The Colorado BLM published the Environmental Assessment for the Sand Wash Basin Herd in Colorado on August 6. The deadline for comments is September 4, 2016.
It is extremely important that you write and comment because the way that the EA is set up, on the surface it looks as though it is a proposal for a simple bait trapping of wild horses, giving at least 80% of the mares PZP-22 for birth control and then removing 50 horses. You might say “well, that’s not so bad.” But in actuality, it is a 10 year plan that opens the door for helicopter removals down to low AML over the period of 10 years, with no opportunity to comment later on the plan. This part of the EA must be changed. Currently, if you look on the BLM’s eplanning website for the project here:
The length of the project is 10 years, with the start date at 03/28/2016 and the end date of 9/30/2016.
And the paragraph that really concerns me is this one:
“In 2016, it is estimated that up to 50 excess wild horses would be sent to the GEMS for adoption. The number of excess wild horses removed in the future may vary depending on holding space at the GEMS or BLM preparation and holding facilities. The number of excess horses removed from the HMA would not reduce the population to below the low end of AML within the Sand Wash Basin following implementation of the proposed action.”
This opens the door for the BLM to remove more horses down the road, without public comments, possibly even down to low AML which is only 163 horses. This urgently needs to be removed from the EA. If what the Wild Horse and Burro Expert Ben Smith told me is true, that they are only doing removals this year and the 10 year part is just for the annual administration of PZP-22, then that needs to be spelled out clearly.
Current population estimate of the Sand Wash Basin Herd is 550 wild horses, and that number does not include foals born this year – there are estimated to be 57 foals born this year. Appropriate Management Level, (AML) for the Sand Wash Basin Herd is 163-362.
This population estimate was made doing an actual ground count by volunteers, the very best way to get an accurate count. I applaud the BLM for this paragraph: “Population estimates in the Sand Wash Basin HMA are likely to be close to the actual number of horses due to the volunteers that observe the horses in a consistent manner, and track foaling and death loss.”
The biggest concern I and others have had was that the BLM could schedule a helicopter roundup and remove 444 wild horses. They do not have room for these horses in short and long term holding. So they worked out a plan to use bait trapping, intending to capture 80% of the mares in the herd and give them PZP, and then remove 50 young horses who will be sent to the Great Escape Mustang Sanctuary (GEMS) for training and placement. You can read about them here: http://greatescapesanctuary.org/
There are three alternatives in this EA:
Alternative A: Bait trapping, Fertility control using PZP-22 and removal of 50 horses which will be sent to GEMS
Alternative B: Bait Trapping, Fertility control using PZP-22, No removal of horses
Alternative C: No Action
The Sand Wash Basin Herd Management Area is 157,730 acres, and there are 4 grazing allotments for livestock ranchers grazing sheep in the area. It is a very dry and arid area, and some years have better rain than others. But in my opinion the very best thing that could happen for this herd would be to raise the AML to 350-600 and retire all the livestock grazing leases, and make Sand Wash Basin a Wild Horse Range. Sand Wash Basin wild horses should be managed as the principle species in this Herd Management Area, as mandated in the 1971 Wild Horse and Burro Act.
This is the BLM response to raising the AML:
“Current monitoring data does not support raising the AML for wild horses within the current multiple use balance established under the RMP. This alternative was not brought forward for detailed analysis because it is outside of the scope of the analysis, and would not be in conformance with the 2011 Little Snake Field Office ROD and Approved RMP which direct the Secretary to immediately remove excess wild horses, and is inconsistent with the BLM’s multiple use mandate.”
This is the response regarding managing wild horses as the principle species and making Sand Wash Basin a wild horse range:
“Alternative D of the Little Snake Proposed Resource Management Plan/Final Environmental Impact Statement (October 2011) analyzed an alternative under which the Sand Wash Basin HMA would be designated as a wild horse range and managed principally, though notexclusively, for wild horses. This alternative would still have included population management,though the AML may have been raised as AUMs allocated for livestock grazing would have been reallocated to wild horses. This alternative was not selected in the RMP.”
Usually RMPs are changed about every 20 years. This is not acceptable. This needs to change.
I encourage you to select alternative B or C – the horses are going to be safest in their homes, with their families. And make sure you ask that the 10 year part of the plan be only applicable to the administration of PZP-22, and that any future removals of wild horses from the range needs to comply with NEPA and have a public comment period beforehand. I would also recommend that you ask that the public be able to observe the bait trapping.
Please comment by September 4, 2016.
Public Comments Can be mailed to:
Little Snake Field Office at 455 Emerson St., Craig, CO 81625
or submitted via email to firstname.lastname@example.org.
Comments are due by September 4, 2016.