envirohorse@yahoo.com online www.californiastatehorsemen.com/envirohorse
May 2, 2001
Ms. Valerie Pilmer
BLM Calif. Desert District (CA-610)
6221 Box Springs Blvd.
Riverside CA 92507
909-697-5200 phone; 5299 fax
vpilmer@ca.blm.gov
Re: Western Mojave Management Plan
Subject: Erroneous Task Group #1 Recommendation to Reclassify Equestrian Use to "Consumptive" or High Impact
We believe that the Task Group #1 has made a serious error in suggesting that horseback riding (equestrian access) be reclassified from LOW IMPACT recreation to "Consumptive" or HIGH IMPACT use. This suggestion appears to be arbitrary and ignores a vast body of literature that defines the horse as a lightweight low impact user. We ask to be provided with the scientific data that has led to this unwarranted decision. We further ask the Task Group to reconsider its prior decision and retain the horse as a low impact user.
THE HORSE: HIGH VS. LOW IMPACT USER
In virtually every mixed use trail reference within the State of California and nationally, the horse has been defined as a low, or lightweight impact user, even in the most sensitive environments: the Natural Preserves!
Edgewood Park and Natural Preserve Master Plan Adopted May 1997 (Parks and Recreation Division San Mateo County) Pg. 11 B. Definitions 6. Definition of Low-Intensity Recreation Uses: "Define low-intensity recreation uses as passive recreation uses that will not create a direct or cumulative adverse environmental impact. Such uses include, but are not limited to, on-trail hiking, walking, jogging, horseback riding, nature observation, education, docent-led group tours, and picnicking and camping " this is a natural preserve of rare serpentine grassland that supports numerous threatened and endangered species. Horses share the same trails as hikers. Bikes are not permitted.
The Mid-Peninsula Open Space District (MROSD) defines Trail Use Suitability to include: Hiking, Running, Equestrian, and Bicycling throughout most of their 43,000 acres of Natural Preserves.
Santa Clara County Countywide Trails Master Plan, 1995,"identifies hiking, horseback riding, and bicycling trails" as lightweight use.
The USDA Region Five Shasta-Trinity Nation Forest Trail Procedure Guide builds trails to include the horse as a lightweight user.
The US Forest Service/USDA Rocky Mountain Region Guide for Mountain Trail Development builds trails for hikers, joggers, and equestrians, all considered lightweight, low-impact users.
The California Trails Foundation uses the California Department of Parks and Recreation Klamath District/North Coast Redwoods District Trail Manual. Section 1.4 Trail Standards for Class I Trails that states, " These trails include handicapped accessible, equestrian, interpretive and hiking trails assigned a Class I point criteria value. "
The State of Washington Department of Natural Resources' Recreation Trail Maintenance produced in cooperation with the USDA and NPS designs trails for low-impact users, including equestrians.
The Bay Area Ridge Trail creates a multi-use trail system around the San Francisco Bay for hikers, bikers, joggers, and equestrians that are all considered lightweight users.
Since 1915, the Rocky Mountain National Park has included equestrians as low-impact users.
What new scientific data does Task Group #1 have to suggest the redefinition of the horse from low impact to a high impact use?
We urge the Task Group to reconsider its decision of November 2000 and January 2001 and restore the horse to its proper status of low impact use to avoid the Plan being factually erroneous and potentially at risk to lawsuits that will be inevitable should the suggested reclassification to high impact use for the horse be pursued. This is an issue of extreme sensitivity in the equestrian community.
EQUINE TRAIL INTERACTIONS
Every trail user group causes some impact to the environment by their use. For lightweight low impact users, the effects are usually minimal. The attempt to describe the horse as "consumptive" use is really a stretch. On what basis is any lightweight trail user "consumptive"? There are scientific studies which clearly indicate that the horse is much more benign to wildlife than hikers, nature studiers and photographers. There are no studies that implicate the horse with spreading weeds. And, natural erosive forces are by far the major alteration factors in trail erosion.
Wildlife Effects
Horses are prey animals. They have eyes on the side of their head. They are herbivores and leave the trace scent of an herbivore on the trail. Humans and dogs are predators. Their eyes are on the front of their face. As they walk, they leave the trace scent of omnivore on the trail that can impact wildlife.
Horses are recognized by wildlife as prey animals, even when a person is sitting on their back. An approaching horse passing along a trail provides sound rhythms in the cadence of a four-footed hoofed prey animal to wildlife, which informs wildlife of a non-threatening presence. For reptiles, rodents and other terrestrial life forms, the percussion pulse of the approaching horse provides warning. Being warned diminishes flushing/flight response that consumes wildlife energy. It is very common to find deer, bobcat and coyotes that allow horses to get within feet of them on trails before calmly moving off. Horses rarely step on lizards, mice and other fast moving wildlife. Slower moving wildlife can easily be avoided.
Bennett and Zuelke (1999) undertook an extensive review of recreation effects on birds and concluded that disturbance from recreation has temporary effects on behavior and movement of birds. Direct approaches caused greater disturbance than tangential approaches, rapid movement by joggers was more disturbing than slower hikers; children and photographers were especially disturbing, and passing or stopping vehicles were less disturbing than human foot traffic. Horses and riders did not disturb birds.
