Public Comments Spring Mountain 1

7/28/2019 Public Comments Spring Mountain 1

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American Wild Horse Preservation Campaign, PO Box 1048, Hillsborough, NC 27278

July 15, 2013

Mr. Randy Swick, Area ManagerSpring Mountain National Recreation Area4701 North Torrey Pines DriveLas Vegas, NV 89130-2301

Via Web Comment Form and Facsimile: (702) 515-5447

Dear Mr. Swick:

These comments on the Spring Mountains Wild Horse and Burro Complex Project

Scoping are submitted on behalf of the American Wild Horse Preservation Campaign(AWHPC) and endorsed by xx citizens. (See Attachment 1 for list of endorsers.)

AWHPC is dedicated to preserving the American wild horse in viable free-roaming herdsfor generations to come, as part of our national heritage. Our grassroots efforts aresupported by a coalition of over fifty historic preservation, conservation, horse advocacyand animal welfare organizations.

I. Overview

The U.S. Forest Service (FS) and the Bureau of Land Management (BLM) are proposing

to create the Spring Mountain Wild Horse and Burro Complex by consolidating the RedRock Wild Horse and Burro Territory (WHBT), the Red Rock Herd Management Area(HMA); the Spring Mountains WHBT; the Wheeler Pass HMA; the Johnnie WHBT; andthe Johnnie HMA. The Herd Management Area Plan (HMAP) described in the ScopingReport would set allowable management levels (AMLs) for wild horses and burros livingin the complex and establish federal manage policies for these areas for the next 10 ormore years.

The plan would establish an unnaturally low AML of just 77-127 horses and 103-192burros for the entire 784,325-acre complex. At the maximum levels, this equates to justone horse or burro per 2,459 acres! Further the plan, if adopted, would reduce the

estimated wild horse and burro population in the complex by 85 percent or more,resulting in the removal of as many as 921 wild horses and burros from the area.


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AWHPC Comments on Spring Mountains Complex Scoping

July 15, 2013

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II. HMAP Perpetuates Failed Approach to Wild Horse and BurroManagement

The HMAP, as outlined in the Scoping Report, would result in the removal of as many as921 wild horses and burros from the Spring Mountain Complex, in an effort to bring thepopulation to the low to mid-range of the newly established AMLs for eachmanagement area. According to the Scoping Report, periodic removals would take placein orderto maintain the population at this low to mid-range. Unfortunately, fertilitycontrol, at this point, does not appear to be an integral part of the proposed managementplan. Instead the Scoping Report states that fertility control could be used on wildhorses within the complex; no use of fertility control is envisioned for burros living inthis area.

In this manner, the HMAP perpetuates the failed approach to wild horse management thatwas designated as expensive and unproductive by the National Research Council(NRC) of the National Academies in its June 2013 report, Using Science to Improve theBLM Wild Horse and Burro Program: A Way Forward. It concludedthatthe BLMspolicy of maintaining artificially low wild horse population levels and conducting

frequent removals of large numbers of horses actually increases wild horse

reproductive rates and worsens agency management problems. (See Attachments 2and 3 for report and summary.)

Regarding the practice of maintaining wild horse populations at unnaturally low numbersand conducting frequent, large-scale removals, the report states:

Management practices are facilitating high rates of population growth.Thus,

population growth rate could be increased by removals thr ough compensatory

population growth f rom decreased competi tion for forage. As a resul t, the

number of animals processed thr ough holding facil it ies is probably increased

by management. p. 5-6 (Emphasis added.)

Free-ranging horse populations are growing at high rates because their numbersare held below levels affected by food limitation and density dependence. p. 5

The indirect effects of management are considerable. One likely response is

compensatory population growth as a result of reductions in numbers . P. 94

Removals are likely to keep the population at a size that maximizes population

growth r ate (see F igure 3-2B), whi ch in turn maximizes the number of animals

that must be removed and processed through holding facil i ties. P. 94 (Emphasisadded.)

Indeed the proposed action could add over 900 wild horses and burros to a holding


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system already overburdened by the warehousing of 50,000 of these animals ingovernment holding facilities (Attachment 4)at a cost to American taxpayers of$120,000 per day. Only a small fraction of those horses will be adopted. BLM DeputyWild Horse and Burro Division Chief Dean Bolstad stated in a news article (Attachment

5):

"Adoption [as a population control strategy] is no longer a logical way to

proceed. We cannot continue to increase the numbers of horses in captivity."

