Protect Wild Horses in Forest Service Devil's Garden Territory

Feds Developing 15-20 Year Management Plan for California Wild Horse Territory: Your Comments Needed by June 1, 2013
Photo credit Linda Hay.


The U.S. Forest Service (USFS) is seeking public input for the revision of the Devil’s Garden Plateau Wild Horse Territory (WHT) Management Plan (TMP). This plan will establish the short- and long-term policies for management of this wild horse territory for the next 15 to 20 years. Native Americans, cattlemen's associations and ranchers are out in full force to reduce the number of horses in the Territory and to reduce the size of the Territory itself. The Devils Garden wild horses need you to speak up for them!

The USFS is proposing to remove 37 square miles from the WHT and to set the "Allowable" Management Level (AML) at just 206 to 402 horses on this 419 square-mile area. If approved, this plan could result in the USFS removing up to 1,369 horses! Currently USFS estimates there are 1,575 wild horses (including the USFS's estimated 315 foals expected this year) in and around the WHT.

The Devils Garden Plateau WHT is currently used by 10 different private ranchers who are permitted to graze the annual equivalent of 2,240 cow/calf pairs; actual use averaged 1,546 cow/calf pairs during 2006-2011. In 2012, the USFS increased private livestock grazing bringing the annual equivalent of livestock on the WHT up to 1,605 cow/calf pairs.

Now is the time to oppose the USFS's proposed action and management plan for the wild horses of Devil's Garden WHT.  Please take easy action below to personalize and send in your comments.  When you click send, your suggestions will be individually emailed to the USFS.

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Comments may be written, faxed and electronically delivered to the contact information below no later than June 1, 2013.
Modoc National Forest Supervisor’s Office
Kimberly Anderson, Supervisor
800 West 12th Street
Alturas, CA 96101
Fax: (530) 233-8709

Please include “Devil’s Garden WHT” in the subject line of the email for easy identification.

For additional information on this project please contact Ranger Tim Knight at (530) 233-5811.

For electronically mailed comments, the sender should normally receive an automated electronic acknowledgement from the agency as confirmation of receipt. If the sender does not receive an automated acknowledgement of the comments, please call the number above. Please indicate if you would prefer to receive future documents and notifications in electronic format.


The deciding official for the Modoc National Forest will be the Forest Supervisor. [Kimberly Anderson is the Modoc National Forest Supervisor.

The Devil’s Garden Plateau Wild Horse Territory (WHT) is located within Modoc County, California beginning about 7 miles north of the City of Alturas. The WHT comprises approximately 232,520 acres of federal land. Of this, 97 percent (224,888 acres) is National Forest System lands administered by the Modoc National Forest’s Devil’s Garden and Doublehead Ranger Districts (MDF) and 3 percent (7,632 acres) is public land administered by the Bureau of Land Management’s Alturas Field Office (BLM).

Aerial inventory (February 2013) using the direct count method updated this estimate to 1,260 adult wild horses. This compares to the last inventory, conducted in 2010 when 854 total animals were counted. Of these it is estimated 641 were adults. As of January 2013, an estimated 1,124 wild horses were present in the Devil’s Garden Plateau. Of these, approximately 269 (24 percent) are residing outside the WHT in areas not designated for their long-term use. Monitoring indicates an average annual population growth rate of 25 percent per year, a sex ratio weighted towards females (43/57 males/females) and an age distribution weighted towards the young age class (age 0-5 years).  ... the most current approved Gather Contract(s) [roundup] and could begin as soon as October 2013.

Cow and Sheep Grazing in WHT

Term grazing permits for 26,880 Animal Unit Months (AUMs) of forage consumption by domestic livestock have been issued by the MDF on all or a portion of the eight grazing allotments within the WHT. During 2006-2011 actual livestock use averaged about 18,547 AUMs (approximately 69 percent of that permitted). Another 4,400 AUMs of forage was allocated for use by the Appropriate Management Level (AML) of 275-335 wild horses in the 1991 Forest Plan. Since 2006, wild horse population size has exceeded the AML upper limit, with actual wild horse use ranging from 6,163 AUMs in 2006 to 16,186 AUMs in 2012 (approximately 140-369 percent of that allocated).

