Comments on AML for Forest Service Herds in Nevada

reposted from the Mustang Project Blog
Comments due by March 19,  Notice of Proposed Action and Opportunity to Comment online here
“The Austin and Tonopah Ranger Districts of the Humboldt-Toiyabe National Forest welcomes your comments on the Wild Horse and Burro Appropriate Management Levels (AMLs) Project. The purpose of this project is to update or establish AMLs and set general management direction for the Wild Horse and Burro territories (WHTs) on the Monitor, Hot Creek, and Toquima Mountain Ranges. We would like your thoughts on the scope of issues to be addressed in the environmental analysis (EA) and your comments on the proposed action.”
“Territory management plans for joint FS/BLM management and monitoring of the wild horse resource are nonexistent or outdated.”
*The 11 WHTs that are affected by this proposed action are located in the Monitor, Hot Creek, & Toquima Mountain Ranges. Because these WHTs are adjacent to BLM administered public lands in these areas, BLM and FS would collaborate on proposed actions regarding wild horses and burros affected. Within the eleven WHTs, there are 21 cattle allotments administered by the FS (14 active and 7 vacant). (See pdf document, page 6, Table 1 for grazing information.) Monitor Wild Horse Territory – History & Info from the FS
WHTs Kelly Creek, Butler Basin, Dobbin Summit, Sevenmile, Little Fish Lake, Monitor North, Stone Cabin, and Monitor South (located within the Monitor and Hot Creek Mountain Ranges). Hickison Burro, Northumberland, and Toquima (located within the Toquima Mountain Range). All are under the jurisdiction of the Austin/Tonopah Ranger Districts of the Humboldt-Toiyabe National Forest. Contact: District Ranger, P.O. Box 130, Austin, NV 89310, (775)964-2671
HMAs – Saulsbury, Antelope, Hot Creek, and Willow Creek. These are under the jurisdiction of the BLM Battle Mountain District Field Offices – Tonopah & Mount Lewis.
Battle Mountain District Office, (Employee Directory)
50 Bastian Road, Battle Mountain, NV 89820, Phone: 775-635-4000 , Fax: 775-635-4034, Email:
bmfoweb@nv.blm.gov, District Manager: Gerald Smith
Tonopah Field Office, 1553 South Main Street, P.O. Box 911, Tonopah, NV 89049, Phone: 775-482-7800, Fax: 775-482-7810, Field Manager: Tom Seley
Mount Lewis Field Office, 50 Bastian Road, Battle Mountain, NV 89820, Phone: 775-635-4000, Field Manager: Doug Furtado
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33 Responses to “Comments on AML for Forest Service Herds in Nevada”

  1. Nini Says:

    More removals??

  2. themustangproject Says:

    I’m not really sure yet if this proposal would be in favor of removals, or if it is something that would be a good thing maybe because of the outdated or non-existent AMLs currently. If they don’t update/create them, there could be room within the old ones or nonexistent ones to remove way more than need to be removed.
    T.

  3. Marilyn Wargo Says:

    It is more likely that land will be gone after a readjustment. The Dead Of Winter by Cindy MacDonald, and her present essay, are warning us of manipulations and removals. mar

    • Marilyn Wargo Says:

      The pdf below is what you need to read to begin, then Cindy MacDonald’s “Two For One” at American Herds Blog. mar

      sandra longley Says:
      March 12, 2010 at 3:40 pm | Reply
      RED ALERT: We need an online form to comment on another gather I ran across this on another research project last night..comment period ends March 19, up around Tonapah Nev. BLM and USFS combining to remove horses…redefining HMAs and AMLs..say due to drought conditions no forage for horses..yet have 21 cattle allotments..one HMA would be down to 6 horses..I have just briefly gone over this and need to get into some research on this..go to the link and read and look at the tables..this is a bit more than just a gather..see what you think..hopefully they will post something online here soon.

      http://budget.state.nv.us/clearinghouse/Notice/2010/E2010-150.pdf

  4. Nini Says:

    That’s what I thought — manipulations & removals . . .

  5. LOUIE COCROFT Says:

    IS EVERYONE SENDING LETTERS TO THE FOREST SERVICE?

  6. Janet Ferguson Says:

    Spying a bright orange butterfly out my window today — I embarked upon a web search to determine the culprit.

