LAST DAY to comment in the scoping process for the Herd Management Area Plan (HMAP) for the Pancake Complex. The Pancake Complex in Nevada consists of 3 Herd Management Area administered by the BLM and the Monte Cristo Wild Horse Territory administered by Forest Service. The area spans more than 1.2 million acres.
In 40 years, BLM has only done removal plans, never management plans.
Earlier this year the court recognized that population growth suppression plans (roundup, fertility control) are not management plans. The only planning document coded into federal regulations is the herd management area plan or the “HMAP.”
The court also found the ten-year gather plan deficient and invalidated it.
That means there are no active or draft plans yet for management or population growth suppression of any kind. (Many of you have been misinformed by another organization that put out a frantic action item that is not accurate.)
There is the current scoping process, then a draft will be created. Once the draft is created you will have another chance to comment. Once all those comments are reviewed, the final will be crafted. If issues substantial issues are raised that are not addressed, then we can appeal or go back to the court. This is how all of public lands planning is done. That is why you see environmental groups appealing, winning something, fighting the next plan, appealing, on and on. There is no “one fix” for anything. If someone is trying to sell you that it is “snake oil” (a false cure).
Pancake HMAP (EA/EIS) comments are due July 15 and the BLM interface for the HMAP can be found HERE
BLM has not specified a closing time, only “July 15.” If you plan to comment try to submit early in case there are issues with BLMs site.
If you have time to craft your own letter: Submit written comments to the BLM Bristlecone Field Office, 702 North Industrial Way, Ely, NV 89301, Attn: Ben Noyes. Comments may be submitted electronically at BLM_NV_PancakeComplexMgmtEval2024@blm.gov .
BLM did not identify a “postmark” cut off for written comments. If you are doing written comments, it would be safe to say get them postmarked before end of day on the 15th.
These are different than the extensive comments WHE submits. Comment periods are not popularity contests. The number does not matter. If one person or 50,000 say the same thing, it only counts once.
Still living in the Pancake Complex
Wild Horse Education is completing our comments today to submit by close of business tomorrow. We submitted comments with our partner in the battle at Pancake (Rewilding America Now, RAN) through our attorney. WHE will also submit additional supplemental comments. (See the court win that brought about these changes HERE)
What is scoping?
Basically, “the scoping period” is where BLM reaches out to stakeholders to identify what is important to include in analysis for a proposed action.
Your responsibility is to provide identification of “significant” issues, areas that need analysis in order to make any determination of actions and provide data (or analysis of data provided by BLM) to support what you are asking for.
BLMs responsibility is to provide you with sufficient data and review of their current practices.
Essentially, if you have a subject you want to discuss, you can discuss it as a “significant issue” that needs further analysis (provide reason and data to support). We keep typing the word “significant” for a reason. That is the single scoping comment requirement.
Old Man, a medicine hat from the Pancake HMA.
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? Pancake has a population of both Damele curlies (the rarest of all curly genes) and Medicine hat paints (extremely rare). Both of these horses have a cultural significance: Damele Curlies to the history of settlement and the Medicine Hat to Native Americans. BLM currently has no plan at all to protect these traits. When they do roundups out there now they do what is called a “gate cut.” Basically anything that is caught is removed. You can request actual data on the population of these horses in the complex and an analysis to protect them.
Is fire fuel your focus? This area is in wildfire country. The state has issued high preparedness warnings for wildfire every year in this area. 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\ 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. Horses are confined behind boundary lines and other species are not. This makes critical habitat identification and preservation even more important.
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.
The northern areas of the complex (the Pancake HMA and the Monte Cristo WHT) are prime habitat where the majority of the curlies and medicine hats live. You can request an analysis that this area be turned into a Wild Horse Range (like the Pryor Mountains) and industry in the area limited or entirely restricted. More than one of the criteria for this analysis is met.
AML of 361-638 is absurdly low for a 1.2 million acre complex where exchange of populations is becoming more limited due to livestock and mining threatening any assertions of stability. BLM never disclosed an actual data-based equation for how they set AML, noting instead things like “agreements” and “settlements.” This is not what the law intended. You can ask for disclosure of all data used to set AML and an evaluation to set a science-based one. Populations in the complex have reached more than 4,000. A true AML would be somewhere between what BLM set through agreements with county and permittees … and the actual number of horses that have lived in the area.
Foaling season identified by data? Say it. BLM is prohibited from helicopter drive trapping during foaling season. But fails to identify it on a site–specific basis as they manipulate foaling times of year with fertility control and fail monitor deviations due to climate change (we are seeing this on the range: foaling season stretches out longer. Perhaps Mother natures way of trying to increase survival rates as species adjust to man-made changes?)
Fertility control? For or against it, comment. BLM needs to determine if fertility control is needed. If it is, a specific type of fertility control must be identified that has been specifically analyzed for use in the complex. They also need a humane protocol for application and a clearly outlined plan that identifies monitoring. BLM must stop just throwing all forms in the pot and just picking what political whims direct.
Can you see how commenting on Scoping is different than commenting on a draft plan? If you were commenting on a Population Growth Plan (Gather-EA) all of these issues would be called “outside the scope.” With an HMAP, they are within the scope and BLM needs to respond, not dismiss.
You can take the fast action by clicking HERE.
If you have time to craft your own letter. Submit written comments to the BLM Bristlecone Field Office, 702 North Industrial Way, Ely, NV 89301, Attn: Ben Noyes. Comments may be submitted electronically at BLM_NV_PancakeComplexMgmtEval2024@blm.gov .
BLM did not identify a “postmark” cut off for written comments. If you are doing written comments, it would be safe to say get them postmarked before end of day on the 15th.
Pancake, 2024
Our teams are out covering both the Blue Wing roundup in Nevada (click here) and the North Lander operation in Wyoming (click here).
Over the last two weeks we also filed additional briefing in the lawsuit aimed at gaining an enforceable welfare policy (the case filed last summer many of you will remember after the death of Sunshine). We have a meeting with the court on a grazing case tomorrow that sits underneath our federal lawsuit to protect another herd down at Stone Cabin near Tonopah (as we battle out the failure of BLM to even identify which horses are BLM and monitor a massive corridor between BLM and Forest Service as part of another HMAP case, Forest Service is set to give the permittee more cattle on the range and fence out horses)
Can you help keep the team in the courts and in the field?
Thank you so much for keeping WHE on the frontline!
Categories: Wild Horse Education
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