Documente Academic
Documente Profesional
Documente Cultură
15,
2015
Paul
E.
Podborny
BLM
Schell
Field
Office
Manager
Via
Email:
blm_nv_water_canyon@blm.gov
RE:
Water
Canyon
Wild
Horse
Growth
Suppression
Pilot
Program
Preliminary
Environmental
Assessment
(DOI-BLM-NV-L020-2015--0014-EA)
Dear
Mr.
Podborny
These
comments
on
the
abovementioned
Environmental
Assessment
(EA)
are
submitted
on
behalf
of
the
American
Wild
Horse
Preservation
Campaign
(AWHPC).
AWHPC
is
dedicated
to
preserving
the
American
wild
horse
in
viable
free-roaming
herds
for
generations
to
come,
as
part
of
our
national
heritage.
Our
grassroots
efforts
are
supported
by
a
coalition
of
over
60
historic
preservation,
conservation,
horse
advocacy
and
animal
welfare
organizations.
The
information
presented
in
these
comments
is
endorsed
by
the
nearly
11,000
citizens
who
have
submitted
comments
on
this
EA
and
Proposed
Action,
as
well
as
the
more
than
19,000
citizens
who
signed
a
petition
to
the
Northeast
Nevada
Great
Basin
Resource
Advisory
Council
(RAC)
endorsing
an
alternative,
more
acceptable
and
scientifically
sound
PZP
fertility
control
program
for
the
Water
Canyon
wild
horses.
I. Overview
The
BLM
is
proposing
to
manage
a
31,000-acre
sub-section
of
the
331,000-Antelope
Herd
Management
Area
by
restricting
the
number
of
wild
horses
allowed
in
this
area,
known
as
Water
Canyon,
to
just
25.
At
the
same
time,
the
BLM
authorizes
the
grazing
of
6,000
sheep
in
the
allotments
that
overlap
the
area,
and
livestock
grazing
levels
have
not
been
reduced
in
light
of
prolonged
drought
conditions.
The
EA
outlines
a
management
plan
for
the
Water
Canyon
area
that
relies
on
roundups
every
two
years
to
remove
horses
and
apply
PZP-22
birth
control.
This
EA
was
prepared
in
response
to
a
recommendation
by
the
Northeast
Nevada
Great
Basin
Resource
Council
(RAC)
urging
BLM
to
implement
a
pilot
program
using
the
PZP
birth
control
vaccine
to
humanely
manage
wild
American
Wild
Horse
Preservation
Campaign,
PO
Box
1048,
Hillsborough,
NC
27278,
contact@wildhorsepreservation.org
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 2
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 3
conditions
have
allowed
very
little
forage
for
livestock
in
the
Becky
Springs
Allotment,
and
on
page
34
that
Under
the
Proposed
Action,
available
forage
for
livestock
would
likely
see
an
improvement
in
quality
and
quantity
over
time
since
the
wild
horse
population
would
be
gathered
in
increments
and
population
growth
rates
would
be
less.
However,
given
that
livestock
grazing
on
BLM
lands
is
a
discretionary
activity,
while
wild
horse
and
burro
protection
is
mandated
under
federal
law,
the
BLM
should
be
seeking
to
make
more
forage
available
for
wild
horses
in
this
HMA
rather
than
reducing
their
numbers
to
make
more
forage
available
for
livestock
grazing.
This
is
particularly
true
given
the
gross
disparity
in
forage
resource
allocation
in
the
Antelope
HMA
generally
and
the
Water
Canyon
Area
specifically.
According
to
the
EA
(page
32)
the
BLM
allocates
6,532
Active
Animal
Unit
Months
(AUMs)
of
forage
for
livestock
in
the
six
allotments
that
overlap
the
proposed
project
area,
allowing
nearly
6,000
sheep,
as
well
as
cattle
and
goats
to
graze
in
the
area
at
various
times
of
the
year.