    Found this. Especially interesting (oh, about wild horses) is their comment about the horses NOT reproducing in a year when food is scarce.

    http://www.enature.com/fieldguides/detail.asp?allSpecies=y&searchText=wild%20horses&curGroupID=5&lgfromWhere=&curPageNum=1

    • Janet Ferguson Says:

      also under the Wildlife Guides tab, at the top, is a drop-down menu which includes Park Guide.

      Haven’t looked for US PARKS in it yet. . . no time right now. . .

  7. arlene Says:

    Why are they doing these round-ups? The horses do not consume all the grazing. It is all about the money. Seven million $$$. OUr letters don’t amount to a hill of beans with these people. They simply do not read them, as with most everything else the will of ‘we the people’ is ignored.

  8. Terri Says:

    Let the Wild Horses have their land ! The BLM policies are cruel and inhumane!

  9. Janet Ferguson Says:

    Here’s my letter due 3-22-10 to Forest Service. Hopefully it bears some resemblence to reality. (Not sure)

    Dear Mr. Martin:

    Due Diligence Issues

    Please provide sources and proof of due diligence by the Forest Services of all your actions prior to issuing the above Livestock Grazing EIS, including all documents previously prepared, prior public commenting periods, and all other formal legal notices to the public.

    Your Term: “Desired Conditions” (definition of)
    What other entities, including government entities and other entities (University studies, etc.) collaborate with the Forest Service on defining desired conditions. Indicate dates of all relevant studies provided by all agencies or entities toward determining these “desired conditions.”

    Your Term: “Essential Ecosystems and Values”
    What do you define as “essential ecosystems and values?”

    What species of cattle are and will be permitted? The EIS must include all studies, by name and date, showing grazing use as it impacts the “Monitor-Hot Creek Rangeland” territories, including the impacts on all areas of wildlife, plants and water. Please give dates of each study and public access information thereto.

    Expansion of Existing Grazing Allotments

    How many head of cattle do you propose to allow permits for on the “vacant” Kelly Creek/North Monitor, White rock, South Monitor, Table Mountain and Monitor Valley East allotments?

    Provide detailed current maps of these allotments showing all existing wildlife species within the last 5 years, and their seasonal variations directly related to this proposal.

    Your proposed expansion of grazing allotment land to an additional 123,431 acres appears under your “Current Management Alternative” Option. How can increasing grazing allotments be seen as anything other than an expansion?

    Request for Further Definitions
    Please define “Livestock” as used in your “(No Action) Alternative”. Specifically, what species fall under your definition of Livestock as used in this proposal? This definition is essential to understanding your “No Action Alternative”. Horses are considered Livestock in the Great State of Nevada. Would you propose to remove all livestock (including wild horses) under this alternative? Please be specific. The public cannot understand your jargon you publish in these notices without further explanation.

    Livestock Grazing Standards
    Livestock grazing can be done responsibly. How will you ensure modern standards are agreed to by permittees and enforced by the Forest Service? What sources have you used in determining proper rangeland management practices to follow for this proposal? Please indicate dates of studies, and where these studies can be accessed by the public, showing they are directly related to and will be proposed for this project.

    FRATERNAL TWINS????
    Another proposal stated for the Austin/Tonopah AML Reduction overlaps areas discussed above. Please provide a document for public use, with utmost dispatch, defining clearly how these use areas overlap. Show the sources and dates of the information sourced for this public document which is essential in understand both proposals.

    I am concerned about your lack of protocol in providing notices to the public. It is not appropriate to already have reached a decision about what you are going to do before you even release the first EA to the public.

    Please provide an additional comment period, along with the information requested, above, before you issue the Final Decision.

    Respectfully,

    Janet Ferguson

  10. LOUIE COCROFT Says:

    JANET, I AM SO GLAD THAT YOU JUMPED IN!

    • Janet Ferguson Says:

      Thanks, Louie! But “the water ain’t fine!” haha

      I would like to thank my editors, our producer, my mother and father, and special thanks go out to Linda of NM upon whose incredible work I based every one of my comments. In such ways we support each other as we edge ever closer toward a better world for our wild horses and burros.

      Thank you.
      Thank you very much.

      • Janet Ferguson Says:

        Oh, and Laura Leigh of course — on her excellent paper from last summer!! (Which, if I had read it then would have save me untold hours of research and study.)

      • Janet Ferguson Says:

        Oh, and Marilyn Wargo who “shot” Linda’s letter over to me.