Yet the HMAP described in the Scoping Report, which will set policy in this area for thenext decade or longer, will do exactly that: increase the number of wild horses incaptivity while at the same time continuing management practices that are fuelingpopulation growth on the range and worsening the BLMs and FS management woes.

III. HMAP Ignores Ecotourism Value of these Herds and Potential for

Community Partnership for their Management

The proximity of the Spring Mountain Wild Horse and Burro Complex to Las Vegas, an

international travel destination that attracts nearly 40 million visitors annually, makes this

an ideal population for the promotion of ecotourism. In addition, theSpring Mountain

Alliancehas produced a detailed plan for partnership with federal agencies in this area for

scientifically-sound management of a healthy range for recreation, wildlife and the

last free-roaming bands of wild horses and burros in the in the Spring Mountains,

west of Las Vegas; and forIncreasing wild horse & burro viewing opportunities

for future generations of horse & wildlife enthusiasts, photographers and American

& foreign visitors.

The proposal details six initiatives for proper management of the wild horses and burros

in this area, beginning with the use of PZP fertility control to manage herds on the range.

The Alliance has been identifying and documenting the movement patterns of wild horses

in the complex and estimates that, within two years, 80 percent of the mare population

could be vaccinated with PZP. To facilitate this process, several alliance volunteers have

been trained by the Science and Conservation Center in application of PZP to wild horses

via remote darting. The Alliance further proposes an experimental PZP program for

burros in the area.

The fact that the Scoping Report is silent on the ecotourism potential of these herds and

the existence of a vibrant community organization offering partnership with the BLM and

FS for on-the-range management defies logic. This is particularly true since the proposal

offered by the Alliance is a win-win scenario for American taxpayers, our federally-

protected wild horses and burros, as well as for the growing eco-tourism segment of the

economy. The final HMAP and EA should reflect these factors.
http://springmountainalliance.org/http://springmountainalliance.org/http://springmountainalliance.org/http://springmountainalliance.org/http://springmountainalliance.org/http://springmountainalliance.org/


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IV. HMAP Continues Practice of Under-Utilizing Proven Fertility Control

Methods

For two decades, PZP fertility control has been used to successfully to manage the wild

horse population in the Assateague National Seashore. (Attachment 6) Further, PZP has

been utilized successfully on burros. (See Attachment 7.)

The recent NRC report upheld the validity of PZP fertility control for use in wild horses:

Tools already exist for BLM to address many challenges . p. 13

I n the shor t term, more intensive management of fr ee-ranging horses and

bur ros would be expensive. However, addressing the problem immediately with

a long-term view is probably a more affordable option than continuing toremove horses to long-term holding facili ties.P. 306(Emphasis added.)

Most promising fertility-control methods for free-ranging horses or burros are

porcine zona pellucida (PZP) vaccines and GonaCon vaccine for females and

chemical vasectomy for males.This conclusion is based on criteria such asdelivery method, availability, efficacy, duration of effect, and potential for side

effects. Although applying these methods usually requires gathering horses and

burros, that process is no more disruptive than the current method of population

controlgathering and removalwithout the fur ther disruption of removing

animals. Consideri ng al l the curr ent options, these three methods, either alone

or i n combination, of fer the most acceptable alternative to removing animals for

managing population numbers.p. 3 of the brief

Under the management regimes reviewed by the committee, BLM will have to

remove free-ranging horses from western rangelands indefinitely unless very

aggressive fertility-control programs are implemented (Garrott, 1991; Eagle etal., 1992; Garrott and Siniff, 1992; Gross, 2000; Bartholow, 2004, 2007). As

briefly discussed in Chapter 2, there may be more horses in the short-term and

long-term holding facilities than on the range. An average of more than 8,000horses are moved from the free-ranging population to holding facilities annually,

and almost 60 percent of the Wild Horse and Burro Programs budget was

allocated to the care and maintenance of captive animals in fiscal year 2012

(BLM, 2012c). The amount of money needed to care for horses in the long-termholding facilities will continue to increase and, in the long run, could consume the

entire budget allocated to the Wild Horse and Burro Program. P. 216

No method that does not affect physiology or behavior has been developed. The

most appropriate comparison in assessing the effects of any fertility-control

method is with gathering. That is, to what extent does the prospective method


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affect health, herd structure, and the expression of natural behaviors compared

with the effects of gathering? The selected methods are considered the mostpromising because they have the fewest and least serious effects on those

parameters. Their application requires handling the animals (gathering), but this

