Calico Complex

The BLM has released a draft Environmental Assessment (PEA) for the Calico Complex: Black Rock Range, Calico Mountains, Granite Range, McGee Mountain and Warm Springs Canyon.

This proposed roundup/sterilize plan is the latest in a flurry of newly released roundup planning documents (more here).

Comments are being accepted by BLM through May 13. You can access the EA and submit a comment through BLM’s portal: https://eplanning.blm.gov/eplanning-ui/project/2010516/570

The Complex of HMAs comprises 584, 101 acres. The area of the proposed action includes areas outside of HMA boundaries where wild horses have gone to look for water and forage as projects for livestock, road construction, fences, mining etc. continue to disturb the Complex and nearby HMAs.

The BLM proposes multiple alternatives in each EA, but identifies the proposed action: removal, population growth suppression through multiple substances, IUDs, non-surgical/surgical sterilization of mares and gelding stallions. (Forms of non-surgical sterilization methods proposed for mares: literally “glue” oviducts shut, another is to burn oviducts with a laser, causing a blockage created by scars.)

Even though not specified in the alternative outline, “GPS radio collars may be attached to wild horse mares, and / or GPS tail tags may be attached to wild horses of either sex, for the purposes of monitoring movements and foaling status,” is noted later in the EA.

Alternative 1, the proposed action, includes 25% of the herd being non-reproducing: sterilized mares and geldings.

Alternative 2 is the same as  Alternative 1, except that released mares would not receive IntraUterine Devices (IUDs) or any non-surgical sterilization procedures of mares. The permanently non-reproducing portion of the horse population in the complex would be no more than ¼ of the total herd at low AML (143 animals) comprised of geldings

The initial removal targets 750-1197 based on a low and high AML target (as of the date of the EA). The proposed action would begin as soon as funding became available to place the operation on the schedule. The EA will stand for about a decade, or until replaced.

The EA breaks down the estimated number of wild hoses and burros by HMA below.

Commentary: Have you read any EA lately?

Yes, they are all the same. Essentially every wild horse EA over the last two years could be a copy/paste; where the specifics of each area (geography, numbers) are changed and some type of sterilization is in one (or more) preferred alternative. All of these EAs have been crafted under the directives sent from former Deputy Director William Perry Pendley. No new directives have been crafted to replace the old ones from the new administration. Once approved, these EAs will stand for a decade. 

It should be noted that this EA (nor do any of the other ones recently released) does not mention any Herd Management Area Plans (HMAP), nor does it assert to tier to any actual management plan for wild horses or burros.

As with most HMAs, or complexes of HMAs, BLM does not maintain ay management plan to protect wild horses and burros from habitat encroachment, set management objectives, etc. In the instance of the Calico Complex it is the degradation of the range needed by the Greater Sage Grouse that makes Calico a priority to “blame the horse or burro” in order to comply with protection plans for the bird (and so they can continue to kowtow to livestock and mining).

Raising AML, reducing livestock, changes to boundary lines, increasing free-roaming behavior through removal of obstructions (distribution of population) and just about any actual management  option that would not consist of population suppression, is not considered in this EA. In other words, this EA tiers to planning that prioritizes and protects everything except horses and burros. Those planning documents have no HMAP, management plan for horses and burros, (that could stop construction of a road, a fence, mine, etc.) and included significant input from the stakeholders involved before being formally proposed.

Basically, when you read an EA for wild horses and burros they begin by telling you what you can not comment on, tell you what they are going to do, and then reassure every interest that has a management plan (livestock, sage grouse) or recreation interest (hunting, OHV) that removing horses wont interfere, and is in compliance with, their interest.

We share your frustration.

Pictures from previous roundups at Calico below

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In the big picture there are two ways actual reform could begin to take shape:

Wild horse and burro management contains what is called “Secretarial discretion.” A directive guides agency priority and framework for activities within existing law. That means that directives from the Secretary of Interior, through/to the BLM Director, could immediately require the agency to craft HMAPs prior to any removal EA being implemented and more. This would give you a voice in actual management of wild horses and burros, not just removals.

If BLM needs an incentive to create responsible and equitable planning, Congress could withhold funding through the Appropriations bill for any removal (except emergency, like fire) where BLM has failed to craft an actual management plan for a herd (HMAP).

Herd management area plans are required by federal regulations and they are included in the handbook. However, BLM claims that there is no timeframe for HMAPs to be crafted or updated, therefore they can ignore doing them for 40 years or more. 

You can find sample letters to draw from HERE. 

You can ask for an HMAP be crafted before a “gather EA” when you comment on the Calico EA. That is one point we are bringing up and are prepared to litigate.

We are crafting our comments for this EA. The EA was just published and it takes time to craft a substantive reply. Comments, if not adequately addressed in the finalization process by BLM, can set up an opportunity for legal action. If time allows, we will publish those comments so you can draw from them.

We are crafting legal action against the newly approved Desatoya EA. If you read both EAs  you can see what we mean by “nearly identical.” (Desatoya documents here)

You can participate in the process as well. If BLM fails to respond appropriately to your concern, you have a right to appeal the decision. BLM does not consider the number of comments, even if 100K people oppose something, as relevant. Comments are being accepted by BLM through May 13. You can access the EA and submit a comment through BLM’s portal: https://eplanning.blm.gov/eplanning-ui/project/2010516/570

A roundup at the Calico Complex led to the creation of Wild Horse Education. In 2009 an eight month old colt was literally run until his feet began to fall off. Then he languished with barely any medical care for over three weeks until he died. BLM would not allow him to be adopted out and proper medical care provided.

At that time there was no humane handling policy and BLM was restricting access to witness roundups on a daily basis. A promise was made to that foal that we would not stop until there was a humane policy and Wild Horse Education, and our litigation record, was begun.

We kept our promise to that young life and today there is a humane policy (CAWP). The policy has a long way to go, but it exists. Our work has expanded into many areas and will continue to fight against slaughter, against abuse and for fair and equitable management as the original law intended.

Yet, our work began one cold day at a roundup in the Calico Complex and a promise to a young colt.

Help keep us in the fight. 

If you are shopping online you can help Wild Horse Education by choosing us as your charity of choice on IGive or Amazonsmile.com