Dear Cynthia Lummis, John Barrasso and Mike Enzi, I oppose the Bureau of Land Management’s (BLM), Surprise Field Office, proposed action (Alternative 1) to set the Allowable Management Level (AML) for the Massacre Lakes Herd Management Area (HMA) at 25-45 wild horses (300-540 AUMs/year) while allowing the annual equivalent of up to 141 cows (1,693 AUMs/year). This grossly unfair allocation violates the 1971 Wild Free-Roaming Horses and Burros Act, which mandates that wild horses and burros are to be sustained on ranges that are considered “principally though not exclusively for their welfare.” Congress declared wild horses and burros a “national esthetic treasure’ when it enacted the Wild Horse Act. Thus, the federal government is MANDATED to protect wild horses, while livestock grazing on public lands is authorized entirely at the DISCRETION of the Interior Department. The extremely low AML range of 25-45 animals in the Proposed Action is arbitrary and not based on science with regard to herd health and long-term sustainability. This AML would place the Massacre Lakes wild horse population significantly below the size of 120-150 animals that the BLM’s own genetic consultant states is necessary to maintain genetic viability and diversity. The proposal to combine the Massacre Lakes HMA into a “complex” with the Bitner, Nut Mountain and Wall Canyon HMAs in order to address genetic and management concerns is not based on science. There is no evidence whatsoever to indicate that the Massacre Lakes herd migrates out of the HMA to nearby areas to intermix with other herds. The National Academy of Sciences (NAS) recently concluded that the way in which the BLM establishes, monitors and adjusts AMLs is “not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change.” The NAS further concluded that AMLs be adaptable to accommodate changes, including in social values. Here the prevailing social value clearly favors a healthy and sustainable wild horse population level, as evidenced by the thousands of scoping and EA comments the BLM has received calling for a reduction in livestock grazing and increase in wild horse AML. I would like to remind the BLM that the Massacre Lakes HMA, as with other public lands, must be managed in the interest of all citizens, not just a handful of special interests (or in the case of Massacre Lakes, one livestock operator) that profit from the tax subsidies accompanying the private use of our public lands. I join with thousands of other citizens in urging you to implement Alternative 4 in the EA, which would allocate 1,200-1,452 Animal Unit Months (AUMs) of forage to 100-121 wild horses and 1,322 AUMs allocated to livestock. This alternative best upholds federal law, which mandates that wild horses are considered ‘principal’ and ‘in balance with other uses’ according to the available forage on the range there. Within Alternative 4, I support this herd being preserved for scientific research purposes since it has been undisturbed since 1988 and appears to have mainly self-regulated for various reasons that need more study. In their 2013 Report, the NAS committee "suggests that existing situations of self-limited populations be studied . . ." Also, the herd could be designated as a "sentinel herd" according to another NAS committee recommendation. Finally, I request the following additional information must be included and analyzed in the EA: 1) The spring evaluations on pg. 42 of the preliminary EA are out of date (2007-2009). Updated data is needed to reflect the current situation on the range. 2) The Social and Economic Values section of the preliminary EA are outdated and the economic importance of livestock grazing in this HMA is artificially inflated. Existing, updated data and models for Modoc County should be incorporated. This portion of the EA should also account for the fact that the majority of jobs in the agricultural and livestock industries are seasonal and/or part-time. 3) The economic impacts of the proposed action including costs for roundup and lifetime holding of horses vs. the economic benefits to American taxpayers of reducing taxpayer subsidized livestock grazing in this area must be incorporated. 4) The important non-market values that exist for the public lands, even though they are difficult to quantify. These values need to be taken into serious consideration with regard to the "human environment." The last part of the definition of "multiple use" from FLPMA demonstrates this non-market value clearly: “(c) . . . with consideration being given to the relative values of the resources and not necessarily to the combination of uses that will give the greatest economic return or the greatest unit output.” The intrinsic value of wild horses and burros falls under this non-market definition. However, the potential for increased tourism and scientific research around wild horses and burros in NE CA/NW NV would be high if any effort was put towards marketing them in this manner. Maintaining the status quo is not the way to increase economic growth and diversity in a rural county. 5) The social impacts on the American public of destroying the wild horse population in this 40,000 acre area is overwhelmingly given the strong support the American public has to protect, preserve and view wild horses living naturally on protected public lands. Healthy horses on healthy rangelands start with a fairer allocation of resources to maintain "their welfare" on their legal public lands In the West. It is hoped the Surprise FO heeds the thousands of comments that support this direction. As the NAS Committee found in their 2013 Report: Pg. 292: “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 above statement applies to those parties beyond the local level. It applies to all Americans who own both the public land and the wild horses and burros that call those lands their home. I expect that the BLM will provide the level of detail and analysis described above in a revised EA, which is necessary for informed decision-making. I further expect that the BLM will provide a full accounting of how many members of the public submit comments on this EA and what their positions are, as the agency is legally required to do under the National Environmental Policy Act. Thank you for including Alternative 4 in this preliminary EA. The next step is to make it the Proposed and Implemented Action based on compromise, cooperation, public preferences and following the law. Sincerely, William Harasym
Posted on: Tue, 24 Sep 2013 02:19:57 +0000
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