View south from Soda Mountain, Cascade-Siskiyou NM, OR-CA. Photo George Wuerthner

On April 24th, 2024, the Vermont Law and Graduate School and Wild Horse Fire Brigade sent a letter to the Bureau of Land Management’s (BLM) District office in Medford, Oregon, proposing a collaboration between the Wild Horse (feral) Fire Brigade and the BLM to reduce wildfire threat through feral horse grazing on the Cascade-Siskiyou National Monument.

Though well-meaning, the Vermont Law School attorneys know little about wildfires or feral horses, which they continuously call “wildlife.”

Fog shrouds valley below Pilot Knob in Cascade Sisikiyou NM, Oregon. Photo George Wuerthner

The Cascade-Siskiyou National Monument (CSNM) is not just a piece of land but a vital ecological link between the Cascade Range and the coastal Siskiyou Mountains. Its unique position straddling the California-Oregon border makes it a crucial part of our natural heritage. Designated in 2000 by Bill Clinton’s Presidential Decree and expanded in 2017 by President Obama, the CSNM now spans 113,500 acres. Its protection is not just a matter of policy but a responsibility we all share to preserve this ecological treasure for future generations.

The timber industry attempt to log the monument’s old growth forests was thwarted when the Supreme Court refused to hear its case. Photo George Wuerthner.

Timber interests challenged President Obama’s expansion of the monument. Still, the Supreme Court refused to hear their case and let two appellate court rulings stand, which determined that the monument’s expansion was legal. For more on the BLM scams that increase logging in the monument, see Andy Kerr’s column.

Enter the Vermont Law School, which now proposes using feral horses to reduce wildfires.

In their April letter to the BLM, the Vermont Law School clinic asserts that wild horses (feral) have a “right” to the open range in the Soda Mountain Wilderness adjacent to Monument lands. The letter requests that Siskiyou County recognize the practicality of the wild horses for wildfire management and formally acknowledge Wild Horse (feral) Fire Brigade’s right to manage its wild (feral) horses on the open range.


Most authorities believe the horse went extinct in North America at the close of the Ice Age, thus all “feral” horses are descendents of Spanish animals. Photo George Wuerthner

There are several problems with the Vermont Law School’s assumptions.

First, feral horses are not, as the Wild Horse Brigade asserts, “native wildlife” in need of restoration.

The Wild Horse (feral)  Brigade advocates for feral horses. Like many horse advocates, they seek an excuse to justify horse grazing on public lands. In particular, the WHFB advocates “rewilding” horses in Wilderness Areas where natural ecological processes and native wildlife should be protected and preserved.

The assumption that feral horses represent “native wildlife” is contentious. However, sound evolutionary evidence demonstrates that the horse lineage disappeared from North America at the end of the Pleistocene. Evidence to the contrary is fraught with issues, and most authorities believe horses went extinct along with other Ice Age mammals like wooly mammoths, giant sloths, camels, and cave bears.

With no natural predators feral horse herds grow rapidly and can harm native wildlife and plants. Photo George Wuerthner

As Dave Willis, who has dedicated decades to protecting the CSNM from grazing, points out: “We’ve invested years in removing (some of) the cattle from BLM allotments in the CSNM, which had a grazing season of a few months a year with legally limited numbers – and now Vermont Law’s “Environmental Advocacy Clinic” proposes legitimizing feral horses (that are already there) all year round.”  

The horses are reproducing, adding to the population, plus the WHFB is continuously adding more horses.

On behalf of the Wild Horse (feral) Brigade, a Vermont Law School Professor sued BLM for BLM’s attempted gather of feral horses on Green Diamond land in BLM’s Pokegama Wild [sic] Horse Herd Management Area (HMA) BLM tried to use a categorical exclusion to gather feral horses on Green Diamond’s private property only – at the request of Green Diamond and local ranchers.

 According to Willis, the BLM’s Pokegama feral horse HMA overlaps the east end of the CSNM, and the BLM’s “Appropriate Management Level” for the entire HMA is 30-minimum to 50-maximum horses. The BLM census estimates 246 Pokegama HMA horses, and grows larger every year.