process is no more disruptive than the current method for controlling numbersand does not entail the further disruption of removal and relocation to long-termholding facilities. Considering al l the cur rent options, these three methods,

either alone or i n combination, offer the most acceptable alternati ve for

managing population numbers. P. 7

Yet not only does the proposed HMAP continue the practice of removing horses from therangean approach to wild horse management that has been deemed to be costly andunproductive by an esteemed independent scientific body -- but also it continues theBLMs failure to utilize PZP fertility control in a manner that will substantially impactherd reproductive rates. Rather than stating that fertility control could be used on the

wild horse population in this complex, the use of PZP fertility controlin partnershipwith community organizationsshould be an integral part of the plan. Such a model isreadily available and working in other BLM wild horse management areas, including theMcCullough Peaks HMA in Wyoming.

It is critically important to note that if PZP treatment of most mares had been

continued after the 2007 roundup, the Spring Mountain Complex wild horse

population could have been sustained close to AML without need for another costly

roundup in 2014.

V. Alternatives that Must be Considered and Pursued

On behalf of the AWHPC coalition and the xx citizens who have endorsed thesecomments, we request that the following alternatives and initiatives be incorporated intothe final HMAP and EA:

A. Higher AMLs

Establish a more genetically viable Allowable Management Levels (AMLs) for wildhorses and burros living in this complex. The proposed AMLs are too low to ensuregenetically viable and thriving populations. The low population numbers will also destroythe great ecotourism potential of these herds, which live near Las Vegas, an international

tourist destination. At one horse or burro per 2,459 acres it will be difficult to even spot,let alone observe, wild horses living in this area.

The following are the AMLs proposed for the management areas within the complex:

Red Rock - 16-27 horses and 29-49 burros

Spring Mountain/Wheeler Pass - 47-66 horses and 20-35 burros


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Johnnie: 14-34 horses and 54-108 burros

Total for Complex: 77 - 127 horses and 103 - 192 burros

By setting and maintaining such unnaturally low allowable population levels far belowlevels where horse and burro populations would exhibit density-dependent regulation, theFS/BLM are continuing a practice that the NRC has identified as contributing to higherreproductive rates on the range.

Further the levels are too low to maintain the genetic viability of these herds. The geneticviability issue is particularly critical for wild burros, of which an estimated 5,800 are leftin the U.S., despite federal protections. The NRC report highlighted the precarious stateof burros in the U.S. today, concluding that if BLMs population estimates are correct,removing bur ros permanentl y fr om the range could jeopardize the genetic health of

the total populati on. The NRC advised that " the BLM may also need to assesswhether the AMLs set for bur ros can sustain a genetically healthy total population. (p.304)

The NRC report would indicate that any burro removals from the range are ill-advised,save for verifiable emergency situations. In addition, plans to randomly introduce horsesor burros to these populations to improve genetic variability are not sufficient to protecttheir genetic viability. Equine genetics expert E. Gus Cothran of the Texas A&MUniversity College of Veterinary Medicine has informed AWHPC (personalcommunication) that introduction of outside animals to genetically compromisedpopulations can take generations to have an effect. Populations that have lost genetic

diversity to the degree that the long-term survival of the herd is compromised may nothave time to wait generations for improvements to genetic diversity. Therefore, thisapproach cannot be used to justify such low, genetically unsustainable AMLs.

B. Manage Horses on the Range with Fertility Control

As stated above, PZP fertility control is an available tool for managing these herds on therange and minimizing the need for removals. A comprehensive PZP program should beimplemented immediately for wild horses in this complex, and a pilot program shouldalso be launched for burros. Both should be done in conjunction with Dr. Jay Kirkpatrickof the Science and Conservation Center in Montana, and in partnership with the Spring

Mountain Alliance, which has already undertaken much field work to identify individualhorses, bands and herds and monitor their movement patterns. SMA volunteer PZPdarting teams are already trained and certified to dart as early as September 2013. Asstated above, SMA believes that 80 percent of the mare population in this area could bevaccinated with PZP within two years. This level would be effective in achieving zeropopulation growth of this herd within several years.


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C. Range Improvement

Keep wild horses and burros within the Complex by repairing and expanding water

sources and implementing other range improvements to help the animals utilize allsuitable habitat areas. Habitat improvements suggested by the Spring Mountains Allianceinclude the following, which should be incorporated into any HMAP and EA:

1. Building water guzzlers and retention basins across the range to disperse thegrazing impact of elk and wild horses.

2. Fencing off ecologically sensitive areas like riparian habitat;3. Building blinds or road pull-outs for safe viewing access to wild horses/burros;4. Patrolling roads to prevent illegal or undesirable human interaction with wild

horses/burros.

