Posted below are the comments Wild Horse Education is submitting to the BLM Resource Advisory Council (RAC) tomorrow, June 26th. We thought that it would be interesting for you to see them as we file new motions and work on replies. Remember the Owyhee case is also active with hearing scheduled in July. We will update as we can.

Click Image to watch video of Triple B

Comments to the RAC

meeting date 6/26/2013

submitted by Wild Horse Education

Laura Leigh

Subject: Three HMA (previously called Triple B) addition Antelope Valley, bait and water trapping

It is with significant frustration that we make these comments for consideration on the bait/water trapping operation set to begin anytime in the above mentioned areas:

• All avenues to address concerns over lack of transparency have gone unheard. This area gained the first court ordered Temporary Restraining Order and subsequent Preliminary Injunction in history to conduct issues. The case is still active in federal court. To dismiss public concern over activities that will now take place behind a veil of secrecy is dismaying. How can the BLM claim on one hand that transparency is a priority and then on the other create such a plan, let alone being on the verge of implementation? It is contrary to even a pretense of transparency and public trust. Moving forward with such a plan is unconscionable.

• Limiting COR observation to 25% of operations, at the control of the contractor, is unacceptable. In every single BLM assertion of any existence of a handling protocol, memorandum or other assertion of policy, BLM repeatedly states that all premises of handling are determined by the COR on a case by case basis. If the COR is not even present how can BLM even assert that handling of animals is appropriate? In light of the court actions, subsequent Triple B Review team findings, continued court actions in other districts to inappropriate handling, continued actions in the Triple B case and ongoing controversy that includes significant media coverage moving forward with the plan is irresponsible to both the public and the animals BLM is mandated to care for humanely.

The current plan is significantly flawed in many additional respects:

1. The Antelope Valley had a removal operation in 2011, 2012 and is included in the significant assessment of the proposed eco-sanctuary. That proposal might require the area to be devoid of wild horses. However the NEPA process is not complete. Moving forward in the Antelope Valley is premature and again creates public distrust. The eco sanctuary is significantly flawed and the inclusion of this area again implies that there is an underlying agenda that is inappropriate.
2. Boyd Spratling has been significantly quoted as saying that field spaying and vasectomies are viable alternatives and are ready to implement. The plan as written would allow such activities to occur without the public ever being aware. There is significant fear that BLM will implement this type of activity during operations.
3. In the last year it has been revealed that many sale authority animals removed from the range have gone to kill buyers. Without public supervision and COR monitoring BLM can not reasonably reassure the public that all animals captured will be accounted for.
4. Implementation of any bait/water trapping during times of year where foals are being born and are very young, where traps are monitored with less than constant diligence, creates the very real prospect that foals will suffer needless and perhaps fatal consequence. Anyone that has been around foals and panels know that foals can easily roll under and not be able to get back to their mothers. foals can be trampled as animals panic as they are trapped. Waiting to implement a bait trap operation until September would be advised.
5. The proposed operation would cut off all water sources in large areas impeding animals from drinking during the heat of summer. Panels can often times inhibit herd movement until a period of acclamation is achieved. It is advised that a tiered trap approach be utilized to limit the distance horses need to travel if they refuse to utilize the areas where traps are set.
6. Numbers of animals to be removed from each area must be identified. Simply leaving an open ended option is not acceptable.
7. In light of the recent NAS report we would hope that BLM would reassess any action until scientific data, suitable under the NAS review, is available. Site specific data Complex wide that includes transitory animals, herd migration, etc. should be part of a reevaluation.
8. Grazing leases being renewed, and new permits being issued, and the many new uses in the district on public land are creating significant public concern. The lack of specific information as to numbers to be removed from each area and the lack of transparency are fueling the impression that the operation will negatively impact the herd in ways that are irretrievable as a way to create needed space for the other uses.

Lastly, it is extremely distressing that comments on these issues to the BLM during scoping, assessment, etc appear disregarded. It appears that the decision to implement this operation (one BLM asserted was impossible in an area this large but is now possible in an area of extreme scrutiny), was decided long before any public comment period. The plan is decided as it was drafted. In the process an interested parties First Amendment rights have been tossed aside. If this can happen with one use on public land it can happen to any. I ask that the RAC take these comments into consideration as they make recommendations to the BLM.

Thank you,

Laura Leigh

President, Wild Horse Education

Reno, NV