ACTION ITEM CLOSED
However this article has good info on how to analyze a document.
The Bureau of Land Management has recently released the roundup schedule for winter 2015. https://wildhorseeducation.org/2014/12/20/blm-2015-roundup-plans-begin-with-cawp/
Before a proposed action can occur BLM must generate a “decision” reached through the National Environmental Policy Act or “NEPA.” (For a “crash course” in NEPA go here: https://wildhorseeducation.org/nepa/)
Many of the operations on the schedule will meet their compliance without any need for further public comment like the operation at the Pine Nut HMA (200 wild horses removed, with a 332 target for capture) through a “DNA.” DNA stands for “Determination of NEPA Adequacy,” in BLM terminology that means that plans have been adequately analyzed without the need to generate new analysis. https://wildhorseeducation.org/2014/12/22/what-is-a-wild-horse-dna/
However the Fish Creek HMA has had a new Environmental Assessment (EA) created to address a ten year strategy. The document was just released and public comment is due by January 23.
Wild Horse Education (WHE) has been actively documenting and addressing multiple concerns on an ongoing basis in this area with BLM. These issues included the necessity of water hauls during the drought (noted in WHE report from 2012 https://wildhorseeducation.org/2012/07/13/drought-in-blm-wild-horse-management-areas-being-watched-closely/) and issues surrounding privately owned domestic livestock in violation of permit terms https://wildhorseeducation.org/2014/12/16/livestock-trespass-in-wild-horse-area/
A brief background of Fish Creek and concerns arising early 2014 https://wildhorseeducation.org/fish-creek-range-2014/
We will give you a sample comment letter to either sign your name to or to use as a template for your own comments at the end of this article. But we are “Wild Horse Education” after all and can not pass up this opportunity to explain process and to show specific examples of note within the EA under discussion. If you simply want to view the comments scroll to the bottom of the post.
(Edit January 13: If you have signed onto the letter we are beginning to compile your names and contact information. As this process continues we will send you all an email update to the conversations conducted based on your input. We will also send you an alert when the Final EA is published. We are pushing for a strong post operation data collection component on Fish Creek. We will be actively involved and will keep you all in the loop. We thank you all for raising your voice in support of creating comprehensive plans that provide data to use in addressing all areas of management within the HMA where the horses live as well as the continued effort to preserve and protect this herd in the very ‘heart of Nevada.’ Thank you).
To view a copy of the EA go here: http://bit.ly/2015FishCreekEAComments
From BLM press release: The Proposed Action includes gathering approximately 500 wild horses, vaccinating approximately 125-150 mares with the fertility control drug Porcine Zona Pellucida (PZP) and returning about 300 mares and studs to the HMA. Approximately 200 excess wild horses, primarily three years of age or younger, would be transported to BLM facilities and prepared for adoption to the public.
As with each part of the NEPA process comments to each document should be formatted to be applicable to the “step” the document covers. For comments to be relevant to an “EA” they need to provide either a specific area that was not appropriately analyzed or provide additional information for analysis.
Please note that the issues with the livestock permittee are outside the scope of this EA. Each use of public land has a protocol unique to that use under law. Issues are being addressed by BLM (we have been actively engaged in ongoing dialogue about these concerns) and we expect to have a formal response from BLM on the matter and any decision concerning that part of process shortly. We will keep you updated. (note: page 27, section 2.5.1 deals with livestock within the parameters of this EA) (update January 16, Livestock permittee gets bill for trespass: https://wildhorseeducation.org/2015/01/09/nevada-rancher-gets-bill-for-livestock-trespass-in-wild-horse-area/)
Please note that setting AML (or the number of wild horses to be “managed”) is also outside the scope of this EA. However please note on page 30, section 2.5.5 “Wild horse AML would be analyzed in future Rangeland Health Assessments which would include involvement with the interested public.” and a footnote “Should the AML for the Fish Creek HMA be adjusted following future analysis and decision, the AML targets would be adjusted accordingly,” on page 14.
Beginning on page 12 you should note section 1.6 “Conformance with Rangeland Health Standards and Guidelines.” This section will give you an idea of the “criteria” that any proposed action must work to achieve.
Page 14 is where the Alternatives for the ten year plan are outlined neatly in a chart. (we have screen grabbed the charts for those of you without the band width to download the entire EA)
(Please note that Alt 4 is included in analysis simply to show through NEPA that it is an alternative that would not comply with land use plans justifying the proposed action).