5. Implementing various range improvement strategies (seedings, etc.) to improvehabitat conditions for wild horses, burros, elk and deer in the area and to enhance

wildlife viewing opportunities in the area.

D. Prohibit Helicopter Roundups

Helicopter roundups are traumatic and dangerous for wild horses and burros.Heartbreaking video footage has shown wild horses and burros being injured, harassed,beaten and killed in helicopter roundups. (Please see NBC News report, Cruel or

necessary? The true cost of wild horse roundups at this link:http://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-the-

true-cost-of-wild-horse-roundups?lite)

The plight of burros in helicopter roundups is particularly concerning. These steadfastanimals react differently than wild horses to helicopter drives. They scatter and resist thechase instead of staying with the herd. (Please see video and report by NBC News, TheBattle Over Burros at this linkhttp://www.nbcnews.com/video/nbc-news/51524838#51524838)

Passive bait trapping operations are less traumatic for wild horses and burros and are alsomore protective of the environment by avoiding the trampling of sensitive plant andanimal species that occurs during helicopter stampedes of wild horses or burros.

Therefore, the HMAP should designate that, if any wild horses or burros are to beremoved from the Spring Mountains Complex, less traumatic bait trapping methods willbe utilized for the well identified and easily captured animals living there. In addition, theHMAP should specify that the BLM and FS work with community groups (SpringMountain Alliance) to identify and remove only the most adoptable horses and burrosand conducting vigorous local adoption drives.
http://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-the-true-cost-of-wild-horse-roundups?litehttp://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-the-true-cost-of-wild-horse-roundups?litehttp://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-the-true-cost-of-wild-horse-roundups?litehttp://www.nbcnews.com/video/nbc-news/51524838#51524838http://www.nbcnews.com/video/nbc-news/51524838#51524838http://www.nbcnews.com/video/nbc-news/51524838#51524838http://www.nbcnews.com/video/nbc-news/51524838#51524838http://www.nbcnews.com/video/nbc-news/51524838#51524838http://www.nbcnews.com/video/nbc-news/51524838#51524838http://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-the-true-cost-of-wild-horse-roundups?litehttp://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-the-true-cost-of-wild-horse-roundups?lite


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However, the HMAP should specify that BLM and FS will resort to removals only as alast resort, after all on-the-range management strategies have been implemented andgiven the necessary time to work. This strategy is mandated by both the current

stockpiling of 50,000 wild horses and burros in government holding facilities and theNRC finding that frequent removals of horses from the range may cause compensatory

E. Maintain natural sex ratios

The Scoping Report indicates that the HMAP will include artificial skewing of sex ratiosfor wild horses. The EA must adequately evaluate the impacts of this proposed action, aswell as present evidence that this strategy will a) be effective in lowering populationgrowth rates; and b) will not impact the natural behaviors of individual wild horses,social bands and the herds as a whole.

In fact, no scientific data exists regarding the impact of sex ratio skewing on individualhorses, bands and/or herds. This element of the HMAP should not be implementedwithout adequate scientific information to understand the implications of sex ratioskewing on the range. In addition, there is no science that shows that the artificialskewing of natural sex ratios contributes to population suppression. In fact, anecdotalevidence suggests that sex ratio skewing interrupts natural social structures and that dueto this disruption, mares may begin to breed at younger ages due to the lack of females onthe range. This would result in an overall increase in reproductive rates.

The EA should consider the findings of BLM field offices regarding sex ratio skewing:

BLM Beatys Butte EA DR FONSI 2009[http://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdf](page 33) states,"If selection criteria leave more studs than

mares, band size would be expected to decrease, competiti on for mares would beexpected to increase, recrui tment age for reproduction among mares would be

expected to decline, and size and number of bachelor bands would be expected to

increase. . . ."