      • Linda Says:

        Hi, Janet. This afternoon I received an email confirming they got my AML letter. I had planned to call today, but, as usual, there were numerous other things on my plate. Did they send you anything?

      • Janet Ferguson Says:

        Thanks. No.

        Will call Williams today. . . I was thinking the same thing.

        Don’t forget to help fight Horse Slaughter from passing the Missouri Senate (it already passed the house) Check out animallawcoalition.com/horse-slaughter/article/1160 and know this:

        (From Vicki Tobin)

        “I have heard from several people that have called that they are puling the ol’ you don’t reside in MO so it’s none of your business. IF YOU GET THAT, TELL THEM IF THEY ARE GOING TO BE SLAUGHTERING HORSES FROM OTHER STATES, THEY HAVE MADE IT YOUR BUSINESS AND THEY MUST LISTEN TO EERY HORSE OWNER IN THE US. HORSES CROSSING STATE LINES TO GO TO SLAUGHTER MAKES IT A FEDERAL ISSUE, NOT A STATE ISSUE.

        Any Wyoming herd comments due Friday!

      • Janet Ferguson Says:

        Here’s My Missouri anti-slaughter letter for the Senators (quotes tons of Laura Allen)(verbatim):

        I am writing you today to urge that you do not support horse slaughtering plants in the State of Missouri. And to remind you this horse slaughter plants in ANY state affects horses in ALL states.

        Horse slaughter is cruel and has no place in American culture.

        The bill that passed the Missouri House of Representatives, (H.B. 747)is basically the same as the introduced bill, except for one significant change: If this bill becomes law, “[n]o law criminalizing or otherwise regulating crops or the welfare of any domesticated animals shall be valid unless based upon generally accepted scientific principles and enacted by the general assembly.”

        This means there could be no local laws regarding the welfare of any domesticated animal including dogs, cats, horses, other pets and farm animals that differ from state laws.
        Also, any current animal cruelty or animal welfare law in Missouri would be void unless it was “based upon generally accepted scientific principles and enacted by the general assembly.” People charged with animal abuse could raise challenges to the law, claiming it was not based upon “generally accepted scientific principles”. Possibly, all laws governing animal cruelty or welfare would simply be void because there was no determination of whether they were based upon “generally accepted scientific principles”. Arguably, current regulations governing animal welfare and protection would be void as well for this lack of this determination and also because they are not enacted by the legislature; regulations are issued by state agencies.
        In 2007 a federal court rejected an attempt by the USDA to allow horse slaughter operators to pay for the inspections. The USDA is currently not authorized to conduct ante-mortem inspections of horses to be slaughtered for human consumption. Without those inspections, it is illegal under the Federal Meat Inspection Act (“FMIA”), 21 U.S.C. §§601(w)(1), 603, to slaughter horses for human consumption.
        If this bill becomes law, it is not clear the USDA would authorize Missouri state inspectors to conduct the required inspections. The funds to pay for the state as well as USDA inspections would come from horse slaughter operators, the same situation in the previous litigation. The judge in that case found the USDA violated the Administrative Procedure Act and the Environmental Policy Act (NEPA).
        Also, there is strong opposition to horse slaughter in the U.S., and the goal is to pass the Prevention of Equine Cruelty Act, H.R. 503/S.B. 727, to end this brutal practice altogether for all American horses. A similar bill passed the House of Representatives by an overwhelming majority in 2006, a vote of 263 to 146, but was never voted on in the Senate.
        In 2007 a law in Texas, Texas Agriculture Code §§ 149.001-.007 was found to ban horse slaughter for human consumption and was upheld by the 5th Circuit Court of Appeals. A ban in Illinois, 225 ILCS 635, on horse slaughter for human consumption was upheld in 2008 by the 7th Circuit Court of Appeals. These state laws and court rulings closed the 3 facilities that were still slaughtering horses in the U.S.; those facilities were located in Texas and Illinois. Rep. Jim Sacia’s once again attempted to overturn the Illinois ban on horse slaughter for human consumption; the Illinois legislature and Illinois voters have never supported this effort.
        Horse slaughter is also illegal in California, CA Penal Code § 598c (“unlawful for any person to possess, to import into or export from the state, or to sell, buy, give away, hold, or accept any horse with the intent of killing, or having another kill, that horse, if that person knows or should have known that any part of that horse will be used for human consumption”). A Mississippi law, MS Code §75-33-3, states that the “term ‘food unfit for human consumption’ shall be construed to include meat and meat-food products of horses and mules.”. In Oklahoma, 63 Okla. Stat. §1-1136, it is “unlawful for any person to sell, offer or exhibit for sale . . . any quantity of horsemeat for human consumption.”
        In 2009 the Rhode Island House of Representatives issued a resolution in support of a federal ban on commercial horse slaughter for human consumption. A similar resolution is pending in California. A bill is pending in New York to ban commercial horse slaughter or trade in horse meat for human consumption. Wisconsin, Senate Bill 142 would also ban horse slaughter.
        The U.S. has never tracked drugs that may be in horses sent to slaughter for human consumption. The European Union has realized just how dangerous horse meat may be for consumers and has issued guidelines regarding these horses.
        This only underscores horses are not a food animal; they are our companions and pets.
        Horse Slaughter is a seedy business.