The Lodgepole wildfire west of Challis, Idaho. Courtesy U.S. Forest Service

One problem with the Vermont Law School effort is the assumption that grazing can reduce large, high-severity fires by reducing fuels. Numerous misconceptions are associated with this proposition.

Wildfires are one of the major ecological processes that have created the dynamic and biologically diverse landscape of the CSNM. The idea that humans must restrict or control wildfire is an anthropocentric concept that ignores the evolutionary role of fire—all kinds of wildfire, including large, high-severity blazes.

Second, all large, high-severity wildfires are climate/weather-driven, not fuel-driven. With high winds, sparks can jump miles ahead of a fire front or any “fuel reduction.”

A widely cited paper advocating livestock grazing to reduce wildfire fuels concludes grazing does not work when extreme fire conditions exist. However, these extreme fire weather conditions are the only times wildfire can rapidly expand and char extensive acreage.

Grazing may reduce fine fuels for a year or two, but the plants grow back rapidly, so any such “solution” requires continuous grazing to achieve any results.

Grazing in very select locations may reduce fuels, but as a landscape tactic, it doesn’t work or effectively halt wildfires under extreme fire weather conditions.


A further problem with feral horses is that they can compete with native ungulates (like other livestock) for forage. Horses have an inefficient digestion system compared to ruminates, so pound-for-pound horses must consume more forage than similar-sized native species like elk.

Given their large size, feral horses can also compact soil (like cattle) and trample native vegetation.

The painful irony is that Vermont Law School has failed to contact local activists like the Soda Mountain Council. Nor are they aware that the Monument proclamation requires that the agency protect the native biodiversity and the region’s connectivity. Feral horses do none of these things.

If you wish to voice your opinion, please contact the Cascade-Siskiyou Manager at lpbrown@BLM.gov and urge the BLM to round up all the feral horses and preclude additional horse transplants.


  1. PJ Jackson Avatar
    PJ Jackson

    This is just a little unclear: are you saying that the “Fire Brigade” horses – which are privately owned – are on Federal (BLM) land?
    Or are they privately owned horses on private (or county or state land)?
    The law varies accordingly.
    And the way this is written, it is hard to tell if you are referring to the Fire Brigade horses or the federally protected (small) herd in the Pokegama HMA?
    Those horses fall under federal law and that is a designated BLM habitat area. Calling BLM to complain about those horses (for doing what, exactly? Eating?) is a little drama- inciting, isn’t it?
    If you have documentation Fire Brigade is running their private horses illegally on public land, then say so.
    That’s certainly a legitimate concern if so.
    An apparent hatred of wild horses is what comes through in this unclear piece, and it’s embarrassingly unscientific -and seems to have affected your clarity and perhaps reason.
    I’m shocked and dismayed to see a scientist I’ve followed and respected write this, encouraging people to make calls based on unclear information.
    And lacking clarity about wild horse law, or the related distinctions.
    (I’m not defending the Fire Brigade group, by the way – they seem more than capable of doing that themselves.)
    l am saying I expect better from you.

    1. Jeff Hoffman Avatar
      Jeff Hoffman

      George has been complaining about wild horses grazing on public land for some time now. I don’t know why he doesn’t just stick to cattle and domestic sheep, they’re the problem here. Horses were at least native here when they became extinct, which is not true for cattle nor sheep. There are so many more cattle than horses that your claim that George hates horses seems like a good possibility.

      1. easternsierraheidi Avatar

        “George has been complaining about wild horses grazing on public land for some time now. I don’t know why he doesn’t just stick to cattle and domestic sheep, they’re the problem here.”

        I am going to guess that George is addressing FERAL horses DESTROYING public land (and native wildlife habitat) because they are. I am also going to guess that you have not had the opportunity to see the damage that these FERAL horses do.

        And you do know that “hating” horses and advocating for native wildlife is not the same thing, don’t you?

        1. Jeff Hoffman Avatar
          Jeff Hoffman

          The fact that you focused on the term “feral” tells me you have a strong anti-horse bias here, but I’ll respond anyway.

