The BLM Carson District has opened external scoping (outside government channels) as they propose crafting a Gather-EA for the Clan Alpine Herd Management Area in Nevada.
Edit March 1: the “participate now” button is finally working on the BLM website!
BLM prefers comments to be submitted via the ePlanning website at:. https://eplanning.blm.gov/
BLM EPlanning page
does not reflect current dates or information. A scoping period was begun in December and closed in January. However, BLM had not (completely) notified the public. We contacted BLM. A new open scoping period began February 3 and closes March 6 March 30th.
Let’s not let this comment period go without public participation due to confusion.
The document currently loaded on the page (Dear Reader Letter) is the same as the new letter with a change of dates to reflect a March 6th March 30th closing date.
You can now use the EPlanning page to submit your comments BLM EPlanning page.
Scroll down to red text for a sample you can copy/paste and use as a starting point for your unique comment. BLM only counts unique letters, not bulk comments (they count those as one comment).
If you do not know what a scoping period is, we describe the process in the article covering the McCullough Peaks scoping period that just closed (HERE).
Scroll down to red text for sample comments. Once scoping is complete, BLM will craft a draft Environmental Assessment (EA) and you will have another chance to make a comment.
A Bit of Background
The Clan Alpine HMA is located approximately 60 miles East of Fallon, Nevada. Clan Alpine consists of 298,064 acres of BLM land and 4,162 acres of a mix of private and other public lands for a total of 302,226 acres. The HMA is mountainous and elevations vary from 4,300 to 10,000 feet. Mountain lions were once common in the HMA and can be noted occasionally in the area today.
In 2010, BLM approved planning documents (EA) that bunched Pine Nut, Pilot and Clan Alpine together. NEPA is supposed to be a site-specific planning process. These sites are not even contiguous and the document was probably an attempt to rush removal document creation and approval.
This kind of historic document can clearly illustrate that “planning” for wild horses has not been a study of migration, utilization, critical habitat needs for the herd and how to manage wild horses on the landscape to achieve a “thriving natural ecological balance.” NEPA (paperwork) for wild horses and burros has always just been a “box to check” for removals.
We can only assume they were lumped together due to the intention to use fertility control in conjunction with removal: In 2000, Clan Alpine was one of the early large field trials done by BLM using hand injected PZP-22 after a large roundup (PZP-22 consists of an initial priming injection of ZonaStat-H and three time-release pellets engineered to release PZP at 1, 3 and 12 months). A field trial from 2000 to 2004 at the Clan Alpine HMA was used to document that a single injection of PZP-22 reduced fertility in mares by 91% in year one, 73% in year two and 38% in year three. The public often thinks PZP is one formula, it is not. PZP has the one year, PZP-22 (1-4 years) and the formula called “SpayVac” that can cause permanent infertility; it is all “PZP” in different formulas and protocols.
In 2017, BLM created a separate plan for the Pine Nut HMA that included a plan for potential inclusion of the Fish Springs area that is off-HMA to be evaluated for inclusion, a potential grazing allotment retirement (if it becomes legal) to allow for re-evaluation of AML and a fertility control component.
BLM has now begun scoping for a distinct Clan Alpine Gather-EA, not an HMAP like they did for Pine Nut while working with local advocates and holding public meetings (remember, the dates are wrong on the letter on their website) HERE.
Clan Alpine is essentially in the midst of what was once wild horse central and was severely impacted by artificial boundary lines drawn in remote and rough terrain back in the 1970s. To the East and West of Clan Alpine there have always been wild horses in those lowlands, but that was “cattle country” back then (which was often excluded as “managed for horses” in the original mapping). Even much of the territory originally identified for use by wild horses and burros have been removed for their use (green shaded above).
Below: The “close-up” map of Clan Alpine is a really good illustration of how (non-science based) boundary lines were drawn in many places all over the West; just draw the line around the bottom of the mountains and leave the lowlands (grazing and water) for the livestock. Note from history: In the winter of 1946, it was documented that 851 wild horses were shot or captured/sold (for slaughter for chicken feed and dog food) after ranchers in the area between Clan Alpine and New Pass-Ravenswood hired hands specifically for that job. At that time there was nothing illegal about that action. But it does confirm the area had a recurring population of wild horses but was left off the map when boundaries for management were originally drawn.
How does that impact things today?
Currently BLM has the AML set at 612-979 on about 300,000 acres. This number represents one of the highest in the nation per acre, so initially you may think this is “improvement.” What this number actually represents is a population that consists of a significant number of transitory animals, not the number identified as “appropriate” to live in the area year round (BLM has been aware of the movement for a long time).
