This Resource Management Plan (RMP) amendment gives us a chance to protest the destructive OHV and remove/reduce livestock on this very large remote wilderness area. There are about a thousand plus wild horses in this area too.
United States Department of Interior
Bureau of Land Management
Oregon State Office
P.O. Box 2965, Portland, Oregon 97208
Subject Line: BLM-SEORMP public comment
Re: Public Comment – Draft Southeastern Oregon Resource Management Plan Amendment/ Environmental Impact Statement D01-BLM-ORW A-V000-2017-0022-EIS – SEORMP
Although I do NOT see an actual beneficial-to-nature alternative, it appears that Alternative B: Emphasize Protection of Wilderness Characteristics is the best one provided by the BLM at this time, as the EIS is currently written.
BLM cannot possibly say that off-highway vehicle (OHV) demolition of our public land (as shown in the above photo) is within a healthy management plan for our lands. This is utter and complete and absolutely unnecessary destruction of the range – a very delicate and arid range. All motorized vehicles on public land for any purpose must stay on designated roadways and these roadways – regardless of need, be it recreation or commercial – must be designed and kept at the least invasive level. BLM cannot possible say that any wildlife are the cause of destruction of the range when this OHV damage is allowed and encouraged on our public land. All motorized OHV should be banned from all public lands but if any OHVs are to be allowed at all on any public land then it must limited to a very few designated public lands where it must be continually monitored closely and this monitoring documented and provided to the public at least annually by BLM in order to decrease as much as possible any destruction of the fragile land by these motorized activities. This kind of “approved” OHV action is a deceptive and dishonest representation of range health management by the BLM.
Motorized OHV activity detrimentally effects the soil, the air, the water shed, the visual resources, and any fish or wildlife that have access to the area – not only during the OHV activity but also after the activity ends. In addition, I strongly insist that all motorized vehicles be banned from off-road travel within any legal Wild Horse and Burro Herd Area (HA) land.
Predator hunting and trapping is ecologically reckless, not only harming individual animals, but also altering predator-prey dynamics, disrupting the social dynamics of predator species, and increasing threats to public safety. For example, coyote populations that are not exploited (that is hunted, trapped, or controlled by other means) form stable “extended family” social structures that naturally limit populations through defense of territory and the suppression of breeding by subordinate female members of the family group. Indiscriminate killing of coyotes disrupts this social stability resulting in increased reproduction and pup survival. Predators have been shown to provide ecosystem services that benefit humans, including the control of rodents and rabbits which are associated with diseases such as plague, hantavirus, tularemia and Lyme disease. All killing of natural predators on public lands managed by BLM must be stopped immediately.
I propose that all legal Wild Horse and Burro Herd Area lands be designated as Areas of Critical Environmental Concern and be managed principally for wild horses [and burros] as per the 1971 Congressional Act and for BLM to utilize their discretion under 43 C.F.R. 4710.5(a) to close livestock grazing in the Herd Areas. These lands are designated by congressional law to be managed principally for wild horse and burro herds under 43 C.F.R. 4710.3-2. Due to past politically influenced management practices of the Herd Areas designated by Congress for wild horses and burros – these wild herds are now in grave jeopardy of losing their genetic viability as well as their designated legal land. This can be largely rectified by BLM following the law and providing these species their designated and legal land as a principle resource. This can be done even as the land is used within a multiple use policy – but the BLM must make its decisions on proven scientific research and not on politically driven pressure from financial interests such as mining, trophy hunting, private domestic livestock and energy corporations. These wild horse and burro herds are part of our extraordinary American heritage and should also be maintained at a viable level under the National Historical Preservation Act. The legal 1971 congressionally designated management objectives to protect wild horses and burros must be immediately and continually put into effect in order to protect these special and unique resources.
Alternative B is the only alternative that will come even close to the BLM’s stated mission to “Sustain the health, diversity and productivity of the public lands for the use and enjoyment of the present and future generation”. The BLM in its mission to manage for a “thriving ecological balance” must take immediate and substantial actions to remove or at least greatly reduce all domestic livestock from our public lands. “All 76 wilderness characteristics units (1,206,780 acres), excluding setbacks, would be managed to protect those [WILDERNESS] characteristics. In these units and WSAs grazing permits would be suspended for the life of the RMP where existing livestock grazing is determined to be a significant factor in not meeting Standards for Rangeland Health. Voluntary relinquishment of a grazing permit would result in certain permitted areas (set forth in Provision 29(2) of the 2010 Settlement Agreement) no longer being available for livestock grazing for the life of the RMP.”
In addition to this EIS alternative, I require that the “determination” of the stated Standards for Rangeland Health NOT be done by the owner or employee of the owner of the grazing lease – as is sometimes done. The last time BLM published Rangeland Inventory Monitoring Evaluation (RIME) data that I could find was for 2015; that showed more than one-third of lands assessed failed to meet BLM’s own Standards for Rangeland Health reflecting minimum quality of water, vegetation and soils – a total of 40 million acres, or about the area of Washington State. The overwhelming portion (more than 70%) of range health failure was due to livestock overgrazing. As by far the biggest disturbance factor on Western range lands, commercial livestock grazing simply cannot be left out of a scientific landscape assessment.
