A Preliminary Environmental Assessment (PEA) was sent out for comment by the public through Feb 14 for the Surprise Complex. The BLM press release that has the wrong link for comments and sends you to the EA for Twin Peaks. The link for the Surprise Complex PEA can he found HERE.
Update: Apparently the one sent to us, two days after sending out a different release to others, has the wrong link. Other groups received the correct link. Odd?
We are also getting reports of multiple error messages from many of our supporters that are trying to make comments through the BLM website. Not only are the dates on documents bizarre, but the interface is rejecting comments. We will update you when we hear back on remedies.
The Surprise Complex lies in northwestern Nevada mostly in Washoe County, Nevada with a small portion in Humboldt County, Nevada. This is one of the areas managed by CA, that physically exists in NV, and covers the NW corner of the state of NV. California actually has very few wild horses that actually live in the state. The number of wild horses managed by CA, that live in NV, gives an impression that CA has more wild horses.
The Surprise Complex contains six HMAs administered by the BLM Applegate Field Office: Massacre Lakes, Bitner, Nut Mountain, Wall Canyon, High Rock, and Fox Hog which are managed as a complex. The Massacre Lakes HMA is included in this Complex because it is adjacent to the Bitner HMA.
The total acreage of the Complex is 396,674 acres. BLM set the AML at 283-496 wild horses and zero burros. However, burros have been observed in what BLM calls the Surprise Complex because, physically, the area is truly part of the Calico Complex (managed by a different district and BLM does not actually manage wild horses using the logic of the landscape but bureaucratic convenience) and burros move around. Our comments will include the absurdity of “0” AML for burros.
This PEA is another example of where BLM sets AML, forage allocation, etc. using pre-National Academy of Sciences report of 2013. Yet the BLM will then cherry pick population suppression tools from the NAS report to insert in a “gather plan” without fixing the data/planning the asserted need is based on. BLM also makes an assertion that there is a management plan, again, but the document they reference is simply an old gather plan that they insert the word “management” into. This is the second time in the history of this complex that BLM is trying to masquerade a “gather EA” for a management plan.
BLM is not mandated to remove, they are mandated to manage. Any population suppression is a tool that can outline, but population suppression is not management.
It should be noted (and we will in our comments) how absolutely absurd these documents are. The BLM asks for comments, but already has the document labelled Final on the eplanning site dated 1/8/2021. That document states the operation will begin in 2011 in conjunction with the Calico roundup. If we operated that poorly, we would have zero credibility and cease to exist.
BLM states the preferred Alternative 1: The proposed alternative would gather excess wild horses and burros using a variety of methods including
helicopter-assisted and bait trapping, adjust the wild population sex ratio to 60 percent males and 40 percent females, and treat females returned to the range with fertility control vaccines or IUDs to slow future growth.
Alternative 2 excludes sex ratio skewing. Alternative 3 is to remove to low AML, and Alternative 4 is the no action alternative that BLM is simply required to include but has already excluded from the final plan.
Video below from 2011 as our work was in its second year. Bad trap, no horses captured, pre-CAWP (the policy driven by our litigation).
Public action items can include actions that address multiple issues in 3 distinct branches of government. In other words the “what you want changed and who can fix it.”
Comments on any proposed action, such as this Preliminary roundup EA, are part of the process of NEPA that is the policy that outlines the process of analysis of an action and the ability of the public to comment and protest.
Specifically, comments on an EA must be tiered directly to statements in the EA (not programmatic complaints, that is a different process). At this time, the document will not be influenced by the number of comments, just the substance (ie. 50,000 comments, or 1 comment, all count as the same in this process under current rules).
If the agency fails to address a legitimate and specific concern when the Final EA is created, the commenter has the ability to challenge the EA legally if they are directly harmed by BLM failure to address the comment and fix the error.
When WHE does our comments it can take time. The comments WHE crafted on the Desatoya EA, that closed last week, it took us weeks to create them. At this time, a broad brush “click and send” comment letter would be an ineffective use of our time and yours.
We are working on our comments for this EA , carefully.
One of our volunteers, Summer Brennan, adopted a wild horse from the roundup at High Rock in 2011. Our work in the field and her love for her horse, brought us together. She is now an official volunteer for WHE and we will be including her in our comment process as we work to protect these amazing wild horses.
Categories: Wild Horse Education