Original Story by Debbie Coffey as seen in the PPJ Gazette
Special Interest Group Disregards Public Opinion
Banner from America’s Wild Horse Advocates (AWHA) with Melissa Ohlsson, Vice President of AWHA as artist
After reading the Federal Register notice (Sept. 6, 2011) announcing the next Wild Horse and Burro Advisory Board Meeting in Arlington, VA, Oct. 13-14, 2011, it seems that the “Public Comment Procedures” as written here may be in violation of your First Amendment right to free speech.
The notice states that “Speakers must submit a written copy of their statement to the address listed in the ADDRESSES section above, or bring a written copy to the meeting.”
Why “must” you do this? It’s a public meeting and you don’t have to submit anything to have the right to speak at a public meeting. You can just tell them your name and tell them you want to speak. Period. The meeting will probably be recorded and the BLM could use the recording for transcription purposes, and any requested written comments should be voluntary. That is not what is stated in the Federal Register. Also, requiring that speakers submit a written copy of their statements could discourage some people (who don’t like to write) from speaking.
You also don’t have to “address the specific wild horse and burro related topics on the agenda.” This is a violation of your First Amendment right to free speech. You can talk about anything you want to talk about. If you want to get up and read “Little Bo Peep” for 3 minutes (or whatever time limit they set), you have the First Amendment right to do that. If the BLM only wants you to talk about topics on the agenda, and then controls the agenda, they could then possibly control the content of public comments, which might then be against your right to free speech.
The notice also states “The BLM considers comments that are either supported by quantitative information or studies or those that include citations to and analysis of applicable laws and regulations to be most useful and likely to influence BLM’s decisions on the management and protection of wild horses and burros.”
Why do we have to include “quantitative information or studies” with a comment or opinion for it to be “most likely to influence” the BLM?
The public has been sending reams of “quantitative information” in public comments to EAs for the roundups, and to Congress, and it obviously hasn’t influenced the BLM at all. Nothing has changed. There is no “new” normal. Your opinion should be considered valid, and considered seriously, without having to site a regulation. You may have more knowledge about a particular subject, or pay more attention to details, and/or ask more questions than many BLM employees.
Many BLM Wild Horse and Burro “Specialists” were Range Specialists prior to “specializing” in wild horses. Do you think there’s a big difference between knowing about weeds and knowing about wild horses? What type of training program does the BLM have for Wild Horse & Burro Specialists? Could the BLM please provide us with some “quantitative information” regarding this at the upcoming Advisory Board meeting?
What training do the WH & B specialists undergo? What qualifications do they need to have in order to become Wild Horse & Burro “Specialists?” Did they ride in a rodeo? Did they ride a horse on a cattle drive? Or did they just see a photo of a horse in a book? It seems like bestowing the title of “Wild Horse & Burro Specialist” on some BLM employee in a field office is akin to you just declaring yourself “Queen for a Day.”
“The BLM will not necessarily consider comments received after the close of business on October 13, 2011.”
BLM Bored Member during March 2011 Advisory Bored meeting ~ photographer unkown
The BLM apparently hasn’t considered, or has just ignored, thousands of comments received over a period of many years. The BLM only seems to respond to lawsuits or public relations nightmares (when the public becomes aware of what seems to be their mismanagement, lack of transparency, and the mistreatment of our wild horses that they’re supposedly “protecting”).
And someone, apparently, needs to set a moral compass for this agency that has denied any wrongdoing and condoned the conduct of Sun J helicopter pilot Josh Hellyer, who apparently made contact with a wild horse using the skids of the helicopter, or at the very least, flew dangerously close to the exhausted horse. After Reno Judge McKibben viewed Laura Leigh’s video of this, he granted a Temporary Restraining Orderfor the use of the helicopter at the remainder of the Triple B roundup.
Our tax dollars might be paying for the rental of the Advisory Board meeting room at the Hyatt Regency, and possibly for the hotel rooms for visiting WH & B Advisory Board members and visiting BLM employees. If Dean Bolstad is attending on Thursday or Friday, it’s a work day, and his time is on your dime. Taxpayers pay BLM employees’ salaries, including Edwin L. Roberson, Assistant Director, Renewable Resources and Planning, whose name is on this Federal Register notice. Our tax dollars pay for the Wild Horse & Burro Program. You’re the taxpayer. You’re the boss. The BLM is accountable to you. Not vice versa.
It also seems as if the BLM chose a time and place where they would get the least public attendance at the WH & B Advisory Board meeting. http://www.gpo.gov/fdsys/pkg/FR-2011-09-06/pdf/2011-22626.pdf
BLM employees seem to read the blogs and websites of horse advocates, so it was likely that they were aware that a couple of weeks prior to the now scheduled Advisory Board meeting, major horse advocacy groups were hosting the International Equine Conference in Alexandria, VA (Sept. 26-28, 2011), including experts from Equine Welfare Alliance and Animal Law Coalition. This Conference was announced July 11, 2011, and the WH & B Advisory Board meeting notice was dated August 29, 2011. It would likely be too expensive for people from horse advocacy groups to attend both this Conference and the WH & B Advisory Board meeting, which seems to show both a lack of foresight and consideration in BLM’s planning.
If the WH & B Advisory Board really wants knowledgeable input to influence BLM decisions, these are the people they should be listening to. Will any of the WH & B Advisory Board members be attending the International Equine Conference? Will BLM’s Dean Bolstad and/or BLM Dir. Bob Abbey be attending all of the sessions? To my knowledge, Bob Abbey hasn’t ever attended one roundup or equine-related function.
This Advisory Board meeting has been set on a Thursday and a Friday, which are work days, guaranteeing the BLM that even fewer members of the public might be able to attend.
Why is the WH & B Advisory Board meeting inVirginia? Most of the members of the public who are affected by the loss of wild horses in the areas where they live, and who have attended the roundups, are in the western states. And wouldn’t it be less expensive if this meeting were held in Reno?
WH & B Advisory Board members are appointed to their position by the President. Yet, it seems that only one Advisory Board member, Tim O. Harvey, has ever attended a “gather” (for one week at the Twin Peaksroundups). You’d think the other Advisory Board members would actually want input from people who have observed the gathers, in many locations, and by different contractors. In detail. It seems the BLM wants to limit the details on public record as well as any input to be considered in making their future decisions.
Maybe BLM’s Ed Roberson should think about setting up some meeting parameters for the Wild Horse & Burro Advisory Board members, like staying awake during the meetings.