Clan Alpine (comment reminder, due tomorrow)

By Laura Leigh on July 16, 2023

2023, Clan Alpine mare and foal

Just a fast reminder that comments on the Clan Alpine Environmental Assessment (EA) for the ten-year gather plan BLM wants to approve for the Clan Alpine HMA are due tomorrow.

BLM wants you to use their electronic submission system on the home page (click the participate now button to submit comments).

If you submitted scoping comments and feel they did not address your concerns in the EA, just submit the same comments.

Or you can copy/paste this sample:

Re: DOI-BLM NV-C0I0-2023-0004-EA

A long term Gather-EA is premature for Clan Alpine. Ten-year gather plans have been deemed to be inappropriate (in another instance) by the courts. BLM needs to go single gather plans based on long-term management plans, not long-term gather plans based on no management plan.

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 The 1993 Clan Alpine document is outdated and lacks data, lacks an actual AML/AUM equation, priorities (such as climate change) are absent and parameters of private uses of the HMA have changed.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 simply not evaluated or assessed the actual methods of gathering wild horses in the proposed EA. Issues of abuse remain rampant. Until the agency addresses this fundamental legal (and moral) obligation a long term gather plan is not appropriate.

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.

Together, we can continue to make a stand for these herds that are usually only seen by most advocates when the chopper flies… and the time to protest or appeal a decision has long gone.