Blue Wing Burros, NV

Last week we told you about an Environmental Assessment (EA) open for comment at Three Fingers Complex. The complex consists of Big Sandy, Alamo, and Lake Havasu Herd Management Areas (HMA) “Wild Burro Gather and Population Control Plan.” The HMAs are located on about 955,000 acres of public, state, and private lands in Mohave, Yavapai, and La Paz Counties in northwestern Arizona.

You can find the draft EA HERE. 

Comments are due October 11.

The following piece was submitted by volunteer Laurie Ford. This extended piece is really good food-for-thought as ou look over the EA for burro capture. Habitat loss and fragmentation is the number 1 driver of removals of wild horses and burros in the West. 

When writing comments, and raising questions, we are no longer just contending with livestock grazing, mining and fossil fuel extraction within the HMAs. Not only has outdoor recreation exploded but renewable energy development has become a major player and could possibly pose one of the greatest threats to our wild horses and burros in the near future. Unfortunately, both of these uses are predominant in designated wild burro habitat such as the Three Rivers Complex.

The Big Sandy HMA, one of three HMAs in the complex, lies within the “battery corridor of Arizona” and home to a lithium mining project (Hawkstone Mining) that claims there is at least 320,000 metric tons of lithium available in the area. While a burro may consume 2-6 gallons of water a day it takes 500,000 gallons of water to produce 1 metric ton of lithium.

DOI-BLM-AZ-C010-2023-0025-EA glosses over such mineral exploration within the HMA despite the devastating impact it will have on these burros over the 10 years they will take to carry out their “management” plan – continual removals.

Additionally, there is continued interest in mineral exploration in the Big Sandy Area which includes two proposed exploration plans (43 CFR 3809) by Big Sandy Inc. and Zenolith USA. Both exploration plans are currently under review and if approved, the exploration activities could entail construction of drill roads and drill pads that may cause up to 180 acres of additional disturbance. Other mineralized properties in the Three Rivers Complex could become exploration targets in the future, which may cause additional surface disturbance. All authorized mining activities require reclamation bonds. (DOI-BLM-AZ-C010-2023-0025-EA pg. 51)

In addition, three major solar projects are currently pending in Mohave County where the complex is located. When developing solar projects, the land, in most cases, must be totally flat and barren with wildlife and vegetation removed – at times permanently sterilized to prevent any future growth or life.

Meanwhile, the current administration is feverishly pursing its green energy agenda with plans to permit a total of 25 gigawatts of renewable energy on public lands by 2025 – more than double what is currently being produced. Through amendments, revisions and new proposals and bills every effort is being made to expedite environmental impact statements under NEPA for certain solar, wind, and geothermal projects that can be approved in less than 1 year,  prioritize and expand renewable energy permitting, reduce leases and fees up to 80%  and update plans and policies which would allow more flexibility for applicants to develop our public lands for renewable energy with ease and speed.

The current areas of public land and water designated as available for renewable energy development—several million acres—are not enough  to reach the goal of net zero greenhouse gas emissions by 2050 and, according to a 2020 report from Princeton University renewable energy projects will need to be sited on roughly 145 million acres – a 4,733% increase – to meet this goal. The Department of Interior is presently focusing on new leasing areas for solar and wind energy outside of the current designated zones. – leases that can last up to 50 years.

The BLM’s Western Solar Plan is also currently being revised to update and expanding solar energy zone areas on public lands, reduce rates and fees by more than 50%, update regulations which will expedite renewable energy projects and permitting for transmission infrastructure across the country. The BLM expects that these revisions will facilitate and grow solar and wind energy development by increasing commercial interest and encouraging additional investment in the use of public lands.

A while back WHE brought up the proposed “New Rule”, AKA “Proposed Public Lands Rule” which, at first glance, appears to be a good concept. But, as usual, the wording throughout the document is vague and open to interpretation – especially when discussing “conservation leasing” – a category of leases on federal lands intended for conservation use issued for a term consistent with the time required to achieve their objective.  These new leases would be in addition to providing land permits to livestock ranchers, mineral extraction entities and other users that have also leveraged public lands for private interests and profits for decades.

The main focus of these conservation leases is to offer renewable energy projects a quicker and easier path to facilitate any compensatory mitigation required for their project to offset potential impacts on natural resources which include native flora and fauna.

