NDoA Meeting and Action Request

On July 31, 2012 at the Nevada Department of Agriculture meeting Dr. Boyd Spratling requested an Agenda item. He has requested that the Nevada Department of Agriculture (NDoA) create “letters” to various officials addressing the BLM Drought management plans (specific Item Battle Mountain).

Dr. Spratling is a member of the NDoA Board and also a member of the National Wild Horse and Burro Advisory Board.

Dr. Spratling did not discuss any specific to the Drought EA of the Agenda item in his presentation but created an overview statement that addresses removal of wild horses as the mitigating factor for drought.

Horses near the area of one of the water hauls in Fish Creek, June 2012

He failed to present any provision in the WFRH&B Act that is the legislation whose intent was to protect these animals as integral and to be managed as “wild” on public lands. He failed to address the real damage to the range being caused by over utilization by domestic livestock.

We ask that you take this opportunity to craft your own letter to representatives in Congress and those within the BLM/DOI structure. Suggestions of recipients are: Ken Salazar (Secretary of the Interior), Mike Poole (acting Director of the BLM), Amy Lueders (State Director, Nevada) as well as your Congressional representatives.

EDITED: This Action request is from 2012. Request EXPIRED but left for educational purposes.

Suggested RecipientsActing Director BLM: Mike Pool
E-mail: mpool@blm.govEdwin Roberson BLM
Assistant Director, Renewable Resources and Planning
1849 C Street NW, Rm. 5644
Phone: 202-208-4896
Fax: 202-208-5010
E-mail: Edwin_Roberson@blm.gov

BLM Nevada State Office,

State Director, Amy Lueders

same address: 

Deputy State Director, Natural Resource, Land & Planning: Raul Morales

1340 Financial Blvd.,
Reno, NV 89502

Our letter is posted below. You may use it as a template to create your own. Personalized letters are more effective. Our letter also has the Drought report from the Diamond Complex as an attachment, feel free to use that as a site-specific example.

Links of Interest:



Sample Letter:

August 4, 2012

Ken Salazar, Secretary of the Interior

Department of the Interior

1849 C Street, N.W.

Washington DC 20240

Ken Salazar,

This correspondence addresses the current drought issues in the state of Nevada with particular emphasis on the Battle Mountain District.  The necessity to craft this letter has come after attending the Nevada Department of Agriculture meeting on the 31st day of July this year, 2012.

During the meeting of the Nevada Department of Agriculture Dr. Boyd Spratling presented a recommendation letter to be sent to you from the Board. At no time in his presentation did he address any site-specific (current) information. At no time during his presentation did he recognize the need to evaluate good business practices involving the overgrazing (documented) by domestic livestock on a public resource.

In light of the presentation and subsequent letter you will be receiving from the Nevada Department of Agriculture we offer the following:

First we would like to commend the Battle Mountain District for showing the forethought to create a drought plan prior to the necessity of action. Proactive management practices are sorely needed in public lands management and should be recognized when they occur.

Secondly the damage to the range by permitees that currently utilize many ranges, not only in the Battle Mountain District of BLM, must be assessed on a site-specific basis. Any permitee not protecting public resource through over grazing or causing over grazing through water hauling on public lands must be restricted. Voluntary compliance is always preferred, but if that compliance is not forthcoming formal restrictions must meet with National support.

Third the proactive actions need to be extended beyond the drought. Each use of the land causes an impact to other uses and users. As livestock permitees turn out their animals site specific monitoring of range health prior to, and post, use must be supported. Improper use of one allotment creates a greater impact to neighboring allotments as well other uses. Impacts to other uses as turnouts occur must also be monitored. Impacts to wild horse movement patterns also need to be monitored as these instances create artificial instances of wild horse impact as animals are forced into smaller and smaller areas by fence line closures and considerable numbers of domestic livestock.

In addition the current economic impact to private land grazing operations and those that must supplement feed (provide hay) is considerable. Many American farmers are taking advantage of foreign markets for their products and the price of hay has risen considerably. The current cost for a private enterprise has risen to approximately $10.00-$18.00 per cow/calf pair monthly. The American public is selling their grazing resource to private permitees at current costs from approximately $1.35-$2.00 for the same resource. Public permitees also do not pay a property tax for the grazing land they utilize. This imbalance is particularly unfair to the American public, as the resource is not being properly protected for future use. Consideration of a fee scale that more appropriately reflects current market rate, that perhaps has a built in scale that can reward those properly utilizing public resource, would be appropriate.

We implore you to recognize this crucial juncture in the Wild Horse and Burro Program. A failure to define clearly a viability of use standard for this mandated legal user, of a small portion of public land, has created a crisis. The Crisis not only exists in over burdened holding facilities but on the range itself.  At no time have these populations been managed as “wild and integral” as intended by Congress.

Before any more removals occur on public land a true viability standard must be created. Faulty boundary lines must be evaluated. Genetic viability to each herd must be understood and protected in a manner reflective of a wild population (a population able to reproduce itself, even with a stochastic event) must be defined as outlined by law. The resources required to sustain those populations must be protected prior to other uses being permitted.

The wild horses and burros, under law, have nowhere else to go. They must be protected within the boundaries that have been established until those boundaries are re-evaluated and corrected.

Other uses have considerable public resource to draw upon.

Attached is a site-specific report on an HMA in the Battle Mountain District. It clearly demonstrates that many areas have, and are, being over utilized by private interests creating artificial impact on a population of wild horses that are (under law) to be managed as wild and integral.

We urge you to support the proactive actions currently transpiring in the Battle Mountain District. We implore you to urge the District to continue to create proactive plans toward creating an actual equity of utilization and protection of public resource. True “multiple use” does not operate in derogation of other uses or users. It strives to understand the complexity of interaction that begins with complete and accurate conversation.


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