          Horses are also native here. You seem to be lumping them into the same category as cattle and domestic sheep, which are not native. Big difference. Native animals naturally grazing and browsing is not “damage,” it’s a natural ecological effect.

          It’s quite possible that the wild horses are now in areas in which they didn’t evolve naturally and wouldn’t be there if not for humans. In that case, of course they’re doing harm, like any other non-native herbivore would be doing. But exactly where in the west horses lived before humans drove them extinct is not known with any certainty, so neither of us can make that claim either way.

          I’m first and foremost Earth First! If you can convince me that the horses at issue here are not native and are therefore doing harm, I’d support removing — NOT KILLING — them. But since there are ecological facts that are unknown about this issue, I think it’s totally immoral to remove a likely native animal just because some humans don’t like the way it interacts with its ecosystem.

        2. Jeff Hoffman Avatar
          Jeff Hoffman

          I tried responding to you, but the system won’t let me. Suffice to say that I strongly disagree; horses ARE native to the western U.S., and there are too many important unknown ecological factors to remove them just because some people don’t like the way they interact with their environment.

      2. Ted Chu Avatar
        Ted Chu

        The most common argument in favor of feral horses by their advocates is that since in many cases cows are causing more damage than horses managers might as well add to that damage by not controlling horse populations. It’s a lose lose argument from a health of the land perspective.

        1. Jeff Hoffman Avatar
          Jeff Hoffman

          Well, that’s not MY argument. It just strikes me as very problematic that when the vast majority of the problem is cattle and native sheep, George is writing about horses, who are native to the west. The latter is my argument.

    2. easternsierraheidi Avatar

      “An apparent hatred of wild horses is what comes through in this unclear piece, and it’s embarrassingly unscientific -and seems to have affected your clarity and perhaps reason”.

      Ah yes – Ad hominem – the only tactic available to those who are incapable of factual discussion.

  2. Chris Zinda Avatar
    Chris Zinda

    Feral horses are an interesting issue, given their invasive status, legal protection and overlap with some enviro groups (like WWP) who not only should know better but use each other for political purposes.

    Feral horses are a problem like all other non-natives on public lands , horse advocates no different than any rancher, MTBer, ATVer, climber, etc., folks who are interested in preserving an experience rather than the land.

    (Adding: wierd use of the word preservation, GW).

    1. Jeff Hoffman Avatar
      Jeff Hoffman

      You have the facts wrong. Horses are not “invasive,” they’re native. Exactly the opposite of what you think. And to say that those of us who advocate for these native animals are “no different than any rancher, MTBer, ATVer, climber, etc.” is not only wrongfully insulting, it’s also factually wrong, and provably so.

  3. easternsierraheidi Avatar

    “……folks who are interested in preserving an experience rather than the land.”

    Tourism (money) and a fervor rooted in an inexcusable depth of ignorance, self entitlement (wanna see horsies!) and lack of critical thinking.

  4. D. Cooke Avatar
    D. Cooke

    Anyone living near the CSNM knows that the serious fire danger is wind-driven conflagration events. Using wild horses to “control fire” in the CSNM is like using minnows to control the tide. Setting aside other issues, it’s a poor justification for feral horses in the monument.

  5. easternsierraheidi Avatar

    I’ll leave this here for the folks who think the horsies sit on the right hand of God and can do no harm. The photos show a limited part of the story.



    I don’t need to see photos – I’ve seen it for myself. Over the past ten years many of the larger wading birds that frequented the wetlands along this shoreline of this lake are no longer seen. The low spots that once held fresh water have become quagmires of horse droppings and brackish mud and the small shrubs that provided cover are gone. I haven’t seen the deer that grazed what used to be the meadows along the lake in a long time either. The grasses are disappearing beneath the hooves and excrement. A lightning fire burned the area upland of Navy Beach in 2020. Now days you can see the plumes of dust raised by the horsies from miles away while the deer and bird populations continue to plummet.