‘Wild horses and burros” are referenced in the land enhancement section (§ 6101.4) of the rule stating:

“Land enhancement means any infrastructure or other use related to the public lands that is designed to improve production of forage; improve vegetative composition; direct patterns of use to improve ecological condition; provide water; stabilize soil and water conditions; promote effective wild horse and burro management; or restore, protect, and improve the condition of land health or fish and wildlife habitat. The term (land enhancement) includes, but is not limited to, structures, treatment projects, and the use of mechanical devices or landscape modifications achieved through mechanical means.”

What does ‘promote effective wild horse and burro management’ mean exactly?” This could easily be interpreted as reducing or eliminating wild horses or otherwise limiting their presence based on the DOI’s current negative stance on wild horses and burros.

The DOI believes “The presence of wild horses and wild burros can have substantial effects on rangeland ecosystems, and on the capacity for habitat restoration efforts to achieve landscape conservation and restoration goals” – much like those supported in the New Rule.

In the BLM’s Wild Horse and Burro Program 2021 Strategic Research Plan wild horses and burros and the environment were listed as the second highest priority for research because:

WHB herds above AML can prevent the BLM from fulfilling its mission to sustain the health, biodiversity, and productivity of public lands and the capacity of western rangelands to offset greenhouse gas emissions may be marginally affected by WHB density. WHB herds that are much larger than established AML values likely reduce landscape resilience to the effects of climate change. Studies of some specific interactions between WHB and the environment may be needed to inform the BLM’s efforts to conserve biodiversity and increase landscape resilience to climate change.

The 2022 budget included s a $35.0 million increase in the Wild Horse and Burro Program to support the health and resilience of rangelands.

Excess wild horse and burro populations under-mine the health of public rangelands and adversely affect other uses of the lands and the species that depend on them, making them less resilient to stressors from climate-driven changes. These degraded landscapes can also contribute to climate change.

The proposed Public Lands Rule provides tools for the Bureau of Land Management (BLM) to improve the resilience of public lands in the face of a changing climate.

The BLM has already identified specific degraded public lands that would qualify for mitigation projects – especially in Arizona and Nevada – “areas of critical environmental concern”.

The Public Lands Renewable Energy Development Act of 2023 (HR 178) was also introduced to the House this year calling for:

The Department of the Interior shall establish priority areas on its land for geothermal, solar, and wind energy projects, consistent with the principles of multiple use and the renewable energy permitting goal.

Among applications for a given renewable energy source, proposed projects located in priority areas for that renewable energy source shall be given the highest priority for incentivizing deployment, and be offered the opportunity to participate in any regional mitigation plan developed for the relevant priority areas.

Remember “Wild horses and burros shall be considered comparably with other resource values in the formulation of land-use plans”?   What happens when these “resource values” were hardly in existence when the plans were originally formulated and “other resources” have entered the picture?

The Three Rivers Complex gather EA is tiered to the Proposed Kingman Resource Area Resource Management Plan (RMP) and Final Environmental Impact Statement (BLM 1993) and Record of Decision (BLM 1995), the Lower Gila North Management Framework Plan (MFP) (BLM 1983), and the LHFO RMP (BLM 2007).

Kingman RMP 1995

● Pg. 18, Goal – “Actively manage for healthy, viable populations of wild horses and burros in an ecological balance with other resource values within the three existing herd management areas.”

Lake Havasu RMP 2007

• Pg. 120 HB-1 “Viable, Color diverse burro populations will be maintained within the HMA, while maintaining a thriving ecological balance with other resources and consistent with other management agencies’ objectives (including wildlife, riparian and upland vegetation, recreation, and others).”

During this time there was no explosion of recreational use – especially with off-road vehicles nor was there impeding renewable energy projects or mining addressed at providing minerals to support renewable energy.

Where’s the renewable energy on public lands? This map shows you CLICK HERE

We hope this is helpful as you craft your comments.

Our team will have more soon from the field and to help you learn the “what, why and when” of comment periods. 

Our wild ones should live free on the range with the families they hold dear. Our wild ones should also live without abuse. WHE carries ongoing litigation to force BLM into open public process to create an enforceable welfare standard for our treasured wild ones. 

Thank you for keeping us in the fight!

Thank you!