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Saturday, January 21, 2012

HELP FOR comments on Environmental Assessments:

Every round-up is preceeded by a Preliminary Environmental Assessment by the BLM, that is then open for a public comment period. After consideration, the BLM then issues the EIS or Environmental Impact Statement and the Roundup begins. Rarely alternatives are considered.
Here are some pointers for the comment period that could and should eventually be considered:


The current draft RMP and EIS are insufficient because no meaningful alternatives are provided and the token alternatives proposed do not adequately protect and preserve wild horses as required by federal law.

The EIS is inadequate for the following reasons:

Lacks monitoring data upon which decisions for resource allocation decisions should be made. Indeed, Rangeland Health Assessments have been performed for fewer than half of the livestock grazing allotments within the planning area. Of those that were assessed, approximately half failed to meet standards, with livestock grazing listed as a causal factor.

Fails to provide any data whatsoever on Herd Areas (HAs) that have been “zeroed out” for wild horses and fails to consider an alternative for reinstating HAs as Herd Management Areas (HMAs).

Lacks data on genetic assessments of wild horses in the HMAs upon which decisions about proper “Appropriate Management Levels (AMLs) and genetic health should be based.

Lacks description and analysis of the impacts of “chemical and other population control measures” to be implemented. This vague language is unacceptable. At minimum the EIS must analyze the impacts of each of the possible options (i.e. permanent sterilization, castration of stallions, spaying of mares, various chemical fertility-control methods, etc.).

Fails to take the required “hard look” at alternatives for wild horse management. In fact, the only meaningful difference between the proposed alternatives considered is the establishment of a wild horse viewing loop and limited removal of fencing.

With regard to the draft RMP itself, I support  Alternative B in the final RMP, only because it offers the most protections to wild horses and the environment by placing greater limitations on energy development, mining and livestock grazing. However, I endorse the American Wild Horse Preservation Campaign’s recommendation that the following provisions be included in Alternative B.

Record # 4110 (Table 2.2, Volume 1) -- Appropriate Management Levels (AMLs) for Wild Horses – The AMLs of five of the seven HMAs are arbitrarily low and genetically unsustainable. Please incorporate the following management actions into the final RMP:
Increase AMLs in all HMAs and reduce livestock grazing, pursuant to 43 C.F.R. 4710.5(a). The current imbalance in which authorized livestock use in the planning area outnumbers wild horse use by at least 23-1 must be reversed.
Increase AMLs in all HMAs to a minimum of 150 animals, which is the minimum number necessary to sustain genetic viability, according to leading equine geneticists. BLM claims of horse movement across HMAs are unsubstantiated and do not negate the need for each HMA herd to have a genetically-viable population number.
Evaluate the current usage of all “zeroed out” Herd Areas, and if livestock grazing currently take place, utilize 43 C.F.R. 4710.5(a) to reduce or eliminate livestock grazing in order to improve conditions and forage availability for wild horses. The relocation of healthy self-sustaining herds to these HAs or  the introduction of horses from holding facilities must be included in the RMP.
Designate all HMAs and HAs in the planning area as wild horse ranges to be managed principally for wild horse herds pursuant to 43 C.F.R. 4710.3-2.

Record # 4111 -- Population Control Measures to Be Used on Wild Horses
Eliminate removals as a population-management strategy in all but emergency situations. Properly utilize non-hormonal PZP fertility control to accomplish this goal.
Prohibit all detrimental types of fertility control, including hormonal fertility control methods, castration, spaying, permanent chemical sterilization, and sex ratio skewing, all of which alter wild horse behavior.
Establish a policy to promote the protection of predator species in an effort to restore natural population control mechanisms and restore the thriving natural ecological balance of these public lands areas.

Record # 4112 -- Dealing with Horses Outside HMAs
Establish a policy to return horses found outside HMAs to the HMAs.  Implement range improvements to eliminate reasons for horses to leave the HMA, i.e. address water shortages by installing guzzlers.

Record # 4113 -- Selective Removal Criteria for Wild Horses
Restrict removals to emergency situations. Conduct any roundups or catch-treat-release operations in a manner that preserves family band structures, so as to maintain the stability and integrity of wild horse social organization and establish humane policies to prohibit roundups in below freezing weather or in weather hotter than 85 degrees F.

