The Bureau of Land Management (BLM), Battle Mountain District Office (Tonopah Field Office) has published a draft Environmental Assessment (EA) for a ten-year removal plan of wild horses for the Stone Cabin/Saulsbury HMAs in Nevada.
The preliminary 10-year Wild Horse Gather EA will be available for public review and comment from October 25 to November 23, 2022.
Scroll down to red text to sign-on to a letter if you do not have time to craft your own and want to comment.
The Stone Cabin HMA is located approximately 30 miles east of Tonopah in Nye County directly off Highway 6, both north and south. Saulsbury is just to the West, a couple of miles off the highway both north and south. The Monitor USFS WHT is located in between the Saulsbury and Stone Cabin HMAs (and it is worth noting that no studies have been done to show which populations spend more time on BLM or USFS land denoting jurisdiction for removal or population growth suppression tools).
These relatively easy to get to HMAs hold historic significance to the history of wild horse advocacy. The site of the first official BLM removal took place in this area (as well as the first official litigation). What is now the adoption program was born here, too.
The Stone Cabin HMA is 407,706 acres and Saulsbury HMA includes 135,018 acres. The total proposed gather area represents 542,724 acres within the Stone Cabin Complex HMAs, and 343,457 acres outside of designated HMAs, in areas primarily adjacent to HMAs where wild horses have moved or may move to during gather activities. (If you note the observation about the Monitor WHT, this language also means wild horses that call Monitor “Home Range” and may flee back home. The Monitor WHT is 380,000 acres.)
In essence this Preliminary Environmental Assessment (PEA), if approved, would give BLM the authority to implement a vast mashup of fertility control from multiple vaccines to sterilization as they implement removals over 1.3 million acres for a period of ten-years. In others words: this proposed plan does not remove a certain number of wild horses one time, it removes and unknown (and implements multiple forms of fertility control to an unknown number) repeatedly over ten-years to repeatedly push the population down to 242-402.
These actions will impact wild horses in Stone Cabin and Saulsbury on BLM land and those living in the Monitor WHTs on USFS land (although not formally noted). These 3 areas have significant transitory populations that repeatedly shift due to increased human activity (BLM has not monitored that change either).
Commenting on the PEA
After carefully reading the PEA to determine where BLM may have misstated their authority and analysis, or finding a lack of data, you can then sit down to write comments. (More info on what the comment period on a NEPA document represents HERE.)
It should be noted that we contacted BLM to address the assertion that this PEA (or underlying documents) contain all of the information and analysis that would be done in a Herd Management Area Plan (HMAP). (An HMAP is a site-specific management plan, more here.)
Essentially, if you do not see where something you want to see happen in wild horse management NOT in the PEA open for comments (or other noted documents) you can write to BLM and ask where to find that subject. Before an HMAP-EA is written a scoping period would occur to determine what was important to the public, inclusion of new scientific methods, new data gathered by the public that demonstrates a potential issue, etc. and you would be able to address that issue. BLM has listed Jeffrey Kirkwood as the contact person for this PEA: firstname.lastname@example.org
The deadline for comments is November 23, 2022.
When a comment period is open many of you ask for a “sign-on” letter or sample comments.
If you want to send your own: A comment is only considered “individually” if it is “unique.” In other words, it must be generated from a distinct email and contain distinct information. You can view the samples we include in this article, but also write your own.
Those of you that are supporters and active members of WHE are included in the comments WHE send. If you are an active observer in this area and want to be included when we appeal (and it is highly likely that BLM will not make the appropriate changes and we will end up running the gamut of the court system on this one) you can reach out to us at: StoneCabinEA@gmail.com
Our comments are still being drafted. When WHE drafts comments it can take time to fully review a document, research how we want to respond and then write. We also have to wedge that time into the briefing schedule we carry on existing appeals. (WHE carries 9 active appeals, including one filed for Bordo Atravesado HMA filed yesterday. WHE also carries 2 active federal court cases). Our comments on this PEA are 13 pages and growing.
The word “preliminary” distinguishes a draft document. The word is dropped when BLM approved the action proposed in the document. A Preliminary Environmental Assessment, “PEA,” will be referenced simply as an “EA” after it is approved.
We provide the following to get those of you started that are interested in writing your own comments and are writing to us asking for samples:
Always preface your comments with the number listed on the EA. Your name, the words “public comments,” the date and, in this case, DOI-BLM-NV-B020-2023-0005-EA.
This PEA represents a flawed Appropriate Management Level (AML) that was estimated more than 30 years ago. This PEA, and all noted underlying documents, do not provide any formula of how AML was set or when it (the formula or actual AML) would be revised. These are parameters an HMAP-EA would fully outline. The document does not reflect an HMAP revision or any equivalency. BLM must prepare an HMAP or amend this PEA to reveal data and equations used to set AML.
The 2022 monitoring BLM notes in this PEA are primarily to expand the use of livestock and are not adequate to demonstrate validity of AML or determine excess wild horses.
The Monitor USFS WHT is located in between the Saulsbury and Stone Cabin HMAs, no studies have been done to show which populations spend more time on BLM or USFS land denoting jurisdiction for removal or population growth suppression tools, determining if horses are in fact off-HMA or representative of transitory movement (that may have always existed and has increased due to human activity) and setting an accurate AML. This PEA was not presented as a joint PEA (or EIS) with USFS. Therefore, this PEA is inaccurate, does not adequately represent appropriate jurisdiction of the resource that is the subject of this proposed activity and must be set aside.
The Gather-PEA includes multiple studies on the procedures, substances, devices, individually but not compounded or “cumulatively.” The combination of long-term mashups of fertility control, or if fertility control is even appropriate in each sub-unit, might be best addressed in an Environmental Impact Statement (EIS) if BLM refuses to do that analysis appropriately in an HMAP-EA or within this PEA or RMP revision.
If you do not have time to craft comments (and want to add your name to the comments listed above) WHE will send in a public supplement to our detailed comments and note your participation.
COMMENT PERIOD NOW CLOSED
Note: You can use the format of these comments to address any subject you like after reading the PEA BLM published. State what BLM asserts, what is wrong with what they assert, why it is wrong, how to fix it.
The “Stone Cabin area” is really significant to those of us at WHE. We have spent a lot of time in these HMAs/WHT. When we won the amazing First Amendment victory ensuring daily access (that was not granted at that time) we were at a roundup in Stone Cabin.
You can help us fight for the wild ones in the area of Stone Cabin by signing the letter above or sending your own. We are gearing up for a fight to gain fair management, integral to the system, for these treasured wild ones.
WHE has compiled several reports that could be useful to you in your advocacy. You can find our resource list of WHE reports for 2022 HERE.
There are many ways you can support our work at Stone Cabin and for all of our herds. You can sign-up to receive our newsletter HERE.
You can also help keep us in the fight while you shop, direct contributions and now even through donation of stock! (More HERE)
Help keep us in the fight