Comment Period on Augusta Mtn Stampede closes 11/6
The BLM’s comment period for the Augusta Mountains HMA Preliminary EA for a Wild Horse Gather closes on 11/6. Please take the time to email your comments to Jerome Fox at AugustaMts_HMA_PrelimEA@blm.gov (mailing address and fax are in the letter). This plan is to capture 344 horses, including 50 outside the HMA. Mares captured within the HMA are to be treated with the contraceptive PZP-22 and released, the 50 horses outside the HMA are to be removed to adoption facilities.
The Preliminary Environmental Assessment Augusta Mountains HMA Wild Horse Gather Plan and letter can be viewed at:
I spent several hours reviewing this plan and here are my comments. If you want to use these as a template for your own comments feel free, but please limit the use of copy and paste as the BLM seems to ignore “form” letters.
Dear Mr. Fox:
I would like to take this opportunity as an American taxpayer to comment on the Preliminary Environmental Assessment Augusta Mountains HMA Wild Horse Gather Plan, DOI-BLM-NV-WO10-2010-0013-EA, due 11/6/2010. I understand that this gather would be conducted primarily for PZP-22 contraception purposes.
After thorough review of the document I found many problems with methodology that I would like to see addressed prior to any gather of wild horses and/or burros that reside in the Augusta Mountains HMA.
First, I would like to voice my frustration in that obtaining access to the original documents used to determine Wild Horse and Burro AMLs is extremely difficult, if not impossible at times – the document you refer to has a date of 1982, and I can find no scanned version anywhere on your website for review. Every EA and EIS I have reviewed constantly refers to these AMLs – but these statements are ALWAYS accompanied by a caveat of “these were determined in a prior decision making process and will not be addressed in this Environmental Assessment,” or something similar. These references are circuitous and put the complete burden on the interested party (again an American taxpayer) to conduct an often fruitless and time consuming search to try to find the hows and whys and whens in regards to these original AML decisions.
Additionally, the compartmentalizing of wild horse gather plans, apart from the other “multi-use” activities that also are occurring in the HMAs fails to provide an interested party with a holistic picture of what IS going on in the areas designated for wild horse and burro use. For example, it would be of great help to be able to compare livestock populations utilizing the same area, mining permits (both those that are current, non-current, reapplied and applied), and other minerals activities that are going on in the HMA etc. I am assuming that every BLM office has a summary of all current and future multi-use activities and projects in their management area – short summaries that could be added to an EA, or a link provided to a document on the BLM’s website – on that has a brief list of ALL activities.
And, it is also extremely frustrating to try to negotiate through this maze of decision making and documentation, when every BLM HMA seems to apply different methodology and reporting on how they reach their decisions to remove wild horses – as was confirmed by the General Accounting Office (GAO) in 2008 as being a problem; a problem that was SUPPOSED to have been remediated according to the Secretary of the Interior.
These above issues are my overall problems in general with every BLM EA I have read. I will address my more specific issues with this preliminary EA in regards to the Augusta Mountains HMA gather plan as follows:
- While the models and graphs in regards to population growth are far more detailed than the other wild horse gather EAs I have reviewed, it is troubling to see that yet again, the default number of approximate 20% increase in population for wild horse herds is repeated over and over again. When I see that number, it raises suspicions that no real field work has been done, and the individuals who wrote this preliminary EA are just depending on a number from a study/population model whose accuracy has been called into question many times.
- On page 8, under the “Alternatives considered but dismissed from detailed analysis” 2.4.1, “Water and Bait Trapping,”, I find it puzzling that this has been taking “out of the equation” so to speak, when I see that this area “contains few wetland and riparian resources” (Page 12) and on page 20 that: “Currently Home Station Wash shows heavy horse use during summer and fall months. ….”Clearly, water traps seem to be a very viable option in this HMA, since there are apparently so few places for wild horses to obtain water. It would also stand to reason that any fertility interventions (PZP etc.) could be employed at this time with proper planning. It certainly would be less stressful for the horses than the current methods employed during the “gathers.” And, with the growing interest of the American public as far as what IS happening with our wild horses, the BLM could probably have humane associations provide volunteers to help with efforts such as this. I think this is a path that needs to be pursued more aggressively with input and help from the public, and not “eliminated from detailed analysis.”