Incredibly,
the
livestock
AUMs
allotted
in
these
six
allotments,
-which
constitute
less
than
one-third
of
the
HMA
--
could
support
544
wild
horses
far
more
than
the
high
AML
of
325
horses
established
by
the
BLM
for
the
entire
HMA!
Given
the
vast
disparity
of
livestock
vs.
wild
horses
in
this
area,
it
is
absurd
and
scientifically
unsupported
to
suggest
that
the
Water
Canyon
Area
can
support
just
25-30
horses.
Federal
regulations
(43
CFR
2710.5)
authorize
BLM
to
close
appropriate
areas
of
the
public
lands
to
grazing
use
by
all
or
a
particular
kind
of
livestock
[i]f
necessary
to
provide
habitat
for
wild
horses
or
burros,
to
implement
herd
management
actions,
or
to
protect
wild
horses
or
burros
from
disease,
harassment
or
injury.
Given
the
gross
disparity
in
resource
allocation
in
this
HMA,
combined
with
the
cost
of
removals
and
holding
of
horses
and
the
fact
that
holding
facilities
for
captured
mustangs
and
burros
are
full
with
nearly
50,000
stockpiled,
the
BLM
must
utilize
this
CRF
if
necessary
to
avoid
removals
of
horses
from
this
area.
The
BLM
proposal
to
establish
an
AML
of
25-30
horses
in
this
area
is
unsupported
by
science
or
data
and
unjustified
in
light
of
the
preferential
treatment
of
commercial
livestock
grazing
over
federally-protected
wild
horses
in
this
area.
At
minimum,
the
current
number
of
horses
must
be
maintained
in
this
area
and
all
plans
to
remove
horses
should
be
cancelled.
B. Helicopters
must
be
eliminated
as
an
option
for
capturing
horses.
Only
bait
trapping
for
the
purpose
of
PZP
birth
control
application,
and/or
remote
darting
of
horses
with
PZP
should
be
utilized.
The
final
EA
and
Decision
Record
should
exclude
from
consideration
the
use
of
helicopters
to
capture
horses.
Helicopter
roundups,
which
force
horses
to
run
for
miles,
are
documented
to
cause
significant
stress.
In
helicopter
drives,
elderly
horses,
very
young
foals,
and
sick
or
injured
horses
are
stampeded
along
with
the
fit.
Bait
trapping
is
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 4
widely
acknowledged
as
a
less
traumatic
and
more
humane
capture
method
for
both
PZP
application
and
removals.
This
EA
acknowledges
on
page
24
that
water/bait
trapping
is
low
stress
in
comparison
to
helicopter
drives.
The
BLM
Wyoming
notes
in
its
fact
sheet
on
a
bait
trapping
operation
in
the
McCullough
Peaks
HMA
that
helicopter
roundups
can
be
harder
on
the
animals
than
a
bait
trap.
(See
http://www.blm.gov/style/medialib/blm/wy/programs/wildhorses/2013/mcpeaks.Par.0963.Fil
e.dat/Fact.pdf)
C.
PZP
fertility
control
must
be
utilized
as
an
ALTERNATIVE
TO
(and
not
in
addition
to)
removals
of
wild
horses
from
the
range
and
ONLY
BE
utilized
WHEN
SUSTAINABLE
POPULATION
NUMBERS
numbers
are
allowed
in
the
Water
Canyon
portion
of
the
HMA.
1.
The
plan
to
reduce
the
population
in
the
Water
Canyon
area
to
just
25
horses
AND
to
treat
half
of
the
mares
with
PZP
is
a
recipe
for
managing
this
herd,
which
is
almost
isolate[d]
from
the
rest
of
the
HMA
due
to
the
installation
of
a
fence
on
the
northern
end
of
the
project
area,
to
extinction.
As
such
the
plan
is
unacceptable.
2.
PZP
should
only
be
utilized
if
NO
removals
take
place,
allowing
the
wild
horse
population
to
increase
to
more
sustainable
levels
before
the
vaccine
begins
to
impact
population
growth
rates.
