From: Carla Bowers <[email protected]>
Subject: Urgent – AWHPC Action Alert on Adobe Town-Salt Springs HMA Roundup EA, due by this Friday, 8/13/10
To: “Carla Bowers” <[email protected]>
Date: Wednesday, August 11, 2010, 11:20 AM
Wild Horse/Burro Advocates & Supporters – Please cut & paste the copy below (from AWHPC) with your personal additions & email it to: [email protected] by this Friday, 8/13/10. Your comments will be hand delivered to the Field Offices in WY since they are not accepting comments by email or fax!
We must keep bombarding the BLM with our opposition to these massive roundups & managing our herds to extinction. Please forward on to your lists & post on Facebook, etc. Also, let me know if you’d like to be deleted from this email list. Please excuse duplicate posts. Thank you.
For the wild ones, Carla B
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Dear Rock Springs and Rawlins Field Offices of the Wyoming BLM:
Please accept these comments on the Environmental Assessment Adobe Town-Salt Wells Creek Herd Management Area Complex Wild Horse Gather (EA WY-040-EA-10-109).
I oppose the BLM’s proposal to roundup approximately 1,951 wild horses from the Adobe Town and Salt Wells Herd Management Areas (HMAs) in Wyoming and permanently remove 1,577 of them from the range. The Environmental Assessment (EA) for this capture plan is inadequate because it:
– Fails to provide a scientific basis or rationale for the decision to remove such a large number of horses. No evidence of range damage, poor condition of horses or other data is presented to justify the determination that these are really “excess” horses & thus must be removed.
– Fails to adequately consider the impacts of the Proposed Action on the horses, including those that are permanently removed, those that are rounded up and re-released, and those left behind on the range. The EA contains no discussion of the harmful effects of social disruption and destruction of family bands, or the expected deaths of horses in holding facilities due to capture-related trauma and stress. Nor does it ensure that horses released back to the range will be released with their original family bands or at least some of them, which should be mandated for the horses’ wellbeing.
– Fails to consider any alternatives to the helicopter stampede of wild horses over rugged terrain for up to ten miles, which has been demonstrated to cause trauma, injury and death.
– Dismisses without foundation, alternatives to the Proposed Action which were submitted by thousands of members of the public. These include:
- increasing Appropriate Management Levels for wild horses;
- reducing livestock grazing so that their numbers are ‘comparable’ to wild horses/burros on the HMAs pursuant to Title 43, CFR, 4700.06(b) that “WH&B shall be considered ‘comparably’ with other resource values in the formulations of land use plans”;
- utilizing BLM’s clear legal authority via Title 43 CFR 4710.5(a) to close or limit livestock grazing in the HMAs and/or designate this area to be managed principally for wild horse herds under 43 CFR 4710.3-2.;
- converting livestock grazing allotments to increase forage for wild horses and allow greater population numbers;
- making range improvements, such as water enhancements, to better distribute horses throughout the HMAs and sustain higher population numbers.
Explanations provided as to why these alternatives were dismissed from consideration are entirely inadequate.
– Fails to evaluate the social, economic and legal impacts of the warehousing of the majority of captured horses in holding facilities, where they will join the 38,000 wild horses already warehoused at huge taxpayer expense.
BLM’s decision to prohibit email submissions of public comments on the EA, along with its dismissal of alternatives suggested by thousands of citizens, is evidence that public input is irrelevant to BLM plans. BLM is proceeding with the removal of nearly 1,600 federally-protected wild horses while continuing to allocate more resources to privately-owned livestock in these designated wild horse areas, indicating that this agency manages our public lands for the benefit of commercial interests rather than the public.
The BLM’s professed commitment to change is not evident in the Adobe Town/Salt Wells capture plan. I join with the 54 members of Congress & Senator Landrieu who have requested that the BLM halt all wild horse roundups. The Adobe Town/Salt Wells Creek roundup should not proceed on the basis of such deficient science and inadequate environmental review.
Sincerely,
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