The Bureau of Land Management (BLM) has multiple “public comment” periods open on documents titled “Draft Environmental Assessment,” or draft EA. These comments from the public are a step required (currently) under the National Environmental Policy Act, or NEPA. The legal intention of this period is to ensure that BLM does sufficient analysis of any proposed action and does not miss any relevant information or area of potential harm. They are not a popularity contest.
When BLM is doing a Land Use Plan or Resource Management Plan (LUP or RMP) the concept of a majority of stakeholder interest holds some weight, or it’s supposed to. In practice the number of comments holds as much weight as a feather on the scale.
Many of our readers have an expectation that we should create “sign-on” letters for EA comments. We don’t. Sometimes we will use our letters to show you how we have formatted so you have an example letter. If you look at the Final EAs, not the drafts, you can see one of the reasons why. A comment is made that covers a distinct concept or area and then the BLM responds. They lump similar comments from the general public under an organization that generated that comment. Looking at the Caliente Final EA you can see how they answer the orgs, even lumping them together, but do not note the number of public comments from a form letter. In other words the comments simply count as the comment from the organization or the originator of a comment (if an individual).
Occasionally we will create a sign on for comments to a document that we are presenting where showing an intense public interest is added to our letter we submit. We did this to assist us as we provided information to the Office of the Inspector General (OIG) and a House investigative team. If control of the House flips in the next election we may finally see some significant movement in areas that require scrutiny from oversight.
However the desire of many Americans to “sign on” to a “comment period letter” demonstrates a growing interest by the public to “do something” about wild horses on public lands.
The ability of advocacy organizations (WHE has it too) to generate 50K comments in less than a week is impressive. The BLM should take note of it. This extreme public interest is indicative of the growing number of people that find agency action unacceptable, even if they do not know how to funnel that interest into the rigid bureaucratic boxes. Several years ago the wild horse loving public did not even know what an EA was or the distinction between federal jurisdictions.
We reviewed the coming roundup schedule as a whole in this article: https://wildhorseeducation.org/2018/06/26/roundup-schedule-fast-look/
At WHE we see the current schedule as an indicator of political control and not a statement of managing for health of an ecosystem or …. anything… but politics. We can see an inflammatory and destabilizing political intention in the schedule as a whole.
In the article on the entire schedule we point out a common thread; hit every area where volunteers need to “walk on eggshells” in a volatile political climate. Is this schedule about controlling voices, excuses to cancel agreements? A volunteer giving blood, sweat and tears to do the job of a BLM employee does not carry the same weight as a “drinking buddy” or political pressure from DC.
Another indicator that you should be aware of is that many of these “EAs” are being presented for public comment along with a final decision record, unsigned. The paperwork to move a proposed action forward without a care about any “number” of members of the public that have a valid objection is clear.
One of the ways that this is accomplished is through exploitation of the fact that in rigid process most of the comments received on an EA are not relevant to that part of the rigid hierarchy of documents. An EA is a subdocument to a land use plan (LUP or RMP). Most comments, like those that reference the number of livestock, are not technically a part of the EA but a land use plan. However in land management all documents are fluid in nature, have tiered drought EAs and multiple mandates. BLM simply counts on a sad reality, there are no comments on record to a land use plan (that may be over a decade old) that object. That is how they play it in a courtroom.
Onaqui is perhaps the most photographed of all of our American wild horses. We will publish the comments we send on Onaqui, but not in this article.
Another org has a sign on letter and if you want to participate in that, we urge you to do it. Your comment wont count in process, but in a legal action the interest demonstrated will give that org an additional “umph” as they present the case to a federal judge. When you sign onto those types of letters do it with that knowledge. Litigation is a last ditch effort and it appears that many orgs will be resorting to an elevation in litigation. All will need your support.
We did an article that outlines a bigger picture and then inserts Onaqui here: https://wildhorseeducation.org/2018/07/03/oldman-a-wildhorse-on-publiclands/
WHE is going to ask that you do something, today.
Remember this? the BLM report to Congress is a 25 page document that is shorter than the Final EA on Caliente. The report to Congress is a demonstration of extreme disrespect to both Congress and the American public. The document is simply a bad joke perpetuated that “BLM and DOI” actually know anything about wild horses except the political faction they aim to grovel to. (if you missed that report read here: https://wildhorseeducation.org/2018/04/27/blm-report-to-congress/)
Call your Congressional representative and urge them to:
Ask your representative to all they can to support an investigation into the BLM wild horse and burro program. Ask your representative to support an investigation into corruption and extremism on public lands.
Deny funding (beyond feeding and caring for captive wild horses) for the BLM wild horse program until Zinke and his staff create a real report on the BLM wild horse and burro program.
Deny all funding for any removal except in emergencies. Deny all funding for experimental procedures that waste tax payer funding.
Ask your representative to demand a full report from Zinke. 25 pages is simply an insult to both you and your Congressman.
Find you rep here: https://govtrack.us
Today Scott Pruit (head of EPA) resigned. We can keep pushing where it really counts and get an investigation directly focused on BLM… from DOI head Zinke on down to the field office. We can. But that is where we really need your hep! Please make your call.
Right now it’s a game of sweep it out of sight. Reward the deed doer and then hide ’em. We need an investigation. https://wildhorseeducation.org/2018/03/26/to-our-readers-ruhs-move-upsets-amodei/
We have been offered a match to contributions up to $5,000 to kick off the “war chest funds” through July 6. All contributions matched.
Categories: Wild Horse Education
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