No
information
is
presented
in
the
EA
to
predict
the
impacts
to
this
herd
of
reducing
its
number
to
a
drastically
low
level,
including
on
the
genetic
health
of
this
population,
which
is
almost
isolated
from
the
rest
of
the
Antelope
wild
horse
population.
3.
A
sustainable
AML
for
the
Water
Canyon
population
must
be
established
and
livestock
grazing
must
be
reduced
accordingly
in
this
area
pursuant
to
43
CRF
2710.5
and
BLMs
adaptive
management
policy.
4.
All
plans
to
remove
wild
horses,
as
part
of
this
fertility
control
program,
should
be
eliminated.
BLM
holding
facilities
are
full
with
nearly
50,000
wild
horses
stockpiled,
at
a
cost
to
taxpayers
of
nearly
$50
million
annually.
Recently,
the
BLM
estimated
that
every
horse
removed
from
the
range
and
not
adopted
will
cost
taxpayers
nearly
$46,252
(Attachment
1)
over
the
life
of
the
horse.
Given
the
BLMs
backlog
of
adoptable
horses
(as
of
April
2015,
there
are
16,670
wild
horses
in
short-term
holding
facilities
in
the
adoption
pipeline
see
http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horse
s_and_burros/statistics_and_maps/holding__adoption.Par.64250.File.dat/Facility%20Report%2
0FY-2015_Mar%20and%20Apr_For%20Web.pdf),
the
BLMs
plan
to
remove
an
estimated
41
horses
from
this
HMA
could
cost
taxpayers
$1.9
million
dollars,
excluding
the
costs
of
capturing
them
in
the
first
place!
This
alone
is
reason
enough
to
scrap
any
plans
to
remove
wild
horses
from
the
Water
Canyon
Area.
D. Use
of
native
PZP
via
remote
darting
or
darting
in
conjunction
with
bait/water
trapping
should
not
be
eliminated
from
consideration.
The
Water
Canyon
area
offers
the
possibility
of
a
community-based
approach
to
wild
horse
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 5
management,
given
the
presence
of
former
RAC
member
Jeanne
Nations,
who
owns
a
ranch
in
this
area.
Ms.
Nations
is
the
individual
who
proposed
the
PZP
pilot
program
as
an
alternative
to
removals,
and
she
is
willing
to
become
certified
to
dart
horses
with
the
PZP
vaccine.
Ms.
Nation
has
extensive
knowledge
and
photographic
documentation
of
wild
horses
in
this
area.
AWHPC
fully
endorses
Ms.
Nations
proposal,
as
did
19,333
of
our
supporters
who
signed
a
petition
in
support
of
the
plan.
AWHPC
stands
ready
to
support
Ms.
Nations
efforts
and
proposal
in
any
way
possible.
Its
important
to
note
that
BLM
is
successfully
managing
numerous
wild
horse
populations
with
PZP
delivered
via
darting,
including
in
the
Pryor
Mountains
Wild
Horse
Range
(MT/WY),
the
McCullough
Peaks
HMA
(WY),
the
Little
Book
Cliffs
HMA
(CO),
Sand
Wash
Basin
(CO),
among
others,
and
is
beginning
programs
in
several
other
areas
where
horses
are
well
known
to
area
residents
and
advocates,
including
the
Onaqui
HMA
in
Utah.
The
Water
Canyon
wild
horses
are
an
excellent
population
for
this
model
of
wild
horse
management,
given
Ms.
Nations
knowledge
of
this
herd.
This
model
should
be
seriously
considered
in
the
final
EA
and
not
dismissed
from
consideration,
as
in
the
Preliminary
EA
on
which
these
comments
are
based.
E.
Alternative
B
Should
Be
Eliminated
from
Consideration
GonaCon
is
an
experimental
fertility
control
vaccine
that
interferes
with
the
production
of
reproductive
hormones,
which
drive
natural
behaviors
in
wild
horses.