Sporadic human use can disturb wildlife. However, "many animals are less afraid of horseback riders than hikers. Riders seldom dismount to touch flora or fauna. Riders can be a dedicated and energetic volunteer and advocacy group. The horse-rider relationship promotes a non-anthropocentric worldview that facilitates ecological understanding. Horses are useful for patrols and surveys. Horse traffic can be used to maintain firebreaks and seldom-used trails." (Williams et al, 1998)
Horses in many ways may be more compatible with wildlife than other user groups.
Floristic Effects
There is no documented evidence of the horse spreading weeds. A Montana study by Tyser and Worley 1992 implicated timothy (Phleum pratense) and bluegrass (Poa pratensis) as species that had been included in past roadside seeding by the local highway authority. In California, the Department of Transportation (CalTrans) has recently been identified as the number one spreader of yellow star thistle by its past practices of scattering various weed-laden hays during roadside rehabilitation projects to control erosion.
It is unknown to what extent high quality livestock forage available contains weed seeds. However, most horse owners would not buy junk hay for their horses. Garbage in, poor performance out! The days of large populations of lower-grade, inexpensive stock horses are long gone. Horses cost money, and the purchase price is only the down payment for ownership. Horsemen cannot afford to compromise their investments by feeding weedy hay. Responsible horse owners are concerned about getting quality feed that has been properly planted, harvested, and cured for their horse food dollar. Many horses are fed processed feedstocks. This is forage that is heated. The heat destroys weed seeds.
The horse has a very inefficient gut: it's a one-way through-put system. Horses are physiologically incapable of vomiting or regurgitating. If something gets stuck on the way through, the only way to get it out is by surgery or physical intervention (at arm's length!). As a consequence, horses must be fed carefully to avoid the common and potentially fatal condition of colic. The bulk of unprocessed forage consumed by California horses is alfalfa (Medicago sativa), rye grass (Lolium multiflorum or perenne), Timothy hay (Phleum pratense) and oat hay (Avena sativa (white cultivated oats)). If horses were a vector of seed spread, these grasses could be prevalent in our open spaces and parks, but they are not. Nor are these forage feeds listed on the California Exotic Pest Plant Council web site at this time. Tamarisk, knapweed, thistles, etc., are the big culprits. Horses do not eat these species, many of which are actually toxic to the equine.
Trail Effects
In a 5-year study, Summer (1990, 1996) concluded that horse traffic was not the single, dominant process active on trails. Trail degradation was a function of landform, climatic and catastrophic events, and geomorphic processes. Seasonal use was important in keeping the soil exposed and vegetative cover absent on trails. Such processes as sheetwash, rilling, gullying and soil creep actively modified and eroded the trails and resulted in a measurable fluctuating rate of change over time. Limited data suggested that foot traffic produced effects similar to horse traffic in exposing the trail to the effects of geomorphic process or climatic events. Intensive runoff resulting form natural events can cause significant geomorphic change in a trail from such processes as gullying and earth slumps. Erosion from these events may overshadow effects of horse use on trails
Williams et al 1998 concur that factors other than user type are more closely linked to trail degradation. Lightly used trails may grow over and require more maintenance, whereas moderate horse activity may help to maintain a multiple-use trail. The bottom line is that horse trails can be maintained on most natural preserves without unacceptably impacting ecological values.
CONCLUSION
The horse is no worse than, and in some respects may be better than other lightweight low impact users in terms of effects on trails. If the horse is a consumptive user, then so too is every lightweight low impact user because we all have some effect by our presence on trails. We suggest that the term "consumptive" should be avoided. As we have shown, the presence of the horse as a lightweight, low impact user on single-track trails does not pose a significant risk to fauna, flora or the trails themselves.
We would like to see the scientific information that supports the decision of Task Group #1 to classify the horse as a heavy impact consumptive user.
The BLM should think very carefully before accepting this particular arbitrary, erroneous and ill-advised recommendation by Task Group #1. We strongly urge the BLM to leave the horse classified rightfully as a low impact, lightweight trail user, as it is treated elsewhere.
I would be happy to provide information on horses that would be helpful to the process of creating a reasonable Western Mojave Management Plan as you go forward with your deliberations. Please do not hesitate to call on me if there is any way that I can be of assistance.
Regards from
Adda Quinn
REFERENCES
Bennett, KA and E. Zuelke . 1999. The effects of recreation on birds: a literature review. Delaware Natural Heritage Program, Smyrna, DE 1977.
Summer, RM. 1996. Geomorphic Impacts of horse traffic on montane landforms 41(2): 126-128.
Summer, RM. 1980. Impacts of horse traffic on trails in RMNP. J. Soil and Water Cons. 35(2): 85-87.
Tyser, RW and CA Worley. 1992. Alien flora in grasslands adjacent to road and trail corridors in Glacier National Park, Montana USA. Conservation Biology 6:253-262.
Williams, B. and L. Conway-Durver. "HORSE TRAILS IN ECOLOGICAL RESERVES" presented at Clemson University Horse Trails Symposium, 1998. Mr. Williams holds a BS Degree in Forestry from Clemson University. He worked for the U.S. Forest Service as a River Ranger on the Sumter National, organized the Association of Forest Service Employees for Environmental Ethics and is the Executive Director of the Chattooga River Watershed Coalition.