Urgent: Eagle Lake Field Office “Rush Fire Emergency Stabilization and Rehabilitation” EA DOI-BLM-CA-NO50-2012-45-EA

Open Letter from Wild Horse Freedom Federation to the BLM


To: BLM_CA_Eagle_Lake_FO_Email@blm.gov, kcollum@blm.gov and d65wilso@blm.gov

Wild Horse Freedom Federation submits the following comments:

Wild Horse Freedom Federation is urging no action (Alternative B) until a complete EA in compliance with NEPA or an EIS is submitted for public review.

The BLM has offered the public only 2 alternatives, either one plan (Alternative A) or no action (Alternative B).  This EA is incomplete for offering only two alternatives, and for the reasons cited below, and contains incorrect, conflicting and skewed information.

Comment on 1.2 Purpose and Need
The “emergency” is moot.  The fire is over.  When the BLM decided to let the fire burn (actually telling local residents in advance the date when the fire would be put out) the fire stopped being an unexpected event, and then became a planned (and thus, controlled) fire.  The backfires started by BLM were not always used to stop the fire, but to clear certain areas.

The BLM made decisions that were not only extremely detrimental to the “productive capacity” of the Wilderness Study Area, but impaired wilderness characteristics, watershed function and ecological processes.
The BLM can bypass NEPA to control the immediate impacts of a real emergency that are “urgently needed to mitigate harm to life, property, or important natural, cultural, or historic resources,” but in the Rush Fire, the BLM violated many of the laws listed in this EA and it’s mandate to ensure a thriving natural ecological balance, with a “let it burn” policy that created this supposed “emergency.”

The multiple use mandate does not excuse the BLM from taking a hard look at the effects of its actions.

Before getting to specific topics in the EA, comments regarding this EA as a whole are:

This EA is incomple because it does not include a map of the livestock grazing allotments.

This EA is incomplete because it does not include a map detailing where the highest concentrations of noxious weeds are.

This BLM EA doesn’t address the fact that a main cause of noxious weed infestations is, and will continue to be, livestock grazing, which disturbs the soil and gives noxious weeds a foothold, even though Table 3.5 on page 55 of the EA notes that casual factors for livestock grazing allotments not meeting the standard for upland soils and biodiversity ARE “livestock grazing” and “historic livestock grazing.”

This EA is incomplete because the maps only include every other township and range number on the maps.

This EA is incomplete because the maps don’t indicate all of the private property that is indicated on the BLM 30×60 minute series (topographic) maps for Eagle Lake and Gerlach.

The BLM’s incomplete data inhibits public comment.

Comment on 1.5 Authority, Laws, Regulations and Other Plans:
With the proposed action of this EA, the BLM will be in violation of the Wild Free-Roaming Horses and Burros Act of 1971.  Wild Horse Freedom Federation has carefully reviewed the photographs of an independent aerial survey of the Twin Peaks HMA taken after the Rush Fire, which were also directed to the attention of Ken Collum, Field Manager of the Eagle Lake BLM office, which prove that less than 400 wild horses remain.

The BLM’s few photographs and maps using only dots in this EA are not proof positive, and we believe BLM’s inventory numbers and claims of 1,324 wild horses are grossly overestimated.  Wild Horse Freedom Federation believes any attempt to remove wild horses from Twin Peaks will wipe out the last of the remaining wild horses on this HMA and be the total eradication of this one “use” in BLM’s multiple use mandate.

The BLM was in violation of the Wilderness Study Area Manual 6330, for not ensuring a thriving natural ecological balance.  While this EA proposes to only reduce livestock grazing temporarily, the planned removal of wild horses will be FOREVER.  The BLM will not ensure, but eradicate, an entire part of the thriving natural ecological balance.

Comment on 1.5.1 Environmental Assessments, other BLM Documents:
This EA is incomplete because it is tiered to EAs and documents that are outdated and obsolete.  Some documents listed in this section are dated 1998 – almost 15 years ago!  Since then, other uses have been approved in this area.

Comment on Map 4 Location & Distribution of Wild Horses & Burros (page 23)
This map doesn’t indicate how many horses each dot represents, as other BLM aerial survey maps have done (for instance, 1-10 horses would be one color dot, 10-25 horses would be a different color dot, and 25-50 horses would be another different color dot).The photographs on pages 70-72 of this EA do not specify GPS coordinates or the exact date the photo was taken.  Most notably, Photograph 1 at the top of page 70 looks like it has been “photoshopped” or altered in some way – if you look at the bottom, right side of this photo, you will see a rectangle like a photo was placed on top of another photo, and the bottom edge of this area is straight (it looks like the green grass cuts off in a straight line).If this photo was altered without notifying the public, this EA is fraudulent.   Also, Wild Horse Freedom Federation notes that there are no more than 10 horses in any of the photos in this EA, and that the BLM did not indicate if any of these photos contained the same horses.BLM could have just “cherry-picked” these particular photos to make it seem like there is “not enough forage.”Comment on 2.1.3 Invasive Plant Inventory and Treatment

The BLM does not specify (or disclose to the public) in this EA, what chemicals will be used. The BLM has not fully explored the effects of herbicide use on endangered animals, including sage grouse.

