Wyoming Wild Horses Fall into the Feds Cross-hairs, AGAIN

Source: Unedited BLM Press Release

(2014) BLM destroying the last of Wyoming's Wild Horses for the benefit of Welfare Ranchers ~ photo taken last week by Carol Walker of Wild Horse Freedom Federation

BLM destroying the last of Wyoming’s Wild Horses for the benefit of Welfare Ranchers ~ photo taken in 2014 by Carol Walker of Wild Horse Freedom Federation

“When it comes to sucking-up to Welfare Cattlemen and violating federal law over the mismanagement of federally protected wild horses and burros there’s nothing like the Bureau of Land Management (BLM) to test the depth of the bottom of the barrel over ethics, legal interpretation and out right lack of any morale compass.

Once again, armed with junk science, bad math, collusion and strange bedfellows the BLM plans to attack the dwindling wild horse herds of Wyoming while our current administration sits with its thumb up its backside as it totally ignors the outrage of the not only the American public, but the world.

Personally, I have had enough!” ~ R.T.


Release Date: 06/09/16
Contacts: Sarah Beckwith
307-347-5207
sbeckwith@blm.gov

BLM Releases Decision for Red Desert Wild Horse Gather

The Bureau of Land Management Rawlins and Lander field offices have released a decision record for an environmental assessment which analyzes a proposed wild horse gather in the Red Desert Wild Horse Herd Management Area Complex.

The Red Desert Complex, which includes the Antelope Hills, Crooks Mountain, Green Mountain, Lost Creek and Stewart Creek herd management areas, is located in Sweetwater, Carbon, Fremont and Natrona counties west and south of Wyoming Highway 287.

At a future date that has yet to be determined, the BLM will gather wild horses in order to return populations to within appropriate management levels, ensure long-term viability of sage-grouse populations within the complex, and administer the PZP-22 fertility control vaccine to mares returned to the complex.

The revised environmental assessment, finding of no significant impact and decision record are available by visiting the BLM website at www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html. The decision is subject to administrative review through the appeal process, which is outlined in the decision record.

Wild horses that are removed will be available for adoption to qualified applicants. For more information about adopting a Wyoming wild horse, visit www.blm.gov/wy/st/en/programs/Wild_Horses.html.

For more information, please contact Mike Calton at 307-328-4200.

The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2015, the BLM generated $4.1 billion in receipts from activities occurring on public lands.
–BLM–Rawlins Field Office   1300 N. Third/PO Box 2407, Rawlins, WY 82301            Lander Field Office      1335 Main Street, Lander, WY 82520

27 comments on “Wyoming Wild Horses Fall into the Feds Cross-hairs, AGAIN

  1. BLM BUREAU OF LAND MISMANAGEMENT WERE DEALING WITH SIMILAR HORSE CRAP FROM THIS CORRUPT AGENCY HERE IN NEVADA …PISSES ME OFF

    Like

  2. Federal Embezzlement Laws
    Embezzling federal money or property is a specific crime, charged in federal district court.
    http://www.criminaldefenselawyer.com/resources/criminal-defense/criminal-offense/federal-embezzlement-laws.htm

    The key is that the defendant had legal access to another’s money or property, but not legal ownership of it. Taking the money or property for the defendant’s own gain is stealing; when combined with the fact that this stealing was also a violation of a special position of trust, you have the unique crime of embezzlement.
    Offenses That Can Be Charged Under State or Federal Law
    Federal Embezzlement Categories and Punishments
    Federal embezzlement laws are broken down by the type of money or property stolen. Here’s a short description of each category, and the associated penalties.

    Convictions whose fines are $250,000 are felonies; convictions with fines of up to $100,000 are misdemeanors.

    Programs receiving federal funds
    Theft of livestock

    This section addresses the embezzlement of livestock, money, or other property worth $10,000 or more, that is connected with marketing or selling livestock in interstate or foreign commerce. Penalties include a fine up to $250,000, up to five years in prison, or both. (U.S.C.A. § 667.)