    The range of this particular herd also overlaps that of the threatened and likely to be listed as endangered Sage Grouse. I have seen first hand what the FERAL horses can do to a lek in a very short time. And then, thanks to the conspiritorial, whoops, I mean “collaborative” work of the BLM and “environmentalists” who seem to have lost the desire and/or ability to understand the consequences square mile after square mile of pinyon/juniper forests are being torn up and cut down to “save” the sage grouse. Somehow they skipped over the fact that they are also killing off the Pinyon Jays who live in those forests. So yeah – kill the native jays and the grouse and the migratory birds and other native wildlife but you’ll still have your (insert expletive of choice here) horsies.

  6. Ted Chu Avatar
    Ted Chu

    The most common argument in favor of feral horses by their advocates is that since in many cases cows are causing more damage than horses managers might as well add to that damage by not controlling horse populations.

  7. Jonathan Ratner Avatar

    Well, I will jump in here (probably a bad idea but I run the site)…..

    I am neither a wild horse lover, nor a wild horse hater. Over the last quarter of a century I have collaborated with wild horse advocacy groups in the mutual fight against the common enemy, the livestock industry.

    Aside from the powerful ‘the enemy of my enemy is my friend’ which I have partaken of from time to time, I look at this question from the perspective of the ecosystem.

    There is a vast difference between how the Great Plains system operates and how the arid West operates.

    There are a few factor that come to mind in the arid west (western 2/3 of WY, western ½ of CO, UT, most of ID, NV, AZ and NM, with eastern OR. This area functions entirely differently that the great plains or what is true prairie. The arid west did not evolve with significant herbivory as can be seen by the formerly dominant plant physiology (as detailed in Mack and Thompson and GTR 169 and elsewhere) which did not evolve to withstand herbivory and, in varying degrees, can not tolerate herbivry, while the Great Plains evolved with (and was able to support) very significant herbivory pressure with the herds of bison (allowed for by much higher precip).

    Mack and Thompson 1982

    Responses of Plant Communities to Grazing in the Southwestern United States RMRS-GTR-169



    In the arid west prior to the European invasion and the introduction of a wide array of invasive species that dramatically changed the fire regime, the sagebrush steppe of the above mentioned area had an extremely long fire return interval. Its only now with cheatgrass and a few other species that the Fire Return Interval is short and fire is an issue in this biome.

    The livestock industry, over the last 5-10 years has pushed the agenda of using livestock as fire prevention. I have to say, it is unfortunate that wild horse advocates are now using the livestock industry playbook.

    I have read most of the literature being put out by the livestock industry claiming more of the same eliminates fire. The literature I have read falls into two basic categories 1) flawed assumptions and flawed design, leading to flawed conclusions 2) that the level of vegetation removal needed to affect fire propagation is so high virtually all other aspects of the ecosystem are damaged, from vegetation to soil building to wildlife habitat.

    Of course the main problem facing the arid west is private livestock production. I am certainly not in the camp that scapegoats wild horses. I have done a lot of work on HMA’s and all the HMA’s I have researched it has been about a 97 or 95% allocation to livestock and 2 or 5% forage allocation to wild horses.

    And while I have collaborated with wild horse advocates in many situations, I am currently litigating against the BLM for its failure to deal with the impacts of burro on and around the Canyonlands HMA of southern Utah, where the livestock permit was bought out in 1999 and the primary factor eliminating recovery of this extremely fragile desert system is the burros.

    While there are some differences in how different species graze plants, within this ecosystem (basically outlined above) all herbivory is detrimental. How I look at it is do you focus on the relatively tiny level of herbivory of wild horses or the massive, nearly universal herbivory of the private livestock grazing our public lands basically for free.

    Let’s keep the discussion civil and fact-based

    1. Ted Chu Avatar
      Ted Chu

      Because managed livestock, which in most cases are cows, are causing damage is not a good argument for allowing feral cows, sheep, burros or horses to add to that damage.

    2. Jeff Hoffman Avatar
      Jeff Hoffman

      I agree with one exception: Horses are native to the western U.S., and that includes the land west of the plains. Horse remains were recently found, I believe in a west coast state.

  8. easternsierraheidi Avatar

    “. How I look at it is do you focus on the relatively tiny level of herbivory of wild horses or the massive, nearly universal herbivory of the private livestock grazing our public lands basically for free.”

