Wissmann 1

Sydney Wissmann

Dr. Joyce Malek

ENGL2089

15 March 2019

Word count: 1782 words

A Rhetorical Analysis of the Pryor Mountain Wild Horse Range FONSI Document

The Bureau of Land Management created the Wild Horse and Burro Program in 1971 in

response to the Wild-Free Roaming Horse and Burro Act, which tasked the BLM with the

protection of the wild horse populations of the United States. In the summer of 2018, the BLM

decided to take action to lower the mustang population in the Pryor Mountain Wild Horse Range.

This decision concluded with a summary of an environmental assessment used to examine the

most feasible way to go about lowering the population, called the PMWHR Bait/Water Trapping

Gather and Fertility Control Environmental Assessment; Finding Of No Significant Impact and

Decision Record (abbreviated as the FONSI). The rhetor, David Lefevre, is the field manager of

the BLM’s Billings office and represents the BLM on the matter of wild horse management in

the Pryor Mountain area. He writes for the general public, although Lefevre’s writing choices

seem to indicate he is aware the document will interest more specific groups like wild horse

advocates and ranchers who are directly affected by the decision.

Several documentaries have been produced about these Pryor Mountain, Montana horses.

Thanks to the popularity of these films, the area is the spotlight for mustang management,

sometimes resulting in negative attention when it comes to horse removals. The BLM asserts that
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the Appropriate Management Level (AML), or how many horses the area can sustain, is 90-120

horses. But in 2018, that number was closer to 150 (Herd Area). The BLM argues that a

population above AML can negatively affect the environment and cause horse starvation. The

agency is responsible for not only the horses, but for the land as a whole, so they must ascertain

the AML for the security of the ecosystems as well as the equines they protect. The BLM

concluded the most effective choice for the Pryor Mountains would be to remove seventeen

specific horses with humane corral traps around food and water sources. In addition, a fertility

control program that involves darting mares (adult female horses) with a contraceptive would

continue, with guidelines on which mares would be darted in order to preserve genetic diversity

and bloodlines. Genetic preservation was the main concern of horse advocates, while another

large group, ranchers, generally want fewer horses to preserve grazeland for cattle. The FONSI

asserted how, why, and when this plan, called the Proposed Action, would take place. It also

provided explanations as to why other plans, particularly those which advocates approved, would

not be effective or feasible. In following government regulations, the document ended with

instructions on how to appeal the Proposed Action in court. The Cloud Foundation, a wild horse

advocacy group, did indeed appeal on the grounds that the plan would be catastrophic for the

genetics of the herd, and a judge ruled in their favor (Peck), so the BLM’s purpose was not

reached to resolve the exigence as it intended. Although the document must operate under the

constraints of government guidelines and ultimately did not achieve the purpose, Lefevre utilizes

logic and emotion when able, establishes his credibility and authority, and uses a concise style to

state the BLM’s purpose of finding a suitable solution for the rising mustang population in a

practical, direct manner.

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Lefevre tries to appease the varied audiences, which consists of wild horse advocates,

ranchers, hunters, and the public at large, all of whom have different goals. It is even

acknowledged in the document that “[p]roper wild horse management sometimes evokes

controversy, emotionalism, and public outcry. Balancing the BLM’s legal obligations with public

sentiment continues to be a challenge in the management of the PMWHR” (4). His persuasive

techniques, however, mostly refrain from using emotion and emphasize logos through logic and

fact. The regulations of government documents place restrictions on pathos because the goal is to

be strictly objective. Unfortunately, strictly using facts is not the most persuasive technique, as a

well-rounded argument must also include emotional value to fully appeal to the audience.

However, Lefevre did try to incorporate pathos in some sections, despite the constraints he is

under. One part emphasizes strong, literal, and negative diction; it details a rejected alternative

that advocates support, called the “No Action Alternative”, and Lefevre makes clear that this

would be calamitous:

Wild Horses would be allowed to reproduce until a population crash controls their

numbers. Under this alternative there would be no way to ensure any population outcome

other than after the population crash occurs as [a] new bottleneck is created for the

remaining animals as nothing is selective as to which horses are “naturally removed”.

Horses would be allowed to exhaust all resources, multiple use relationships would be

ignored, and the public could observe horses in lower body condition until a crash

occurred and the individuals perished (11).

Lefevre employs the proper diction required of a government piece, while also invoking feelings

of pain and suffering through words like “crash” and “perished”. He attempts to persuade the

audiences to reject this alternative by using pathos and logos simultaneously. Ethos is featured as
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well with a pervasive sense of authority; the reader does not question the fact that this will be the

result nor does the reader feel he lacks expertise. The technique of utilizing discouraging

language to prompt empathetic responses is a form of persuasive writing Lefevre employs to

convince the audiences to approve his decision over the proposals they support.

Lefevre certainly has an authoritative voice; perhaps this is in part because of the no-

nonsense language he uses, but he also imparts a credible and confident style separate from that.