- On page 8, again under the “Alternatives considered but dismissed from detailed analysis” 2.4.2, “Remove and Reduce Livestock from the HMA.” In the first place, the statement in regards to FLPMA i.e. “which directs the Secretary to immediately remove excess wild horses once it is determined excess wild horses exist,” does not apply in this case, as there no excess of wild horses. This gather is to PREVENT an excess occurring, which is apparently not covered in FLPMA. But, I do agree that prevention is better than the alternative, but FLPMA does not apply here, and the statements following that sentence do not really make much sense. In addition, I have the same problem in this preliminary EA that I have in every other gather plan EA (and EISs) I have read. In this EA, I saw no statistics or figures that indicate that population counts of cattle and sheep are verified via FLYOVERS i.e. the same statistical methods used for counting populations of the wild horse herds. So, this reveals that there is no real verifiable science to indicate HOW MANY DOMESTIC LIVESTOCK ARE ACTUALLY UTILIZING THESE AREAS. Of course, there are indications as to how many AUMS are open allowable open grazing times etc., but I am unconvinced that this provides a fair determination of range use. Currently, it seems that the BLM provides allotments for ranches, but (according the BLM’s own website describing its issuance and monitoring of grazing permits) does not independently verify the number of livestock that are running in a particular allotment. Apparently the BLM relies on the individual/corporation that holds the grazing permit to tell them how many head they are running in an allowable area. (I won’t even begin to get into how unreliable that counting method is, especially in light of the fact that grazing permits are basically paid for by the head. If this is not the case, I would appreciate more information on this from BLM staff.) Clearly, in order to determine the impact large grazers are having on an area, ALL large grazer species populations (whether wild or domestic) must be evaluated using the same methodology. This evaluation would include damage to riparian areas, creation of trails and hoof action damage to soils etc, as it appears that this damage is currently 100% attributed to wild horses in this EA. It seems that given current technology, riparian and other areas that are at risk could be monitored via relatively inexpensive wildlife cameras, instead of relying on “sitings, hoofprints and manure” to make the determination that wild horse herds are causing the majority of the environmental damage in a particular location that other large grazers also utilize. I also believe that having camera evidence would go a long way to convince wild horse advocates that the BLM is doing a thorough and balanced job in the field of comparing environmental damage done by domestic livestock as compared to wild horses and burros.
- I see that 50 horses that have strayed outside the HMA are to be removed to either short or long term holding. If this proposal is approved, I would like to see language specifically stating that these horses are covered under the WFRHBA, and are not classified as “estrays.”
- On Page 33, the report describes in details how changes in the environment can impact the health of wild horse and burro herds, leading to catastrophic illness, suffering and death. In nature, it is the environment that always determines species survival. But, even in light of this, one must take into consideration that for humans, seeing animals, especially animals as beloved as wild horses, suffering and dying can be unbearable for many people, including many BLM field personnel I’m sure. So, in environmental emergencies, it seems that a pre-emptive use of the passive trap method would be highly effective (especially in the case of water – as this seems to be the resource that is the most in contention), and remove animals at either for adoption, or relocation to another more suitable area to PRIOR to the situation deteriorating in suffering, illness and death of the horses.
- I would like to see field research on the effects IN THE FIELD of PZP-22 contraception, including any significant changes in behavior, impact on herd dynamics etc.
- I also feel that any gathers or interference with wild horse and burro herds from any area prior to doing a thorough study of the environmental impact of domestic livestock grazing is not what the American taxpaying public wants or will continue to tolerate.
Thank you for allowing me to comment on this preliminary EA.