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Jan 22, 2014

Focus:Animal Welfare
Action Request:Protest
Location:United States
To:
 blm_nv_ca_sagegrouse_eis_comments@blm.gov ,
 
Subject: NVCA GRSG Draft EIS Comment, Wild Horses

Bureau of Land Management

Dear Madam, dear Sir,

The Greater Sage Grouse Planning Strategy (GSGP document encompasses much of the land base in the Nevada-California sub-region and will affect land use policies in these areas for decades. Included in this area is critical habitat for large numbers of federally-protected wild horses and burros.

Unfortunately, the plan and the Environmental Impact Statement (EI do not adequately protect wild horses and burros in accordance with federal laws and regulations. The information included in these documents is outdated and incomplete. The EIS does not adequately reflect the Bureau of Land Management’s (BLM’s) MANDATE to protect wild horses and burros vs. its DISCRETION to authorize livestock grazing.

Impacts to wild horses are not adequately analyzed. For example, the EIS states that “Under all alternatives, no direct change would occur to areas allocated as HMAs [Herd Management Areas]/WHBT  [Wild Horse and Burro Territories] for wild horses and burros" (page 50, CH 5). However the rest of the paragraph outlines how each alternative will restrict wild horse and burro use.

None of the alternatives analyzed adequately protects wild horses and burros. In some sections the EIS wrongly lumps wild horses together with livestock. Alternatives described would allow the BLM too much discretion in forage allocations to private livestock and wild horses.

In some alternatives, reductions in forage allocations would be borne equally by livestock and wild horses, despite the fact that livestock vastly outnumber wild horses in terms of: 1) land impacted (66% of BLM land used for livestock vs. 12% of BLM land used for wild horses); 2) forage allocated within wild horse Herd Management Areas (82+% for private livestock vs. 18% for federally-protected wild horses); and 3) population numbers (livestock outnumber wild horses by at least 50-1 on BLM land).

Finally, the EIS fails to consider the significant differences in range impacts caused by livestock vs. wild horses.

In summary, the final EIS must include the following:

1.    Language to direct all BLM districts to preserve wild horses and burros above a level that allows for adequate genetic diversity. Genetic diversity must be specifically defined in the final EIS.

2.    Directives that prohibit the reductions of current Animal Unit Months (AUM of forage allocated for wild horses and burros. The EIS must outline a reduction, and if necessary elimination of livestock grazing, before a reduction of AUMs for wild horses and/or burros. Discretionary livestock grazing occurs on a drastically larger scale in critical sage grouse habitats than wild horse and/or burro usage.

3.    Provisions to allow for increases in wild horse and burro Appropriate Management Levels and for restoration of zeroed out (Herd Area) habitat.

4.    Requirement that any land use policy changes resulting from the sage grouse plan be in conformance with the National Academy of Sciences’ 2013 recommendations for reform of federal wild horse management program.

5.    Detailed and comprehensive information on the following:

a.    Clearly defined maps that delineate all HMAs and Herd Areas, data on number of horses estimated within each area, AUM allocations for wild horses and/or burros COMPARED with livestock usage.

b.    All information describing and documenting the differences between wild horse and burro and livestock range impacts;

c.    All genetic reports and documentation of genetic viability status of all wild horse and burro herds within the planning area.

Given that the EIS is analyzing a plan that may significantly impact wild horse and burro management, providing for the protection of a viable wild population of wild horses and burros (a population capable of reproducing itself without human interference and the resources available to sustain that population) is not outside the scope of this document. The EIS is analyzing an all inclusive management plan that will significantly impact protected wild horses and burros, as a result, we expect all of these issues to be addressed in the final EIS.

Sincerely:  
Visibility: Everyone
Posted: Wednesday January 22, 2014, 10:45 am
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Sun c. (95)
Sunday January 26, 2014, 10:13 am
Done! I removed the smiley face in the letter...very cute! But just in case.

salome reis (0)
Thursday February 6, 2014, 8:37 am
done

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Anneke Andries
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