The BLM has not informed the public if it will distribute the herbicides using aerial spraying (in which BLM essentially carpet-bombs the land and water with toxic chemicals), or if BLM employees will find the weeds out in the field and spray them directly using tanks carried on all-terrain vehicles or backpacks. This EA also doesn’t include any requirements that the BLM explore other options for removing noxious weeds first, before aerial spraying. BLM should hand-pull, mechanically remove or burn weeds where possible.

Comment on 2.1.5  Protective Fence

Permanent Fence (page 18) and Map 3 (page 19) indicate that out of the 315,577 acres burned in the Rush Fire, the BLM plans to use American taxpayer’s money to build at least one permanent fence on PRIVATE PROPERTY.  For instance, it looks as if the bottom permanent fence on Map 3 is right on private property in the Smoke Creek Ranch area, and not on public lands.

At least one other part of the permanent fence seems to be in areas that would benefit grazing areas for privately owned companies (for instance, John Espil’s Sheep Company and Clark’s Valley Land & Sheep Co.)

On page 13, MAP 2, the 2012 Rush Fire Seeding Sites, out of the entire 315,577 acres that were burned in the Rush Fire, the BLM has selected to have American taxpayers pay to reseed areas including PRIVATE PROPERTY and areas around a powerline.

Comment on 3.10 Wild Horses & Burros

BLM plans to PERMANENTLY remove wild horses & burros, while only temporarily reducing livestock grazing “until vegetative establishment objectives are met.”  This may be less than 2 years.

The BLM claims a reason to remove wild horses & burros is there is not enough forage for to sustain them.  Per maps, less than 1% of the 315,577 acres burned in the Rush Fire were severely burned.  Some areas were not burned at all.

BLM did not address ANY NATURAL regrowth of vegetation in this EA.

The BLM also claims a reason to remove wild horses & burros because there is not enough water for them.  This is contradictory to BLM’s other assertions within this same EA, in section 2.1.11, which indicates there is increased watershed flow and water catchments.

Wild Horse Freedom Federation, after examining independent scientific research, believes the BLM has overestimated the population inventory of wild horses & burros, and that any attempt to remove them will permanently eradicate this “use” from their federally protected Herd Management Area.

Comment on 3.12 Recreation Facilities & Human Safety

On page 77, what data does BLM have/use to substantiate its claim that there is a “low frequency” of wild horse observation?  What comparison studies have been done regarding/differentiating wild horse observation from, for example, wildlife observation?

Has every single member of the public who has gone on public roads or onto public lands been obeserved by the BLM or reported to the BLM why they went where they went or what they went to observe?  Does the BLM not consider wild horses & burros to be part of the thriving natural ecological balance?<

Again, and lastly, Map 1, on p. 3 of the EA, shows areas within the fire perimeter of “no burn”, light burn, moderate burn, and severe burn, but the great majority of the fire area is shown as no burn or light burn, with a minor amount of moderate burn and almost no severe burn (severe burn shows as only a small fraction of 1% of the fire area)., and there will soon be, if not already, natural regrowth, so the BLM should not remove any of the wild horses & burros, or adjust their current AMLs.
Wild Horse Freedom Federation

11 comments on “Urgent: Eagle Lake Field Office “Rush Fire Emergency Stabilization and Rehabilitation” EA DOI-BLM-CA-NO50-2012-45-EA

  1. As always a clear concise report offering plenty of ammunition for public comments. Comments that might get read but in reality will mostly be ignored unless each of us write a similarly clear message void of nasty language or name calling. Just present the facts as R.T. did. If enough of us do that it will probably get some attention.

    One inside source tells me that we must keep up our vigil because management is starting to feel the pressure. At no time has the agency been under such scrutiny. They can’t scratch their ass without someone reporting it to the public or someone taking a picture or video of them doing it. The internet has brought us closer than ever to a concerted effort to fight for the rights of the animals and ours as their owners. We should take every advantage.

    We all have to participate. Thanks to R.T. for providing the fodder. If done correctly this could stop the Twin Peaks Roundup.


  2. Great thought and research was put into this letter and thank you to Wild Horse Freedom Federation. The comments are due tomorrow, Tuesday December 18, 2012.

    Bureau of Land Management
    Eagle Lake Field Office
    Attn: Ken Collum
    2950 Riverside Dr., Susanville, CA 96130

    May I add that this BLM EA says over and over again that they must capture the WH&B “to prevent the horses and burros from succumbing to starvation …” This is political garbage to justify their already-made decision and violates the NEPA law that requires valid facts be provided to the public.

