My comments on the Triple B Scoping Letter dated June 14th, 2012

Bryan K Feull,

I read your scoping letter on Triple B and have some comments regarding the letter.

It states that over 60,000 gallons of water were delivered to Triple B during 2011, but doesn't state if all that water was consumed by horses or by other wildlife or by livestock. In order to put that amount of water in perspective, I have to call upon my knowledge of gas fracking procedures which use 250,000 BARRELS, or More, of water. That comes to Seven Million, Eight Hundred and Seventy Five thousand Gallons of water (that's 7,875,000 gallons) for one gas well. Your 60,000 Gallons would fit inside that number a hundred times over.

It also equates to the amount of water 4000 horses can drink in one day, or 1,000 horses can drink in four days, or 100 horses can drink in 40 days , you see where I'm going with this ... And your letter does not specify if only horses drank the water which would be pretty unlikely or how much evaporated or if the horses were disturbed by the water trucks and left the vicinity.

I'm also concerned about the fact that your agency is seeming to mix its messages on this extended gather. Is the water the issue or is the fact that the horses are over your arbitrarily set AML the issue? Would there be a "water" issue if there were fewer livestock on the HMA? Your scoping letter leaves out the number of AUM's reserved for livestock, an estimate of how many livestock are actually out there, and the specified time periods that the livestock can remain on the HMA.

I have also seen very recent (taken in mid-June) pictures of water tanks on the Triple B HMA full of water with adjoining seeps and the riparian areas are not trampled or muddy. Why doesn't the BLM build a few of these type of water tanks, some have lasted for fifty years or more, to bring water to the surface for all wildlife in the HMA? And how have they managed to survive for fifty years if the wild horses damage the tanks as the ranchers and BLM alleges. It does seem as though there is water there and better management on your part would reduce the necessity for 10 or 12 water tankers a year to go to the area, and reduce the impact of all that activity on the fragile environment as well. 

I'm also confused as to why the BLM, with a wild horse sanctuary nearby, can't wait until the timing is right to gather these horses and take them to the proposed sanctuary so that they don't have to go through the stress of being rounded up, hauled off, stuck in STH, then in a maintenance facility and ultimately trucked across the country to a LTH, where surely many of them will end up.

While not in the "scope of this document" the BLM can surely fast track a sanctuary which has been in the works for nearly three years, so that some of these horses can stay in the HMA in which they were born.

I am also distressed that no mention of reproduction control is given. If you have the means, use it. I'm tired of seeing so many horses hauled off when better management on your end would reduce the number of horses in LTH and the need for constant gathers, something your recently retired boss, Bob Abbey, stated was the goal for the WH&B program several years ago but which I have seen little evidence so far.

Best Regards,