        Horse thefts in all states will increase if slaughter returns to any one state in the the United States.

        Time, thought and money needs to go to education and real solutions to stem the irresponsible breeding of horses in this great country, not to giving organizations like quarter horse or thoroughbred breeders a free ride in their thoughtless and cruel breeding programs where they breed excess horses.

        Also thought and assistance must be on hand for owners of the “family” horse who can no longer afford their care. Rescues need support and financial support for people to humanely euthanize their horse through veterinary means rather than dump them at an auction. People don’t even know there are Killer Buyers at these horse auctions, and sell their horses straight into the slaughter pipelines.

        By the way, go to the internet and do some google searches, if you have any idea how many weekly horse auctions there are all over this state of Missouri and all over this country? It is too easy for irresponsible breeders or owners to dump their horses, and this legislation will make it even easier for such horse dumping. Try to think creatively about solutions. When YOUR horses have reached the end of their lives, would you take them to the slaughterhouse???

        Horse slaughter is not a humane solution. Go to a slaughtering plant yourself and watch them. I dare you.

        Sincerely,

        Janet Ferguson
        St. Louis, Missouri

        Please go here for a thoughtfully written and comprehensive article discussing the issues and possible real solutions, for the problem of the “so-called” “excess horse.”

        “Sensible Debate Over Unwanted Horses”

        http://www.horsetalk.co.nz/features/horseslaughter-152.shtml

      • Linda Says:

        Hi, Janet,

        I went to the ALC article you posted, and was SHOCKED to find a comment that some person “thinks” Massachusetts has passed a bill allowing horse slaughter for human consumption at state prisons.

        I grew up in MA, and IMMEDIATELY called the MSPCA Nevins Farm Horse Rescue. I spoke with a woman who said if horses were being slaughtered for human consumption in MA, or if there was any such bill before the legislature, the MSPCA would be the first to hear about it.

        Also went to Alex Brown Racing, and there wasn’t anything about MA in their pro-slaughter bills list. Lots of other states though. So depressing.

        If anyone has credible information to the contrary, PLEASE let me know ASAP.

      • jo bunny Says:

        linda, i live in MA & the person who made the comment is WRONG. massachusetts has NOT passed any such law. WYOMING was the state that passed the law opening up horse slaughter & feeing the horsemeat to prison populations (you can credit slaughterhouse sue for that). i’ll look for the article & comment to which you are referring on ALC & see if i can set them straight. you can read more about the wyoming law at RT’s website http://rtfitch.wordpress.com/2010/03/12/the-princess-a-duke-and-a-plan-that-goes-doink/

      • Linda Says:

        jb, bless you! Now I can go back to writing Wyoming Scoping and Missouri Slaughter comments without MA in the back of my mind. Hope there’s nothing else coming up for at least a few days. I need a breather!

        As for “Princess Sue” – if slaughter comes back to Wyoming or any other state, may her family’s plates be piled high with toxic horseflesh. Oh, I keep forgetting, she wants that toxic horseflesh on other people’s plates!

  11. LOUIE COCROFT Says:

    JANET, I LANDED SMACK DAB IN THE MIDDLE OF A BUNCH OF WRITERS–IS JOHN STEINBECK HERE ANYWHERE?

  12. Janet Ferguson Says:

    For our sakes, I hope not:

    (from Wikipedia)

    John Steinbeck died in New York City on December 20, 1968 of heart disease and congestive heart failure. He was 66, and had been a life-long smoker. An autopsy showed nearly complete occlusion of the main coronary arteries.