    Good point but, like the Canyonlands issue you related, feral horses are now present in large numbers in places like the shore of Mono Lake – preserved for the value to wild birds – and is not grazed by livestock.

  9. Chris Zinda Avatar
    Chris Zinda

    Adding, what might be getting lost is a law school supporting the use of horses in a designated wilderness whose legal mandate is preservation, fundamentally natural processes.

    Reminds me of this:

    “Our wilderness areas, here and there, and thus eventually everywhere, are in danger of being taken away from us for other uses. They also are in danger, here and there, and thus eventually everywhere, of being destroyed as wilderness by overuse, misuse, and even by various measures for their supposed protection.” – Zahniser, 1953

  10. William E. Simpson II Avatar

    OK, so it seems there is a debate about George’s article.

    First, let me say that George is more of traveling vagabond pursuant to his own claimed accolades; “visited hundreds of mountain ranges around the West, more than 400 wilderness areas, more than 200 national park units, and every national forest west of the Mississippi, George is the author of 38 books on environmental issues”. George has very little in-depth boots on the ground experience with forestry, wildfires, or wild horses.

    Oo be clear, unlike George, I have lived on the southern edge of the Cascade Siskiyou National Monument and Soda Mountain Wilderness for the past decade (10-years), studying the ecosystem daily. In October of 2019, I took Lauren Brown (CSNM Manager) and her boss Elizabeth Berghard (BLM District Manager) on a nature hike into the area near the California border, which they’d never seen before, even thought they manage it. They saw huge snags that had been struck by lightening and burned furiously, but the fire was held in check to a limited area by the grazing of the ground fuels by horses, which had clearly been in the area as evidenced by aged horse dung. I have some great selfies of myself with Elizabeth and Lauren, and photos of both Elizabeth and Lauren (BLM) standing together by one of the burned snags to which I refer. They saw the truth, and that too was documented.

    In 2018, I was the Technical Advisor to the CALFIRE (Fresno) commanders at the Camp Creek fire-line on the south side of the CSNM for the first 9-days of that 38,000 acre wind-driven blaze. I documented how, exactly, the fire-grazing by the horses benefited the suppression efforts, created fire breaks of low-fuels, and larger safe zones for men and equipment that safely staged in-front of the oncoming wind-driven wildfire.

    Interestingly, that inferno, called the Klamathon Fire (2018) was stopped in the immediate area where the horses had managed annual grass and brush fuels for centuries. And the Cascade Siskiyou National Monument was saved.

    This was all documented and photographed. And the BLM District Manager Elizabeth Berghard and Lauren Brown are also aware of these events.

    Funny, I didn’t see George Wuerther anywhere around during that wildfire!

    In fact, it wasn’t until 3-days into that inferno that even the BLM assistant CSNM manager Joel Brumm finally showed up and opened the gate up the tank-gate to the north of the fire-line so we had a way out in case we didn’t stop the fire at the areas managed by the horses.

    George has never fought wildfire, but he sure has a lot of opinions about wildfire.

    Unlike George, I have fought wildfire; I’ve looked into the eyes of the dragon and breathed his deadly breath. It’s so-called ‘experts’ like George who have ZERO practical experience who continuously muck things up. Books, videos and field trips only get you so far… and that’s not to suggest academics are useless.

    I too have many years of university study, but it was augmented by full immersion into the subjects via empirical, boots on the ground experience. I have been studying the behavioral ecology and ethology of the horses on the Monument for 10-years, full-time 24-7 on and immediately around the CSNM, including depredation of these horses by bears, mountain lions, wolves (wolf-coyote hybrids), coyotes and bobcats. I have documented the forensic evidence of depredation during that time as well.

    More here: https://www.youtube.com/watch?v=UGgikERhTog

    I have videos of the bands of horses in the CSNM resting and using riparian areas with mountain springs without any degradation as they have for centuries! If they were indeed damaging the landscape as is ignorantly posited by Mr. Wuerther, then the CSNM would have not been declared as ‘pristine’ in the year 2000 when the Monument was formalized, or 24 years later as seen in my hundreds of photos and videos of the areas used by the horses!

