Comments on this Preliminary EA must be received on or before May 18, 2012. Mailed comments should be sent to ensure delivery by May 18 and directed to Melanie Mirati, BLM Winnemucca Field Office, 5100 E. Winnemucca Blvd., Winnemucca NV 89445-2921. Comments can also be submitted by email to BLM_NV_WDOJacksonMtnsWildHorseEA@blm.gov. Email messages should include “Jackson Gather” in the subject line.
Please feel free to copy and paste all or part of the below suggested comments into an email. Add anything you may feel pertinent or change the comments. You have a voice in the process. Remember to put “Jackson Gather” in the subject line to: BLM_NV_WDOJacksonMtnsWildHorseEA@blm.gov
Comments EA Jackson Mountain HMA and gather area
As an interested party to wild horses and burros on public land I respectfully submit the following comments:
Discussions with the District office have described a potential drought emergency with removals discussed during May and June. This EA does not outline such a plan nor give the public sufficient information on the specific area, scope or nature of any pending emergency. Therefore until such information is provided to the public all such removal operations must be dropped. Water hauling or moving the population via flyover or horseback are the only acceptable alternatives during the foaling season.
Any alternative must impose proportionate removal of livestock.
The proposed operation is scheduled for July. Without a humane care standard fully outlined, implemented and disclosed to the public any operation is not acceptable considering the conduct admitted to in BLM’s Triple B team review and actions of Federal Court Judge Howard McKibben. The work product document presented to the Court should, at bare minimum, be implemented immediately.
The EA notes that horses have moved off of “HMA” land in search of water and forage. The EA fails to address that the original boundary lines drawn were inaccurate. A failure to include seasonal movement is omitted. Within the Secretaries authority is the ability to revaluate the boundary lines and redraw them. This option should be part of any EA.
In addition this EA fails to detail what a viable use is of wild horses within the HMA. As a prioritized use within the HMA the standard of viability must be clearly outlined before other uses are permitted. The “multiple use” mandate requires that the use be viable. Under the Wild and Free Roaming Horse and burro Act the population must be able to reproduce itself and be managed with minimal interference.
No plan that implements permanent sterilization techniques is acceptable at this time. Until the effects of introductions of large numbers of sterilized animals onto the range is fully understood this alternative should be rejected.
Instead of permanent sterilization this operation should not occur until no earlier than September to appropriately utilize PZP in an effective manner toward population growth suppression. In September the fragile population will begin to stabilize and a more effective operation could proceed.
Each roundup is a single event designed to solve a specific need. If the EA is to cover more than one removal event it must be specific in it’s projection of scope. This EA fails to provide any such information. Therefore this EA is invalid with the exception of a single event.
The use of any material other than the black drape that allows observation of handling of animals is unacceptable and seen as an attempt to hide handling practices. Reasonable, not restricted, access must be priority.
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Video taken at the Calico Roundup 2012
Same district, same Wild Horse and Burro specialist.