Livestock grazing has at least the following major negative ecological impacts:
- Significantly Alters Plant and Animal Communities (Wagner 1978, Jones 1981, Mosconi & Hutto 1982, Szaro et al. 1985, Quinn & Wal-Genbach 1990, as cited in Fleischner, 1994) (Belsky, Matzke, Uselman, 1999) (Donahue, 1999) (Wuerthner, Matteson, 2002)
- Decreases Biodiversity (Fleischner, 1994) (Wilcove, Rothstein, Dubow, Phillips, Losos, 1998) (Belsky, Matzke, Uselman, 1999) (Wuerthner, Matteson, 2002)
- Elimination of Native Predators (Donahue, 1999) (Wuerthner, Matteson, 2002) (GAO, 2005)
- Introduction of Invasive Plants and Diseases (Mackie 1978, Longhurst et al. 1983, Menke, Bradford 1992, as cited in Fleischner, 1994) (Wilcove, Rothstein, Dubow, Phillips, Losos, 1998) (Donahue, 1999)
- Soil Compaction and Accelerated Erosion (Fleischner, 1994) (Belsky, Matzke, Uselman, 1999) (Donahue, 1999) (Wuerthner, Matteson, 2002)
- Hydrologic Disruption and Contamination (Fleischner, 1994) (Belsky, Matzke, Uselman, 1999) (Wuerthner, Matteson, 2002)
- Habitat Destruction (Fleischner, 1994) (Wilcove, Rothstein, Dubow, Phillips, Losos, 1998) (Belsky, Matzke, Uselman, 1999) (Donahue, 1999) (Wuerthner, Matteson, 2002)
The negative impacts of livestock grazing are well documented and most scientists have indeed recommended the removal of livestock from public lands in order to improve the ecological conditions and protect the native flora, fauna, and other public resources (Fleischner, 1994) (Donahue, 1999) (Belsky, Matzke, Uselman, 1999) (Wuerthner, Matteson, 2002). This is especially true in the EIS designated wilderness areas.
EIS page 3-130 (excerpt). “Wild Horses Cumulative Effects Summary. The cumulative impact analysis area used to analyze cumulative impacts on wild horses includes all lands within the planning area boundary. Loss of native vegetation and declining ecosystem health on public lands, all contribute to reductions in the ability of public lands to support healthy wild horses and their habitat. The herbicide risk, and the disturbance and potential short-term localized loss of some forage or cover, can contribute to these pressures on wild horses, but the net effect of all alternatives is beneficial as they attempt to control invasive plants and restore native habitats.”
Removal and reduction of private domestic livestock would solve many of the BLM’s concerns for the wild horses and for the habitat in these wilderness areas. One of these is the BLM’s statement that loss of native vegetation and declining ecosystem health is an issue to the health of the wild horse herd health. Of course, this is true and since wild horses are legally allowed to live in and forage in wilderness areas on public lands, the removal of private livestock would allow for those resources within the designate wilderness areas to then become available to the wild horses and other natural wildlife. The removal of livestock would add to the health of the native vegetation and would greatly improve the health of the ecosystem on these public lands.
BLM often purports that there is not enough forage and habitat for the wild horses and burros, even though the BLM permits thousands of cattle and sheep to graze on these same public lands, despite the fact that, unlike the wild horses and burros, the livestock are not required to be “protected” as an “integral part of the natural system of the public lands.” 16 U.S.C. § 1331. In choosing any scientifically unsound, controversial, untested, and radical approaches for the management of wild horses and burros, the BLM violates its obligations under the Congressional Wild Horse and Burro Act to “protect” these “wild and free-roaming” horses and burros as “living symbols of the historic and pioneer spirit of the West” and to ensure that “all management activities shall be at the minimal feasible level.” Id. §§ 1331, 1333(a).
As made clear by the Wild Horse and Burro Act’s implementing regulations, the BLM “may close appropriate areas of the public lands to grazing use by all or a particular kind of livestock . . . if necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury.” 43 C.F.R. § 4710.5(a). With suspension of domestic livestock grazing permits or reductions in AUMs occurred, forage, cover, and structure would be maximized for wildlife inside and outside of wild horse Herd Management Areas. The absence of livestock trampling and utilization would increase herbaceous cover that would benefit ungulate forage, ground nesting birds, and small mammal hiding cover and forage. Removal of domestic livestock grazing would also limit damage to sensitive riparian areas, and reduce the need for standing water for livestock, which can contribute to the spread of West Nile Virus (BLM 2015d), though some water sources would likely be maintained for wild horse populations. Removing spring developments and allowing riparian areas to recover would improve cover and forage for many wildlife species. Suspended grazing in pastures/allotments that are not meeting standards while treatments are implemented could also have a net benefit on wildlife habitat.
By law the BLM can and should close appropriate areas of public lands to grazing use by all domestic livestock, if necessary, to provide habitat for wild horses or burros; to implement herd management actions; or to protect wild horses or burros from disease, harassment, or injury. 43 C.F.R. § 4710.5.
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