As numbers have grown beyond the AML upper limit, livestock operators have experienced an increasing number of conflicts between wild horses and their permitted livestock use. Fence damage has increased as have maintenance costs. In some locations, wild horses have been very aggressive and kept livestock (and wildlife) from using the available water. In other locations, heavy-severe utilization by wild horses has prevented the operator from making use of all or a part of their term permitted grazing use.

Monitoring indicates existing wild horse numbers are within the available capacity in the Surveyors Valley area. No wild horses are known to have used the Potters since at least 1986. By contrast, monitoring indicates wild horse numbers may be above the available capacity in the Emigrant Spring and Pine Springs Allotments as well as the Black Rock Pasture of the Timbered Mountain Allotment and the Timbered Pasture of the Carr Allotment. In these areas, heavy to severe utilization has occurred on a number of upland areas. In addition, little or no residual vegetation remained in spring 2012 due to heavy use by wild horses over the winter. A substantial number of springs, seeps and meadows are nonfunctional due to the degree of loafing, trampling and trailing that has occurred. Many of these exhibited residual stubble heights of less than 2 inches in October 2012, and were altered by more than 70 percent due to trampling. Plant vigor and species diversity have also been negatively impacted. Wildlife use of vegetation by elk, deer, and antelope appears to be within capacity.

Reducing the WHT

The FS is proposing to reduce [by 37 square miles] the land in the Wild Horse Territory by changing the boundaries from Map 2 to Map 1 below. The FS claims an "administrative error" "incorporated about another 23,631 acres" which connected what the FS is now referring to as to the "East" and "West" home ranges. "In conformance with the 1971 WFRHBA, the MDF proposes to return to the management of wild horses within the WHT boundary established in 1971 (Figure 1)."

Wild Horse Use Within WHT

Wild horses occur throughout the WHT, with the exception of Potters. In some areas, wild horses are present only in certain pastures, or have preferred use areas in which they have established home ranges. The Carr portion of the WHT appears to have adequate suitable habitat to sustain a year-round population of wild horses, but heavy use by wild horses in the Timbered Pasture indicates the existing numbers may not be in balance with the available water and forage. In Emigrant Spring, existing wild horse numbers are contributing to forage overutilization and unsatisfactory upland and riparian conditions. Pine Springs has adequate suitable habitat to sustain a healthy population of wild horses over the long-term, but current wild horse numbers are leading to unsatisfactory upland and riparian conditions over portions of the area.

The Mowitz Allotment has adequate forage, cover and space, but may lack adequate year-round water to sustain a wild horse population over the long-term. Wild horses routinely leave the WHT in search of water (most of the existing water sources dry up by mid-season most years). Wild horses have not been observed in the Horse Camp or Lone Pine Pastures of the Potters Allotment since at least 1986. As the two comprise only 4,812 acres, there may not be the space necessary to sustain a reproducing herd of wild horses long-term. However, Potters may provide suitable habitat for a small number of geldings. In Surveyors Valley, wild horses concentrate their use adjacent to the Surveyors Valley and Deadhorse Flat Reservoirs. Upland utilization is generally moderate indicating adequate suitable habitat to sustain year-round use by the existing number of wild horses.

Wild horses are poorly distributed in the Timbered Mountain Allotment. The majority of wild horse use is on the west side of the Black Rock Pasture. Although wild horses also utilize the Cow Head Pasture, the available water dries up by mid-season most years. As a result, the Cow Head Pasture may not be able to sustain a year-round population of wild horses over the long-term. Wild horse use in the Deer Hill Pasture is minimal and none were observed in the Timbered Mountain Pasture in 2012. This data indicates the Timbered Mountain Allotment has adequate suitable habitat to sustain a healthy herd of reproducing wild horses in the long-term, but the number of wild horses in the Black Rock Pasture has led to deteriorated upland and riparian conditions.

USFS Scoping Notice (Dec 2012)