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  3. In the event that any employee of the Department of Interior / Bureau of Land Management is caught making false statements or concealing information, then they are in violation of Title 18 (18 U.S.C. § 1001). Making false statements (18 U.S.C. § 1001) is the common name for the United States federal crime laid out in Section 1001 of Title 18 of the United States Code, which generally prohibits knowingly and willfully making false or fraudulent statements, or concealing information, in “any matter within the jurisdiction” of the federal government of the United States, even by mere denial
    18 U.S. Code § 1519 – Destruction, alteration, or falsification of records in Federal
    investigations
    Current through Pub. L. 114-38. (See Public Laws for the current Congress.)
    US Code Per the US Department of Justice, the purpose of Section 1001 is “to protect the authorized functions of governmental departments and agencies from the perversion which might result from” concealment of material facts and from false material representations.

    Like

    • Definition of MALFEASANCE

      law : illegal or dishonest activity especially by a public official or a corporation
      Examples of MALFEASANCE
      The investigation has uncovered evidence of corporate malfeasance.
      a campaign to impeach the governor for malfeasance in office>

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  4. HOW and by WHO are the judges for the Wild Horse & Burro lawsuits chosen?

    Well-connected rookie judge to preside over Khattala Benghazi trial
    http://www.washingtonpost.com/blogs/in-the-loop/wp/2014/07/07/well-connected-rookie-judge-to-preside-over-khattala-benghazi-trial/

    Just three months into his tenure on the federal bench, and before his formal investiture ceremony later this week, newly minted U.S. District Judge Christopher “Casey” Cooper has been handed one of the most high-profile and politically sensitive American terrorism cases in recent years.

    Cooper, who was confirmed by the Senate in March, has been randomly assigned by the court’s selection system to preside over the U.S. government’s case against Ahmed Abu Khattala, a suspected ringleader in the deadly attack on U.S. outposts in Benghazi, Libya.

    Cooper, 47, was part of the Obama administration’s transition team and is one of the more connected people in D.C. legal circles. His wife, Amy Jeffress, is a former national security adviser to Attorney General Eric Holder.
    With his father-in-law, Cooper successfully defended senior Saudi government officials in a lawsuit brought by families of victims in the Sept. 11, 2001, attacks.

    Like

  5. Sept. 15, 2015
    Court Gives BLM Green Light to Destroy Colorado’s Historic West Douglas Wild Horse Herd
    Zeroing out entire wild horse herd not viewed as constituting “irreparable harm.”
    https://rtfitchauthor.com/2015/09/15/court-gives-blm-green-light-to-destroy-colorados-historic-west-douglas-wild-horse-herd/

    Today, Federal Judge CHRISTOPHER R. COOPER
    denied a Preliminary Injunction to stop the Bureau of Land Management (BLM) from carrying out its decades old quest to remove the entire West Douglas wild horse herd. Tomorrow the BLM will begin a helicopter roundup and removal of wild horses in and around the herd area with the ultimate goal of zeroing out the herd (area).

    Like

  6. There were decisions made that allowed these roundups to take place
    Those who made those decisions and those who initiated the roundups are responsible
    They should not be forgotten in the annals of history

    ROCK SPRINGS GRAZING ASSOCIATION
    JOHN HAY /President of ROCK SPRINGS GRAZING ASSOCIATION
    JUDGE NANCY FREUDENTHAL/U.S District Judge
    JUDGE HARRIS L. HARTZ/Tenth Circuit Court of Appeals
    JUDGE NEIL M. GORSUCH/Tenth Circuit Court of Appeals

    Like

  7. John Hay at Rock Springs Wind Energy Forum
    John Hay of the Rock Springs Grazing Association discusses land used for wind farms. He supports Tasco Engineering’s Wyoming Wind Energy Project
    JOHN HAY /President of ROCK SPRINGS GRAZING ASSOCIATION

    Like

    • “SOUTH OF RAWLINS”

      Big Wyoming wind farm clears another government hurdle
      http://trib.com/news/state-and-regional/big-wyoming-wind-farm-clears-another-government-hurdle/article_d8485240-39b4-5f70-bd54-31aa1687882d.html#utm_source=trib.com&utm_campaign=%2Femail-updates%2Fbreaking%2F&utm_medium=email&utm_content=read%20more

      One of the biggest wind projects under development in North America cleared another regulatory hurdle Wednesday with the release of a federal environmental study looking at the first-phase installation of 500 wind turbines.

