Naval
Weapons Center, China Lake, California.
The agenda Includes:
Friday, December 5 — (1) The ecologi-
cal Impact of wild horses on the public
lands; (2) the ecological Impact of wild
burros on the public lands; (3) burros
on and adjacent to the Naval Weapons
Center: (4) presentations by conserva-
tion, wild horse and burro, livestock, and
wildlife organizations; (5) burro re-
search; (6) wild horses in the Challls
EIS; (7) agency reports; (8) public
comment; and (9) Advisory Board dis-
cussion and recommendations.
Saturday. December 6— An aerial and
ground tour, of lands administered by the
Naval Weapons Center, National Park
Service, and the Bureau of Land Man-
agement. The tour will leave the Naval
Weapons Center at 8 ajn. Individuals
desiring to participate in the field trip
other than official participants will ar-
range for their own transportation and
lunch.
The meeting will be open to the public.
Time has been set aside beginning at 3:30
p.m., September 5, for brief statements
by members of the public. Those persons
wishing to make an oral statement must
Inform the Director (330), Bureau of
Land Managmeent, in writing prior to
the meeting of the Board. One written
copy of all oral statements identifying
the author Is desired to provide a record
for the minutes. Any interested person
may file a written statement with the
Board for its consideration. Written
statements may be submitted at the
meeting or mailed to the Director (330> ,
Bureau of Land Management, Washing-
ton, D C. 20240.
Additional details can be obtained by
contacting the Office of Public Affairs,
Bureau of Land Management, Federal
Building, 2800 Cottage Way, Sacramento,
California 95825.
Minutes of the meeting will be avail-
able for public Inspection 60 days after
the meeting at the Office of the Direc-
tor (330), Bureau of Land Management,
Interior Building, Washington, D.C.
20240.
George L. Turcott,
Associate Director.
| FR Doc .76- 20821 Filed 11-5-76; 8: 46 am)
FEDERAL REGISTER, VOL. 40, NO. 21 3— THURSDAY, NOVEMBER 6, 1973
Appendix 36
United States Department of the Interior
BUREAU OF LAND MANAGEMENT
WASHINGTON, DC. 20240
1214(330)
IN REPLY REFER TO
DEC 1 1975
Memorandum
To:
Deputy Assistant Director, Resources
From:
Director
Subject: Delegation of Authority--December 1975 Meeting of
the Wild Horse and Burro Advisory Board
Pursuant to the authority delegated to me by the Secretary of
the Interior, I hereby delegate to you authority and responsi-
bility to act as the authorized representative of the Secretary
at the December 5-6 meeting of the joint National Advisory
Board for Wild Free-Roaming Horses and Burros.
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