    My research impressed Re-Wilding Europe so much that when they launched their wildfire-focused online Journal ‘GrazeLIFE’ they asked me to use my study for the inaugural article! Here it is: https://grazelife.com/blog/wild-horse-fire-brigade-lessons-in-rebalancing-north-american-ecosystems-by-rewilding-equids/

    Frankly, the saying that George is a 1/4-inch deep and a mile wide on the subject matter is accurate. The man has no real depth of empirical focus on any real area. I spent the late 1960’s and early 1970’s going to university and also doing forest management (logging and occasionally fire suppression). I spent a lot my formative years as a teen hanging out with my brother-in-law (A Klamath Native American) learning the old indigenous ways, including tracking, hunting and fishing the area now considered the Cascade Siskiyou National Monument, well before a bunch of city folks moved into the area and discovered that pristine (even at that time, with hundreds of horses there) area, and deemed it needed to be a ‘Monument’.

    The horses on and around the Cascade Siskiyou National Monument (CSNM) have been on that landscape for the past 440-years, according to published cultural archeology (and per Dr. Yvette ‘Running Horse’ Collins) peer-reviewed doctoral dissertation at Alaska University. According to Dr. Collins, Sir Francis Drake noted the indigenous peoples of the area living-among wild horses, just I am and have been doing for the past decade. And there are horse fossils in the same area, indicating habitation for millennia.

    Funny how late human arrivals to the area in the 1980’s & 1990’s failed to realize that the area was according to everyone so ‘pristine’ and should have protection, yet they utterly failed to recognize that that horses were part of the herbivory on the landscape for thousands of years, per the hard evidence, not opinion. So their idea of protecting the area came to pass in 2000 with Clinton’s Monument being created. Of course, instead of asking the correct question, what made the Cascade Siskiyou National Monument so ‘pristine’, so much so that it deserved special protection, they immediately started undoing nature’s balance that had worked for millennia, with horses being part of that balance as the ONLY large-bodied herbivore that manages wildfire fuels (grass and brush) and also effectively re-seeds a wide range of plants and grasses (ruminants do not), thus completing their life-cycles and benefiting all the other co-evolved species on the landscape.

    For a so-called ‘ecologist’, Mr. Wuerther is painfully ignorant when it comes to the differences between the anatomy of horses and ruminants (deer, elk, cattle, sheep, goats); teeth, hooves and digestive systems, which are critically important to understand when it comes to the co-evolution of a myriad of species of flora and fauna (including horses) in the Monument and it’s management.

    Unlike Mr. Wuerther, through a 5-year contract with California State University, Sacramento, we (my partner and I) are Teaching the world’s first wild-horse ecology-ethology (herbivory and wildfire fuels management) wilderness field-study courses to qualified university students, under the direction of the Chair of the Environmental Department at CSUS. Our all-volunteer Org. has two (2) PhD’s on the board, each of who did their doctoral research on wild horses. We know what we’re talking about, and have the empirical experience and data that backs it up.

    Arguably, G. Wuerther can’t hold a candle to the experience and knowledge of a man argued as the world’s leading expert on equine evolution and paleontology, Dr. Ross McPhee.

    Dr. MacPhee says our horses are ‘Native’ and makes the point very clear in this article to some other poorly informed people over in Wyoming at Cowboy State Daily. You can read what Dr. MacPhee has to say on that subject here: https://cowboystatedaily.com/2022/09/13/letter-to-the-editor-rod-miller-is-wrong-horses-are-not-an-invasive-species/

    Regards, William E. Simpson II
    Executive Director – Wild Horse Ethologist
    Wild Horse Fire Brigade

    YouTube: https://www.youtube.com/@wildhorsefirebrigade2191/videos

    1. Chris Zinda Avatar
      Chris Zinda

      As you are the ED of WHFB and eyond arguments of native, I ask that you explain how the use of horses to manipulate/”manage” fuels in designated wilderness is seen by you and your org as not a violation of the Wilderness Act.

      Thank you.

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George Wuerthner is an ecologist and writer who has published 38 books on various topics related to environmental and natural history. He has visited over 400 designated wilderness areas and over 200 national park units.

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George Wuerthner