Wild Horse Education comments below to the Scoping Letter on the proposed BLM removal plan of the South Steens HMA in Oregon.
Comments must be received by April 29th: Lisa Grant, Burns District Office email to firstname.lastname@example.org
You may use our comments as a template to craft your own.
These comments address scoping letter to the proposed ten-year plan being crafted and addressed in Document 4700 (ORB050/0RB060) pertaining South Steens wild horse Herd Management Area (HMA) in Oregon.
We realize that the current budget constraints are being met with requests to compose decision records that would require less extensive preparation over time. However any plan that spans a decade must incorporate the fact that new data must be gathered prior to any removal action to ensure that appropriate genetic diversity, population levels and herd health are factored into any actions that span the decade covered by this proposed EA. No broad stated purpose of action is appropriate based on data gathered in 2013 that may be incomplete, inaccurate or fails to incorporate any new methodology available throughout the course of any EA/ROD issued pursuant to the crafting of this initial assessment.
A recognition of the current holding crisis must also be reflected in the crafting of current assessments for range management. All efforts must be made to utilize birth control methods in a fashion that maximizes potential for effectiveness. The use of small scale bait and water trapping, darting of PZP, and cyclical application of PZP must be assessed.
Included in any assessment of management of wild horses the effects of permitted grazing must be understood. Impacts due to turnout time of livestock and how they change wild horse utilization of available habitat must be understood. Over utilization of winter ranges (low lands) must be assessed. Inappropriate allocation of livestock permits is a factor in that winter range use of forage must be maintained for wildlife and wild horses. Adjustments of livestock permits (timing of turnout and minimal reductions) should be assessed to maximize range production to accommodate populations at high AML until PZP applications minimize numbers of wild horses removed. Cost savings of this approach should be analyzed.
An analysis of fencing must be included in any management assessment. Non-essential fencing must be removed and drift fencing minimized to inhibit artificial over use of the range.
Predator control data must be included in the assessment to determine if it interferes with population controls that create an unnecessary cost of removals and other population control methods.
Controls for protecting genetic components present in the South Steens herd must be outlined in the EA/ROD. Genetic information must be published in the EA and criteria for monitoring the alleles present in the population, and safeguards against their loss, must be included. Reintroduction of outside the HMA animals is NOT protection of the unique aspects of the South Steens.
Drought plans or other potential emergent situations should be assessed. Histories of such events should be included in any assessment that proposes to manage over a decade. Provisions for temporary feeding and water hauls should be included and what criteria would trigger removals.
In the event that helicopter or bait trapping operations are a necessity a clear and enforceable policy for human handling must be included in the EA/ROD. Follow all expectations set by the courts in ongoing actions in federal court concerning other areas managed by the BLM including: Helicopter distance, barbed wire, limited use of hotshots, not running animals so youngsters can not keep up with the herd. Ramifications for not following such handling protocols must be included in the EA/ROD.
Any operations for removing animals such as, but not limited to, helicopter roundups and bait trapping must be done in a manner transparent to the public. Criteria for observation opportunities and participation must be made available a minimum of thirty days prior to removal operation.
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EXPERIMENTAL STEERING COMMITTEE MEETING, Cedarville CA 4/25
The meeting of the Modoc-Washoe Experimental Stewardship Steering Committee, was held today, Thursday, April 25, at 9 a.m. at the Bureau of Land Management Surprise Field Office, 602 Cressler St., in Cedarville.
From BLM press release ““Other agenda items include updates on recovery from last summer’s wildfires, a report on flash grazing and discussion about management of wild horses and burros. A committee exploring options for reopening Cedarville’s lumber mill also will present a report.”
There was an emphasis from the committee to sell or destroy animals in holding. Also a lack of recognition of any parameters of the Wild Free Roaming Horse and Burros Act except the provision of sale authority. Other proposed management strategies were glossed over.
No representative from the wild horse advocacy sits on the Board.
It would be suggested that members of the public attend such meetings including RAC’s, Advisory Boards and special committees.
A total of seven people spoke representing public interest in wild horses and burros. Representing in person was Carla Bowers. A teleconference line was set up for those that could not make the meeting in person. Elyse Gardner (Humane Observer), Deb Coffey (journalist), Deniz Bolbol (AWHPC), Lauren Wachs (TCF), Laura Leigh (WHE) and an individual Sherry Auster (unsure of name spelling) participated in public comment. Comments were limited to three minutes.
Updates and expanded info coming soon on many issues.