Bullfrog (Burro) Comments due October 18th

By Laura Leigh on October 16, 2024

The BLM has an active comment period for the Bullfrog Burro HMAP and “gather-EA.”

Comments are due October 18th. BLM did not include “by the end of business.” But try to get your comments in as early as you can. Use the “Participate Now” button on the BLM website. You can access documents and BLMs participation portal HERE.

If you do not want to write your own comments, you can sign-on to a joint public simple note by clicking HERE.

Preface

The Herd Management Area Plan (HMAP) is the planning document neglected for 40 years that would have set AML transparently and noted critical habitat needs. These baselines would have been set 40 years ago… before BLM gave away all the critical resources to profit driven interests. If HMAPs were done 40 years ago (and updated every 10 years as originally intended) wild horses and burros would have been protected on their limited designated ranges (only 12% of public lands). Instead, their homes have been carved up.

BLM only re-started doing HMAPs due to our litigation after neglecting them for decades. The doorway to protect our wild ones has just opened over 50 years after the law was passed to protect them.

Today, we sit at “ground zero.” Our wild ones are being pushed to numbers that have not been seen since Congress declared them “fast-disappearing” on the landscape and have been treated with fertility control agents (GonaCon) that many herds will never recover from (more on this paradigm shift we must rise to meet soon).

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Above: The Bullfrog HMA is located in an area where over allocation of water for mining is leaving humans, wildlife and burros in a really bad spot. On top of existing mining, this area is being targeted now for lithium.

Without an existing HMAP there has been no mitigation to protect any habitat for burros for 50 years. Now, when the resources have reached a critical juncture where there is concern there is not even enough water for existing mining, BLM finally releases an HMAP Scoping period.

If you do comment, key points to remember:

Industry must be limited and existing habit protected to maintain a thriving burro population in the area designated for burro use.
Water improvements are key to keeping burros deeper in the HMA and off roads.
A “burro viewing loop” should be created to move tourists off the highway.
An overpass or “burro crossing” should be installed.
No roundup should happen until after BLM mitigates decades old damage to burro habitat and increases the number of burros to a sustainable genetically thriving AML.
No removal should occur until the HMAP fully analyzes goals and objectives for the herd.

Bullfrog (The following is submitted by WHE volunteer Laurie Ford to share some of her thoughts about the HMAP Scoping and BLM management).

As of September, 2024, 3,290 burros are languishing in holding facilities – up from 3088 only a month prior. There are no long-term pastures available for burros. The number of burros being sold (immediate title transfer with no protection from being sold to slaughter) has skyrocketed – likely attributed to their increasing value at the kill pens due to the demanding China Ejio trade. In 2023 1105 burros were adopted and 877 sold – almost double from the previous year.

According to The International Union for Conservation of Nature, in less than 10 years we will have met 2 of the three criteria set for these burros to be considered an endangered species – we will have reduced their population by 80% and left fewer than 2500 adult males on all rangelands.

BLM’s belief that almost all wild burros can be removed from the wild and placed into private care is falling apart.

Reactionary management through removals and warehousing has failed.

The agency relies on holding facilities and adoption programs to handle the animals it gathers. (Richard Stephens Special to the Pahrump Valley Times July 28, 2023)

The Bullfrog HMAP must be finalized providing humane, sustainable proactive solutions and alternatives serious consideration an analysis before drafting any gather plan. This should have been done in 2012 when the Wild Burro Gather Plan and Environmental Assessment (DOI-BLM-NV-B020-2011-0102-EA) stated the future may also involve development of a Herd Management Area (Plan) that took them decade to begin while wringing their hands and neglecting obligations.

A dozen burros were shot and killed in 2018 in the Bullfrog HMA. BLM never found out who did it.

The creation of an HMAP is not the only reiteration taking place between the 2012 and the 2024 Bullfrog Herd Management Area Management Evaluation.

In 2012 the problem of burros congregating in urban areas and along roadways and becoming habituated to humans feeding them already existed. This is not due to hunger. It is because of the continual interaction with humans disrupting natural foraging, behavior and movement. The EA emphasized the need to Minimize conflict with humans in the town of Beatty, Nv and collisions on highways and roads. It also stated Inadequate fencing around Beatty has led to burro-human interactions. (DOI-BLM-NV-B020-2011-0102-EA)

No… humans simply present and uneducated leads to human-burro interactions. Even when there is fencing, humans want to interact and will feed burros causing habituation in every area across the West. Why hasn’t BLM created a viewing loop off the highway so townspeople and tourists alike can see burros and no create a hazard?

There has been some discussion of the BLM instituting fertility control measures to keep the burro population under control, but nothing has been done along that line yet. (Pahrump Valley Times July 28, 2023)

This statement is typical as the BLM basically ignores burro management because “almost all wild burros can be removed from the wild and placed into private care at costs that are comparable to the cost of treating and releasing them.” So BLM has simply stuck with the “burros are easy to place” line instead of management on range.

Highway 95 runs right through the Bullfrog HMA creating a safety issue for both the burros and the public. Once again, this problem was presented in 2012 with no solutions considered except to continue conducting nuisance and emergency gathers.

