Public comment for the 2022 North Lander Complex EA

February 17 2022

In response to North Lander Complex proposed roundup/gather DOI-BLM-WY-R050-2021-0037-EA 

What I wanted to say below….due to ‘eplanning word count limits, I had to omit most of what I had written.

Here is the my extended version 2022 North Lander comment PDF updated March 27 22 with more valuable documented links and information. Available for download and sharing for advocates to use in the wildhorse and burro effort. #2022northlander

To whom it may concern,

This is my first response to a public comment, so it will be longer as I have a lot to cover.  At the end I will cover this herd specifically, though overall… they are a part of this in its entirety.

As a new advocate that has deep dived into the world of wild horse, burros, and BLM… I can honestly say I am extremely disturbed at what I am witnessing from this government:  month after month…. and year after year.

Since my first experience visiting a wild Onaqui herd in March of 2021, one of the most incredible experiences I have known in my entire life, and finding out about their upcoming roundup soon thereafter…  I have spent thousands of hours researching everything I can get my hands on regarding WHB.

Seemingly… one atrocity after another. 

From chemical genocide (zero growth), fertility research and the detrimental physical and mental effects to horses noted by scientists (PZP, Gonacon, Spayvac, Ovariectomy, gelding and castrations), compensatory reproduction, roundups, contractors, facilities, partnerships with ranchers, livestock subsidies, AML, AMU’s, grazing allotments, oil and gas leases, mining (uranium, gold, ore), environmental damage, WHB land stolen and the acreage diminished, financials, stats, congressional reports, EA’s that misrepresent the facts, and WHB advisory boards stacked with conflicts: cattle ranchers and Spayvac owners!

Deemed Pest Animals by the researchers you put in charge of the fertility studies (Killian). These studies clearly working in favor of the US AG, USDA cattle industry. Conflicted interests?  I’d say so.

The very people in charge of their federal protection status (BLM, DOI), working against them at every turn! Do you not consider them an important, iconic, and federally protected species?

That seems like a lot to take in already, but there is more!

Then there are the ‘designated wild horse herd areas’ with NO HERDS – completely zeroed out, 50 years of changes to the 1971 WFRHBA, riders slipped in to allow for helicopters, slaughter, euthanasia (murder), and captive bolts to kill healthy animals.  Thousand of horses repeatedly missing from facilities (audits required), the slaughter pipeline and YOUR directinvolvement in all of it. 

Witnessing internal BLM and DOI cover-ups to hide the truth (see Martha Mendoza), blatant lies and outright deceit on us, the American people that ‘YOU WORK FOR’.   


This nation I had always thought was a nation of high morals and standards, a nation that believed in TRUTH and JUSTICE is seemingly full of DISHONESTY, LACK of MORALS, DECEIT, and straight up CORRUPTION to the highest government levels. One administration to the next!

I have gone through thousands of articles, documents, studies, lawsuits, videos, and FOIA’s from other  public advocates concerning the crimes taking place against WHB and our public lands, and to verify all that I have heard. Unfortunately… every time I tried to prove these stories wrong or embellished… I am shocked that I located overwhelming evidence of its truth, though often hidden deep.

As a citizen, I am seriously angered at your excessive efforts to control and ERADICATE this ‘wild and native’ species (and other natural predators and wildlife) due to ‘special interest groups’ and conflicts from the powerful livestock, hunting, and energy/mining industry. Your full on effort to repeatedly ignore the wishes of ‘WE THE PEOPLE’ who wanted enactment and protection of these lands, and the WHB herds in 1971 and still, and for you to uphold those laws today; Not to change them, and circumvent them at every opportunity to continuously work against original laws to eradicate (zero out) the entire species.

While you repeatedly claim that isn’t your motive or intention, as we watch one herd after another be diminished into non existence… it’s hard to take you seriously.  As of September 2021, BLM claims 177 HMA’s on 26.9 million acres of public lands across 10 Western states. Down from 266 herds in 1996, and 329 herds in 1971. And WHB their land area has also shrunk enormously.

WE EXPECT YOU TO: Not steal their land, and dissolve their protected areas in favor of ‘for profit ranchers’ and mining/extraction companies that rape, pillage, pollute, and destroy the once spectacular landscape for their personal profits. While it may be multi use lands, ‘the multi’ is clearly on a severely uneven playing field. Selling out AMERICA to the lowest bidder (often foreign companies), and putting an enormous financial burden on the tax payers to do so. It makes absolutely no sense!  

