Blue Wing: Management Plan (Last Call for Comments)

By Laura Leigh on May 30, 2024

Comments are due by June 1 on the Blue Wing Herd Management Area Plan (HMAP).

You can find the project on BLM ePlanning and submit comments via email or postal service. BLM does NOT have a simple “participate now” button on their planning page to facilitate comments.

The email to submit comments is: BLM_NV_WDO_WHB@blm.gov

BLM did NOT even provide a specific subject line for comments they direct you to submit through a general email address for the district WHB program. We suggest you use the subject line to clearly state “Blue Wing HMAP Scoping” and/or including the assigned number DOI-BLM-NV-W010-2024-0027-EA.

Many of you are asking that we do a sign-on letter. We know your time is really limited and want you to know that our team is working very hard to submit as comprehensive a document as we can under this short deadline. We will speak for our the wild ones and when a sign-on letter is appropriate, we will provide you with one. A “click and send” would not be appropriate for an HMAP scoping. Individual emails or letters are the only things BLM will consider. However, your email can deal with one subject or dozens. You do not have to write an entire management plan that addresses everything. You can if you want to, but it is not required to provide comment.

Blue Wing burro

This is your chance to comment on management, not just removal plans.

At the Blue Wing Complex, as it is with the vast majority of Herd Management Areas (HMAs), for nearly 40 years all you have been able comment on are plans that simply deal with population growth suppression (roundups, fertility control). When you address any of the issues with the Gather-EA in your comments (the number of horses and burros allowed that represent genetic bankruptcy that were set through an agreement and not data-based, the placement of fencing that inhibits exchange between HMAs, the vast areas “zeroed out” that could be evaluated for management, etc.) you are repeatedly told your comments are “outside the scope” of a gather EA. That is because those issues are supposed to be identified and addressed in the document called the Herd Management Area Plan.

The court now recognizes the distinction between the two documents. BLMs regulations, handbook and how they operate clearly outline that these two things are not the same.

Scoping is supposed to identify “past, present and future” issues on a site-specific basis to provide an analysis of any “substantial” conflict and/or item to include as a management strategy. Scoping is supposed to help BLM define “goals and objectives” to create sound alternatives for management options in the draft HMAP EA or EIS (that will also have a comment period before being finalized).

We do not understand how BLM can repeatedly be allowed to do removals to reach “goals and objectives” for forty-years that were never defined in an HMAP. Doing a few years of removals to catch up with the new 1971 law is understandable. But 40 years of removals is simply not “ok.” For the vast majority of herds the “goals and objectives” were simply agreements made with permittees as sort of “place holders” until the 1971 Act was codified into law. After codification, the HMAP is the only actual management document noted in regulation.

BLM gave the public very little information when they announced scoping for the HMAP at Blue Wing (while our court case is in final briefing). We are working on trying to get a second scoping period to deal with this deficit. After scoping, BLM has to create a “Scoping Report.” We are asking for another comment period after that report is created, and before BLM drafts the HMAP itself, so that refinement of public input is allowed after some semblance of a data set is provided.

What do you want to see in a management plan? Basically, this is your chance to address all of the things you have been prohibited from addressing. You can pick one or two things… or dozens.

Examples:

Is genetics your pet peeve? Blue Wing covers an over 2 million acre removal zone where BLM set AML at 333-553 wild horses and 55-90 wild burros. BLMs own expert cites the incredibly fragile genetic makeup of this complex and the HMAs do not have much exchange (movement between). Bury BLM in citations on genetic health along with your comment.

Is fire fuel your focus? This area is in wildfire country. The state has issued high preparedness warnings. BLM has never addressed how many horses and burros should be on the range so they can perform a beneficial use removing fire fuels. If this is your focus send BLM in the new research demonstrating this beneficial use and why wild horses are much better at reducing fire fuel (not increasing noxious weeds) than cows and demand AML be analyzed scientifically to address this issue.

This is also your chance to demand that critical habitat for horse/burro use be identified, and seasonal movement needs identified, to create limits on industry and potential issues to be identified for mitigation. Every single management plan for any species identifies habitat needs to sustain viability. Water improvements, fence removal, seasonal corridors, are all identified in management planning for every other species. If the new research on the “native, non native” issue is a pet peeve of yours? You can add it to a comment related to habitat. However, habitat protection is expressed in the law no matter what label BLM puts on a horse or burro.

Is repatriation of zeroed out areas your thing? Here is an example of a longer comment:

“BLM omitted the inclusion of over half the acres in the complex from current HMAP scoping documents by omitting individual Herd Area (HA) acreage . BLM cannot simply exclude what they do not want to address. Inclusion of HA land is both appropriate and set by existing precedent. The land designated as “HA” represents more than half the land base of the complex in existing planning.

Current law recognizes the portion of Shawave “zeroed out” (the Antelope Range, Selenite Range, Trinity Range, and Truckee Rang) as “designated for horse and burro use.” Current law allows evaluation of these areas for repatriation. Considering the costs of capturing and holding wild horses and burros, evaluating HA for repatriation, outlining steps to guide repatriation, should be a substantive issue identified for evaluation in the HMAP.

Since BLM set AML at “0” in a portion of Shawave, the Antelope Range, Selenite Range, Trinity Range, and Truckee Range, these areas have been included in removal plans. This demonstrates that both horses and burros still utilize these areas as preferred habitat regardless of any agreements made with private interests to remove all horses and burros. Even without seeing census maps done over the last 4 decades, continued “gathering” of animals in these locations indicates habituation on legally designated lands.

Setting interim AMLs in the HAs to account for historic occupation (more than “0”) would be appropriate. The HMAP should provide clear guidance for guide monitoring and research to provide data to evaluate the areas for inclusion as HMAs and raise AML.”

When advocates say wild horses and burros are just removed to suit livestock and ming and everything else, it is not just rhetoric. The paperwork shows that statement is true. BLM just skips the piece of the law that mandates “management” and the planning needed to accomplish the task, the HMAP.

Burros: Burros are not horses. Defining foaling season, growth rates, habitat needs and monitoring plans specifically for burros is important. It is critically important that BLM recognize that burros are much more susceptible to capture stress and resulting health issues and death than horses are. You can put all of that in your comments.

Comments are due by June 1 on the Blue Wing Herd Management Area Plan (HMAP).

You can find the project on BLM ePlanning and submit comments via email or postal service. BLM does NOT have a simple “participate now” button on their planning page to facilitate comments.

The email to submit comments is: BLM_NV_WDO_WHB@blm.gov

You can send a comment on one thing or dozens… the important thing is that you speak out.

Thank you! Our wild ones need an educated an active advocacy more than ever.

We were offered a match! If you added a contribution to your shirt purchase, that amount will also be matched! All contributions to help us stop abuses will be matched for the Month of May by a generous supporter up to $5,000.

We need your help to continue to document, expose, work toward reform with lawmakers and litigate. Our wild ones deserve to live free on the range and free from abuse.