BLM has created a district wide removal EA for Southern NV. Is this the “new way” for BLM paperwork and our litigation? We have been waiting for BLM to file one of these. We are ready.

The Bureau of Land Management (BLM) Southern Nevada District Office (SNDO) has prepared an Environmental Assessment (EA) to remove wild horses and burros from 5 Herd Management Areas (HMAs), one conjoined Wild Horse Territory (WHT) managed in conjunction with Forest Service and a Wild Horse Range (different legal designation than an HMA). These areas comprise all of the territory in the district where wild horses live.

The agency makes a claim there is a need to prepare the EA to address “vehicular collisions” in the district. However, this is a district wide removal plan, not a site specific document. These areas (for the most part) are not conjoined, are multi-jurisdictional and essentially represent the first district wide removal plan we have seen come out of the agency. (you can read the EA here: https://eplanning.blm.gov/epl-front-office/projects/nepa/94207/20008620/250010151/DOI-BLM-NV-S030-2018-0002-EA.pdf)

This EA is an example of BLM becoming increasingly lazy in their responsibilities to “manage.” The only creativity we see recently from BLM is to amp up destruction with the least amount effort expended.

Lumping all HMAs in a district in an umbrella to justify any removal, in the entire district for a ten year period, is not acceptable. BLM already has the ability to tier a “public safety” emergency to an existing EA for an HMA. The district needs to create EAs, site specific NEPA, and include vehicular incidents in each EA.

Southern NV is notorious for not doing anything at all until a crisis hits (this is the district of Cold Creek).

BLM as created a “district issue” EA, not a specific management action EA for an HMA. If BLM claims this is “site specific NEPA” what will be next? Districts (or states) will do one document to cover all HMAs and just claim “overpopulation” to roundups tens of thousands of wild horses and burros? NEPA was not intended to be an umbrella, it was to be the “fine tooth comb” of analysis work.

We will comment on this EA.

We will also file our own distinct “district wide” litigation. Will BLM fight our challenge and negate it’s own EA, or will they withdraw this EA?

If BLM moves forward with these district wide plans they will open the door for rapid removals with little to no analysis. However, they will also open the door for a new kind of litigation. A kind of litigation we have had in the planning stage for over a year. We had a feeling BLM was going to try to take this shortcut on NEPA (analysis).

BLM is looking for any opportunity to implement the mass removals proposed in backdoor deals by the Cattlemen’s Ass’n and partners. Those deals also involve massive conflicts of interest by BLM Deputy Directors including the current BLM Chief, William Perry Pendley. (We have filed against Pendley and will have news soon.)

The next few months will be a pivotal time to determine how litigation in decades to come will be filed and fought. 

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