Thanks to AWHPC for this alert (online here)
Please send your letters by May 21 on the Bureau of Land Management’s (BLM’s) latest proposed mass round up — 1,000 Nevada mustangs living in the Owyee, Rock Creek and Little Humboldt HMA’s are targeted for permanent removal beginning in July 2010. See sample letter below.
In northeastern Nevada, just south of the Owyee Desert, lives a population of wild horses who are descendants of Cavalry re-mounts and 19th century ranch horses. These gray, bay, black, brown, roan and sorrel horses inhabit three BLM Herd Management Areas (HMAs), encompassing nearly 500,000 acres of Columbia Plateau and the Great Basin region lands.
Despite the fact that wild horses have thrived in the Great Basin region – approximately 70 percent of the BLM’s wild horse HMAs are located within this vast rolling plateau and high desert region – the agency continues to maintain that the area cannot sustain even moderate numbers of horses. Meanwhile tens of thousands of privately-owned livestock graze on public lands in this region.
Earlier this year, the BLM rounded up and removed nearly 2,000 wild horses living in the Calico Mountains Complex in Northwestern Nevada. Now the BLM’s Tuscarora Field Office is making plans for the mass removal of more Nevada mustangs, and the fates of 1,000 wild horses living in the Owyee, Rock Creek and Little Humboldt HMA’s are on the line.
While the agency maintains that the more than 750-square mile area encompassed by these HMAs can only support 440 wild horses, it authorizes ten times that amount of livestock — over 4,000 head — to graze the same area!
The BLM is seeking public comments on a Preliminary Environmental Assessment (EA) for this capture plan. This EA fails to seriously consider realistic alternatives for keeping these horses on the range, thus avoiding the high cost of warehousing wild horses in off-the-range holding facilities. These skyrocketing costs have rendered the BLM’s wild horse program fiscally unsustainable, according to the U.S. Government Accountability Office, the Senate Appropriations Committee and the Secretary of the Interior himself.
The BLM now stockpiles more wild horses in holding facilities (36,000+) than are left in the wild (>33,000). This latest roundup continues the BLM’s unsustainable cycle of mass roundup, removal and stockpiling of America’s wild horses.
By May 21, please personalize, cut and paste and email the sample letter below to the listed email addresses. Please circulate this alert to friends and family as well – the time to speak up for Nevada’s mustangs is now! SAMPLE LETTER: To: Tuscarora_horse_gathers@blm.gov, Chair@ceq.eop.gov, David_Overcast@blm.gov, Bruce_Thompson@blm.gov
Subject: Comments on Owyhee, Rock Creek & Little Humboldt HMA Preliminary EA
To Whom It May Concern:
I write in opposition to the plan by the Tuscarora Field Office to roundup 1,400 wild horses from the Owyhee, Rock Creek & Little Humboldt Herd Management Areas (HMAs) and permanently remove 1,000 of these mustangs in a roundup scheduled to begin in July 2010. The preliminary Environmental Assessment for this capture plan is inadequate for the following reasons:
1. The EA fails to adequately consider realistic alternatives to the permanent removal of 1,000 horses from the range. These include options for range improvements (such as repair to damaged water springs) as well as aggressive fertility control through round up and vaccination of all mares with PZP immunocontraception before release back to the range.
The Appropriate Management Levels (AMLs) of 337-561 wild horses established for these three HMA’s, which comprise more than 480,000 acres (more than 750-square miles), appear to be artificially and arbitrarily low. The BLM has been found repeatedly, most recently in 2008 by the Government Accountability Office, to arbitrarily set AMLs for wild horses.
2. The EA fails to give serious consideration to an alternative that would reduce livestock grazing within these HMAs. The agency clearly has the authority to implement this alternative pursuant to 43 C.F.R. 4710.5(a), which allows for closure of livestock grazing on areas of public lands “if necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury.” Currently, BLM authorizes the equivalent of more than 4,000 cow/calf pairs to graze per year within the three HMAs in question, and actual use is reported at the equivalent of over 1,000 head per year.
3. The EA fails to adequately evaluate the impacts to the horses of helicopter stampede and permanent warehousing in BLM holding pens and pastures. A recent report by the American Wild Horse Preservation Campaign on the deaths of wild horses as a result of the roundup in the Calico Mountains Complex, found a vast majority of those fatalities were related to the stress and trauma from capture, loss of freedom and the destruction of wild horse family bands. The report included the opinion of Dr. Bruce Nock, Associate Professor at the Washington University School of Medicine and expert on the physiological effects of stress on animals that the capture and removal of wild horses “is extremely detrimental to their long-term health and soundness.”
4. The EA states that wild horse AMLs and livestock grazing levels are set by existing land use plans, but fails to consider the fact that these plans are not set in stone and the agency, through its adaptive management policy, has the discretion to re-assess and amend them to address these matters.
5. The EA fails to evaluate alternatives for meeting the BLM’s “multiple use” mandate without livestock grazing by maximizing opportunities for wildlife, wild horses, recreational use, and ecotourism.
In conclusion, the Tuscarora Field Office’s plan to permanently remove 1,000 wild horses from the range and warehouse the majority of these horses in long-term holding pastures violates the intent of Congress that America’s wild horses be managed on the range in a humane and minimally-intrusive manner that preserves their wild and free-roaming behavior. As such, the agency is obligated to seriously assess alternatives to this mass capture and removal plan, something that this EA has failed to do.
As a result, I ask that the roundup of horses from the Owyhee, Rock Creek and Little Humboldt HMAs be canceled.