Therefore,
GonaCon
will
alter
natural
behaviors
and
therefore
have
significant
negative
impacts
on
wild
horses.
The
National
Academy
of
Sciences
concluded
that
Further
studies
of
its
behavioral
effects
are
needed
before
GonaCon
is
used
by
the
BLM.
(See
attachment
2)
Therefore
this
experimental
fertility
control
drug
is
not
appropriate
for
field
use
and
should
be
dropped
from
consideration.
III. No
Valid
Excess
Determination
Made
to
Justify
Removal
of
Wild
Horses
Removal
of
41
wild
horses
will
not
restore
the
Thriving
Natural
Ecological
Balance
(TNEB)
in
this
area,
as
required
by
law.
The
Wild
Free
Roaming
Horses
and
Burros
Act
(Wild
Horse
Act)
states
clearly
that
excess
determination
is
a
two-step
process
the
BLM
must
determine,
first,
that
an
overpopulation
exists,
and
second,
that
it
is
necessary
to
remove
horses
in
order
to
maintain
a
thriving
natural
ecological
balance
(TNEB).
Here,
the
largest
threat
to
TNEB
is
livestock,
which
vastly
outnumber
wild
horses
in
this
area
(thousands
of
sheep
grazing
vs.
a
relative
handful
of
wild
horses.
Indeed
livestock
are
present
in
this
area
year
round,
and
livestock
grazing
levels
have
not
been
reduced
despite
prolonged
drought
conditions.
No
evidence
has
been
presented
to
document
that
wild
horses,
as
opposed
to
massive
livestock
grazing,
threaten
the
TNEB
of
this
area,
nor
has
any
evidence
been
presented
to
support
the
claim
that
the
removal
of
41
horses
as
opposed
to
the
reduction
in
massive
sheep
grazing
levels
--
will
restore
the
areas
TNEB.
III. EA
is
Inadequate
A.
Lack
of
Specificity
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 6
The
EA
does
not
describe
the
plan
with
enough
specificity
and
certainty
to
allow
for
adequate
analysis
of
its
impacts.
It
leaves
open
the
possibility
of
helicopter
roundups
and
use
of
GonaCon,
but
the
impacts
of
these
actions
are
not
adequately
analyzed.
B.
FULL
RANGE
OF
ALTERNATIVES
NOT
ANALYZED
Instead
of
analyzing
the
full
range
of
alternatives
to
the
proposed
action,
as
required
by
NEPA,
BLM
rejected
viable
alternatives
including:
1. Eliminating
removals,
and
remote
darting
horses
in
combination
with
bait
trapping
and
darting
with
native
PZP,
which
is
less
expensive
than
PZP-22.
This
is
the
alternative
that
was
presented
by
Ms.
Nations
and
endorsed
by
the
RAC
and
it
should
be
considered
seriously
in
the
EA
and
implemented
in
the
DR
for
the
reasons
explained
in
Section
II
D
above.
2. Reduction
of
livestock
grazing
to
avert
any
wild
horse
removals.
With
holding
facilities
full
and
every
horse
removed
and
not
adopted
costing
taxpayers
nearly
$50,000
(Attachment
1),
this
is
a
viable
and
cost-effective
alternative
that
must
not
be
dismissed.
The
cost-savings
realized
by
reductions
in
taxpayer-subsidized
livestock
grazing
make
this
alternative
even
more
desirable
(Attachment
3)
Public
opinion
polls
document
that
the
public
strongly
supports
wild
horse
preservation
on
public
lands,
while
support
for
livestock
grazing
on
public
lands
Is
minimal.
(Attachment
4).
The
National
Academy
of
Sciences
(Attachment
2)
affirmed
the
importance
of
social
preference
in
wild
horse
and
burro
management:
Horse
and
burro
management
and
control
strategies
cannot
be
based
on
biological
or
cost
considerations
alone;
management
should
engage
interested
and
affected
parties
and
also
be
responsive
to
public
attitudes
and
preferences.
