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URGENT: Two Quick Actions to Oppose Roundup of Wild Horses

September 22, 2010
by

Please take a couple moments to complete and submit the following two actions if you have not yet done so, the deadline for comments is September 23, thank you:

1. Please click HERE to Oppose Wild Horse Roundup in Nevada’s Clan Alpine, Pilot Mountain, and Pine Nut Mountain Herd Management Areas.

2. Please click HERE to Oppose Wild Horse Roundup in Nevada’s Lahontan Herd Management Area.

1. BACKGROUND

Your Voice Is Needed: Oppose Another Unnecessary Roundup of Our Wild Horses

Nevada’s Clan Alpine, Pilot Mountain, and Pine Nut Mountain Herd Management Areas:
224 Wild Horses Targeted for Removal

Public Comments Due By Thursday, September 23, 2010

Please take quick action today to oppose the latest herd targeted: the wild horses of the Clan Alpine, Pilot Mountain, and Pine Nut Mountain Herd Management Areas (HMAs) in Nevada. In November and February, the BLM plans to round up – via helicopter stampede – a total of 1,111 wild horses and permanently remove at least 224 of them, including any weanlings and yearlings, living in and around the HMAs. This is another drastic and unnecessary roundup of wild horses done in the name of protecting the range while still allowing grazing allotments for private livestock operators, which use the same lands for cheap grazing.

BLM PhotoThe Interior Department’s Bureau of Land Management (BLM) claims that this vast, nearly 670,000-acre range can support only 987 to 1,573 horses. Meanwhile the agency continues to allocate resources within this public land area to privately owned livestock rather than to our federally-protected wild horses. The Environmental Assessment for this proposed roundup is available here.

We must make our voices heard. The BLM must understand that Americans feel strongly about protecting our wild horses.

what you can do graphic

Please personalize the letter HERE and be sure to share this action alert with friends and family. Every voice counts. The deadline to submit comments is ThursdaySeptember 23, 2010.  Please be sure to include a mailing address so that BLM does not have an excuse to dismiss your comments.

Submit the form HERE to send your comments to:

  • President Obama, White House
  • Congress
  • Department of Interior
  • BLM Carson City District Office

Letters can be sent via U.S. postal mail or by facsimile:

Stillwater Field Office Manager Teresa Knutson
Sierra Front Field Manager Linda Kelly
5665 Morgan Mill Rd.
Carson City, NV 89701

Facsimile: 775-885-6147

Telephone: 775-885-6005 (For additional information ask for Steve Kramer, Planning & Environmental Coordinator)

1. MESSAGE TEXT

Clan Alpine, Pilot Mountain, and Pine Nut Mountain HMA EA (DOI-BLM-NV-C010-2010-0019-EA)

Dear [Decision Maker],

I oppose the proposed wild horse roundup that wastes tax dollars to unnecessarily roundup 1,111 wild horses permanently removing 224 horses, with the majority slated for long-term holding from the Clan Alpine, Pilot Mountain, and Pine Nut Mountain Herd Management Areas (HMAs). Based on the low reproduction data outlined in the Environmental Assessment (EA) there is no scientific support to continue a fertility control program at this time. The lack of reproduction for these herds has not been studied and is unknown; further implementation of fertility control could have further detrimental impact on the herds. The removal and fertility control proposed is not based on science, but rather BLM faulty and continued lack of science or understanding of on-the-range management.

The EA completely omits consideration of alternatives available to mitigate the need for the roundup – namely the BLM’s discretionary authority to:

* Re-evaluate and increase wild horse Appropriate Management Levels (AMLs) by reassessing and amending the Herd Management Area Plans (HMAP) and Carson City Consolidated Resource Management Plan (CRMP) under BLM’s Adaptive Management Policy (established by Interior Secretary Order N0. 3270, March 9, 2007);

* Decrease or eliminate livestock grazing in affected HMAs pursuant to 43 C.F.R. 4710.5(a); and

* Designate such areas to be managed principally for wild horse herds under 43 C.F.R. 4710.3-2.

I urge Carson City District Office and Stillwater Field Office to postpone the proposed roundup and modify the AMLs to accommodate the wild horses currently in the HMAs. Management on the range should be utilized to address the horses outside an HMA. The Proposed Action should be postponed while such a process is undertaken.