We often hear that no alternative covers any public input. We would like to point out that all options: Proposed Action (moderate fertility control), Alt 1 (No fertility control but a projected 1000 horse removal), Alt 2 (no removal, aggressive fertility control) and of course the standard Alt 3, are all analyzed in the EA.
A detailed written comparison of alternatives follows. Of note is that if fertility control is not used helicopter removals would likely need to occur every 3-5 years to conform with the underlying frame for any alternative. The removals to meet that objective could include what is called “gate cut,” meaning everything captured is shipped to holding. Page 58 also makes this notation (section on population modeling WinEquus) Alternative 1 does not include the use of fertility control to limit population growth, and the population size would be regulated through gathers and removals. The model was set to show only removal of horses 4 years of age or younger in order to transport only the most adoptable horses to BLM facilities for adoption. Through the modelling, the population size does approach the high level of AML by 2025, but requires the removal of over 900 horses through four gather events to achieve this. (and later in the EA describes gate cut gathers associated with this model as an actual likely method).
Of note is that Alternative 2, no removals, has this notation using WinEquus “The ending population in 2025 according to the model would be 100 wild horses higher than the Proposed Action.” (with the initial distinctions between the proposed action and this alternative being no removals and more aggressive use of fertility control with initial application of an additional est. 100 mares) (some of the myths exposed in the anti birth control campaign here: https://wildhorseeducation.org/12928-2/)
(We screen grabbed a chart of alternative comparison below)
When creating a management plan BLM uses population modeling based in WinEquus. The flaws in the system to address the alternatives in this EA are discussed in the EA. However the resulting chart gives a good visual to comparisons of alternatives (if not completely accurate). Please note the estimated number of wild horses removed under each alternative (Alt 1) and the number of wild horses treated with fertility control (Alt 2). BLM uses the term “gathered” to mean “trapped,” not removed. Please note comparisons of Alternatives. (Alternative 3 is essentially the concept of fertility control we have seen in the past, even though we usually do not see it followed through with, with sex ratio skewing as a component).
Of note but not “appropriate” for comments to this EA is the term “AUM.” AUM’s (Animal Unit Months) are the amount of available forage allocated to a given use, domestic livestock/wildlife/wild horses. This allocation is addressed in land use planning in underlying documents referenced as “LUPs” or “RMPs.” This is a part of the process of managing wild horses or burros that we address, and are addressing, in land use planning. We have screen grabbed the chart below so that you can see the allocation as it currently stands for wild horses. (An “RMP” will be available in draft form sometime within the next year for this district and we will alert you to appropriate comment timetables. RMPs take years to write and we have been actively engaged).
Livestock grazing AUMs are listed on page 64, although outside the scope of the actions proposed in this EA (dealt with through separate rangeland health evaluations, terms many of you are coming to understand through the recent rider passed by Congress that places livestock production in a position above funding to do assessments) is included in a chart screen grabbed from the EA.
If you continue to read through the EA you will see tables showing invasive plant species, soil analysis and native plant species analysis. Drought analysis showing precipitation tables for the 3 years. A multitude of photographs plant communities and water sources (or the lack thereof) are included (please note, drought is real).
A common complaint is that any realistic look at how wild horses utilize the range is not present in EAs. We would like to bring your attention to page 81, “Wild horses prefer to drink during the first part and last parts of daylight and tend not to linger at the water source (Ganskopp and Vavra 1986).”
“Mitigation” is a term being picked up now in conversations with the public. That term is used in this document to mean “mitigation of damages” associated with the “proposed action.” In other words, in the analysis of alternatives are the impacts from capture, birth control and release that can be mitigated. Range improvements, forage allocation, AML (number of wild horses on the range) are comments that would be said to be “outside the scope of this EA.” These issues ARE being addressed through the processes that address each area. So in this document things like animal welfare WOULD be appropriate comments under this heading. A Comprehensive Animal Welfare Policy is in the final stages of implementation (inclusion in contract language). As the policy is not complete the latest version of the IM addressing this issue is discussed and added in Appendix. Concerns and comments would be appropriate. (begins page 95) Also see Appendix G, page 163 to view the version of CAWP.
Observation is another area that would be appropriate to comment. The Appendix governing observation is from 2010. We will add the need to update in our comments.
There is a section on history of actions in the HMA. Chart included below.
Reading this EA will not only give you a deeper understanding of the proposed actions and alternatives for Fish Creek, but give you a basis for comparison to actions proposed in other areas and to compare the adequacy of analysis. (We have read a lot of EAs and many have serious gaps in information and analysis of multiple alternatives such as the Owyhee Complex EA where we are still addressing serious flaws).