The
BLMs
preferential
treatment
of
discretionary
livestock
grazing
versus
its
mandatory
duty
to
protect
wild
horses
is
on
full
display
in
the
Water
Canyon
area,
where
6,000
sheep
are
authorized
to
graze
in
allotments
that
overlap
the
project
area,
but
the
BLM
wants
to
allow
just
25
horses.
The
final
EA
must
consider
an
alternative
to
reduce
sheep
grazing
in
this
area
to
allow
for
a
higher
AML
for
this
area.
This
alternative
is
not
outside
the
scope
of
analysis.
Federal
regulation
43
CFR
4710.5
Closure
to
livestock
grazing
authorizes
BLM
to
close
appropriate
areas
of
the
public
lands
to
grazing
use
by
all
or
a
particular
kind
of
livestock
[i]f
necessary
to
provide
habitat
for
wild
horses
or
burros,
to
implement
herd
management
actions,
or
to
protect
wild
horses
or
burros
from
disease,
harassment
or
injury.
BLM
typically
states
that
the
agency
utilizes
this
regulation
only
in
cases
of
emergency,
but
nothing
in
it
limits
use
to
emergency
situations.
Further,
a
fiscal
emergency
does
exist
due
to
the
fact
that
wild
horse
holding
facilities
are
at
capacity
and
consuming
the
majority
of
the
BLMs
wild
horse
and
burro
program
budget.
Leaving
horses
on
the
range
and
making
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 7
C.
IMPACTS
ANALYSIS
INADEQUATE:
NEPA
requires
the
BLM
to
take
a
hard
look
at
the
anticipated
environmental
and
cumulative
impacts
of
the
proposed
actions.
As
part
of
its
NEPA
analysis,
the
BLM
must
take
the
hard
look
mandated
by
Congress,
by
evaluating
the
unique
resources
that
will
be
impacted
by
the
proposed
actions.
1.
Impacts
From
Livestock
Grazing
As
disclosed
in
the
EA,
sheep
vastly
outnumber
wild
horses
in
this
area.
The
EA
fails
to
provide
any
evidence
to
support
the
claim
that
wild
horses,
not
the
vastly
larger
number
of
livestock
are
responsible
for
this
damage.
In
addition,
the
EA
fails
to
consider
the
different
ways
that
wild
horses
and
sheep
utilize
the
range
and
the
different
impacts
that
result.
2.
Economic
Impacts
not
addressed.
Despite
scoping
comments
requesting
the
EA
analyze
economic
impacts
of
the
proposed
action,
the
EA
fails
to
do
so.
As
stated
above,
the
BLM
now
estimates
each
horse
removed
from
the
range
and
not
adopted
costs
taxpayers
$46,250
(reference
provided
in
AWHPCs
scoping
comments).
The
EA
failed
to
fully
disclose
and
analyze
the
true
costs
of
the
proposed
action
which
now
calls
for
removing
419
horses
over
3
years
from
this
HA
for
a
cost
of
more
than
$19
million
over
the
lives
of
the
horses.
The
EA
also
fails
to
analyze
the
cost
savings
that
could
be
realized
by
leaving
horses
on
the
range
and
reducing
publicly-subsidized
livestock
grazing
in
the
HA.
The
cost
of
public
lands
grazing
is
detailed
in
the
attached
Center
for
Biological
Diversity
report.
(Attachment
3)
3.
Social
Impacts
not
addressed
The
American
public
has
a
deep
and
passionate
connection
to
wild
horses.
As
the
Wild
Horse
Act
recognizes
wild
free-roaming
horses
and
burros
are
living
symbols
of
the
historic
and
pioneer
spirit
of
the
west
16
U.S.C.
1331.
The
BLM
should
consider
the
social
impacts
of
the
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 8
proposed
action
to
reduce
the
population
of
wild
horses
in
the
Water
Canyon
area
to
just
25,
while
continuing
to
allow
thousands
of
sheep
to
graze
on
these
public
lands.