Record # 4117 -- Year-Round Water Sources
Install a system of strategically-placed large, in-ground guzzlers to help maintain and conserve adequate water sources year-round.  Require livestock permit-holders to keep their water improvements operating and available for wildlife, including wild horses, even when the grazing seasons conclude.
Establish a systematic process for allocating water and accounting  across all multiple uses.
Restore, in an environmentally-sound manner, water sources to better manage wild horses within HMAs.
Although stated as an objective for management action, the draft RMP does not detail how the BLM would ensure a continuous supply of water for the wild horses under its jurisdiction.

Record # 4121 -- Fences
Remove fencing to the extent possible, and minimize construction of new fencing, to create corridors for natural migration by wild horses and other wildlife species. This will minimize any impacts on the range.

Thank you for your consideration.




Also very helpful are the conclusions and recommendations in the brochure published by the Animal Welfare Institute.  www.awionline.org

1. A new agency should be formed within the government that is dedicated to the protection of wild horses and burros, modeled after other federal programs for unique species or landscapes...


2) All agency actions affecting wild horses and burros should comply with relevant laws and regulations (such as WFHBA and NEPA)

3) The BLM should implement a moratorium on wild horse and burro roundups until a comprehensive review of all aspects of the wild horse and burro management program is completed. (the USGS has not completed a comprehensive census of the horses and there have been no proper studies of range conditions - see above DOI complaint by PEER in regard to the scientific range studies that omitted cattle grazing)

4) Wild Horses and burros for whom no perspecitive adoptive homes exist should NOT be rounded up and removed from the range.Adoption pre-selection and mustang makeover competitors...no more 45 000 horses in long term holding facilities)

5) The agency should reestablish the historic ranges of America's wild horses and burros as they existed in 1971 when the WFHBA was enacted. (Then 53 million of public land now approx 32 million left).


6) The boundaries of original HAs (herd areas) should be examined carefully to ensure that wild horse and burro seasonal migratory pattern, as well as the habitat needs of self-sustaining populations, are provided for.(Checker pattern is very difficult for the animals to navigate and if arrangements to consolidate are made, they should NOT result in REDUCTION of wild horse range)


7) The agency must immediately disclose its data and rational for permanently removing wild horses and burros from over 21.5 million acres of public lands since 1971 (data it had originally promised to release in March 2009), and must reevealuate all Ha's from which wild horse and burro populations have been entirely removed to assess their suitability for the eventual return or reintroduction of these animals.

8) Wild horses and burros (especially geldings) currently in privately contracted Long Term Holding facilities and incapable or reproducing (approx. 1/2 in holding today) should be returned to the wild, thereby actualizing a huge cost savings to taxpayers.

9) Fences and gates used to rotate livestock but which prohibit wild horses and burros from roaming freely within their historical herd areas should be removed.

10) The BLM should review its forage allocation process to ensure that forage is allocated comparably to wild horses and burros, livestock and wildlife as required by regulations.

11) The agency should establish AMLs that ensure self sustaining and genetically viable wild horse and burro herds and that are based on up-to-date and comprehensive sampling of rangeland vegetation production, composition, abundance, vigor and other factors affecting rangeland ecology and health.

12) The agency should take steps necessary to guarantee that adopted wild horses and burros are protected from commercial exploitation for the remainder of their lives. Persons selling horses and burros to slaughter should be prosecuted to the full extent of the law and banned from future adoptions, as should those individuals found guilty of animal neglect or abuse.

13) Nominations and appointments to the National Wild Horse and Burro Advisory Board must be conducted objectively and -ideally- by an independent third party with the goal of identifying the most qualified individuals to serve on a diverse and active committee - one with a genuine interest in the proper management and conservation of wild horses and burros, not merely one that will defer to BLM proposals and decisions.

14) The agency should evaluate with assistance of independent scientific experts, which wild horse and burro herds offer god public viewing and interpretation opportunities, are of ecological, historical and cultural significance, and/or have unique and interesting characteristics for special designation as  "ranges" as provided for in the WFHBA

15) The agency must conduct an independent and candid review of its National Wild Horse and Burro Program and related land-management programs and policies and - pursuant to NEPA - prepare in a timely fashion and with full public involvement a PROGRAMMATIC ENVIRONMENTAL IMPACT STATEMENT. In the interim, the agency must refrain from management actions that compromise the health, genetic viability and overall welfare or our nation's wild horses and burros

(Excerpt from "Managing for extinction" by the Animal Welfare Institute.)

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