The methodology for developing this removal plan is flawed because of the following deficiencies:

– Unscientific determination of horse “overpopulation” or “excess”: Based on “Appropriate Management Levels” (AMLs) set 15 to 19 years ago, this proposal wrongly claims that the HMAs’  650,000 acres (or 1,043 square miles) can only sustain 1,573 horses (approximately two-thirds of a square mile of land for each horse). The BLM has been found repeatedly, most recently in 2008 by the Government Accountability Office, to arbitrarily set AMLs for wild horses. The AMLs are not based on science and must be re-evaluated.

– Incomplete information on HMA horse reproduction: The data presented in the EA raises more questions than it answers and outlines the lack of data and scientific information needed in order to administer fertility control. The Clan Alpine HMA’s 2010 census indicated an increase of only five (5) horses since 2007. There is no data to support implementing further fertility control on this herd given the low reproduction rate. Before administering any additional PZP, research and study is needed to confirm the reasons for the low birth rate. Has disease affected the herd? Has predation increased? Is the PZP affecting the mares too strongly? The latter question is critical to research because the vaccine may have adversely affected the Clan Alpine mares if it was (1) administered to fillies younger than two years old, (2) given for more than five consecutive years, or (3) the mares receiving it were in excellent health and condition at the time.  In such cases  too young, too long, too healthy  PZP tends to work too strongly, resulting in long delays in restoring fertility or outright sterilization, according to the vaccine’s developer, Dr. Jay Kirkpatrick. Thus it is of paramount importance to determine why the population growth rate is essentially zero and not just blame it on an undercount.

– Lack of current census: The Pilot Mountain and Pine Nut Mountain HMAs have no recent census data; only a partial count of horses reportedly living outside Pilot Mountain was done. Moreover, although AMLs are not supposed to include foals, BLM plans to reduce the herd based on including an estimate of them in the count.

– Inappropriate allocation of more resources to livestock than wild horses: Removal of 224 federally-protected wild horses from their designated HMAs while awarding nearly twice as many resources to privately-owned livestock is evidence that the BLM is not preserving and protecting the wild horses as the law intends.

– Harmful effects omitted in EA: The harmful effects of social disruption and destruction of family bands that the proposed roundup would cause is not addressed in the EA. Further, the EA downplays the deaths of wild horses that can be expected to result, first during the helicopter roundup and the stress of the roundup on heavily pregnant mares due in the Spring, older animals and those with disabilities.

– Fails to reconsider alternatives: Alternatives to the helicopter roundup should be considered and reviewed in the EA to mitigate the helicopter stampede. BLM routinely uses helicopter roundups over rugged terrain running horses for up to ten miles, often resulting in trauma, injury and death. No roundup is necessary at this time and fertility control should not be administered until the proper research and study outlined above are conducted.

The fact that BLM plans to remove at least 224 federally-protected wild horses from their designated herd management area while allocating resources to privately-owned livestock is evidence that this agency is not preserving and protecting the wild horses as the law intends. Despite rhetoric about change, the BLM continues business as usual, and the Clan Alpine, Pilot Mountain, Pine Nut EA and capture plan is further evidence of this fact. I join with the more than 54 members of Congress who have requested that the BLM halt all wild horse roundups. The roundup proposed for the Clan Alpine, Pilot Mountain, Pine Nut HMAs should not proceed on the basis of such a faulty scientific basis and an inadequate environmental review.

2. BACKGROUND

Take Action to Oppose Ridiculous Nevada Roundup Which Proposes To Leave Behind Only 7 Wild Horses in Lahontan HMA

Public Comments Due By Thursday, September 23, 2010

Established back in 1993, and still implemented today, the Bureau of Land Management’s (BLM’s) Carson City District Office decided that the Lahontan Herd Management Area (which is 17 square miles) would only be able wild horsesto accommodate 7 to 10 horses. This ridiculously low number is a death sentence for a wild horse herd. This small number of animals is forced to inbreed and provides little to no genetic diversity or social structure for wild horses. The BLM claims the horses are leaving the herd management area due to poor forage. Given the small number of horses in this herd, this is the perfect opportunity for the BLM to begin to manage horses on the range and stop the broken cycle of roundup, removal and stockpiling of wild horses.

The Environmental Assessment for this proposed roundup is available here.

