by Debbie Coffey ~ (Director of Wild Horse Affairs at Wild Horse Freedom Federation) published in PPJ Gazette
The BLM has NOT proved an excess of wild horses and burros
BLM’s Wild Horse Harvesting Machine by John Holland
The Bureau of Land Management (BLM) continues at a breakneck pace to leave non-viable herds of wild horses on public lands and while it also considers cutting back on livestock grazing (watch out for drought management plans in your area).
Meanwhile, over and over again, extractive industries and new energy projects seem to go almost unchecked for use of massive amounts of water that adversely impact public lands and risk contamination of aquifers.
Just an aside on the letter below, Melani Mirati was the BLM’s COR (Contracting Officer’s Representative) at the 2012 Calico wild horse roundup and made the decision to allow the contractor (Sun J Livestock) to use a hot shot (electric prod) on a horse that had been stuck in a trailer and had just fallen on the ground. (video link under SOURCES below).
Open Letter to the BLM:
May 18, 2012
| Melanie MiratiBLM Winnemucca Field Office5100 E. Winnemucca Blvd.,
Winnemucca NV 89445-2921 |
RE: Public comment/Jackson Mountain wild horse gather
Dear Ms. Mirati and BLM Winnemucca Field Office:
In this document, BLM states:
“1.4 Purpose and Need for Action:
The purpose of the Proposed Action is to remove excess wild horses from within and outside the HMA, to manage wild horses at the established AML ranges for the HMA, to reduce the wild horse population growth rate in order to prevent undue or unnecessary degradation of the public lands by protecting rangeland resources from deterioration associated with excess population of wild horses within and outside the HMA boundaries, and to restore a thriving natural ecological balance and multiple use relationship on the public lands.”
My comment: The BLM has NOT proved an excess. It seems that not only are there no photos or videos shown to the public to verify the BLM’s estimation of the number of wild horses on the HMA, in order for Ms. Mirati’s population estimation to be correct, the mares would have to be giving birth to litters.
At the same time your office claims to need to remove wild horses to “prevent undue or unnecessary degradation of the public lands by protecting rangeland resources from deterioration associated with excess population of wild horses…,” on January 2012 your office issued an EA for the Hycroft Mine Expansion Project, which uses 900 million gallons of water a year (did you request 1′ and 5′ water drawdown maps for this EA?). A wild horse only drinks 15 gallons of water a day.
This Hycroft Expansion Project will use an additional 5,895 acres of PUBLIC LAND, with 2,172 acres of “new disturbance.” ON PUBLIC LAND, it seems this one project has 85 acres of roads, 176 acres including an open pit, 451 acres for heap leach pads, and 451 acres for waste rock facilities. Wild horses leave some hoofprints and eat some forage.
Please explain, exactly, how removing the wild horses will “restore a thriving ecological balance.”
Also, please explain how the Hycroft Mine Expansion’s many uses of water and disturbance of public lands, KEEP a “thriving ecological balance” and with 5 years needed for reclamation, how is this not years of “undue degradation” or “deterioration?”
Your district also has the Coeur Rochester Mine Expansion Project. In August 2010, the EPA sent a letter to Bob Edwards of the BLM, stating that the EPA was concerned about this 7th Amendment to the Plan of Operation (POO) since 1986 and that no Environmental Impact Statements (EIS) were conducted regarding the Plan of Operation OR its amendments. The EPA stated it had concerns about the proposed project’s “potential direct and cumulative impacts on water and air quality.”
24 years and no EIS? It sure seems that “uses” of public lands that make more money get Findings of No Significant Impact (FONSI), which is in violation of FLPMA (Federal Land Policy and Management Act).
Your office also gave a FONSI to Newmont Mining’s Sandman Exploration Project, in the EA, it states this project will cause 500 acres of disturbance, and “none of the drilling products to be used under the Proposed Action contain hazardous substances and all are approved for well drilling and would therefore, not contaminate ground water aquifers or surface waters. Material Safety Data Sheets (MSDS) for common drill additives are included in the Plan.”
Then
“2.1.9 Solid and Hazardous Materials …Hazardous materials utilized within the Project Area would include diesel fuel, gasoline, and lubricating grease.”
Isn’t lubricating grease used on the drill? (If so, shouldn’t lubricating grease be considered a drilling product?). Hydraulic fracturing (fracking) is being used for this project, isn’t it? It seems a Finding of No Significant Impact is often given to uses that have the potential for a LOT of impact.
In conclusion, without any photographs or videos of the wild horses, you cannot prove there is an excess and you only have the legal authority to remove the wild horses from their HMAs (Herd Management Areas) if there is an excess.
