The agenda was set back in 2009. We have been dragged back a decade; not just on protections for clean air, water, etc., but also in wild horses. Ken Salazar created the “Salazar plan.” Even though formally rejected, implementing that agenda has been a goal of BLM since it was introduced. (Yes, former Secretary of Interior Salazar that helped shuffle off nearly 1800 wild horses to a family friend for slaughter. )

Today, the “Path Forward” is a plan to accelerate that agenda. What we are seeing today is not new. We have been fighting this exact same mechanism for over a decade. It is just more obvious as the “corporate partners” came “out of the closet” this year (HERE). There are many that “sell you” the idea they are fighting for change, but have not been in a “fight” for a very long time and get in the way of those fighting. (more soon)

We really have been dragged back in time a decade.

Twin Peaks is now on the list.

Twin Peaks father and son, mom across the alley. Dad was found in a holding facility, mom and son never seen again.

The Bureau of Land Management (BLM) has released the final decision documents for the Twin Peaks Area.

The Twin Peaks HMA covers nearly 800,000 acres in Lassen County, California, and Washoe County, Nevada.  AML (stocking level set by BLM) for wild horses is 448 – 758 animals. The AML for burros: 72 – 116. BLM writes they “believe” there are 2350 wild horses and 520 burros and 40 mules. (Legally speaking, the use of hat word is “clever.”)

The Alternative chosen (the decision made by the BLM): 

The HMA would be gathered to low AML (448 horses, 72 burros) which would comprise the potential breeding population. After low AML is reached, to reduce the number of animals in long term holding, a portion of male horses would be sterilized, either by gelding (neutering) or vasectomy, and returned to the HMA. These non-reproducing males would bring the population closer to mid-AML (from low AML), but not to exceed a 60:40 male to female ratio. No male burros would be gelded or neutered to be returned to the HMA. All animals treated with any type of fertility control would be freezemarked and identified according to current policy. Intact studs and mares released back to the HMA would be selected to maintain a diverse age structure, historical herd characteristics, and correct conformation.

When you do the math, under this EA BLM plans to remove wild horses over “a period of time.” It does not state there will be one removal of 1102 wild horses and 448 burros.If done over the ten year time frame, the EA is set as a frame from multiple roundups that could remove more than the math, on todays numbers, suggests.

The EA also continues to do “sex skewing” that has not demonstrated to effect population growth and one “mother nature” will work against to return the herd to the “male/female” ratio that the herd contains based on natural reproduction in that herd (the ratio of females born will increase, it’s what nature does.)

What we want you to note is the number of sterilized animals BLM plans to return to the range: “After low AML is reached, to reduce the number of animals in long term holding, a portion of male horses would be sterilized, either by gelding (neutering) or vasectomy, and returned to the HMA. These non-reproducing males would bring the population closer to mid-AML… “

If you pull out a calculator, complete the objectives in the EA in one swoop, use “mid AML” as a mathematical 608 wild horses, use the sex ratio skewing outlined, the herd in the 800,000 acre area looks like this:

365 males and 243 females: 269 stallions, 96 (geldings or vasectomies, not specified), 200 treated mares (the EA leans toward GonaCon, not PZP), 43 reproductive females. (This would only represent the “math” if BLM actually knows which horses die on range during the life of the EA. If the aggression on the range increases mare and foal mortality? The actual ratio wont be known.)

Behavioral ramifications created in this type of situation are not appropriately analyzed.  The aggression on the range, in the fight to obtain reproductive females, will increase, by both stallions and vasectomized males. This is the first step toward turning Twin Peaks into what the Sheldon herd was like before it was wiped from the face of the earth. Throw in a percentage of spayed mares? This is exactly what Sheldon (USFWS) was before the end. (Sheldon is gone. The herds that lived there were zeroes out. But before that happened? Sheldon was an experiment ground for brutal minds that created the most behaviorally “messed up” bunch of wild horses. (we will do another “flashback” article this coming week.)

You can view the Finding of No Significant Impact (FONSI) HERE. 

For those looking to understand any “wild horse problem” it is vital to begin to understand the sham of public process, analysis, equity of management. These “roundup EAs” are a core problem.

It is important to understand the way BLM does NEPA for wild horses, compared to the manner in which it performs the function for all other interests. We do not see Herd Management Area Plans (HMAP) that address actual preservation objectives for the herd and protections of habitat for wild horses. We see “management assertions” in NEPA for removal documents.

Stocking levels (AML) and forage allocations are regurgitated, not analyzed or changed. Comments requesting validation or adjustments are “outside the scope” of the EA.  Requests to protect wild horses from encroachment from mining and livestock? Also “outside the scope of the EA.”

The roundup Environmental Assessments (EA) is considered a “management” document but is titled, Twin Peaks Herd Management Area Wild Horse and Burro Gather Plan.

If NEPA was done as if we were a profit driven interest like livestock or mining? We would have an actual voice in the process. If wild horses were truly manages as “wild” by BLM the process would be more akin to the massive sage grouse documents. (Wild horses are the only living heartbeat managed by BLM. With sage grouse they had to be involved because USFWS was on the verge of listing sage grouse on the ESA. BLM only does these “gather EAs” to govern removals, there is not a place for engagement through NEPA for real management.) 

This EA has an Appeal (protest) period through December 2. Appeals are filed with the Interior Board of Land Appeals (IBLA, a form of public land court). BLM usually allows for a period of time of 30-45 days post close date on Appeals as a measure of when to begin an action. Many advocates skip the IBLA process and wait until a roundup is on the schedule to go into Federal District courts. There are a number of reasons for this; one is that the IBLA has no electronic system for filing (making briefs more difficult to track and manage through post offices), the system in IBLA is often referenced as “cow court” by environmentalists as the primary function the IBLA was set to serve was to carry the massive load of legal actions filed by the livestock industry. (When you hear BLM or livestock complain about advocates that file litigation? We have begun a preliminary count of legal actions. At this juncture our research shows: actions filed by livestock in the last 10 years outnumber wild horse suits by 100-1 and rising.)

If we look at past actions as predictors of future actions? BLM plans to start Twin Peaks no later than summer 2020 and could begin as early as this February. (Helicopters can only fly from July 1- the last day of Feb.  Bait trapping can occur all year. BLM is completing a secretive removal of 1250 in NV via bait trap. Twin Peaks could be done that way… even though in the past BLM claimed it was impossible.

It seems the “impossible” is only “possible” when it suits a predetermined agenda. BLM still says darting is only “possible” in tiny areas as they obstruct anyone from proving it can be done in large areas.

The agenda was set back in 2009. Ken Salazar created the “Salazar plan.” Even though formally rejected, implementing that agenda has been a goal of BLM since it was introduced. The “Path Forward” that was incorporated into the BLM report to Congress in 2018, cleared the way.

Coming soon:

2009, Salazar, the last of the Sheldon, and the fate of the wild (what did advocacy do, what did BLM do, and why we now have “Path Forward,” a regurgitation of the Salazar plan. 

We will also have news on WHE field work and a new legal action this week. 

~~~~

Help us stay in the fight! All of our work is possible because of your support. Thank you!