by Guest Columnist Nell Walton ~ founder/editor of AllHorsesPost
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:
http://www.blm.gov/nv/st/en/fo/wfo/blm_information/nepa0/wild_horse_and_burro/Augusta.html
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.
Sincerely,
Nell Walton
Categories: Horse News, Wild Horses/Mustangs
Straight from the Horse's Heart 
Why can’t we use the “Freedom of information act” to obtain these documents. All documents. That is our right & they know it!
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Nell, THANK YOU. It would be good for all memebers of the ASPCA to also comment in this EA. It is time that the public becomes much more aware of these documents and the process (or lack thereof) in the decision making. These are, after all, OUR WILD HORSES, OUR WILD BURROS and OUR PUBLIC LANDS.
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Problem is they are doing a really lousy job of posting when comment periods open, although they are required to by federal law. They aren’t even including the opening of comment periods in the RSS feeds from the various states and I am raising hell about that. I am also being requested to be listed as a “newsletter” that they are required to notify of comment periods, and I have talked to RT about doing the same. When I hear back from them I will let you know what they say. This is total BS.
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It sure is a bunch of BS, Nell. I already read and commented on this excellent response on the ALLHorses web site.
I will respond to them too, although I’m beginning to wonder why.
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Nell,
Would you mind checking on something for me? On the BLM site for the Augusta roundup, their letter says comments must be received within 30 days and their letter is date stamped Oct.6th and the month of October has 31 days. So… are we sure that they will accept comments through the 6th of November??? My guess is that we had all better get our comments sent in by the 4th or 5th or better yet …”today”. I don’t want our comments being “immediately tossed” because of the date. Thank you.
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You made a great letter with so many good points. This is the type of letter that the BLM should really look at for constructive ideas but I wonder if they will. They are very quick to have their prescribed acceptance letter and if one word is not right I’m sure it gets filed in the cylindrical file next to the desk on the floor. Good luck with your letter and will use some of this for my own.
Thanks!
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@Lynette – this is one thing that the judge brought up in his denial of the TRO in New York – we have to have a record that we have made comments for any legal proceedings going forward.
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send snail mail as louie has been doing..there is a paper trail then..the only response I have received is when I do it that way too..ny e-mail submissons have not been acknowledged
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Sandra, are you in Oregon? I’m over in Western OR, SE of Portland. Please consider me as a resource if you need an extra pair of hands, feet, etc. I’m new to this but I catch on quickly. : ) karenoregon@yahoo.com
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Hi, Karen-I am in Bend-and happy to find anyone out here who wants to be involved..will be in touch!
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I will resent the email I just sent with a return receipt requested.
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Well done, Nell.
I always ask for a receipt and sometimes do and sometimes don’t get one but all correspondence of this kind needs to say: “receipt requested”.
When I don’t get one, I should actually follow up and send again and ask for a receipt again until I finally get one (resending the original letter with the original date) noting that I had previously sent it and had not received an answer yet … or something like that. I do believe that technically an email can be used in court since it is dated on your computer as to date sent and content?
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They can definitely be used in court – don’t I know it………
If anyone wants to read about my own legal battles in Federal Court, the info is here in an old blog. http://whistlersear.wordpress.com/about/
5 years this case took. And we lost…….
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There were over 10,000 comments on the disastrous Calico Massacre/Round-up
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Perhaps, with each of these comments copies should also be sent to the President and to David Axelrod. 10,000 comments sent to them would be good.
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10,000 comments is a good goal to shoot for, but you guys need to spread the word around. I have posted on a lot of websites (forums), but it is usually hard to get people to do this – immediate resistance because they see a 60-200 page document and just think its too much work, plus they need to understand how critical it is……
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Nell, you are so right. It needs to be SIMPLIFIED and reduced to the lowest common denominator. At the BASE, it is VERY SIMPLE–made to look complicated so as to confuse and discourage. Break it down and present in,clear, concise language–not government mumbo jumbo.
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We could do that here and on these blogs. Post a template for people to follow–like is done on the various petitions. They can read and assimilate those and then make their own evaluations and comments. Take these things apart and examine them–let everyone add their thoughts–we do that on everything else.
