Urgent: Comment on the Carson City RMP revision plan

Pine Nut HMA

FROM Wild Horse Education:

This is crucial to comment on. There are 21 Herd Management Areas effected directly by this RMP. All decisions in the district on wild horse and burros (all public land issues) are based on the “RMP,” Resource Management Plan. This is the document that all “EA’s” (therefore roundups) are based on.

Comments are due by Midnight, TONIGHT.

A “copy paste” is listed below. Please take this simple Action.

Here is the scoping document specific to Wild Horses and Burros:https://www.blm.gov/epl-front-office/projects/lup/22652/34881/36305/9.1_WH&B.final.pdf

The scoping document specifically asks for your input on these areas (copied and pasted from document):

Should HMA boundaries be adjusted, combined and/or eliminated?

What criteria should be used to make habitat and population suitability and viability determinations?

What methods, other than removal through gathers, should be considered to achieve AMLs?

How should BLM address wild horse and burro urban‐interface issues?

Which HMAs are suitable for the long‐term management of wild horses and burros?

What age structure and sex ratios are appropriate to ensure healthy future herds of wild horses and burros?

Where are habitat improvement projects appropriate?

What kinds of improvement projects are feasible?

When is it appropriate to develop or augment water for horses and burros?

Any other issues or concerns with the management of wild horses or burros?

Below is a suggested letter to Colleen Seivers, RMP Project Manager

The email address for comments is:  BLM_NV_CCDO_RMP@blm.gov

you may copy and paste this, or use it to formulate your own, but please send as soon as possible.


Colleen Seivers,

I write to you as an interested party to wild horses and burros. When crafting the new (revisions) RMP for the Carson City District the following should be paramount as this mandated use has become threatened by the encroachment of other users.

The vast majority of users of public land have considerable resource available to their use. Wild Horses and burros are restricted to the boundary lines that, in many cases, were inaccurately drawn. This finite, and flawed, space is vital to the survival of this American Heritage species as intended by Congressional law. Within these boundary lines horses and burros are to be considered a principle, but not exclusive, use. Currently they are not managed as such. This mandated use is the lowest of priority.

To perpetuate a use of public land the viability of that use must be first priority. Populations must be managed to perpetuate the species with a minimal level of interference. Populations capable of breeding to sustain genetic viability, without interference, must be maintained before other uses are allowed.

Numbers within the boundaries of HMA’s should all be given a minimum management level of 150 individuals that are of reproductive age.

If current boundary lines do not allow for that viability standard, the authority to change those lines currently exists and must be reviewed. If areas are too small to accommodate the viable population than HA land bordering the HMA can be added. If areas are too small to support a viable population than the real possibility that the lines were flawed must be taken into account and corrected.

Public/private cooperatives must adhere to all standards as any contractual agreement and must be made available for public comment and competitive bid. Any public cooperative that requires removal, handling or range repair (springs, fencing) must be reviewed carefully against any standard of conflict of interest. No allotment permittee for livestock grazing should hold any permit to remove wild horses from any public land.

The language in the standing RMP (quoted below) must be enforced with the recognition that this language applies to all permitted activity including extractive industry.

“Designated wild horse and burro ranges are devoted primarily to the protection and preservation of wild horses or burros. This means that other uses may be constrained to the extent necessary to provide fully for their welfare. This could require reductions or closure to livestock grazing, although in the case of the Marietta Herd Area, current livestock/wild burro use areas overlap only slightly. “

Please recognize that the vast majority of the public is unaware of the decision making process on public land. There is an assumption that horses exist protected and viable due to an act of Congress. A greater effort needs to be made to educate the public to the multitude of projects that have potential impact. The damages to wild horses are not being appropriately mitigated without public participation, yet the public remains uneducated to the process.

The impacts to sex ratio skewing are not fully understood. Until further data is available that clearly demonstrates a population control impact without adverse effect to herd behavior it should be suspended. PZP should only be utilized within the confines of known seasonal effectiveness. Under no circumstances should surgical sterilization of mares be employed as the risk of infection and death is too great. Currently surgical sterilization of stallions should not be employed until impact to the behavioral structure on the range has be adequately documented.

The Carson City District should adopt a humane care standard for all roundups and with facilities in the district. Until the National office compiles and implements a policy the district should implement an interim policy to ensure the humane handling of animals.

The expectation is that the Environmental Assessment associated with the proposed revision will adequately document the risks to the HMA’s occupied by our protected wild horses from the extractive industry coming into these ranges. Any permit that adversely effects the areas occupied by wild horses and burros must effectively replace, repair, restore and all damages, encroachments or loss of surface use. If those projects can not effectively do so they must be denied.

All HMA’s are suitable for management. Under authority given in the ACt of 1971 the Secretary set up sanctuaries (or Herd Areas). The land base and resources have been taken from the protected American Heritage Species and utilized for other interests. The  impetus at this juncture needs to be on the management of wild horses and burros on their entitled land as a prioritized use.



3 thoughts on “Urgent: Comment on the Carson City RMP revision plan

  1. Email sent to BLM re. Carson City District.

  2. Lisa G. says:

    Once again looking for your snail mail addy on this web page to donate. All the “please support the work” buttons take me to PayPay and I would rather send a check.

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