____________________________________________________
SOURCES:
https://www.blm.gov/epl-front-office/projects/nepa/30004/36055/37911/Preliminary_EA.pdf
http://www.epa.gov/region9/nepa/letters/coeur-rochester-mine-preliminary-ea.pdf
http://www.blm.gov/nv/st/en/fo/wfo/blm_information/nepa0/minerals/hycroft.html
http://www.blm.gov/nv/st/en/fo/wfo/blm_information/nepa0/minerals/sandman.html
video, below, of 2012 Calico Roundup by Elyse Gardner, Humane Observer:
Click (HERE) to visit the PPJ Gazette and to Comment
Categories: Horse News, Wild Burros, Wild Horses/Mustangs
Straight from the Horse's Heart 
Is this moron for real? And was that other mutant in the trailer kicking that poor horse while it was down? Shocking, shocking – what horrible people – PLEASE let me loose with that electric prod, let’s see how fast they get to their feet – idiots!!
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Let it be noted for the record that what these BLM employees are doing to this injured horse is exactly what the Tennesee Walking Horse Abuse Video showed was being done to the TWH who was too injured to get up after the horse’s feet were soured, so they use hot shot to the head.
This is more CRUEL and INHUMANE treatment. Who are these people and why do they have jobs in the federal government?
We need to find out how to make sure that government employees do not escape prosecution for animal cruelty.
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To Hoofhugs –
You ask “who are these people”? The BLM person in charge (and stood and watched) during he hot-shots on this down horse is your Winnemuca Field Office Wild Horse and Burro Specialist … Melani Mirati. She is in charge of the upcoming Jackson Mt. WH&B capture also. What does that tell us?
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Exactly!!! Why aren’t these animals held in just as high regard as the Tennessee Walking Horses? They are ALL Horses!! They are all Equines!!! Why isn’t SOMEONE prosecuting these men like they are prosecuting Jackie McConnell?
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I agree with Ms. Coffey that per BLM population figures, the wild horses appear to be having “litters”!
Thinking out loud:
BLM published Jackson Mt. population statistics:
131 Wild Horses Feb-08
323 Wild Horses Feb-09 (147% increase – i.e. “having litters”)
410 Wild Horses Feb-10
520 Wild Horses Feb-11
660 Wild Horses Feb-12
But WHOA! On top of those bogus numbers BLM then says in the EA that the population (pre-foaling 2012) is 740. Did they just add an extra 80 for good measure? Or to help justify their funding for capture?
But WHOA (again)! On top of all of that, BLM then said in the EA that the Jul-12 population would magically be 930!!!
It has been a long time since I had any math and science classes, but from what I remember … these population increases for wild horses are impossible. Even if we use BLM’s favorite and overused statement that wild horse herds can “double in four years” the herd would be about 262 wild horses on the Jackson HMA pre 2012 foaling – not 740. The AML is 130-217, thus the 262 estimate would barely be over the AML.
If the BLM attempts to capture about 800 wild horses from the Jackson Mt. HMA and there are only about 325 actually on the HMA … that says to me they will be zeroing out this HMA and returning only a few non-reproducing horses to the range.
Where are the post gather reports and data and photos (both field and aerial) giving evidence of the BLM population numbers that were done after the last roundup in 2008 and evidence of their current population estimate? Using data from the Jackson Mt. EA and BLM published Herd Management Area Statistics, for fiscal years 2008 – 2012 this herd will have increased from a post-gather population estimate in 2008 of 131 animals to a projected 940 animals by end of foaling for 2012. This would equal an approximate increase of 565% since FY 2008 (or 717% post-foaling 2012 – five foaling seasons). Why should we believe BLM’s statement of current population when there is no data to prove it?
If I told you I had $7,000,000 in my checking account …would you take my word for it? Of course not! Where is the proof for the BLM population numbers? Disclosure is required in legal documents and is required by the federal NEPA decision making process and without it … the document (Jackson EA – environmental assessment) and subsequent FONSI and Record of Decision is not and will not be legal.
At its most basic level, NEPA requires that the decision-maker, as well as the public, be fully informed, i.e. “… information is available to public officials and citizens before decisions are made and before action is taken.” 40 C.F.R. § 1500.l(b). NEPA ensures that the agency “will have available, and will carefully consider, detailed information concerning significant environmental impacts; it also guarantees that the relevant information will be made available to the larger [public] audience.” Robertson v. Methow Valley Citizens Council.
In my mind, a 717% increase can only be explained by the word “litter”.
