Adobe Town wild horses (photo: Carol Walker)
Comments & Guest OpED by Bonnie Kohleriter
TO: Jay D’Ewart, Wild Horse and Burro Specialist (See also cc below) 4700 (WYD04)
FROM: Bonnie Kohleriter
RE: Response to EA DOI-BLM-WY-D040-2017-0022EA 2017 AML Gather EA
This EA proposes to round up and remove 1560 wild horses down to the supposed low AML in Adobe Town, Salt Wells, and Divide Basin Herd Management Areas (HMAs).
The last gather and removal in these 3 HMAs was completed in October, 2014. I am looking at the number of horses reported following the gather and removal in 2014 presented in the March 2015 National Statistics as well as the number of horses reported in 2016 and 2017 National Statistics. These numbers found in the National Statistics for 2015, 2016, and 2017 were generated by Jay D’Ewart. I assume these numbers were accurately reported. I have read no evidence in your EA as to how you arrived at these numbers or your suggested excess numbers except for you to say adjustments were made. I assume a normal growth rate is 20-25% yearly as that is what the BLM repeatedly claims, true or untrue. In light of the Allowable Numbers (AMLs) and the National Statistics the following information is presented here:
- In 2014 your plan was to gather and remove horses to the low AML. Yet the results show you rounded up and removed horses well below the low AML in Salt Wells and Divide Basin. The low AML for Salt Wells is 251 but you left 117. The low AML for Divide Basin is 415 but you left 195. THIS IS WRONG.
- In 2015 in Adobe Town you logged in 602 horses but in 2016, 1030 horses with a growth rate of 71%. In 2015 in Salt Wells you logged in 117 horses but in 2016, 728 horses with a growth rate of 522%. And in 2015 in Divide Basin you logged in 195 horses but in 2016, 670 horses with a growth rate of 241%. 71%, 522%, 241% growth rates are impossible, exaggerated, and fallacious measured against accepted rates of 20-25% THIS IS WRONG.
- In 2016 in Adobe Town you logged in 1030 horses but in 2017, 820 horses with a negative growth rate of -20%. It looks like no horses were born in 2016 and horses were dying more than the usual? In 2016 in Divide Basin you logged in 670 horses, but again in 2017, 650 horses with a negative growth rate of -2%. Negative growth rates of 20% and 2% are highly unlikely unless a catastrophe occurred which it did not. THIS IS WRONG.
- In your EA you claim to have made adjustments from your scoping letter numbers in March of 2017 to April of 2017. For Adobe Town your numbers are now not 820 but 1123 with a growth rate of not -20% but 8%. For Salt Wells your numbers are now not 825 but 976 with a growth rate of not 16% but 34%. For Divide Basin your numbers are now not 650 but 737 with a growth rate of not -2% but 13%. All of these numbers and percentages are out of the norm except for the original growth rate of 16 % in Salt Wells…-20%, 8%, 34%, -2%, 13% are unlikely growth rates. THIS IS WRONG.
- With all of Jay D’Ewart’s unlikely, impossible numbers he now wants to round up and remove not 1, 029 horses but 1,560 horses in the fall of 2017. It was pointed out to him in the scoping comment period of March 2017 that the numbers of horses stated in Adobe Town and in Divide Basin at that time were at near high AML which did not seem to warrant a gather and removal at this time. Of course, he subsequently raised the numbers in April, 2017 so that they now reflect over high AML.
- Jay D’Ewart appears to do the fly-overs counting numbers of horses, is in charge of the development of the environmental assessment, and is the lead in gathering and removing the wild horses. With his highly questionable and outrageous numbers, I am concerned about his using these horses in order to continue to gain for himself meaningful employment. I am not only concerned about Jay D’Ewart, but also about other BLM Wild Horse and Burro employees, wherein the norm in this agency throughout the years has been the only tool for protecting, managing, and controlling these horses and burros, that of counting them, rounding ‘em up and removing them.
7) Not only does Jay D’Ewart want to round up and remove horses in the HMAs but he wants to round up and remove horses on private lands. This is a number he has not told us in his EA. This requesting to remove horses or burros on private lands by welfare ranchers who have both public and private land for ranching, seems to have increased in recent years.
Through the years Jay D’Ewart knows I have questioned his numbers again and again. Back when gather numbers were being shown the public as well as facilities received numbers I called Jay D’Ewart to challenge the disconnect between the two sets of numbers only to notice the change within two days. Kimberly Foster and Dennis Carpenter, the Field Managers don’t appear to question D’Ewart’s numbers, June Wendlandt, the State Lead, doesn’t appear to question D’Ewart, numbers, Alan Shepherd in the On the Range Mgmt. office in the Washington D C which decides on who will have gathers and removals doesn’t appear to question D’Ewart’s numbers. And so the gather and removal goes on with who now knows how many horses are left in the Adobe Town, Salt Wells, and Divide Basin Herd Management Areas in Wyoming on 2.4 M acres.
Stringent oversight, accountability, and decision making in the BLM Wild Horse and Burro Program needs to be improved. Overpopulation, overpopulation seems to be the mantra of the wild horse and burro program personnel as well as of the welfare ranchers on our public lands, but how much of the so called overpopulation is a result of inflated or made up numbers due to a desire for personal gain other than doing what is right for the horses and the burros and what is right for the land.
August 10, 2017
Cc Senators Feinstein, Udall, Murkowski, and Dean Bolstad, Director of the BLM WHB Program.