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I see the problems in every EA as follows:
1) population and enviromental damage of all large grazers are not thoroughly evaluated
2) Cattle/sheep are not actually counted – but based on grazing permits per head (as far as I can tell)
3) technological solutions are not pursued
4) passive trap is never considered
5) BLM sees public as more of a nuisance, and takes steps to avoid communication and transparency, they don’t get that they work for us
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Nell, this sure is a piece of work! When I wrote my first EA comments, I responded point-to-point, which ended up being about 8 pages in Word. Now most are about 4. I save them all to refer to, since most of the EA language and formats are pretty much the same.
And I totally agree that there’s ABSOLUTELY no way for these EAs to be correct or for us to respond to them in a meaningful way unless ALL impacts to the HMAs are part of the same document. I ask for this every time.
My pet peeve – grazing and browsing wildlife – deer, bighorns, pronghorns, and especially ELK (out-of-control in many areas). I want to know the census, have AMLs established for each species and projections on population growth, and removals (to the LOW figure) when they exceed the AML, etc., the same as for the wild ones . No dice so far.
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I realize it’s important to comment, but seriously…does it ever make a difference with the killers? It seems so futile, but as someone mentioned, we need a paper trail.
There have been some suggestions, but I can’t even get my Fed reps to acknowledge the content of my letters, much less a written reply.
The DOI is cheating on this comment period crap and I don’t know how we can physically and realistically prove it, other than not one comment has ever changed or atopped a planned roundup that I know of. It’s almost like we need to have a national advocate, centralized clearing house for all our comments and letters to reps….and that takes bucks and committed full-time workers.
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Actually – individual comments are much more effective. If they get enough of them they have to do something. Twin Peaks listed their comment count, and also in the Wyoming EA for the more recent gathers they also listed them. So, they are reading them, but from what I gathered from reading both documents there were very few challenges to the science – at least, they didn’t report them if there were. IF enough people participate, it will have an effect, and in any event it is just a dull task that has to be done, but the more people that do it, the better.
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Like water on a rock
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@Louie – Grand Canyon is proof that the method does work……..
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Sandra can relate more about one of the Oregon round-ups. She attended and dispensed a GREAT DEAL OF INFORMATION to the observers, as well as the onsite BLM employee, who was cordial and professional. Our comments did make a difference there.
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In today’s paper – Val Kilmer just dropped the asking price for his 5,328-acre ranch near Santa Fe by $10 million. It was first listed for $33 million, now $23. That’s a little over $4,300 an acre. Still cheap for the Santa Fe area, but $235 and acre is a whole lot cheaper. Even if NM does nothing more than buy the land and sit on it, the state would be STUPID to pass this up.
BTW, there’s an acre in Farmington that just listed for $120,000. No house, just land. YIKES!
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Does Val come with the ranch???
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You don’t want him to. Trust me. 🙂
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Kilmer’s ranch would be so ideal for wild horses. I sold him a couple of horses, and we rode the ranch a few times. There’s endless water, an amazing variety of geological features, trees and cliffsides for protection from the weather, etc. It would be awesome if NM bought that for this purpose. Maybe neighboring Forked Lightening Ranch would agree to allow the horses to roam there, too.
Maybe some letters of encouragement to Gov. Richardson?
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Love it, Elaine – your comment about Kilmer. Anyway….. I’ve been writing encouragement to Gov. Richardson, but I’m not from NM.
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Off-topic – Yesterday the USGS released findings that Alaska’s North Slope contains less than one-tenth the amount of oil previously estimated. Maybe the polar bears and other Arctic wildlife will get some kind of break on this one, if only for a while.
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IT IS VERY IMPORTANT THAT EVERYONE UNDERSTAND THAT ALL GOVERNMENT AGENCIES AND OFFICIALS PAY MUCH MORE ATTENTION TO LETTERS RECEIVED IN THE MAIL THAN THEY DO TO EMAILS OR PETITIONS. I worked as a personal liason for a State Senator, as well as being involved in a HUGE precedent setting legal case that took nine years and finally WON at Supreme Court level. I am also a certified equine appraiser and legal consultant in horse-related cases. In EVERY case, letters that were mailed to officials had a great deal more weight than emails or petitions. Emails are considered akin to junk mail, while signed, original, paper letters are kept, filed, and often used for quotes or to verify public concern.