NEPA
requires
federal
agencies
to
consider
environmental
effects
that
include,
among
others,
impacts
on
social,
cultural,
and
economic
resources,
as
well
as
natural
resources.
Thus
the
BLM
must
consider
both
legal
and
social
factors
and
impacts,
in
making
land
use
decisions,
such
as
setting
and
maintenance
of
AML
and
grazing
allocations.
This
was
highlighted
in
a
1982
National
Academy
of
Sciences/National
Research
Council
report
on
the
BLMs
wild
horse
and
burro
program:
Attitudes
and
values
that
influence
and
direct
public
priorities
regarding
the
size,
distribution,
and
condition
of
horse
herds,
as
well
as
their
accessibility
to
public
viewing
and
study,
must
be
an
important
factor
in
the
determination
of
what
constitutes
excess
numbers
of
animals
in
any
area
.
.
.
[A]n
otherwise
satisfactory
population
level
may
be
controversial
or
unacceptable
if
the
strategy
for
achieving
it
is
not
appropriately
responsive
to
public
attitudes
and
values.
.
.
.
Biologically,
the
area
may
be
able
to
support
500
cattle
and
500
horses,
and
may
be
carrying
them.
But
if
the
weight
of
public
opinion
calls
for
1,000
horses,
the
area
can
be
said
in
this
context
to
have
an
excess
of
500
cattle.
For
these
reasons,
the
term
excess
has
both
biological
and
social
components.
In
the
above
example,
biological
excess
constitutes
any
number
of
animals,
regardless
of
which
class
above
1,000.
Social
excess
depends
on
management
policies,
legal
issues,
and
prevailing
public
preference..
The
importance
of
social
considerations
was
reaffirmed
in
the
NAS
report
of
2013.
Here
the
public
opposition
to
the
BLMs
plan
to
remove
an
estimated
41
horses
from
this
area
and
then
to
treat
the
remaining
mares
with
PZP
fertility
control
is
evidenced
by
the
nearly
11,000
citizens
who
have
submitted
public
comments
on
this
EA
and
the
more
than
19,000
citizens
who
signed
a
petition
endorsing
the
recommended
pilot
PZP
program,
which
involved
managing
wild
horses
on
the
range
with
PZP
in
order
to
eliminate
the
need
for
removals.
The
petition
was
presented
to
the
Northeast
Nevada
Great
Basin
RAC
at
its
October
2014
meeting.
The
number
of
public
comments
and
petition
signatures
received
by
the
BLM
opposing
the
current
proposed
action
and
endorsing
an
alternative
PZP
pilot
program
MUST
BE
reported
in
the
final
EA.
Finally,
the
EA
must
consider
the
social
factors
that
play
a
role
in
land
use
decisions
and
management
policies,
and
it
must
adequately
consider
the
BLMs
authority
to
modify
land
use
decisions,
such
as
wild
horse
AMLs
and
livestock
grazing
allocations
through
a
variety
of
tools,
including
the
agencys
adaptive
management
strategy
as
well
as
agency
regulations.
Clearly,
the
prevailing
public
preference
supports
protection
of
wild
horses
on
public
lands,
while
a
minority
wants
to
ensure
that
public
lands
are
available
for
livestock
grazing.
D.
Information
Omitted
from
the
EA,
Rendering
it
Inadequate
1. NAS
findings
&
recommendations:
The
EA
fails
to
incorporate
the
findings
of
the
NAS
recent
review
of
the
BLM
Wild
Horse
and
Burro
Program,
and
its
June
2013
report,
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 9
Using
Science
to
Improve
the
BLM
Wild
Horse
and
Burro
Program:
A
Way
Forward.
The
BLM
has
cherry
picked
the
findings
of
this
report,
mentioning
only
the
finding
that
agency
wild
horse
census
data
likely
under-reports
wild
horse
numbers,
while
omitting
entirely
the
other
findings
that
were
highly
critical
of
the
BLMs
program,
including:
- Current
management
approach
is
fueling
high
population
growth
rates.
