(I used the comment form at AWHPC and their provided comments sent it to the BLM. Usually I read the E/A's and send in my own comments but no time to do that these days. This is just here for my records).
The Proposed Action continues the BLM’s failed capture-remove-warehouse cycle, which has created a fiscal crisis for the Wild Horse and Burro Program. I support water/bait trapping for the application of PZP or PZP-22 in order to humanely suppress population growth without removing horses from the range.
I urge the Wells Field Office and Elko District to cancel plans for the removal of wild horses from the Triple B, Maverick-Medicine and Antelope Valley Herd Management Areas (HMAs) as outlined in Environmental Assessment (EA). The Proposed Action in the EA fails to outline the specific number of horses targeted for removal and fails to provide an adequate justification for the continual removal of wild horses from this area over a five-year period during which environmental conditions will change. The BLM must re-evaluate the Proposed Action on an annual basis in order to evaluate the need for the action in light of the changing environmental conditions, as well as to provide the public with opportunity to comment on the rationale behind decisions to conduct wild horse removals into the future.
The EA failed to take a hard look at the following issues that would mitigate the need for the Proposed Action:
- Manage the existing population (which only exceeds high AML by a few hundred wild horses) by using non-hormonal, safe and reversible PZP fertility control to suppress population growth. This alternative was not even considered or analyzed as a means to mitigate the Proposed Action of wild horse removals.
- Relocate any horses outside of the HMAs back into the designated area instead of removing them, and remedying the conditions that are causing horses to leave the HMA. The EA failed to outline how the horses were leaving the HMA - instead claiming that horses would only return to the areas outside the HMA. The BLM must "take a hard look" and analyze the reasons why horses are leaving the HMA, possible remedies to this problem and evaluate the other possible actions before jumping ahead with the agency's intention to implement the Proposed Action.
- Increase, either temporarily or permanently, the dangerously low "Allowable" population levels (aka AMLs) for wild horses in the HMAs. The EA failed to give any consideration to temporarily increasing the number of horses in the HMAs, failed to take a hard look at and consider BLM’s Adaptive Management Policy (established by Interior Secretary Order N0. 3270, March 9, 2007), failed to analyze the BLM's authority pursuant to 43 C.F.R. 4710.5(a) and 43 C.F.R. 4710.3-2 to increase forage and habitat for wild horses.
In addition to above mentioned deficiencies, the EA failed to provide the information below, which was specifically requested by the public to be analyzed during the scoping period for this EA/Proposed Action:
- Provide all forage allocations, usage (Animal Unit Months or AUMs) and listing of livestock grazing allotments within the HMAs for each of the past three years. Include all current grazing and projected grazing for the next 6-12 months.
- Provide a full accounting of all water sources on the range, including how fencing and engineering of wells and springs for livestock grazing has impacted water availability for wild horses and other wildlife species.
- Provide information on location of all fencing within the HMAs.
- Thoroughly disclose all genetic data on each of the herds (all genetic reports should be provided in the EA appendix); analyze the impacts of the proposed action on the genetic health of each herd and the individual animals.
- Provide all monitoring data for each area, which includes data that clearly separates the impacts on range conditions of livestock use from wild horse use.
- Provide data that demonstrates the BLM’s knowledge about how cows utilize the environment, including data about usage of stream riparian areas.
- Disclose all predator-killing activities within and around the HMAs. The mounting data on the impact predators can and do have on wild horse population growth must be adequately addressed through the disclosure of predator-kill data, analysis and an alternative must be considered for the BLM to support the protection of predators in and around the HMAs in order to restore a Thriving Natural Ecological Balance (TNEB).
I expect that the BLM will re-issue the EA with the above requested level of detail and analysis needed for informed decision making. I further expect that BLM will provide a full accounting of how many members of the public submit comments on this EA and what their positions are, as the agency is legally required to do under the National Environmental Policy Act.