Wild horses in Clan Alpine are often the exact individuals included in the AML and inventory of New Pass/Ravenswood to the East and Augusta to the North. The areas considered “off HMA” (in between) are actually migratory routes and territory occupied by wild horses before the 1971 Act passed.
Above: Closer view and context of location of Clan Alpine.
Our members have monitored the area for over a decade.
The boundary lines are extremely inaccurate as any reflection of the statement of law “the land they now stand” in 1971.
Seasonal migration between Clan Alpine and the surrounding HMAs is so prevalent that when BLM announced a “verging on emergency” roundup for February 2011 of 580 wild horses (that they counted in summer) we had to write to BLM to let them know the horses were not there and they needed to do a flight before any roundup. BLM did the flight… and cancelled the roundup noting “An aerial census conducted in late December of the wild horses in the Clan Alpines shows that the population is low enough that gathering horses in that area to treat the mares with a fertility control vaccine is not warranted at this time.” Yes, the horses had moved into the adjoining HMAs (seasonal move). It seems BLM just continued to do flyovers in spring/summer (and not in winter) to count wild horses in Clan Alpine instead of changing timing to better understand (what should be a complex of) individual HMAs.
Large numbers of wild horses consistently move from one HMA to the other and flyovers (for inventory) are not coordinated and concurrent. It should be pointed out that BLM has been aware of this “AML overlap” for a very long time.
Do wild horses find themselves in trouble in parts of Clan Alpine? Absolutely. Remember HMAs are not “open range” but a series of livestock fenced grazing allotments (that are further divided into pastures), mining roads and pipelines/transmission lines. Sections of Clan Alpine have heavy use by private industry and recreation (increasing every year) and that can impact movement, water, forage utilization.
Recently we published an article about “Green Energy” and how fast tracking, while approving hard rock mining expansion at rapid rates, is a real threat. We included a section on the Green Links transmission line that will run the Highway 50 corridor in NV and told you to expect the HMAs on that corridor to face new removal plans. Clan Alpine is on the corridor.
So as you look into Clan Alpine to craft your comments keep both historical flaws and future impacts in mind.
BLM prefers comments to be submitted via the ePlanning website at:. https://eplanning.blm.gov/
BLM EPlanning page is now functional and you can use the “participate now” tab to submit comments.
In Scoping, you can ask for anything you want (if you can support the request).
SAMPLE Scoping Comment:
Re: DOI-BLM NV-C0I0-2023-0004-EA
A long term Gather-EA is premature for Clan Alpine. A review of management planning has been needed in the area for a long time and noted in 2010 planning documents.
In 2010, DOI-BLM-NV-C010-2010-0019-EA, stated that management goals and objectives (defined in management planning) would be evaluated for all 3 HMAs (Pine Nut, Pilot, Clan Alpine) noted in the document. To date, BLM has only crafted an updated HMAP for Pine Nut Mountains (2017). The 1993 Clan Alpine document is outdated and lacks data, lacks an actual AML/AUM equation, priorities (such as climate change) are absent and parameters of private uses of the HMA have changed.
Underlying planning documents remain deficient in addressing the population overlap with New Pass-Ravenswood and Augusta. Any Gather-EA is likely to include wild horses that are being counted in the aforementioned HMAs as contributing to all the AML of all 3 HMAs.
BLM has not disclosed any monitoring data at Clan Alpine during an HMAP-EA revision process to rectify the omissions in the 1993 plan for Clan Alpine (beyond the fertility control data of 2004). It is disappointing that BLM did not run concurrent data sets on herd movement during the PZP-22 trials at Clan Alpine or track the number of treated horses that were captured in neighboring HMAs. This lack of open discussion and disclosure underscores that a Gather-EA is premature and HMAP scoping should begin.
For the reasons stated above, I request that a proper HMAP-EA be created prior to any Gather-EA that addresses the deficits and looks at managing the 3 HMAs (Clan Alpine, New Pass-Ravenswood and Augusta) as a complex to address flaws in inventory data and craft data based decisions. The HMAP-EA evaluation should include range improvements to address habitat loss and to create a strategy to better distribute populations throughout the HMAs.
You can check ePlanning to see if BLM has updated the website to include a button to accept comments: https://eplanning.blm.gov/eplanningui/g,roject/2022686/510.Link is now functioning (March 1).
OR comments may also be submitted via mail to: 5665 Morgan Mill Road, Carson City, NV 89701, via email: email@example.com or fax at (775)-885-6147. If using a method besides the BLM interface, remember to reference the NEPA title as a subject line: DOI-BLM NV-C0I0-2023-0004-EA
Help keep us in the fight.
Categories: Wild Horse Education