      The U.S. Bureau of Land Management’s environmental analysis tentatively allows planning for the Chokecherry-Sierra Madre wind project south of Rawlins to continue. The agency found no new problems after looking at exactly where the developers propose to put the turbines.

      The document focuses on plans by Power Company of Wyoming, a subsidiary of The Anschutz Corp., to install 229 wind turbines in 2019 and another 271 in 2020

      Like

      • From CASPER STAR TRIBUNE
        The growing battle between Wyoming lawmakers and the largest wind developer in America
        Benjamin Storrow 307-335-5344, Benjamin.Storrow@trib.com
        Benjamin Storrow
        May 19, 2016

        State lawmakers and the developer of the largest onshore wind farm in America are increasingly at odds these days. The subject of their strife: a proposal to raise Wyoming’s wind-generation tax.

        Power Company of Wyoming officials say the measure puts in limbo their plans to build 1,000 turbines in Carbon County. The 3,000 megawatt project — enough to power nearly 1 million homes — will be left at a disadvantage relative to renewable producers in other states, they argue. Wyoming is already the only state in the country with a wind-generation tax.

        The Denver-based company had planned to begin construction on a haul road this year. Now, it is uncertain if that work will begin.

        Wind power can provide benefits to the climate and consumers, said Republican State Sen. Cale Case of Lander.
        But it in a state where tourism provides a significant source of revenue, the spectacle of wind mills dotting Wyoming’s open vistas comes at a cost. Developers should pay to compensate for that loss, he said, arguing the change is permanent.

        “My son, my grandchildren will never see the Wyoming I saw,” Case said.

        Like

  8. Leave the horses and burros alone. If you want to sell the horses and Burris that’s one thing but to move them because the ranchers want to feed there cattle there. That’s bull crap. Tell the ranchers to water there ranches for better feeding on there own property

    Like

  9. GAO Report 1990

    http://www.gao.gov/assets/150/149472.pdf
    GAO found that despite congressional direction, BLM’S decisions on how
    many wild horses to remove from federal rangelands have not been
    based on direct evidence that existing wild populations exceed what the
    range can support.

    BLM could not provide GAO with any information demonstrating that federal
    rangeland conditions have significantly improved because of wild
    horse removals.

    We do not agree with BLM’s position that our statement reveals a misunderstanding about how BLM develops its appropriate management levels, We understand that wild horse levels are prepared as part of the land use planning process mandated by FLFNA. However, we do not believe that a level can be justified as representing a sound management decision merely because it is recorded in a land use plan. If a level is developed without regard to land conditions or wild horse range impact, its inclusion in the land use plan does not make it more useful or appropriate. In this connection, BLM provides no evidence to refute our finding (along with the finding of Interior’s Board of Land Appeals) that wild horse levels are being established arbitrarily without a sound factual basis.

    Like

    • Louie, while that is old info it reminds me of something that remains mostly overlooked in these issues. If removing wild horses is based on FONSI info (finding of no significant impacts) then why the heck remove them at all? If these wild animals are causing the harms described then their removals should indeed result in significant impacts – significant rangeland improvements to be precise. Yet we never see these identified or published. Removals just keep being scheduled like some robot machine which isn’t capable of independent thought or results analysis, only replicating past actions without any attention to results.

      Like

      • IcySpots, Karen Sussman talked this about when she was interviewed on Wild Horse & Burro Radio Show in April.

        There is and never has been any proof that they are the cause of range damage.
        There is NO monitoring validation to prove otherwise

        http://www.blogtalkradio.com/marti-oakley/2016/04/07/ts-radio-wild-horse-burro-radio-guest-karen-sussman-president-ispmb
        Guest will be: Karen Sussman, President of the International Society for the Protection of Mustangs and Burros (ISPMB).

        WILD HORSE REMOVALS ARE NOT LINKED TO RANGELAND CONDITIONS

        ANIMAL PROTECTION INSTITUTE OF AMERICA
        IBLA 89-285, 89-286 Decided October 16, 1990
        Appeals from decisions of the State Director, Nevada, Bureau of Land Management, approving final plans for removal of excess wild horses in the Carson City, Battle Mountain, and Winnemucca Districts,
        Nevada, Bureau of Land Management. NV 03337 and NV N6-89-1.

