Subject: Comments on BLM’s plan to remove over 300 wild horses from the South Steens Herd Management Area/Oregon
BLM Burns District Office
28910 Hwy 20 W
West Hines, OR 97738
I oppose the BLM’s plan to remove over 300 wild horses from the South Steens Herd Management Area (HMA) in Oregon.
This is a very popular herd for wildlife watching and photography, and all efforts should be made to preserve and protect these horses on the range, where they belong and are enjoyed by the public.
In this era of sequestration and budget cuts, and at a time when the agency has run out of room to house captured mustangs due to the stockpiling of 50,000 wild horses in holding facilities,
it is shocking that the BLM Burns office is proposing to continue the same broken approach to wild horse management.
Instead of removing wild horses from the range, the agency must fully and properly implement a PZP fertility control program.
The present wild horse population in the South Steens HMA can easily be accommodated by modest adjustments to authorized livestock grazing in the HMA in order to give fertility control the time necessary to stabilize population numbers in the short-term and reduce herd numbers over the long-term.
Since the BLM allocates 72% of forage in this HMA to livestock and not to federally-protected wild horses, this is an entirely feasible alternative.
I urge the Environmental Assessment (EA) for the proposed roundup to include alternatives to:
• Manage the current wild horse population utilizing Catch Treat and Release (CTR) methods for the vaccination of all mares over 1 year of age with PZP-22 or native PZP fertility control. The current wild horse population should be maintained without removals through reductions in livestock grazing pursuant to 43 C.F.R. 4710.5(a). The BLM has a statutory mandate to protect wild horses, while livestock grazing occurs at the discretion of the Interior Department. Livestock grazing is not required to fulfill the agency’s multiple use mandate.
• Capture horses for CTR in a minimally intrusive way and in a manner that preserves the integrity of herd social structure throughout the CTR process. Bait and/or water trapping should be considered as an alternative to helicopter roundup.
• Relocate any horses outside the boundaries of the HMAs back inside the federally-designated range.
• Guarantee humane treatment in capture operations. Recommendations by the Humane Society of the United States and the ASPCA (American Society for the Prevention of Cruelty to Animals) should be incorporated into these standards.
• Provide full transparency for capture operations, including making real time video available from trap sites so the public can monitor this government operation.
I support the BLM Burns District’s plan to manage this wild horse population with natural sex ratios and to reject gelding of stallions, as neither method impacts population growth and both have significant negative impacts on wild horses.
In addition, the EA and final plan should include a complete analysis and disclosure of:
• All information on previous roundups (gathers) in the South Steens HMA, including number of horses captured, removed and returned to the range, as well as the number of mares inoculated with fertility control, the number of stallions gelded and returned to the range, and the estimated post-gather population.
• Detailed annual census information, both actual counts and projected population numbers, including data on which population projections/estimates are based.
• Complete breakdown of livestock grazing in HMA, including active and actual AUMs used over past 10 years.
• Detailed economic analysis of the alternatives, including the projected costs to taxpayers of the proposed capture operation, short- and long-term holding costs versus the cost of fertility control program and forage allocation adjustment to leave and maintain the South Steens horses on the range and avoid removals.
• All genetic analyses of the horses and potential impact of the proposed removal. All genetic reports should be included in the EA’s appendix.
• All forage allocations, usage (Animal Unit Months/AUMs) and listing of livestock grazing allotments within the HMA, both current and annual numbers for each of the past three years to enable valid comparison and analysis.
• A full accounting of all water sources on the range, including an explanation of water allocations for all uses in the HMA, as well as how fencing and engineering of wells and springs for livestock grazing has affected water availability for wild horses and other wildlife species.
• All monitoring data for each area, which includes data that clearly delineates the separate impacts of livestock and wild horse use.
• Information on predator-killing activities within and around the HMA for each of the past three years and analysis of how these activities impact the Thriving Natural Ecological Balance in the HMA.
I expect that the BLM will provide the level of detail described above, which is necessary for informed decision making.
I further expect that the BLM will provide a full accounting of how many members of the public submit comments on this scoping and the EA and what the positions are, as the agency is legally required to do under the National Environmental Policy Act.