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I agree with Ms. Coffey that per BLM population figures, the wild horses appear to be having “litters”!
Thinking out loud:
BLM published Jackson Mt. population statistics: 131 Wild Horses Feb-08, 323 Wild Horses Feb-09 (147% increase – i.e. “having litters”), 410 Wild Horses Feb-10, 520 Wild Horses Feb-11, and 660 Wild Horses Feb-12.
But WHOA! On top of those bogus numbers BLM then says in the EA that the population (pre-foaling 2012) is 740. Did they just add an extra 80 for good measure? Or to help justify their funding for capture?
But WHOA (again)! On top of all of that, BLM then said in the EA that the Jul-12 population would magically be 930!!!
It has been a long time since I had any math and science classes, but from what I remember … these population increases for wild horses are impossible. Even if we use BLM’s favorite and overused statement that wild horse herds can “double in four years” the herd would be about 262 wild horses on the Jackson HMA pre 2012 foaling – not 740. The AML is 130-217, thus the 262 estimate would barely be over the AML.
If the BLM attempts to capture about 800 wild horses from the Jackson Mt. HMA and there are only about 325 actually on the HMA … that says to me they will be zeroing out this HMA and returning only a few non-reproducing horses to the range.
Where are the post gather reports and data and photos (both field and aerial) giving evidence of the BLM population numbers that were done after the last roundup in 2008 and evidence of their current population estimate? Using data from the Jackson Mt. EA and BLM published Herd Management Area Statistics, for fiscal years 2008 – 2012 this herd will have increased from a post-gather population estimate in 2008 of 131 animals to a projected 940 animals by end of foaling for 2012. This would equal an approximate increase of 565% since FY 2008 (or 717% post-foaling 2012 – five foaling seasons). Why should we believe BLM’s statement of current population when there is no data to prove it?
If I told you I had $7,000,000 in my checking account …would you take my word for it? Of course not! Where is the proof for the BLM population numbers? Disclosure is required in legal documents and is required by the federal NEPA decision making process and without it … the document (Jackson EA – environmental assessment) and subsequent FONSI and Record of Decision is not and will not be legal.
At its most basic level, NEPA requires that the decision-maker, as well as the public, be fully informed, i.e. “… information is available to public officials and citizens before decisions are made and before action is taken.” 40 C.F.R. § 1500.l(b). NEPA ensures that the agency “will have available, and will carefully consider, detailed information concerning significant environmental impacts; it also guarantees that the relevant information will be made available to the larger [public] audience.” Robertson v. Methow Valley Citizens Council.
In my mind, a 717% increase can only be explained by the word “litter”.
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In order to fully realize how much time and research Debbie has put into her letter, you have to take a look at this Environmental Assessment. This is just ONE document that has had to be researched. Past records and documents also have to be reviewed and compared. It is probably safe to say that MOST of the public is completely unaware of the process:
188 PAGES of Environmental Assessment to wade through, digest and assess. It goes on and on, like a game of chess:
Click to access Preliminary_EA.pdf
U.S. Department of the Interior
Bureau of Land Management
Preliminary Environmental Assessment
Jackson Mountains Wild Horse Gather
APRIL 2012
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i guess they didn’t heed judge mckibben’s warning in court. jerks. please~please publish their names. darn low mustangers.
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Debbie Coffey,
For the record, you are one of my journalistic heroes. You just may be the best investigative reporter in America right now. We just need to clone you.
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Thanks, Hoofhugs! We are all learning from each other, and the more we learn, the stronger our voices become.
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these people r nut why can’t people stop this! what has happen to this world .God help them and stop this crazy stuff from going on
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The livestock contractor and every BLM worker should experience the hot shot where the sun doesn’t shine so they k.ow how it feels. Maybe these cow people wouldn’t be so accepting of the practice :
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Litters? I questioned their misguided math. Where did these boys n girls go to school?
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Terri-
They went to “finishing school” at BLM and those teachers (literally!) tell them that if they want to keep their jobs and medical and retirement then they will say exactly what they are TOLD to say … regardless if it is a fact or not … and even more often they are told to look the other way and say nothing … because if they don’t admit to seeing corruption then it would have to proven that they did see it in a court of law in order to be proven guilty. That’s my opinion from my observations and personal experience with BLM.
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What kind of morons come up with these ridiculous figures? Do the so-called “powers that be” actually think anyone would believe this? Even non-horse people, if told that a mare can give birth to ONE foal a year, would question this kind of math and science.
If these poor wild horses were cloning themselves, their numbers couldnt explode in the numbers these morons are putting out there.
Debbie, you deserve much credit for all the work youve done on this!
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