City, State, Zip
BLM Field Manager
Billings Field Office
5001 Southgate Drive
Billings, MT 59101
Response to Preliminary EA DOI-BLM-MT-0010-2012-0001-EA on Pryor Mountain Wild Horse roundup for 2012.
First of all I want to thank your office for taking the bait/water trapping approach to this roundup instead of using helicopters. I also appreciate that you are attempting to manage the population at the high end of the AML because of the use of population control (per the RMP) which is something not all Field Offices seem to plan for or understand.
Yet, I do not agree with removing so many youngsters at once … up to 2/3 of the 1 to 3 year olds will be removed in a short time (per page 12) and for such a small herd, that impact is hard to calculate.
I agree with others that you should wait until its clear how many foals are born in 2012 and make a decision then even if you have to do a smaller removal than planned.
BTW, I am aware that the chart on Page 5 & 6 is intended to show forage utilization levels, but the two pictures on Page 6 do not line up properly, Photo 2 having been taken much farther back from the road and at a slightly different angle than Photo 1 so it makes it more difficult to assess the exact conditions of the Lone Pine pasture at that particular spot. It would have also been helpful to have more than four point of comparison (Key Area C-19 Lone Pine, Area Q F.S, Pens Meadow and South T.B Pens) and more than one set of pictures to really help those who don't have boots on the ground get an idea of any detrimental change in grazing conditions. I am really surprised at the percentage of change in the utilization levels since when I spoke with Mr. Bybee in late August, he said the ranges hadn't deteriorated all that much. How do you account for such a deterioration in such a short time if Mr. Bybee's assessment was correct? (August to October) And why do you say the deterioration is due to increase in population between 2010 and 2011 when the number of births and deaths were about the same?
Could there be changes in forage utilization levels due to the reconstruction of the Forest Service Fence? If so, how do you plan to mitigate that so that more horses don't end up being removed to compensate for a fence? Are you also aware that a small band of horses was found dead next to the fence this past winter? Did they die because they could not get to their accustomed pasture and did not know that the way was blocked permanently?
I also have to wonder why the BLM uses pictures of a barren location with horses of little color to use in its E/A photos when we know the pastures look much healthier and many of the horses have striking colors and characteristics. At first glance, it seems that the PMWHR is a barren place and the horses come in plain, brown wrappers when we know that is not the case. After all, the auction after the last roundup went quite well with many horses, especially stallions, going to private bidders for fairly high prices. How do you plan to offer these young horse for adoption? There is sure to be interest in these horses and it would be helpful to know what your adoption process is going to be.
I also was interested in reading on Page 19 of some uranium exploration pits. Where can I read more on these regarding when they were dug, by whom and if there is some move afoot to develop uranium on the PMWHR?
And finally, when I spoke to Mr. Bybee in August, he mentioned that the horses weren't using the water guzzlers as much as had been hoped. What can you do to encourage use of these guzzlers to decrease the strain on the range pastures, make the range healthier and to decrease the need for future roundups?
PMWHR - Pryor Mountain Wild Horse Refuge
FONSI - Finding of No Significant Impact. A favorite term of the BLM when responding to advocates calls for reduced or no roundups.
RMP - Resource Management Plan. The Bible for each district and the fallback reason for telling advocates to go pound sand as in "The AML for this herd management area is set at two horses and we know that is the correct number of horses because that's what it says in the RMP."
Preliminary E/A - Preliminary Environmental Assessment. The same as the EA (see below). Just with the word "preliminary" in front of it.
EA - Environmental Assessment and the same as the Preliminary EA, just without the word "preliminary" in front of it. The BLM has to issue this before it tells you to go pound sand.