The BLMEA for the South Steens Wild Horse Gather[http://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFi

nal.pdf] (page 41) states,Skewing the sex ratio of stal l ions v. mares wouldresul t in a destabil ization of the band(stallion, mare and foal) structure movingit from five to six animals to three animals. Social band structure wil l be lost

resul ting in combative turmoil as surplus stall ions attack a band stall ion tr ying

to capture his mare. This could resul t in the foal being either ki ll ed or lost. The

mare and foal will not be allowed to feed or water naturally as the stallion tries tokeep them away from the bachelor bands of stallions, resulting in stress to the

mare during her lactation condition.
http://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdfhttp://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONSI_DR_09012009.pdf


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Black Mountain Hard Trigger EA, p.19 [https://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdf], states, competition for mares would beexpectedto increase, recruitment age for reproduction among mares would be

expectedto decline [meaning younger mares would begin breeding] Fightingbetween band stallions and surplus stallions could result in the mares and foalsnot being allowed to feed and water naturally as the herd stallion tries to keep

them away from bachelor bands.

VI. Impacts that Must be Analyzed in EA

A. Impacts of helicopter roundups on individual wild horses and burros, and onendangered plants and animals in the Complex. According to the scoping notice,numerous species of concern are present in this area and could be impacted byhelicopter stampeding of burros.

B. Economic impacts of the proposed action including disclosure of all costsassociated with the capture and removal of operation itself, as well as the costs forshort- and long-term holding and adoption preparation for the burros removedfrom the range. A comparison of costs for alternative actions suggested in thesecomments vs. the approach detailed in the Scoping Report must be presented.

C. Genetic Impacts of the proposed removal of 85+% of the estimated wild horseand burro populations in the Complex and to establish AMLs of Red Rock 16-27horses/ 29-49 burros (Red Rock); 47-66 horses/20-35 burros (SpringMountain/Wheeler Pass); and 14-34 horses/54-108 burros (Johnnie) must beevaluated. All genetic reports should be included as an appendix in the EA.

D. Social impacts of all proposed actions must also be analyzed. NEPA requiresfederal agencies to consider environmental effects that include, among others,impacts on social, cultural, and economic resources, as well as natural resources.Thus the FS/BLM must consider both legal and social factors and impacts, inmaking land use decisions, such as setting and maintenance of AML and grazingallocations. This was highlighted in a 1982 National Research Council report onthe BLMs wild horse and burro program:

Attitudes and values that influence and direct public

priorities regarding the size, distribution, and condition of horseherds, 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]notherwise satisfactory population level may be controversial or

unacceptable if the strategy for achieving it is not appropriatelyresponsive to public attitudes and values. . . .
https://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdfhttps://www.blm.gov/epl-front-office/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-2012-0010_Wildhorse_Prelim_EA_Final.pdf


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Page 10Biologically, 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 thiscontext 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 onmanagement policies, legal issues, and prevailing public

preference..

The NRC Report released this month also highlighted the importance of

public opinion as well as the BLMs failure to offer a collaborative policy

making process in which the public can meaningfully participate. The NRCs

findings regarding social considerations for BLM include:

Horse and burro management and control strategies cannot be based onbiol ogical or cost considerations alone; management should engagein terested and affected parties and also be responsive to publ ic atti tudes and

preferences. Three decades ago, the National Research Council reported that

public opinion was the major reason that the Wild Horse and Burro Program

existed and public opinion was a primary indicator of management success(NRC, 1982). The same holds true today. p. 292

In 1982, the National Research Council noted that public opinion was themajor motivation behind the wild horse and burro protection program and aprimary criterion of management success, suggesting that control strategies

must be responsive to public attitudes and preferences and could not be based

only on biological or cost considerations (NRC, 1982, p. 54). p. 271

Thus, BLM should engage with the public in ways that allow public input toinfluence agency decisions, develop an iterative process between public

deliberation and scientific discovery, and codesign the participatory process

with representatives of the public. p. 13 and p. 288

BLM has involved the public in a consultative way in the past, but to move tothe right in Figure 8-1 toward a collaborative process, BLM and the publicmust come together to work in new ways and with a new spirit. p. 289

The NEPA process provides for public comment and review and increasespublic participation in environmental decisions although the relationship is

consul tative rather than collaborati ve, tends to be bureaucratic, and does not

foster deliberation (Hourdequin) p. 229

The committee beli eves that in the case of planning for the management offr ee-ranging horses and bur ros, substanti ve publi c participation is


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Page 11warranted because of the depth and breadth of publ ic concern and the need

for a long-term, sustainable program.P. 280

However, given the high level of public concern regarding the management offreeranging horses and burros, the diverse values that come to bear on theissue, and the substantial scientific uncertainty that is inevitable in dealingwith such complex issues, effective public participation practices are

essential. Therefore, BLM should engage with the publi c in ways that all ow

publi c input to i nf luence agency decisions, develop an iterative process

between public deliberation and scientific discovery, and codesign theparticipatory process with representatives of the public. (p. 288)

The prevailing public opinion that wild horses and burros should be humanelymanaged on the range is evidenced by thousands of citizens who have endorsedAWHPCs comments on this scoping, urging the FS/BLM to consider a humane cost-

effective alternative to the removal of large numbers of wild horses burros from thepublic lands. This strong public preference mandates that the FS/BLM fully consider allalternatives that would accomplish this goal and avoid the mass capture and removal ofwild horses from their home in this public lands area.