BLM says: Wild burros are wandering onto U.S. Highway 95 through the town of Beatty causing collisions with motorists, resulting in a public safety hazard. Multiple collisions per week have been reported at times. Many wild burros are residing inside the town of Beatty, Nevada searching for forage and water, creating hazards to citizens of Beatty, pets, motorists, and property damage. Burros residing in town and their interaction with the urban environment could threaten the health and overall well-being of the wild burros and public safety.

In 2012, BLM told WHE members that toured the area that BLM was going to do water improvements deeper in the HMA to encourage burros to stay away from the highway and was considering a “burro crossing.” In typical BLM fashion, that never happened.

Here we are, twelve years later, and the BLM is echoing the same sentiments with the only “solution” BLM ever proposes – remove and warehouse.

Traffic accidents increase as burros are drawn into roadways seeking food and water.

Intentional feeding and watering of the burros by the public is a persistent issue that encourages the wild burros to seek resources in town, placing both humans and burros in dangerous situations. Vehicles pulled aside to offer human food to wild burros are increasingly observed in areas with high interface between wild burros and the traffic of Highway 95. Increasing education and outreach efforts with the public in Beatty, NV, and the surrounding area is an important objective of the Tonopah Field Office for future management. (Management Evaluation Bullfrog Herd Management Area September 2024 pg. 12)

Even today, the only other suggestion is to education the public rather than create and enforce an ordinance making it unlawful to feed the burros. BLM could easily create a “burro viewing loop” and do a water improvement to draw burros off the highway… then people could see the burros and decrease collision risk.

It is arguable that having the burros in town is good for local businesses. It has been shown that something that “stops the wheels turning” causes travelers who have slowed down or stopped to be more likely to notice and patronize businesses. (Richard Stephens September 12, 2024) Implying that “drawing burros in” is done intentionally by businesses in town.

Across the country overpasses have been created for wildlife to cross highways and facilitate their natural movement. This solution, along with reinforcing fencing, would improve wild burro distribution and disperse wild burro use – a current focus in future management (pg. 11) – must be included in the HMAP.

Water is another ongoing issue – one the Nevada Department of Wildlife was able to address by installing water developments {i.e. guzzlers} to accommodate the Bighorn Sheep population in the area of the adjacent Sterling Silver Mine.

If a similar proactive approach had been taken in 2012 the AML of the Bullfrog HMA could have very likely increased by 2024.

Reasonably Foreseeable Future Actions

Future activities which could occur include water developments and spring enclosures, and mineral exploration activities, and maintenance of existing and construction of new sections of transmission lines. The AML of the Bullfrog HMA could be increased as proposed in the 2007 EA and RHE if additional water sources are developed in the ―dry‖ areas of the HMA. Any decisions regarding the appropriate level of burro use would be determined based upon inventory, use patterns, and availability and condition of water and forage, following consultation with interested public. (DOI-BLM-NV-B020-2011-0102-EA pg. 49)

Instead, BLM wants to reduce the Bullfrog population to AML and THEN:

Assure sufficient water and forage exist for wild horses and/or burros in herd management areas. (Bullfrog Evaluation 2024 pg. 14)

While wild burros frequently travel long distances between water sources and preferred feeding locations, providing and maintaining multiple reliable water sources greatly improves wild burro distribution, leading to improved health of the herd and the rangelands they depend on. Continuing to monitor, maintain, and improve water sources on the HMA will remain a focus of the management in the future. (Bullfrog Evaluation 2024 pg. 11)

Burros can go long periods without water (often 3 days) and sustain water loss up to 30% of weight and restore fluid loss in 2 to 5 minutes. Moisture is also extracted from plants the burro consumes.

Yet, while a burro may consume 2 gallons of water, the millions of gallons that will be utilized by the North Bullfrog Mine doesn’t seem to be a major concern. Neither does the fact that the footprint of the mine may displace wild burros, increasing use of the remaining resources in the HMA, particularly with the current extreme levels of overpopulation. (Bullfrog Evaluation 2024 pg. 15)

Finally, the BLM must stop applying the Henneke body score to burros. In 2012 the EA claimed a History of poor wild burro health and Henneke body condition scores of 3 (thin) or less.

A body score of 3 for a burro reflects an ideal condition and weight – not thin and poor health.

Baby in the Bullfrog HMA

FUTURE MANAGEMENT

From BLM: The TFO is preparing a Bullfrog Herd Management Area Plan (HMAP) to guide management of the wild burros and their habitat into the future. The HMAP update will address the following management objectives:

• Sustain healthy populations of wild burros within the Herd Management Area AML range.
• Assure healthy range and riparian conditions.
• Utilize all population growth suppression methods.
• Disperse wild burro use.
• Minimize conflict with humans in the town of Beatty, NV.
• Public education and outreach.
• Minimize collisions on highways and roads.
• Maintain desert tortoise habitat.
• Other issues as identified.

An HMAP Scoping is a time you can comment on anything you want to. BLM uses comments to identify issues and potential solutions before crating a draft management plan.

If you do comment, key points to remember:

Industry must be limited and existing habit protected to maintain a thriving burro population in the area designated for burro use.
Water improvements are key to keeping burros deeper in the HMA and off roads.
A “burro viewing loop” should be created to move tourists off the highway.
An overpass or “burro crossing” should be installed.
No roundup should happen until after BLM mitigates decades old damage to burro habitat and increases the number of burros to a sustainable genetically thriving AML.
No removal should occur until the HMAP fully analyzes goals and objectives for the herd.