BLM wild horses in Flanigan, Dogskins and Granite are north of Reno.

BLM press release:

CARSON CITY, Nev. – The Bureau of Land Management, Sierra Front Field Office is requesting any data, other information or photographs pertaining to the vegetation condition, utilization levels, riparian condition and wild horse condition within the Flanigan Herd Management Area (HMA). The HMA is located west of Pyramid Lake. Data must be submitted byApril 23, 2018.

After the data is received, the BLM will prepare a draft Evaluation of the Flanigan HMA. When completed the draft Evaluation will be available for public comment before it is finalized. The Evaluation will be used in drafting a Herd Management Area Plan for the Flanigan HMA.

The Evaluation will describe the history of the HMA, condition of riparian areas based on functional assessments, and vegetative trends based on rangeland health assessments. The purpose of the Evaluation is to assess the existing conditions of the HMA, and to assess if the objectives of maintaining a thriving natural ecological balance in relationship to the multiple- use mandate of maintaining a healthy range for wildlife, livestock, and wild horses is being achieved.

To be considered, the data can be sent electronically to blm_nv_ccd_whb@blm.gov or submitted by mail or in person to the Carson City District Office at 5665 Morgan Mill Road.

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What and why, this is important. 

Process is an extremely important aspect of any effective advocacy. As advocates we know you are aware of the constant confusion over process and that makes it difficult to distinguish the distinctions between effective advocacy and the “hamster wheel” of rhetoric.

The budget debate for 2018 (2019 has just begun) is a clear example of the consequence. Frantic, frustrated and confused many in the public rode a roller coaster thinking the issues were addressed, only to receive the next frantic email blast asking for you “fight the budget.” Understanding process will save you a feeling of being on a constant roller coaster of confusion. (a magazine is available to help you understand how all bills, the budget included, become law and where wild horses fit into the “big picture” HERE).

The current framework for wild horses (and it can change with a policy memo as BM has broad discretion with how wild horses and burros are managed) is governed by something you here referenced as “NEPA.” The National Environmental Policy Act (NEPA) requires and analysis of any action proposed by a federal land management agency. (you can read a simple guide to NEPA HERE).

When doing a NEPA analysis agencies determine compliance with multiple factors for the proposed action; land use plans, current management laws and directives, handbooks.

This press release is using some terminology that will be new to many of you. “Evaluation of the HMA.” This is the pre-work for a “Herd Management Area Plan,” or HMAP. An HMAP would then become an underlying document to any other action like a removal of wild horses.

BLM making a public request for data prior to creating a management document is usually referenced as a “scoping comment period.” It is important for advocates to engage at this level, or the only voices at this level will continue to be the ones advocates disagree with.

We applaud BLM Carson District for changing the way they make a scoping request in this instance. Traditionally using the phrase “comment period” has generated masses of sign on letters, mailers, and petitions that are most often theoretical in nature and do not address the purpose of the portion of the process of gaining relevant site specific information. The entire purpose of public comments is to ensure full analysis. The best way to ensure full analysis to try to complete a comprehensive data set.

Once as much information is gathered an HMAP can then receive a “public comment” to incorporate public interest.

This is the first such request we have seen from BLM in wild horse management. What they do with any relevant data is yet to be seen.

We hope all BLM offices make this type of request standard practice. Not only will it assist BLM with filling in gaps in their own data set, it will begin a dialogue where it needs to begin, the beginning. 

We will walk you through the steps of HMAP creation in a webinar. Wild Horse Education has completed three draft HMAPs as we await, as patiently as possible, for other districts to begin a process that reflects the intention in the Carson press release. WHE has done extensive work in many HMAs over the course of the last decade that evaluate all underlying factors, gathered data, and created baselines for planning and management. We are awaiting, a long time now, for those districts to move these discussions into a request for input. We will announce the webinar date soon.

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You can help us stay on the range. We are in the process of completing the spring data run in multiple HMAs in the West. Contributions will receive a free gift, an E-Zine on one area that explains a lot about what is happening to our wild horses. (more info HERE)