        Like

  10. http://www.fsis.usda.gov/horses/horses.html look up this Bute test and see why I again smell a Rat. CLG-PBZ3.PDF METHOD NUMBER R26. Reading this I realized they are Testing Kidneys for bute in horses ( only accurate method period) but the ALWAYS test kidneys in BOVINE always kidneys. Read where it shows they test 4-6 kidneys of Bovine but Only 1 of equine muscle samples. Why so low of testing? Why so inacurate a method? They know its not going to be honest testing. The ELISA test is being utilized and other comparable testing equipment or information is accepted???? What? Science is exact measures exact protocol not at random. The study of way fewer samples shows they know the higher the sampling the less horse carcasses pass. They also have information about freezing samples which indicates delays. Horse slaughter is more money with more speed. So somethings amiss with the USDA tests.

    Like

    • Sue Wallis dead horses dream is Alive and well in Wyoming. Why havent the good horsemen and women in Wyoming REARED UP and Said No way? They need to kick the BLM in the sun doesnt shine here spot and stop this!

      Like

  11. https://en.wikipedia.org/wiki/Regulatory_capture

    Regulatory capture is a form of government failure that occurs when a regulatory agency, created to act in the public interest, instead advances the commercial or political concerns of special interest groups that dominate the industry or sector it is charged with regulating.[1] When regulatory capture occurs the interests of firms or political groups are prioritised over the interests of the public, leading to a net loss to society as a whole. Government agencies suffering regulatory capture are called “captured agencies”.

    This is the techie name of what is actually what is. Nothing more, more thing else.

    Like

    • There IS no better symbol of freedom – youre right! Looking at Carol’s pictures of these glorious animals – always makes me wonder where the heck are all those supposedly “ugly jughead runts” that we hear about from the “jugheads” that want to get rid of our wild horses? I don’t think I have ever seen pictures – in STH & LTH and certainly not in the wild that were EVER anything but beautiful creatures that don’t deserve to be treated the way they have been – as if they don’t matter! Reading the description & looking at the pictures from the “tour” at Broken Arrow makes me sick – honestly – looking at those horses – many with eyes closed because of the sand & wind blowing – how can anyone – even somebody that doesn’t know horses – see that & believe its humane to treat these symbols of freedom that way!

      Like

  12. Whistleblower – Informant Award
    The IRS Whistleblower Office pays money to people who blow the whistle on persons who fail to pay the tax that they owe. If the IRS uses information provided by the whistleblower, it can award the whistleblower up to 30 percent of the additional tax, penalty and other amounts it collects.

    News from the Whistleblower Office
    • The Secretary of the Treasury reports to Congress each fiscal year on the use of Internal Revenue Code section 7623. The Whistleblower Office Report to Congress for the fiscal year ending September 30, 2015 was released on February 10, 2016. Reports for prior years are also available.
    • The IRS Whistleblower Office is testing a proposal to send annual letters to whistleblowers to notify them that the IRS still has their claim under consideration. Letters will be sent in March and April 2015.
    • Commissioner Koskinen Statement regarding Whistleblower Program dated August 20, 2014
    • Deputy Commissioner for Services and Enforcement Memorandum dated August 20, 2014
    • Treasury issued final regulations to implement section 7623 effective on August 12, 2014: The regulations generally apply to claims that are open as of the effective date. Section 301.7623-4, which contains the rules for determining the amount and payment of awards, applies to claims for award under section 7623(b) that are open as of August 12, 2014, and to information submitted after that date. The amount and payment of awards under 7623(a) for information received prior to August 12, 2014 will be paid under the rules described in the Internal Revenue Manual.
    Sequester Notices
    • Fiscal 2016 Sequester Notice from Whistleblower Office effective October 1, 2015: Impact on whistleblower payments.
    • Fiscal 2015 Sequester Notice from Whistleblower Office dated October 1, 2014: Impact on whistleblower payments.
    • Fiscal 2014 Sequester Notice from Whistleblower Office dated October 1, 2013: Impact on whistleblower payments.
    • Fiscal 2013 Sequester Notice from Whistleblower Office dated March 1, 2013: Impact on whistleblower payments.
    Information About Submitting a Whistleblower Claim

    Who can get an award?
    The IRS may pay awards to people who provide specific and credible information to the IRS if the information results in the collection of taxes, penalties, interest or other amounts from the noncompliant taxpayer.

