Pryor Mountain Wild Horse Range JMAP Open for Comments

By Laura Leigh on April 14, 2020

The BLM Montana-Dakotas office manages one HMA, the Pryor Mountain Wild Horse Range HMA. A Preliminary Joint Management Area Plan (JMAP) has been released for public comment.

The BLM handbook notes a Herd Management Area Plan (HMAP) to serve as a baseline to inform land use planning and removal EAs. An HMAP will serve as an underlying document to inform any proposed action (ie mining, oil and gas, etc) subject to the National Environmental Policy Act (NEPA). The JMAP is the equivalent of the handbooks “HMAP” for the Pryor Range. (To learn more about NEPA click HERE).

It should be noted that only a handful of HMAPs exist in the West; 270 HMAS and only 5 have an HMAP. (example: the state of NV has 83 HMAs and only 1 has an HMAP).

Comments must be submitted on the Pryor JMAP no later than close of business on Friday, May 15, 2020

You can find material, and the comment submission button, at this link: https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&projectId=1502632&dctmId=0b0003e881535a67#

Noted management goals for the Pryor herd in the JMAP:

Approximately 90-120 wild horses would be managed as a breeding population.
Balancing sex ratios of the population to be adjusted to a 50/50 male/female sex ratio.
Wild horses that display good confirmation and a variety of colors will be selected first to by placed back on the JMA.
In keeping with wild horse management decisions from the 2015 RMP, maintain a mix of colors and bloodlines within the JMA, not allowing any specific color or bloodline to dominate. Maintaining all bloodlines will no longer be a management goal.
Any individuals who are part of a dominant bloodline could be considered for removal.
Stallions or mares may be from a different HMA but displaying similar or desired characteristics of the wild horses within the JMA may be released to maintain or increase the genetic diversity of the herd.
Remove excess animals through a selective removal criteria.
Excess animals will be removed to the low-range of the AML upon determination that excess animals are present.

You can view other stated objectives at the link noted above.

Substantive comments addressing the listed objectives, and suggestions for alternative goals, must be received by May 15.

(Do these objectives sound like wild horse management or a range breeding program? Do you have substantive comments that reflect your stance? If so, they need to be in by the deadline.)

Why don’t we have a petition or sign on letter? For public comments in NEPA (EAs, MAPs, etc) sign on letters are irrelevant and dismissed. In recent litigation (Case No. 3:18-cv-00059-LRH-CBC, Triple B) an org tried to use a petition to demonstrate a legal threshold. It failed. Petitions and “sign on” are good for legislative issues, not NEPA comments. If we gave you a petition? your input would be dismissed. Yes, we know there are still petitions for NEPA comments. Federal agencies and courts will dismiss your investment as just “button click.” Take the time to craft a comment to demonstrate your interest as a taxpayer with a stake in the outcome.

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The Pryor Mountain Wild Horse Range is one of only four designated wild horse and burro ranges in the country. The Pryor Mountain Wild Horse Range was created by order of the Secretary of the Interior, Stewart L. Udall on September 9, 1968. prior to the Wild Free Roaming Horses and Burros Act (WFRH&B Act) of 1971.

From the WFRH&B Act: “range” means the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros, which does not exceed their known territorial limits, and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple-use management concept for the … “

In practice BLM only uses this standard in management documents addressing “Wild Horse and Burro Ranges” and not Herd Management Areas (HMA). To date, no data has been provided by the bureau to demonstrate any process the bureau undertook to make that determination; they simply claimed they had that authority to use the definition of the word “range” in the Act and apply it only to “Range” with an upper case “R.”

The Pryor Mountain is an the area where BLM will note the mandate “managed principally, but not exclusively, for wild horses and burros.”

The Pryor Mountain Wild Horse range comprises about 38,000 acres and has an AML of 90-120 wild horses.

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