To remove the wild horses and burros from their native lands, then charge livestock users only $1.35 a head to use that same public land, while paying $5 a head to feed the wild horses captured and ‘held’ in mostly un-viewable private facilities (where they should not be held in dirty corrals full of manure 2 feet deep, unable to walk and sustaining broken legs that lead to unnecessary deaths, ex: DELTA facility). Not to mention the other costs (contracts) associated with the WHB programs that wouldn’t be an issue if you didn’t remove the ‘wild animals’ from the land in the first place.

Your inefficiency to ‘micro manage all wildlife’, and the wilderness is failing miserably! Nature is not intended to be manipulated by human hands!

Right now, the majority using this public federal land is ‘private for profit companies’ that often get subsidies paid for by taxpayers as well. These lands don’t belong just to the cattle and ranchers, and the energy and mineral extractors that feel entitled to these lands because they have been working the system for generations.

These lands belong to ‘us’ as well (329.5 million citizens). I’d bet the majority who (if they knew, media blackouts) would disapprove of the roundups and treating all wildlife (not just horses) with pesticide concocted fertility, which goes directly against them being ‘wild and free!’

What we (the majority) want to see when we visit OUR property is wildlife true to their nature, not cattle and sheep as far as the eye can see. Not decimated lands stripped of its beauty by mineral mining, and fracking industry, leaving destruction and tax payer cleanup of their waste left behind, or toxic superfund sites. There is an entire 82 page report ‘edited without wild horse mentions’ of public protest regarding the jun 2014 Lander RMP that shows that the people do not want this! Yet you again ignore our public wishes in favor of private corporate energy and mineral extractor’s interests.

When I look at the coverage of land that is solely grazing on the maps, and see the small fenced  territories for the horses and other wildlife (that are shared also with livestock in most cases) and your claims consistently saying horses are overpopulated and the problem;  That the resources cannot sustain the area, so you remove the horses and burros, and then put thousands of livestock in their place immediately.  We see what you are doing…. We are watching, and we are documenting!

To look and see a disappropriate number of livestock being consistently, completely, and intentionally ignored in the equation ( When anyone can see that 36000 – 80000 horses are not to be blamed for the damage of 2,900,000 million livestock that have been degrading OUR LANDS for the past hundred years.  

Your own evidence proves this. But you spin it, twist, and repeat the nonsense; saying it over and over again, which doesn’t make it true. That is pure propaganda!


We actually read the documents you put forth, the ones our ‘government representatives’ are supposed to read but clearly aren’t.  They default on their duties, fall for your talking points, skim over the top, and believe all you tell them. They only have to look deeper to reveal the bias, lies and deceit. SHAME ON THEM for not doing their jobs and cutting corners against the wishes of the American people who don’t want this!

But the worse part of it all… is too having these herds not able to reproduce and carry on their diverse genetics for future stability of their families.   To make their herds not only ‘non viable’ due to small herd sized and genetic deformities that ‘your own people’ like Dr. Gus Cothran, Redge Johnson (2020 WHB Summit  – Herd Viability – Watch at 11:32 – 13:43) have stated in reports: causing birth defects from inbreeding, and removal of the strongest genes. Even organizations like the Cloud Foundation recognize the truth as they push your narrative of fertility using toxic pesticides, and removal.  (feb 2 13  Observations of contraceptive use in the Pryors – Cloud Foundation)

You yourself have recorded the dangers of these chemicals (PZP) not being safe for the food chain, for the environment which is why you have been ordered by law to keep detailed records of the horses you treat.  So that they don’t accidently end up in the food chain, or in my dogs food.

You intentionally give ‘FDA exemptions’ to pesticides like Gonacon. Pesticides should never be exempted!

You are aware that these often ‘fertility concocted contaminated horses’ end up across the border in Mexico and Canada as you look the other way as adoption incentive programs (adopters) and buyers like TOM DAVIS continuously sell/send these horse across the border, often sidestepping the legal channels, making back door deals with past and current government employees like Sally Spencer, Ken Salazar, Steve Leonard, Gus Warr…. This list is long and well documented.  Even allowing indicted criminals: CATTOOR and Heaverne (deceased), who knowingly lied on documentation, in courts, and got caught illegally rounding up horses for slaughter were still allowed to remain ‘federal contractors’. Did you allow this specifically because you knew they had no qualms about selling horse to slaughter behind the scenes?

You are aware that studies have been done about the damage caused to animals after treated with these pesticides vaccines as there are lists of reports.  ( ).