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@elaine – I faxed mine also.
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Perfect! 🙂 We need to bury them in paper.
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When we get done cleaning up this mess, we’ll work on the Court system–lot’s of work for active, involved citizens to do
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I just found this (see below)!
Many of us have asked to see the midwest long-term holding facilities and here is our chance. I know some of you are “credentialed media” and I hope you can go. This information is on the BLM website “news release”. I know that this visit will be “staged” but still worth the trip and photos. The only information I have of “long-term” facilities is of the three-strikes ranch … and we know that was really bad … so I know anyone who can go will be prepared with some “really good” questions for Debbie Collins (your tour guide) since she is one of the PR people for the National WH&B “Team” (marketing specialist) … and has gone to some roundups and supposedly visited Honey Bandit, so I would not be surprised that you will hear and see the sugar-coated version of the truth … but YOU know the real truth and can ask the real questions … and perhaps ask her about some of the animal abuse that is documented on video and why they won’t let us put a “horse-cam” on the helicopters and many other transparency questions. Good luck!
BLM Announces Media Tour of Two Long-Term Wild Horse Holding Pastures in Midwest
The Bureau of Land Management announced today that it is hosting an all-day tour for credentialed media of two long-term holding pastures in the Midwest. The tour will take place on Tuesday, Nov. 9, at wild horse holding ranches in Pawhuska and Foraker, Oklahoma, both located within two hours of Tulsa.
The BLM estimates that approximately 38,400 wild horses and burros are roaming on BLM-managed rangelands in 10 Western states, based on the latest data available. Wild horses and burros have virtually no natural predators and their herd sizes can double about every four years. As a result, the agency must remove thousands of animals from the range each year to control herd sizes.
Off the range, there are 37,800 other wild horses and burros that are fed and cared for at 19 short-term corrals and 16 long-term pastures. (As of October 2010, there are approximately 11,400 in corrals and 26,400 in Midwestern pastures.) All wild horses and burros in holding, like those roaming the public rangelands, are protected by the BLM under the 1971 Wild Free-Roaming Horses and Burros Act.
BLM staff will meet credentialed media at 8 a.m. on Tuesday, Nov. 9, in the lobby of the Hilton Garden Inn Tulsa Airport, 7728 E. Virgin Court, Tulsa, Oklahoma (phone number: 918-838-1444). It will take about an hour and a half to drive from the hotel to the first of two long-term pastures. BLM staff will escort media representatives to the ranches; ranch owners have declined to be interviewed.
To RSVP, please e-mail Debbie Collins at Debbie_Collins@blm.gov or call her at 405-790-1056. Responses by Friday, Nov. 5, would be appreciated
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I saw this on Facebook also and posted a comment about when will “credentialed media” and the public be allowed to view the horses at short term holding like Broken Arrow. I wonder what there idea of “credentialed media” is—probably not blogs where most of us get the “real” information now.
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Yeah, I’ll bet the ranch owners have ‘declined to be interviewed’- after some heavy handed pressure from BLM. “Shut your mouth or lose the big fat gravy train that we just put you on.”
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Gee! I thought our publically owned wild horses and burros on privately owned concentration camps were off limits to the bill paying public. Something change?
It brings new meaning to the proverbial “dog & pony” show.
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OMG … does it never end!
Just found this on BLM “News Release” (I guess we need to be checking this more often) regarding upcoming Oil and Gas lease of our land in California. In the release it says: “BLM is required by law to periodically offer federal land for lease for oil and gas exploration and development.”
I know nothing about the leases of our public land to the energy hogs … but is their statement true? Are they REQUIRED by law to do this?
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YEP!!!! But they are required to assess with a multi-use intent (that’s the law too). We all know they don’t. The wild equines are on the bottom of the “use” list…last to be allowed to stay (if at all), first to go.
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Nell,
I forgot to say, “very good letter”!
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