The NRCs review panel chair, Dr. Guy Palmer, summed up the situation well,commenting at a at a press conference on the reports release that No one really wants tosee more horses in long-term holding just from an economic viewpoint. Secondly, this is

not the vision that is associated with what the public wants to see with the horses on thesewild lands. (See Attachment 8)

The NRC report states explicitly:

A program of continuing, ad in f in itum removals may not be economically

sustainable or social ly acceptable. P 259 (Emphasis added.)

The sum total of the points above indicates that the FS must ensure a change in directionwith this HMAP that will set policy in this area for the next decade or longer.Continuation of the business as usual policies is simply not acceptable, scientificallysustainable or fiscally defensible.

VII. Information that Should be Provided

The EA for the proposed HMAP must include the following information in order to givethe public the opportunity to comment in a meaningful way on the proposed plan:

A. All forage allocations (AUMs) within the Complex.B. Range monitoring data, including a detailed breakdown data distinguishing wild

horse impacts from impacts caused by other uses within the Complex.C. Documentation of herd population count/census numbers and a complete


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Page 12demographic breakdown of the wild horse and burro populations. Detailed

information on census methods underlying population estimates is particularly

important given the NRCs finding that robust inventory procedures were

adhered to on few HMAs during the most recent decade of population

monitoring. The committee identified five primary weaknesses in inventoryprocedures: inconsistent methods, likely movement of horses among HMAs,

little or no effort to quantify detection probability and apply corrections

accordingly, no attempt to quantify precision of abundance estimates, and

inadequate record keeping and database management.(P. 56)D. A complete listing of water sources available to wild horses within the Complex.

A full disclosure of all fencing in and around the Complex.E. A list of all range improvements, such as water restoration and/or enhancement,

both completed in the past 5 years and planned for upcoming years.F. Available scientific information on burros in the American West, including

information on dietary preferences, relationship between reproductive rates and

water availability, natural behavior and range usage data.

VIII. Conclusion

The NRC report clearly stated that the BLM's business as usual for managing wild horsesand burros is expensive and unproductive and must immediately change. The proposaloutlined in the Scoping Report omits these important and independent scientific findingsthat removal increases the birth rate in the remaining bands. I f PZP treatment of mostmares had been continued after the 2007 roundup, the Spri ng Mountain Complex wild

horse populati on could have been sustained close to AM L without need for another

costly roundup in 2014.

There is still time to change course to a more sustainable, humane and less taxpayercostly management approach for the Spring Mountains Complex. Due to their proximityto Las Vegas, an international tourist destination, these herds hold great ecotourismpotential. On behalf of the AWHPC coalition and the thousands of citizens endorsingthese comments, please take this opportunity to implement an experimentalvolunteer/agency plan that truly protects these national icons on the range so that theymay live their lives as nature intended while being enjoyed and appreciated by visitorsfrom all over the world.

Thank you for your consideration.

Sincerely,

Suzanne Roy, Director


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Attachments:

1. List of citizens endorsing AWHPC comments2. Using Science to Improve the BLM Wild Horse and Burro Program: A Way

Forward, National Research Council of the National Academies, June 20133. Using Science to Improve the BLM Wild Horse and Burro Program: A Way

Forward In Brief, National Research Council of the National Academies,June 2013

4. BLM Facilities Report, June 20135. BLM wild horse management at a crossroads, Salt Lake Tribune,

November 11, 20126. Achieving population goals in a long-lived wildlife species (Equus caballus)

with contraception, Dr. Jay Kirkpatrick and Allison Turner7. Turner, Liu and Kirpatrick,Remotely delivered immunocontraception in free-

roaming feral burros, Journal of Reproduction and Fertility (1996) 107, 31-35.

8. Panel: U.S. Should Let Nature Cull Wild Herds, Associated Press, June 5,2013

Public Comments Spring Mountain 1

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Transcript of Public Comments Spring Mountain 1