    Besides I do not ever plan to have 3 wives.

    Apart from that, we should all wish for a father who will let us live free in his Monterey Beach house; provide paper for our manuscripts, and send us money when we need it.

    Thank goodness for John Steinbeck, a national treasure, and all his helpers, wives and all! He is truly an American Icon.

    Now I need to go read AT LEAST ONE of his books. Louie, which one do you recommend?

  13. LOUIE COCROFT Says:

    “TRAVELS WITH CHARLIE”. YOU WILL LOVE IT. I ALSO FOUND IT ON TAPE IN A SECOND HAND BOOK STORE. HE TRAVELS WITH HIS POODLE, CHARLIE, THROUGH THE COUNTRY IN THE SIXTIES–IN A TRUCK AND CAMPER. HE WANTS TO GET A FEEL FOR WHAT IS GOING ON AND HOW THE PEOPLE ARE FEELING ABOUT THINGS–A TIME OF GREAT CHANGE AND TURBULENCE. HIS INSIGHT IS WELL WORTH READING. WE REALLY COULD USE HIM HERE.

  14. Janet Ferguson Says:

    I remember that book — my Dad read it in the ’60’s — I remember there was a picture on the front of a big water spaniel (black) or ? in the front seat of a (pickup truck?)

    You are right — I wonder who that person could be — I vote for Richard Symanski (now a college professor) who wrote, “Wild Horses and Sacred Cows.” He went out into Nevada to find out more about wild horses and interviewed ranchers, BLMers, etc. You would be amazed at the stories in his book, published in the 80’s. I have had the book since Christmas and haven’t even begun to plumb the depths of anecdotes, names, places and events he speaks of. Should be required reading for all advocates!!

  15. LOUIE COCROFT Says:

    JANET, I HAD ALREADY SENT A LETTER–NOTHING LIKE YOURS, THOUGH. MINE IS JUST A PLAIN OLD LETTER. I WOULD HAVE LIKE TO READ YOURS BEFORE SENDING MINE–I SURE COULD HAVE IMPROVED UPON IT.

  16. LOUIE COCROFT Says:

    JANET, “TRAVELS WITH CHARLIE” WAS WRITTEN BY JOHN STEINBECK. IT MIGHT HAVE BEEN ONE OF HIS LAST. THE POODLE, CHARLIE, WAS HIS TRAVELING PARTNER.

  17. Janet Ferguson Says:

    I will try to put my letter on here by day’s end or first thing (by noon) tomorrow. Here’s my ideas so far:

    Probably will lean on the vagueness issue as well as the “if it ain’t broke (and you can’t flatly say you have PROOF that hooves will destroy the “sensitive plants”) — don’t fix it idea.

    Plus the idea that there are ‘way too many WHT’S they are trying to deal with at once, plus the idea that if the law has been in place since 1971 why the heck haven’t they already done this stuff; why are they relying on Brown 2006 so heavily which only shows vague trends that “may occur” to OTHER (vaguely defined) POSSIBLE outcomes — basically they repeat themselves in a miasma of jargon, and unsubstantiated non-statements — such as using the words: (check it out!!) “May” instead of “Will”; “Could” instead of “Will”, because if they used the word, xyz “will” result in; instead of xyz “may” or “could” result in, someone could hold them to a higher standard of proof.

    That’s where I’m going with it, anyway and I’ll put it up here when it’s done; all you can do is work from where you are at and call it like ya see it?! We can’t all be forest biologists or beaurocrats steeped in the miasma of jargon and deception, but we can do our best.

    • Janet Ferguson Says:

      Note no studies done on actual damage to certain sensitive plants by horses.

      I am going to ask for a side-by-side chart of cattle/horse-burro overlap and also a chart they have done on issues involving grazing impact.

      Or sometthing like that

  18. Janet Ferguson Says:

    I wish more people would put there letters up here. Always have wished for that.

  19. LOUIE COCROFT Says:

    JANET, SANDRA MILLER HAS HER LETTER–I THINK IT IS ON THE LONDON PROTEST THREAD. MY LETTER IS SO BLAND THAT I DON’T THINK IT WOULD BE MUCH HELP TO ANYONE–THAT IS WHY I KEPT PESTERING YOU GUYS TO WRITE. MINE CAN JUST BE IN THE COUNT. I THOUGHT THE DEADLINE WAS MARCH 19, SO I SENT IT LAST WEEK.

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