SAMPLE COMMENT LETTER TO ADD YOUR NAME TO (or use as a guide to create your own). Please note that adding your name to our letter will STILL allow your comment to count (we nave worked out a submission system with BLM). It will assist us in making our other efforts stronger as well. Please see explanations above about dealing with concerns outside the scope of this EA such as forage allocation (AUM) and existing domestic livestock issues. (This letter is the one we will submit on behalf of the organization. Ms Leigh will submit a more detailed analysis and continue to engage other areas of concern).
Mail written comments to the BLM Mount Lewis Field Office, 50 Bastian Road, Battle Mountain, NV, 89820, attention Michael Vermeys, Acting Field Manager.
Comments may also be provided through e-mail to this address: 2014FishCreekGather@blm.gov.
We respectfully submit the following comments and recommendations to the Preliminary EA for the Fish Creek HMA and thank you for the opportunity to participate.
Environmental Assessment DOI-BLM-NV-B010-2015-0011-EA
EA Section 2.3.5, Animal Identification and Monitoring We would like to recommend specifically an intention to include monitoring to gather additional information on herd dynamics and effects of helicopter drive trapping/ PZP administration/release on existing wild horse population. As comparative data would be available from consecutive years prior to operation from drought monitoring, band restructuring information could be obtained through use of game cameras and field monitoring immediately after release. The additional information could be pertinent to complete analysis of determination of appropriate future capture methods in this HMA.
On page 58 it is noted that PZP branding with additional identifier for mares will be utilized. We would recommend utilizing some type of HMA brand to assist in data collection post operation of studs released for tracking purposes relevant to herd structure (including genetics information) and confirmation of HMA exchange.
In addition page 58 makes notation of genetic analysis. Historically this analysis is utilized to track herd generalities. We would strongly suggest inclusion of a tracking method specific to each individual wild horse released. The information could be utilized to create complete analysis of any actions utilizing birth control treatment in order to conform with guidelines 5.4-5.7 of the standards of “Healthy Wild Horse and Burro Populations” noted in section 1.6.
We offer in support of our comments (1-3) the National Academy of Sciences (NAS) review, June 2013, page 3 (Findings) “Management of free-ranging horses and burros is not based on rigorous population-monitoring procedures.” As protocol recommendations from the report are forthcoming inclusion of such additional actions would be appropriate.
Appendix F, Public Observation IM dated 2010, should be replaced or amended to include the state IM of July of 2014. Please update.
In addition to trap site adoptions we would like to see inclusion of data that tracks wild horses removed from Fish Creek through the system of holding. Tracking information could be relative to future analysis of any selective removal alternatives proposed in future action alternatives.
Additional comment: Field monitoring of current population of wild horses residing in the Fish Creek HMA shows mares currently in the late term gestation phase. Although we do realize that CAWP is included in it’s draft form as an Appendix to all proposed actions, we must make this notation in recognition that animal safety is a primary concern. Although perhaps outside the scope of this EA we recommend during pre-operation briefing to include a need for parameters of distance, speed, temperature and handling to be strictly monitored and adhered to.
With the inclusion of the comments and recommendations contained in this letter we support the proposed action as the option to best achieve all mandated objectives through a moderate adjustable approach. We would like to recognize the flexibility of the proposed action, based on ongoing monitoring, to limit removals and adjust implementation of fertility control to achieve preservation of historic herd composition and to adjust AML.
We would ask that additional consideration be given to reduction in the number of horses removed based on population modeling used in Alternative 2, no removals, has this notation using WinEquus, “The ending population in 2025 according to the model would be 100 wild horses higher than the Proposed Action.” We ask that you consider an initial reduction of numbers removed and incorporate into the “proposed action” a reduction from 200 to 100 wild horses to be removed, with the recognition of ongoing selective removal and fertility control measure (adjustments based on monitoring would be available in the ten year plan). Holding space is a real concern as we move into a potential year of additional stressors due to drought and increasing concerns over availability of space should an emergency such as fire occur.
Wild Horse Education
and the undersigned members of the public
To add your name to this letter fill out the following form
Wild Horse Education will be active with continuing to monitor this HMA and engage in areas outside the scope of this EA to benefit wild horses in the area and create accountability to all aspects of rangeland health and wild horse viability. Main Website: http://WildHorseEducation.org “Join us with ‘one click’ of your mouse on the range, roundups, courtroom, meeting and holding facilities.” Help us stay on the road to real change.
Slideshow including charts, wild horses of Fish Creek, trespass livestock, a few of range and water