Even those of your own people hired to do the research on genetic viability, Dr. Gus Cothran whose 2008 report still has not been released, know the truth. You don’t seem to cite them. Why is that? Does their evidence go against your narrative and agenda? That isn’t a real question… I already know the answer!

One of the most important articles to read regarding what BLM’s intentions truly are, is one of their own documents. Oct 2008  Internal Use Draft – BLM Wild Horse and Burro Program Alternative Management Options   (TAGS: Euthanasia of Animals for Which an Adoption or Sale Demand Does Not Exist, Adjusting Sex Ratios to Favor Males, non-reproducing herds (sterile animals) in some existing herd management areas (HMAs) or herd areas (HAs), eliminate wild horses, Returning the animals to the range following sterilization after a few months in STH facilities has potential to spread infectious disease to the wild herd, Fertility Control for Stallions, Castration, Vasectomy, permanently sterilized, spaying, ovariectomy, Mortality rates, mass euthanasia, Carcass disposal, rendering contracts, air curtain incineration, overdose of a barbiturate anesthetic, gunshot to the head, penetrating captive bolt, slaughter (graphic), rendering service, burial at a local landfill, burial on-site, sales without limitation – all ages, sales not limited to U.S, increase stallions per herd, contributes to foal infanticide, Fertility, PZP, their safety has not been confirmed by the FDA or EPA, Gonacon, spayvac, contraception, permanent sterility, genetic DNA, Benefits and Cost Savings) 

The line that gets me…. ‘Benefits and Cost Savings’. As its seems you have no qualms about taking multiple healthy lives for the simple fact of ‘saving money’ which clearly would be saved if you stopped the public welfare livestock grazers, get them off our public lands, remove the fences and let nature be nature. I know… your reply is there is laws in favor of the grazers (Taylor Grazing), but we know those laws can be changed as we have seen from 50 years of changes to the 1971 WFRHB act.

It’s hard to believe that members of congress would approve any of these efforts if they ever read the BLM document above in its entirety.

History Repeats Itself

Looking back at a gruesome history of human annihilations that have taken place of living beings, the similarities are notable. Violently taking entire families: forced from their land, capture, assault, murder, death, segregation, separation, sterilization, abortions, imprisonment, enslavement, mass euthanasia, extermination, elimination, speciecide (genocide), in all accounts…. a HOLOCAUST!

 There is no other word that describes it so completely.

Officially, a government ‘tax payer funded’ wild horse and burro holocaust! 

Authorized by those in charge of their care and federal protection (BLM, DOI, CONGRESS) !!!

This is despicable, reprehensible, and it ‘should be’ condemnable actions taking place by this government.  It is clear there is no oversight or accountability taking place on this WHB program at all!

I may be new to this fight, but I am dedicated new advocate, and I have made it my mission to make sure the American People have access to what I have found, and what you have tried to make disappear and forgotten.

“The problem with the idea that history repeats itself is that when it isn’t making us wiser it’s making us complacent.”

Lisa Halliday  

Wild horse and burros have army of peaceful and passionate advocates who will never be ok with these heinous crimes taking place…. We will never be complacent!   


Now that I have gotten that off my chest, let’s talk numbers of the North Lander Complex.

“The environmental assessment analyzes a range of alternatives for gathering and implementing population growth suppression measures to achieve and maintain the AML. Suppression measures that are analyzed include gelding or vasectomizing stallions; reducing the reproducing population through adjusted sex ratios; using flexible intrauterine devices (IUDs) on mares; and using the fertility vaccine GonaCon-Equine”

1.  According to your own 2008 (killian) studies, Gonacon is less effective than PZP (spayvac). Why would you use a less effective treatment? Since you say it is safe to eat meat treated with Gonacon, are you choosing this over PZP so that the horses don’t have to be documented and can eventually end up in the food chain in countries that eat horse meat? It is noted that the public has no access to majority of facilities  and horses are routinely missing and un-accounted for. Where are the horses really going?     2008  Four-year contraception rates of mares treated with single-injection porcine zona pellucida and GnRH vaccines and intrauterine devices – Killian, Thain, Diehl, Ryan, Miller

2.  These 4 individual HMA’s consist of extremely small herd sizes:  Conant Creek (AML: 60-100), Dishpan Butte (AML:  50-100), Muskrat Basin (AML: 160-250) and Rock Creek (AML: 50-86). . 

According to respected researcher Dr. Jay Kirkpatrick –  “removal of animals, and particularly the younger animals targeted in the Adopt-A-Horse program also removes genes from the herd at an alarming rate. These young horses have never had the opportunity to breed and therefore their genetic contributions to the herd are lost forever. About 75% of BLM’s wild horse management areas have 200 or fewer animals in each, and the continual removal of genes from the herd may have significant consequences.”