    The IRS is looking for solid information, not an “educated guess” or unsupported speculation. We are also looking for a significant Federal tax issue – this is not a program for resolving personal problems or disputes about a business relationship.
    What are the rules for getting an award?

    The law provides for two types of awards. If the taxes, penalties, interest and other amounts in dispute exceed $2 million, and a few other qualifications are met, the IRS will pay 15 percent to 30 percent of the amount collected. If the case deals with an individual, his or her annual gross income must be more than $200,000. If the whistleblower disagrees with the outcome of the claim, he or she can appeal to the Tax Court. These rules are found at Internal Revenue Code IRC Section 7623(b) – Whistleblower Rules.

    The IRS also has an award program for other whistleblowers – generally those who do not meet the dollar thresholds of $2 million in dispute or cases involving individual taxpayers with gross income of less that $200,000. The awards through this program are less, with a maximum award of 15 percent up to $10 million. In addition, the awards are discretionary and the informant cannot dispute the outcome of the claim in Tax Court. The rules for these cases are found at Internal Revenue Code IRC Section 7623(a) – Informant Claims Program, and some of the rules are different from those that apply to cases involving more than $2 million.
    If you decide to submit information and seek an award for doing so, use IRS Form 211. The same form is used for both award

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  13. From some of my old notes on the Red Desert complex:
    65,471 AUMs livestock authorized within HMAs
    5,760 AUMs – 8,688 AUMs for legally designated wild horses within the HMAs.
    7-11 times more forage to private/corporate owned, invasive and non-native species cattle and sheep than to federally protected wild horses.

    This is MY land and I want them to remove their welfare livestock OFF my land and if welfare ranchers can’t support themselves on their own deeded land then they are not good livestock managers and they NEED to fail and not be continually supported by ME with my land and my taxes.

    Like

  14. DECLARATION OF LLOYD EISENHAUER

    Katherine A. Meyer
    Meyer Glitzenstein & Crystal
    1601 Connecticut Ave., N.W.
    Suite 700
    Washington, D.C. 20009
    (202) 588-5206
    Timothy Kingston
    408 West 23rd Street, Suite 1
    Cheyenne, WY 82001-3519
    (WY Bar No. 6-2720)
    (307) 638-8885

    Attorneys for Defendant-Intervenors
    IN THE UNITED STATES DISTRICT COURT
    FOR THE DISTRICT OF WYOMING
    Rock Springs Grazing Association, Case No. 2:11-cv-00263-NDF
    Plaintiff,
    v.
    Ken Salazar, et al.,
    Defendants,

    DECLARATION OF LLOYD EISENHAUER
    I, Lloyd Eisenhauer, declare as follows:

    1. I live in Cheyenne, Wyoming. I am a former Bureau of Land Management
    (“BLM”) official with extensive experience in the Rawlins and Rock Springs Districts in Wyoming and intimate familiarity with the public lands under BLM management in those areas. I have reviewed the consent decree proposed by BLM and the Rock Springs Grazing Association (“RSGA”) in this case and provide this declaration based on my longstanding knowledge of, and management of, wild horses and livestock grazing in the Rock Springs and Rawlins Districts.