    I have been to Twin Peaks and Buckhorn HMAs since last summer’s fire and the fire burned in a patchwork pattern which left plenty of forage for the WH&B and wildlife plus forage had already started re-growing plus there were very few WH&B to be found (their population inventory is complete hocus-pocus) plus the ones we did find were healthy plus I have many many photos of the WH&B taken as recently as Thanksgiving weekend and these photos show that ALL WH&B that were found are FAT AND HEALTHY.


  3. I am making a correction for RT on the above comment until he is able to do so in the article. The sentence that “only 9% of prime habitat for wild horses & burros was burned within the Herd Management Area in the Rush Fire” referred to only one HMA, so the correction is the following:

    Map 1, on p. 3 of the EA, shows areas within the fire perimeter of “no burn”, light burn, moderate burn, and severe burn, but the great majority of the fire area is shown as no burn or light burn, with a minor amount of moderate burn and almost no severe burn (severe burn shows as only a small fraction of 1% of the fire area).

    Debbie Coffey


  4. Excellent criticism of this very tendentious EA that purports to justify the wholesale reduction of those remaining Twin Peaks wild horses. This is a sly and ill-willed plan by our supposed public servants to accomplish their agenda to further eliminate the wild horses from the public lands. All the while they will claim that they are rescuing the wild horses from starvation. What a bunch of blankety blank! In fact these hypocrits are setting the wild horses up for a miserable roundup and enslavement, concentration camp conditions of suffering and death, and very possible death shortly in the maniacal slaughter plants of Mexico or Canada, or, if the likes of Sue Wallis have their way, right here in our country. We wild horse advocates must stand up and stop this blatant subversion of the Wild Free-Roaming Horses and Burros Act of 1971. This law of the land represents the will of the General Public and was passed unanimously by both houses of Congress. I list 19 points of law that must be used to restore the herds in my book, the fruit of over 4 years and really my whole life. Please consider getting this or if you have it already getting it as a gift for Christmas/Hanukkah/New Year. It is available online at http://www.amazon.com/Wild-Horse-Conspiracy-Craig-Downer/dp/1461068983 and as an eBook with color pictures at http://www.amazon.com/dp/B009XJ64P4


  5. Simple math…WWP wins with water and avarian species issues, the livestockers have temporary removals (if at all)….but by god…the wild equines are gone and are set to a different standard as the remaining users and vegetation.

    Fairly clear to me that they (DOI/USDA/STATES) are there to eradicate them.

    That is a violation of the 1971….no matter how the scuz squirm their way thru the eventual holocaust.


    • Whoops..think the proper spelling is “avian” (birds).

      And the equines, wild and domestic keep dying.

      And the world keeps beating humans up in power struggles; wildlife dies; water and land is poisoned…and many watch Wall Street…for profit.

      I say it is time to take action to refuse to participate in the Wall Street manure…find your own investment and never buy into B$.


  6. If the horses have to leave so do all the ranchers and livestock. Our tax money must not be used for private property. No tax monies should be allowed for replacing livestock lost during the fire set by BLM. Their livestock budget needs to be cut or they need to be disbanded.. The BLM has mismanaged and destroyed everything in its path. Oust them all.


  7. Admittedly I haven’t read the whole article but I would like to point something out here. Last night on the news they showed the Bay Area rain totals for up to date averages. Every county in the Bay Area is above 100% rainfall since July 1.

    While this may not relate to the Susanville area it does show that we are indeed having a good winter wet snow and rainfall wise.

    Yes, we were dry last year. Well so were alot of other people. You didn’t see horses keeling over, These horses know how to survive, No they won’t be 5’s on the Henneke chart but they have skills to overcome obstacles that would stop most of us from surviving out in the wild. These are not hot house tb’s. They have skill sets that most of us should be observing and learning from. How to live off the grid and be environmentally friendly. If we would apply those skills to us we wouldn’t be fracking, we wouldn’t be drilling for oil, minerals and so forth tearing up Mother Earth for no good reason.

    There is no telling the long term effects of all those chemicals. We see bad side effects now but what about years from now? when children are born with the terrible birth defects. Are those chemicals to blame?

    I’m about to move. Where I live now we don’t have composting. My new home–we have a compost can. It’s a whole new thing for me to learn. And I’m ready to dig in and do my part. No I won’t be perfect and I’ll probably make mistakes. But I want to do my part to be kinder to Mother Earth. And I have wonderful support to help me learn those things. I know its suppose to be easy but living one way for ahem years I now have to set in a whole new skill set. I look forward to this change. I can be kinder and more mindful of what I’m tossing out.

    it comes back to the horses. How we look and see Mother Earth–reflects how we treat not only each other but our wildlife. I don’t like snakes (scared to death of them) and some spiders. But its the mindset that I’m speaking of.


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