still smells the same.
Gary W. Medlyn
Field Manager/Egan Field Office
BLM Ely District Office
HC 33 Box 33500
Ely, Nevada 89301
Fax: (775) 289-1910
The following are my comments on the Pancake Preliminary EA DOI-BLM-NV- L010-2011-0023.
Page 3: Jakes Wash Herd Management Area has been returned to Herd Area Status consistent with the Record of Decision (ROD) and the 2008 Approved Ely District Resource Management Plan (RMP) at management action WH-5, which states: “Remove wild horses and drop herd management area status for those ... as listed in Table 13.” Removal of all excess wild horses from the Jakes Wash HA is needed at this time in order to implement this management direction ….
Yet, there are 132 horses living in Jakes Wash, evidently not in danger of starvation or they would have been removed earlier. It seems odd to me that the BLM couldn't facilitate a well or water guzzler in the area that would provide wild horses with water during the summer months. I realize the RMP is set for now, but I do NOT understand why the only solution is removal especially since, if the herds were in dire straits, you surely would have gone in there by now and removed them and not waited four years after the RMP was written.
Page 10: 2.1 Alternative A. Proposed Action – Phased-in Gather and Population Growth Control Alternative.
Under the Proposed Action, the BLM would gather approximately 65-70% of the existing wild horses (approximately 1,435-1,540 animals in the initial 2012 gather) every two to three years with a target removal of approximately 800-1,000 excess wild horses per gather over a period of six to ten years.
It is my understanding the giving the mares PZP will help maintain a stable population. If that is the case, why on earth do you think you'll need to go back in every two to three years to remove another 800 - 1,000 horses if you're only leaving a breeding population of 361 horses, 60% of those being males, after this winter 2012 gather. Even if you miss 30% of the horses on the range per gather, after the first gather that might be 600 horses which at 20% reproduction rate would produce about 120 foals the first year and only a few more than that second year. If your released mares are under the effect of PZP, then there would be very few foals from them the first year or two.
Your untreated horses would be breeding at a normal rate. The treated mares (144) would be breeding at a much less than normal rate. You would only have 1,000 horses on the range (assuming you gather 70%) after the treated mares were released at the end the first gather.
At the end of the second gather, you will have, at most, only a few hundred horses left. At the end of the third gather, you will have gathered nearly all of them. Sorry, I don't understand your math, your numbers or what you will achieve by going back in every two years and expecting to remove 800-1,000 horses unless you plan to zero out the HMA. It is physically impossible for 600 untreated horses and 144 PZP'd mares to produce enough horses to make your estimated gather numbers .. even if all the mares have triplets.
I also object to the sex ratio you are artificial creating. Band stallions attain a harem for a reason. To have more bachelor stallions will only harry the band stallions and cause them to lose their mares, creating artificial disruption in their society. Think of a summer camp where 60% of the attendees are horny males and you might understand the impact skewing the sex ratios will have on the females. Stable bands without the pressure of constant turnover in social structure are much better for equines, as well as humans. This seems to the latest attempt at population control and lacks field study. Not only that, since PZP'd mares are more likely to breed with bachelor stallions, creating this artificial ratio seems pointless.
Page 23: The management action to achieve zero wild horses within the Jakes Wash HA reflects the recent evaluation based on multi-tiered analysis from the Ely Proposed Resource Management Plan/Final Environmental Impact Statement (November 2007) table 3.8-2 and page 4.8-2. The components and herd characteristics: forage, water, cover, space, and reproductive viability. If one or more of these components were missing, or there was no potential for a stable shared genetic pool, the herd management area was considered unsuitable. The Jakes Wash HA has inadequate forage, water, space, cover, and reproductive viability. The current estimated population at implementation of the gather would be 132 wild horses following the 2011 foal crop.
The phrase I have outlined in bold says to me that any time the BLM decides to manage an HMA as a non-reproducing herd, the next step could easily be to zero it out since, per your EA it would lack "reproductive viability." Therefore, the BLM creates the scenario necessary to zero out an HMA after declaring it a non-reproductive herd area. Are you guys really that obvious?
Page 24: Concentrations of wild horses and cattle around the limited water sources during this time increases competition with wildlife for water resources and negatively affect the associated range resources.
At least you admit, though in a roundabout way, that livestock also negatively affect water sources.
Page 29: When gelding procedures are done in the field, geldings would be released near a water source, when possible, approximately 24 to 48 hours following surgery. When the procedures are performed at a BLM-managed facility, selected stallions would be shipped to the facility, gelded, held in a separate pen to minimize risk for disease, and returned to the range within 30 to 60 days. Gelding complications (eviscerations, anesthetic reaction, injuries during handling, etc.) that result in euthanasia or mortality during and following surgery of this type is rare and would be expected to be less than five percent of the animals treated.
Eviscerations? This is unbelievable. I have never heard of a properly trained veterinarian eviscerating a stallion during gelding. Is it possible that un-trained, improperly supervised and/or the simply incompetent are performing these procedures?