    2. I grew up in Pine Bluffs, Wyoming with a livestock and farming background, served in the Marines for four years, and then owned a livestock business from 1952-1958. I enrolled in college in 1958, studying range management. From 1960-1961, BLM hired me to assist with collecting field data for vegetation assessments and carrying capacity surveys related to livestock and wild horses. These surveys were conducted in the Lander, Kemmerer, and Rawlins Districts. When I graduated in 1962, BLM hired me full-time to serve in the Rawlins District in Wyoming, where most of my work focused on grazing management involving sheep, cattle, and wild horses. From 1968-1972, I was Area Manager of the Baggs-Great Divide Resource Area in the Rawlins District. In 1971, the Wild Free-Roaming Horses and Burros Act was enacted, and in the spring of 1972, on behalf of BLM, I conducted the first aerial survey of wild horses in Wyoming, recording the number of horses and designating the Herd Management Areas (“HMAs”) for the Rawlins District. After a stint as an Area Manager with BLM’s Albuquerque, New Mexico office, in 1975 I took over as the Chief of Planning and Environmental Analysis in BLM’s Rock Springs District for three years. I was the lead on all planning and environmental assessments. During that time, I also served as the Acting Area Manager of the Salt Wells Resource Area, which is located in the Rock Springs District. In 1979, BLM transferred me to its Denver Service Center to serve as the Team Leader in creating the agency’s automated process for data collection. I received an excellence of service award from the Secretary of the Interior commending me for my work as a Team Leader. In 1982, I became the Head of Automation in BLM’s Cheyenne office, where I managed and implemented the data collection and processing of various systems related to BLM programs. I retired from BLM in 1986, and have stayed very involved in the issue of wild horse and livestock management on BLM lands in Wyoming, and have written articles about the issue in local and other newspaper outlets. I have won various journalistic awards, including a Presidential award, for my coverage of conservation districts in Wyoming. Along with a partner, I operated a tour business (called Backcountry Tours) for six years, taking various groups into wild places in Wyoming – without a doubt wild horses were the most popular thing to see on a tour, in large part due to their cultural and historical value. I also served six years on the governor’s non-point source water quality task force.

    3. Based on my longstanding knowledge of wild horse and livestock management in the Rawlins and Rock Springs Districts, and in the Wyoming Checkerboard in particular, I am very concerned about BLM’s agreement with RSGA, embodied in the proposed Consent Decree they have filed in this case, under which BLM would remove all wild horses located on RSGA’s private lands on the Wyoming Checkerboard.

    4. The Checkerboard is governed by an exchange of use agreement between the federal government and private parties such as RSGA. However, due to state laws, property lines, and intermingled lands, it is impossible to fence the lands of the Wyoming Checkerboard, which means that both the wild horses and the livestock that graze there roam freely between public and private lands on the Checkerboard without any physical barriers. For this reason, it is illogical for BLM to commit to removing wild horses that are on the “private” lands RSGA owns or leases because those same horses are likely to be on public BLM lands (for example, the Salt Wells, Adobe Town, Great Divide, and White Mountains HMAs) earlier in that same day or later that same evening. Essentially, in contrast to other areas of the country where wild horses still exist, on the Wyoming Checkerborad there is no way to distinguish between horses on “private” lands and those on public lands, and therefore it would be unprecedented, and indeed impossible for BLM to contend that it is removing all horses on RSGA’s “private” lands at any given time of the year, month, or day, considering that those horses would only be on the strictly “private” lands very temporarily and intermittently on any particular day .

    5. Another major concern with BLM’s agreement to remove all horses from the private lands of the Wyoming Checkerboard is that BLM is undermining the laws that apply to the Checkerboard, and wild horse management in general, which I implemented during my time as a BLM official. Traditionally, BLM officials (myself included) have understood that, pursuant to the Wild Horse Act, wild horses have a right to use BLM lands, so long as their population numbers do not cause unacceptable damage to vegetation or other resources. In stark contrast, however, livestock (sheep and cattle) have no similar right to use BLM lands; rather, livestock owners may be granted the privilege of using BLM lands for livestock grazing pursuant to a grazing permit that is granted by BLM under the Taylor Grazing Act, but that privilege can be revoked, modified, or amended by BLM for various reasons, including for damage to vegetation or other resources caused by livestock, or due to sparse forage available to sustain livestock after wild horses are accounted for. BLM’s tentative agreement here does the opposite and instead prioritizes livestock over wild horses, by proposing to remove hundreds of wild horses from the Wyoming Checkerboard without reducing livestock numbers – which, in my view, is contrary to the laws governing BLM’s actions as those mandates were explained to me and administered during the decades that I was a BLM official.

    6. While I do not agree with every management action taken by BLM over the years in the Rock Springs District, I can attest – based on my longstanding employment with BLM and my active monitoring of the agency’s activities during retirement – that BLM has generally proven capable of removing wild horses in the Rock Springs District, including by responding to emergency situations when needed and removing horses when necessary due to resource damage.