Please take a minute to oppose this roundup HERE. We must continue to make our voices heard. The BLM needs to know that Americans want out wild horses protected and kept free in the wild.

what you can do graphic

Please personalize the letter HERE and be sure to share this action alert with friends and family. Every voice counts. The deadline to submit comments is ThursdaySeptember 23, 2010.  Please be sure to include a mailing address so that BLM does not have an excuse to dismiss your comments. 

Submit the form HERE to send your message to:

  • President Obama, White House
  • Congress
  • Department of Interior
  • BLM Carson City District Office

2. MESSAGE TEXT

Lahontan HMA EA (DOI-BLM-NV-C020-2010-0018-EA)

Dear [Decision Maker],

I oppose the proposed wild horse roundup that wastes tax dollars to unnecessarily roundup and remove 94 wild horses and leave behind only 7 to 10 horses in the 17-square-mile Lahontan Herd Management Areas (HMA). This proposal is fiscally irresponsible as the majority of the horses removed will be warehoused in government holding facilities for the remainder of their lives.

The EA completely omits consideration of alternatives available to mitigate the need for the roundup – namely the BLM’s discretionary authority to:

* Re-evaluate and increase wild horse Appropriate Management Levels (AMLs) by reassessing and amending the Multiple Use Decision (MUD), Herd Management Area Plans (HMAP) and Carson City Consolidated Resource Management Plan (CRMP) under BLM’s Adaptive Management Policy (established by Interior Secretary Order N0. 3270, March 9, 2007);

* Decrease or eliminate livestock grazing in affected HMAs pursuant to 43 C.F.R. 4710.5(a); and

* Designate such areas to be managed principally for wild horse herds under 43 C.F.R. 4710.3-2.

Management on the range should be utilized to address the horses outside of the HMAs not removal. The Proposed Action should be postponed while the MUD is modified to accommodate the current population and create an on-the-range management program.

The artificially low AML for the Lahontan HMA violates the intent of Congress and the will of the American people to preserve America’s wild horses  modern science clearly outlines that allowing only 7 to 10 horses in the area forces the animals to inbreed and negatively impacts the social structures of wild horses. Based on the current science, removal of horses should not occur. On-the-range management should be implemented to keep horses in the HMA in a humane and minimally-intrusive manner that preserves their wild and free-roaming behavior.

The methodology for developing this removal plan is flawed because of the following deficiencies:

– Arbitrary and artificially low AML based on assumptions and inadequate data: The Appropriate Management Level (AML) is, and has been since it was set 17 years ago, arbitrary and artificially low and threatens the genetic viability of a self-sustaining herd. The BLM only allows 7 to 10 horses on the 17-square-mile HMA. The BLM has been found repeatedly, most recently in 2008 by the Government Accountability Office, to arbitrarily set AMLs for wild horses.

– Harmful effects omitted in EA: The harmful effects of social disruption and destruction of family bands that the proposed roundup would cause is not addressed in the EA. Further, the EA downplays the deaths of wild horses that can be expected to result, first during the helicopter roundup and the stress of the roundup on heavily pregnant mares due in the Spring, older animals and those with disabilities.

– Fails to reconsider alternatives: Alternatives to the helicopter roundup should be considered and reviewed in the EA to mitigate the helicopter stampede. BLM routinely uses helicopter roundups over rugged terrain running horses for up to ten miles, often resulting in trauma, injury and death. The roundup is not necessary at this time and a management plan should be implemented.

– Fails to evaluate the social, economic and legal impacts: Majority of the removed horses are slated for government holding facilities, where they would join the more than 38,000 wild horses already warehoused at taxpayer expense. Details surrounding the costs involved in the capture, short and long-term holding must be described in detail for the public to comment.

The roundup proposed for the Lahontan HMA should not proceed on the basis of such  faulty science and an inadequate environmental review. Given the relatively small number of horses involved, the Carson City District Office and Sierra Front Field Office should implement an on-the-range management plan that does not involve the removal of any horses. By managing this herd on the range, the BLM would fulfill Congress’ intent to keep wild horses free roaming and avoid the zoo-like conditions of long-term holding.

One Comment leave one →
  1. karen lyons kalmenson permalink
    September 23, 2010 5:20 am

    the tragedy of this notification
    as it is being sadly read
    ia at the end of this deadline
    horses will end up, dead
    a click on the puter
    words well chosen and few
    with our voices together
    this round up, undo

    Like

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