The damage to rangeland resources that results from excess numbers of wild horses is also contrary to the WFRHBA, which mandates the Bureau to “protect the range from the deterioration associated with overpopulation”, “remove excess animals from the range so as to achieve appropriate management levels”, and “to preserve and maintain a thriving natural ecological balance and multiple-use relationship in that area”. Once the vegetative and water resources are at these critically low levels due to excessive utilization by an over population of wild horses, the weaker animals, generally the older animals and the mares and foals, are the first to be impacted.
No .. the overpopulation is the cattle which outnumber the horses by up to 10:1. Multiple use does NOT mandate that the horses have a smaller share of the range AMU's than livestock. To do so is to pervert the multiple use mandates to the benefit of the BLM livestock/welfare ranching program, (a program that costs many times what the WH& program costs and has a negative benefit to taxpayers).
Page 35: wild horses that have congenital (genetic) or serious physical defects such as club foot, limb and dental deformities, or sway back and should not be returned to the range.
A club foot is not a serious physical defect. If the horse could travel well enough to be gathered and has survived successfully in the wild with that "deformity", why does it need to be euthanized? Many domestic horses survive fine with a club foot and since these horses are now in the care of the federal government, will not be bred, and will probably be incarcerated in long term holding, what difference does it make if the horse has a club foot or a sway back? It is shocking to me that a horse can survive in the wild with certain deformities, but not in your care. I find this excuse used to euthanize an otherwise healthy horse to be an exercise in faulty logic. The horse is no longer in the wild. It is in the care of the United States government and is no longer considered a wild horse. Why apply standards that aren't relevant to the horse's circumstances?
Page 35: The BLM has been gathering excess wild horses from public lands since 1975, and has been using helicopters for such gathers since the late 1970‟s.
And there have always been problems using helicopters and the Sun J pilot is about to be charged with animal cruelty due to his gather tactics, his use of the helicopter as a battering ram and the way he puts the helicopter in such close proximity to the horses, often right on top of them. I hope you don't use this person unless his flying tactics have improved, he answers to Judge McKibben and he has taken some anger management classes.
page 42: Table 3. Pancake Herd Management Area
% of Permitted Ten Year Percent Actual Allotment Season of Use Allotment Use Average Use of Permit
in HMA (AUM)** AUM Use Use
Duckwater* Monte Cristo** Pancake Black Point Six Mile South Pancake
3/1 to 2/28 6/21 to 9/18 7/01 to 10/15 Cattle 4/15 to 10/31 Sheep11/1 to 4/15 3/15 to 4/30;100% 100% 17% 96% 100%
18,363 1,129 609 1,209 1,155
*Duckwater Allotment; South Sand
Thank you for showing the egregious over allocation to livestock instead of wild horses. The charts are very thorough and clearly show that livestock is favored over wild horse by several multiples ranging from a few months a year to nearly all year round in some HMA's.
Page 36: Trampling and trailing damage by wild horses in/around riparian areas would also be expected to increase, resulting in larger, more extensive areas of bare ground. Competition for the available water and forage between wild horses, domestic livestock, and native wildlife would continue and further increase.
Yet, in another section you state that the wild horse travel the HMA while the livestock stay close to the water sources. Wouldn't some 3,000 pound cow standing in a stream bed defecating and urinating do more damage to a riparian area than a horse that comes in, drinks and then leaves?
Page 37: The current over population of wild horses is contributing to resource damage and decline in functionality of spring sources.
The author of this EA has already admitted that livestock contribute to resource damage and should have included livestock damage in the above sentences as well.
Page 48: When the helicopter is working close to the ground, the rotor wash of the helicopter is a safety concern by potentially causing loose vegetation, dirt, and other objects to fly through the air which can strike or land on anyone in close proximity as well as cause decreased vision.
Those objects can impact the horses as well and since the Sun J pilot often gets closer than 10 to 15 feet (documented) he causes a dangerous situation on the ground to any horse he hazes. I have seen wash from the helicopter so dense that it was probably impossible for a horse to know which way to go as the copter was right on top of them (documented). I have never heard of an observer causing this to happen nor of an observer being hit by debris since they are often kept so far away from the roundup that telephoto lenses are necessary to see anything, that is if the view is not obstructed. The Sun J pilots hunt and terrorize flying tactics are a danger in and of themselves. Please speak to Judge McKibben if you have any doubt.
In addition, BLM employees should remember that the helicopter crew works for the BLM and the taxpayer, not the other way around so the BLM should be able to tell the temporary, contracted helicopter crew that the taxpayer should have a decent view of the trap site and gather route. You really should stop hiding behind the likes of Sue Cattoor and her counterpart at SunJ. Contractors generally do what their clients want them to .. not the other way around. If a contractor tells me only what I can't do and what they won't do if I hire them to repair my home, I fire them and find someone else to do the work that I want done. Certainly you have experienced WH&B specialists on hand and don't need to rely on a relatively new roundup outfit for all your decisions on the ground?
Page 49: Appropriate BLM staffing (public affair specialists and law enforcement officers) will be present …
Your continued use of law enforcement officers is an insult and a provocation to law abiding citizens as well as to members of the press who want to exercise their First Amendment rights.
Best Regards,
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