    7. Considering that wild horses exhibit different foraging patterns and movement patterns than sheep and cattle, and also than big game such as antelope and elk, no sound biological basis exists for permanently removing wild horses from the Wyoming Checkerboard at this time. In particular, wild horses tend to hang out in the uplands at a greater distance from water sources until they come to briefly drink water every day or two, whereas livestock congregate near water sources and riparian habitat causing concentrated damage to vegetation and soil. For this reason, the impacts of wild horses are far less noticeable on the Checkerboard than impacts from livestock.

    8. In addition, because livestock tend to eat somewhat different forage than wild horses (horses tend to eat coarser vegetation such as Canadian wild rye and other bunch grasses, whereas cattle and sheep mostly eat softer grasses), there is no justification to remove wild horses on the basis that insufficient forage exists to support the current population of wild horses. Also, because cattle and sheep have no front teeth on the front part of their upper jaws, they tend to pull and tear grasses or other forage out by the root causing some long-term damage to vegetation, whereas wild horses, which have front teeth on both their front upper and lower jaws, act more like a lawnmower and just clip the grass or forage (leaving the root uninjured), allowing the vegetation to quickly grow back. These differences are extremely significant because if there were a need to reduce the use of these BLM lands by animals to preserve these public lands, it might be cattle and sheep – not wild horses – that should be reduced to gain the most benefit for the lands, and which is why BLM, during my time as an agency official, focused on reducing livestock grazing.

    9. BLM’s agreement with RSGA states that RSGA’s conservation plan limited livestock grazing, primarily by sheep, to the winter months to provide sufficient winter forage. This is a good example of “multiple use” management, since wild horses and sheep have very little competition for the forage they consume and the seasons during which they use parts of the Checkerboard. During winter, sheep use the high deserts and horses utilize the uplands and breaks (i.e., different locations) for forage and protection. During the summer, when sheep are not present, wild horses use various landscapes on the Checkerboard. This multiple use should continue for the benefit of the livestock, the wild horses, and the public and private lands involved.

    10. I am also very concerned about BLM’s agreement with RSGA to permanently zero out the Salt Wells HMA and the Divide Basin HMA, leaving no wild horses in those areas that have long contained wild horses. I have been to fifteen of the sixteen HMAs in Wyoming, and to my knowledge none has ever been zeroed out by BLM. It is my view, based on everything I know about these areas and the way these public lands are used by wild horses and livestock, that BLM has no biological or ecological basis for zeroing out a herd of wild horses in an HMA that existed at the time the wild horse statute was passed in 1971, as is the case with both the Salt Wells and Divide Basin HMAs. And, again, because the wild horses have a statutory right to be there, whereas livestock only have a privilege that can be revoked at any time by BLM, there also is no authority or precedent, to my knowledge, for the agency to zero out these two longstanding wild horse herds simply to appease private livestock grazers.

    11. The zeroing out of wild horses in the Salt Wells and Divide Basin HMAs is also concerning because it would mean that, in those two longstanding HMAs, there would no longer be the “multiple use” of these public lands as required by both the Wild Horse Act and the Federal Land Policy and Management Act. Currently, while there are other uses of this public land, such as by wildlife, hunters, and recreational users, the two primary uses in those HMAs are by wild horses and livestock. If BLM proceeds with its agreement with RSGA to zero out wild horses in those HMAs, the only major use remaining would be livestock use, meaning that there would be no multiple use of those BLM lands. Not only will that potentially undermine the laws that BLM officials must implement here, but it has practical adverse effects on the resources – multiple use is very beneficial for the environment, and particularly for sensitive vegetation, because different users (e.g., livestock, wild horses) use the lands and vegetation in different ways. When that is eliminated, the resources are subjected to an unnatural use of the lands which can cause severe long-term damage to the vegetation. As a result, zeroing out these herds would likely bedevastating for the vegetation in these two HMAs, because livestock would be by far the predominant use in this area.

    12. Turning the White Mountain HMA into a non-reproducing herd, as the agreement between BLM and RSGA proposes to do, is also a farce, and violates the meaning of a wild and free-roaming animal. This is essentially a slow-motion zeroing out of this HMA, and is inconsistent with any wild horse management approach I am familiar with that BLM has implemented on public lands.

    Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and correct.
    Lloyd Eisenhauer

    Like

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