He signs the document and refers to the Proposed Action as his decision. The decision record

portion starts with his assertion: “Based on the analysis of Environmental Assessment … it is my

decision to adopt the Proposed Action” (9). He is only the acting manager of the office, yet his

power is clear. His basis of the decision in fact and the detailed explanation of why the Proposed

Action was approved also contributes to the ethos of the piece. There is no room to question

credibility, and Lefevre references numerous laws to further support the BLM’s authority to

make this decision. Precautions such as location assessments are addressed in order to further

gain the respect of the audience. In addition, the specialized lexis involving acronyms such as

“AML” and “HMAP” seems assertive; Lefevre is a part of the discourse community, as evident

by his knowledge of the lexicon, and so he holds more authority to those in the audience also

part of the wild horse community. Using the proper lexicon means the person understands the

logic and attitudes of the community (Klass 42), so Lefevre finds it beneficial to use the

specialized language to connect with his audiences. However, for an audience that is the general

public perhaps only mildly interested in the exigence of wild horse removal, the techniques used

for authority and credibility may be off-putting and dissuade those unfamiliar with the problem

from finish the reading. Even those in the community may misunderstand and find his approach

too dogmatic. Although the public may find the Lefevre’s authoritativeness and lexis difficult to
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understand, his use of “my decision”, basis of his argument in strong evidence, and specialized

lexis contribute to his ethos for the more specific audiences of advocates, ranchers, hunters, and

environmentalists.

The style of the document is concise and answers the exigence thoroughly within the

constraints of the guidelines of a government document. The environmental assessment this

summary is based on goes into much further detail, but the FONSI succinctly summarizes the

information. It may seem repetitive, but this falls under the constraints of its format, which must

follow a certain order. In fact, the repeated emphasis of the Proposed Action strengthens the

definitiveness of the decision by leaving no room for error or questioning. For example, Lefevre

states:

Removing excess wild horses and managing population growth through fertility control

efforts would reduce the level of use of rangeland vegetation and help alleviate

competition for resources between wildlife and wild horses (5).

In this example, the style is formal and the point is clear just as it is in the rest of the text. The

passive voice pervades throughout the document and lends to its formality by distancing the

BLM from the actions it wants to take. The order of the FONSI is constructed in a way that

properly answers the exigence, starting with the decision, providing background and rationale for

it, disproving alternatives, and then reiterating rationale to again emphasize why the Proposed

Action is the best choice. The point is made that the public did have a part in this decision, as

Lefevre concedes that refinements were incorporated into the Proposed Action after public

comment (2). Each public comment was addressed in the original environmental assessment, but

once again this text is able to concisely summarize such information in a way that shows respect
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for the varied audiences. The brevity of the document and its simple but also formal diction

allow for a tidy communication of the BLM’s purpose to properly maintain the PMWHR.

The exigence was not an easy one to address. Wild horse management is steeped in

controversy, and even a document showing a solid grasp of persuasive techniques, authority, and

formality could not resolve a management issue in the BLM’s favor. As Keith Grant-Davie states

in his article about rhetoric, “the conclusion of a compound rhetorical situation may be harder to

determine than the end of a single-discourse situation, particularly if the subject is perennial”

(506), and wild horse management is certainly a perennial, multi-faceted dispute. Regardless, the

FONSI meets its goal of communicating the BLM’s purpose of humanely reducing the mustang

population to its varied audience of advocates, ranchers, environmentalists, and the public,

although it ultimately did not solve the exigence of a deteriorating environment under to a

population above the AML as the BLM’s purpose intended.

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Works Cited

Grant-Davie, Keith. “Rhetorical Situations and Their Constituents.” Spring Review, 1997.

“Herd Area and Herd Management Area Statistics.” BLM 1 Mar. 2018. Web. 1 Mar. 2019.

www.blm.gov/sites/blm.gov/files/wildhorse_programdata_2018hmastats.pdf

Klass, Perri. “Learning the Language.” Excerpt originally published in Not an Entirely Benign

Procedure, Putnam, 1987.

Lefevre, David. “Finding Of No Significant Impact and Decision Record PMWHR Bait/Water

Trapping Gather and Fertility Control Environmental Assessment DOI-BLM-MT-A010-

2017-0055-EA.” BLM. Web. 1 Mar. 2019. eplanning.blm.gov/epl-front-

office/projects/nepa/89925/153182/187726/FONSI_and_DR_Bait_Water_FC_2018.pdf

Peck, David. “No horse roundup on Pryor Mountain range." Lovell Chronicle 30 Sept. 2018.

Web. 1 Mar. 2019. trib.com/news/state-and-regional/no-horse-roundup-on-pryor-

mountain-range/article_3b16a961-374f-580a-94a9-217b78f924d5.html

“PMWHR Bait/Water Trapping Gather and Fertility Control Environmental Assessment DOI-

BLM-MT-A010-2017-0055-EA.” BLM. Web. 1 Mar. 2019. eplanning.blm.gov/epl-front-

office/projects/nepa/89925/153181/187725/2018_PMWHR_bait_gather_fertility_control

_EA_final.pdf