- Appropriate
Management
Levels
lack
scientific
basis,
transparency
and
equity.
- Using
fertility
control
is
more
cost
effective
over
the
long
run
than
continuing
to
remove
horses
from
the
range.
- Only
acceptable
and
approved
fertility
control
method
currently
available
without
further
research
is
PZP.
- BLM
should
engage
with
the
public
in
ways
that
allow
public
input
to
influence
agency
decisions,
develop
an
iterative
process
between
public
deliberation
and
scientific
discovery,
and
co-design
the
participatory
process
with
representatives
of
the
public.
2. Monitoring
data
to
justify
the
establishment
of
such
a
low
AML.
No
monitoring
data
is
presented
to
document
the
impacts
of
wild
horses
or
to
explain
how
BLM
delineates
impacts
from
a
relative
few
wild
horses
from
the
impacts
of
vastly
larger
numbers
of
livestock
in
the
area.
No
information
is
provided
regarding
the
rangeland
conditions
of
the
allotments
that
overlap
the
project
area,
how
many
of
these
allotments
are
failing
to
meet
rangeland
health
standards,
and
what
the
causes
of
these
failures
to
meet
standards
are.
3.
No
modeling
or
genetic
data
to
predict
impacts
of
proposed
action
on
the
wild
horses
of
the
area.
In
conclusion,
the
EA
is
inadequate
because
it
failed
to
analyze
a
reasonable
range
of
alternatives
as
required
by
NEPA
and
instead
analyzed
a
foregone
conclusion
the
removal
of
horses
via
helicopter
drive,
bait
and
water
trapping
from
the
HA.
The
only
other
alternative
analyzed
the
extreme
sex
ratio
skewing
as
a
mechanism
for
total
elimination
was
not
reasonable
or
scientifically
supported.
All
other
reasonable
alternatives
were
rejected.
In
addition,
the
Impacts
Analysis
was
woefully
inadequate
and
skewed
toward
analyzing
the
impacts
of
wild
horses
on
ranchers
and
hunters,
constituencies
to
which
the
BLM
caters,
while
completely
failing
to
analyze
the
impacts
to
the
general
public,
which
supports
wild
horse
preservation;
recreational
users
of
the
public
lands
who
enjoy
wild
horse
watching
in
the
West
Douglas
HA;
and
to
the
American
taxpayers
who
are
being
asked
to
foot
the
bill
for
this
expensive
roundup,
removal
and
stockpiling
of
horses
as
well
as
for
the
continued
publicly-
subsidized
livestock
grazing
that
the
horse
removal
is
being
undertaken
to
increase.
For
all
the
reasons
stated
above,
AWHPC
opposes
the
Proposed
Action
and
concludes
that
the
EA
is
inadequate.
For
all
of
these
reasons,
the
BLM
must
scrap
this
current
plan
and
EA
and
go
AWHPC comments on Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary EA
June 14, 2015
Page 10
back
to
the
drawing
board
to
come
up
with
a
pilot
program
that
more
closely
aligns
with
the
RAC
recommendation
and
with
best
available
science,
and
an
EA
that
fully
analyzes
all
impacts
and
alternatives
to
this
plan.
Sincerely,
Suzanne
Roy,
Director
sroy@wildhorsepreservation.org
919-697-9389
Attachment
1:
BLM
Comparative
Cost
Between
Adopted
and
Unadopted
Horses
Attachment
2:
Using
Science
to
Improve
the
BLM
Wild
Horse
and
Burro
Program:
A
Way
Forward,
National
Academy
of
Sciences,
June
2013.
Attachment
3:
Costs
and
Consequences:
The
Real
Price
of
Livestock
Grazing
on
Americas
Public
Lands,
Center
for
Biological
Diversity,
2014.
Attachment
4:
National
Polls
on
Attitudes
toward
Wild
Horse
Protection
and
Uses
of
Public
Lands.