2. As I could cover all those sections individually, Ginger Kathrens of The Cloud Foundation’s comment on the 2014 LANDER RMP covers them all.  From Gus Cothrans genetics, sex ratio, to vasectomies, and fertility…. Plenty of documentation listed for your perusing and consideration

3.  According to the charts you show in the EA, the horses are multiplying by 20% a year. Let’s look at the reality of this claim compared to 2020 records (not shown in your EA charts)

  • 375,000 acres of land, of which about 90% are BLM-administered public lands. NW corner adjoins the Wind River Reservation where wild horse laws do not apply. / Fremont County
  • Complex AML:  320-536 / These 4 individual HMA’s consist of extremely small herd sizes:  Conant Creek (AML: 60-100), Dishpan Butte (AML:  50-100), Muskrat Basin (AML: 160-250) and Rock Creek (AML: 50-86)
  • 2020 Livestock AMU: 49,823  sheep & cattle  
  • 2021 Livestock AMU: 49,911  sheep & cattle  (allowance increased since 2020)  
  • 2020 est pop: # 1,619  horses   #  0 burros   #  24,715 cattle & sheep (actual use)
  • 2021 est pop: # 1,664 horses   #  0 burros   #  ? cattle & sheep
  • 2022 est pop: # 1997 horses   #  0 burros   #  ? cattle & sheep

Gregg (2014), the wild-burro birth rate is about 14%; however, 50% of foals perish before their first birthday. Therefore, the effective increase in new burro-foals is just 7%. Gregg, K., LeBlanc, L., & Johnston, J. (2014) Wild Horse Population Growth

You claim the numbers grow by guesstimating 20% annually, but according to your previous reports the numbers show only a 45 horse increase in this complex between 2020 and 2021. That’s about 3% annual growth, not 20%. / 20% would be 323 horses, but that didn’t happen, so are you fabricating an overinflated number here?

Since you didn’t mention an actual amount of horses to be removed in the EA, we have to assume you will remove all horses to reach the low AML of 320, or under (history shows us that is expected). If you say there are #1997 horses (inflated), that means you intend to remove 1500-1700? How long will it take to accomplish this gather of this size? A month, or ten years? Of the ones returned, how many of them will be permanently sterilized as there is no mention of this on the 2022 gather schedule?

When you inflate the numbers, and then take off too many horses at one time, you’re left with herds that are not viably sound for genetic reproduction. I could mention Cothran’s genetic reports, and other reports mentioning the damage to herd viability, but seemingly you don’t cite them in any of your EA’s as they are familiar to you.

There is documented proof of the damage these deadly roundups and contractors have done to herds.

We could mention how the pesticides, and fertility cause abscesses, sickness, death, females acting like males, permanent sterility to the wild herds genetics   (feb 1 16  FACT SHEET: The Truth about PZP – Protect Mustangs). We know you are aware of it as it has been shown to you thousands of times, and on thousands of comments by “We the People’, and yet you chose to ignore our voices. You allow us to comment on EA’s (but have not once that I can see) have you changed your narrative from our extensive efforts. We go through the motions to elicit change within, all while knowing you have NO INTENTION of taking action in the horses favor.  You have every intention of following through with your plan of decimation, and sterilization without change. We know this, yet we continue on un-waivered.

One day, maybe someone will hear us, and put an end this reign of terror for these graceful and deserving gentle creatures, and the humans that are so greatly affected by them. That is my hope, and until that day comes, I will continue in my advocacy for the wild horses and burros of this nation!

If the truth shows us anything, ’History repeats itself, but in such cunning disguise that we never detect the resemblance until the damage is done.”

Sydney J. Harris

7 thoughts on “Public comment for the 2022 North Lander Complex EA

Add yours

  1. Interesting that this post is anonymous, when Jennifer has researched well. Is this comment from a BLM empliyee or associate

  2. Telling how it truly is. Wake up America! Stop the greed, lies and murder of the American wild horses. Politicians like to say remember the Holocaust, how about they remember the slaughter of our Indigenous? This is no different, killing for profit, you are all so sick, deceptive and evil.

  3. Excellent. Now, this should be published by every newspaper, tv station, online news organizations, etc.

    1. Thanks Susan… I wish I could have said it all on the EA. the best I could do was link to this. I felt so censored as I repeatedly had to delete the majority of this to fit in their word count box.

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