Thanks to Lyn in Colorado for this excellent letter! Eagle_comments
Be sure to include the Eagle HMA Wild Horse Gather
DOI-BLM-NV-L020-2009-0051-EA in your title.
BLM Ely District Office
HC 33 Box 33500
Ely, Nevada 89301
Attention: Mary D’Aversa, Schell Field Manager
Fax: (775) 289-1910
Email at: email@example.com
also good to cc: President Obama, Secretary Salazar and BLM Director Bob Abbey (contact information here)
I object to the Eagle Nevada roundup of the wild horses scheduled for February 2010 for the following reasons:
The Preliminary Environmental Assessment is incomplete and does not establish a scientific basis for removal of over 85% of the wild horses in the Eagle HMA. This failure requires a complete Environmental Impact Statement taking into consideration all the scientific evidence to protect “the natural ecological balance of all wildlife species which inhabit such lands . . ” and “any adjustments in forage allocations on any such lands shall take into consideration the needs of other wildlife species which inhabit such lands.” WFRH&B Act (1971) I underscore the word “other” because nowhere in the WFRH&B Act are wild horses and burros referred to as anything but “wild” and the intent of Congress and the WFRH&B Act was that they be managed as a “wild” species alongside the needs of “other” wildlife.
The EA is clearly constructed to construe the multiple use aspect of the WFRHB Act in favor of livestock use and for the removal of wild horses. Removing the “principal” user, the wild horses, to meet AML’s that are below the scientifically determined minimal level for any herd (150-200) animals was not the intent of the 1971 WFRHB Act when it mandated management at the “minimal feasible level,” for “multiple use, sustained yield.”
The DOI/BLM has exceeded it’s authority by eliminating the alternative to reduce or remove livestock to address the deteriorating range conditions. How can the range be managed for multiple use, sustained yield, without a detailed comprehensive analysis of the impacts of all users ? How is it that “sustained yield,” only applies to the livestock program which net revenue yields only a 2% net return to the permittees and only a 2% yield to the total beef production in the U.S. and whichyields OVER a 500 million annual expenditure in taxpayer money? The only “excess” I see in the Eagle EA is an excess of bias and taxpayer money going toward sustaining the commercial livestock interests.
The Eagle EA states that “livestock grazing can only be reduced or eliminated following the process outlined in the regulations found at 43 CFR Part 4100. Such changes to livestock grazing cannot be made through a wild horse gather decision.” The Federal Land Planning & Management Act “exemption clause” say’s: in relevant part, “where a tract of the BLM lands has been dedicated to specific uses according to other provisions of law, it shall be managed in accordance with such laws.” So how does 43 CFR Part 4100 get around the “exemption clause” of the Federal Land Planning & Management Act’s, those “other provisions of law” being the WFRHB Act.
These issues warrant a Moratorium on the roundups until Congressional hearings are held on the pending legislation to amend the Wild Free-Roaming Horse and Burro Act.