Scoping Cedar

By Laura Leigh on February 16, 2022

NOTE MARCH 2, 22: BLM “participate now” button is not active, BLM has not fixed it. Email your comments to: thowell@blm.gov

Most often when the public is asked to give input on anything the Bureau of Land Management (BLM) proposes for wild horses and burros is the “comment period” on an already determined action they have prepared and Environmental Assessment (EA) to accomplish. (Example: The Gather EA comment period)

When BLM proposes a management plan (or a new management option that can have far reaching implications) they are supposed to begin with a process called “scoping.” Scoping is done before a draft planning document is put out for the public to comment on (essentially a comment on a draft plan is to point out where BLM did not completely analyze an aspect of the proposed action and to supply information to support or disapprove of a proposed option). “Scoping is the process by which the BLM solicits input on the issues, impacts, and potential alternatives and the extent to which those issues and impacts will be analyzed…”

On February 4, 2022, the BLM Salt Lake Field Office (SLFO) launched a 30-day public scoping period before an environmental assessment (EA) is prepared for the proposed wild horse population control plan on the Cedar Mountain Herd Management Area (HMA). The purpose of this scoping period is to give the public an opportunity to help in “identifying issues, alternatives and providing data that would be used in preparing this EA supporting the SLFO’s decision making process.”

BLM should be doing a full Herd Management Area Plan (HMAP). An HMAP-EA would not limit your input to only an aspect of population growth suppression, it would allow you to address all aspects of management from habitat to foaling season and to determining any use of population growth suppression (vaccines, methods of application, roundup, etc).

However, the scoping process is being offered prior to BLM crafting a draft EA on “population growth suppression.” Scoping is a vital part of the NEPA process the BLM has failed to allow the public to participate in; scoping is usually limited in “gather EA” planning to county commissions, tribes, etc. omitting the public from participation.

The 411,636 acres of the Cedar Mountains Herd Management Area (HMA) is located 50 miles west from Salt Lake City, Utah. The scoping for fertility control is carrying over the current Appropriate Management Level (AML) of 190-390 wild horses. (One of the differences between the scoping being offered and an HMAP would be addressing the “how/when/what” of determining an AML and things like limiting/removing livestock.) Historically, BLM creates “Gather EAs” that tie Cedar with Onaqui.

Scoping is a simple process that allows anyone with relevant information on the herd and the processes BLM could implement to participate.

A sample scoping comment could be:

The appropriate place to determine any population growth suppression would be in conjunction with an evaluation of the process used to determine AML. I hardily insist BLM craft an HMAP that incorporates any population growth suppression planning around determination of actual foaling season in the Cedar HMA, AML equation and adjustment, industrial encroachment on the herd, critical habitat identification/preservation planning.

Until an HMAP is completed (based on current available data and the need to comply with current underlying planning documents) I recommend the BLM use the least invasive methods to employ any fertility control such as darting and only use vaccines in a protocol that can be reversed (PZP native annually). BLM should only employ these methods for less than 4 years as an appropriate HMAP-EA is created for both the Cedar Mountain HMA and the Onaqui HMA.

The underlying documentation for Cedar Mountain has been historically tied to that of the Onaqui HMA. If BLM is doing a distinct scoping for the Cedar HMA centered on population suppression, then any planning should either include the Onaqui HMA or create a new underlying planning document (HMAP) that distinguishes the Cedar Mountain HMA from the Onaqui prior to completion of any potential management option for Cedar.

I recommend crafting distinct HMAPs for each HMA as soon as possible.

I thank you for the opportunity to participate in the scoping process.

Sincerely,

(your name)

Info on how to participate provided from BLM press release:

NOTE MARCH 2, 22: BLM “participate now” button is not active, BLM has not fixed it. Email your comments to: thowell@blm.gov

Interested members of the public, local governments, Tribal members, organizations, and other stakeholders are encouraged to provide comments during this public scoping period to help identify alternatives, refine the proposed action, clarify issues, and identify new issues.

All comments must be submitted by 4:30 p.m. on March 5, 2022, to be considered. Written comments will be accepted at the address below or through the BLM’s NEPA register at https://eplanning.blm.gov/eplanningui/project/2017715/510. Please refer to Project Number: DOI-BLM-UT-W010-2022-0005-EA

Or mail to: Salt Lake Field Office, Attention: Tami Howell, 491 North John Glenn Road Salt Lake City, UT 84116

UPDATE: WHE has taken Cedar into legal action. We will update when the case resolves (it can take a year or more).

Help keep us in the fight.