While Congress ponders how much money to give BLM for their administration of the Wild Horse & Burro Program, here are a few stories I wanted to share about what is going on in the wonderful world of wild horses and burros as well as a link HERE to my letter to the U.S. Senate Committee on Energy and Natural Resources regarding continued funding of the Program.
MOJAVE-SOUTHERN GREAT BASIN RESOURCE ADVISORY COUNCIL MEETING (RAC) - February 18, 2010
While the rest of Las Vegas was holding up protest signs for Obama’s limo brigade, I was taking notes at the RAC meeting held in BLMs Las Vegas office.
Led by Chairman John Hiatt, Representative for Wildlife, most Board Members engaged in a lively conversation about wild horses and burros with a special emphasis on the advocates themselves. Generally denigrating, commentary was peppered by such choice tidbits as, “There’s no use talking to these people as they have already made up their minds” and “They don’t understand the problems”.
Following a general round of back patting and self congratulations for the Board helping to get letters of support submitted for BLMs removals in the Calico Mountains, Chairman Hiatt waved around a glossy, colored postcard of Pryor Mountain mustang Cloud on one side and captured wild horses on the other as Mr. Hiatt extolled upon the nature of ungrounded propaganda organizations use to excite ignorant horse and burro lovers across the county.
Not to be left out, a variety of BLM personnel ranging from National Program Office Chief Communications Office Doran Sanchez and District and Field Office Managers such as Mary Jo Rugwell, Thomas Seley and Rosemary Thomas, were also in attendance.
Rosemary reported to the Board that the Eagle HMA’s removal operations had been postponed due to guidance from the national level encouraging BLM to follow public processes instead of issuing Full Force and Effect decisions to remove the animals. No mention was made that safety considerations had been cited in BLMs press releases.
Chief Communications Office Doran Sanchez also reported that BLM was initiating a campaign to counter all the misinformation being spread by “bad blogs”.
As a result, last week a request was sent to Mr. Sanchez as well as National Program Office’s Wild Horse & Burro Lead Dean Bolstad to supply more information about what exactly that entails, what is the current allocated budget to launch and sustain this campaign, what is the projected time frame BLM will engage in this effort and will it be done “in house” or is BLM hiring a marketing firm to handle the efforts. So far, no response has been received but will keep you posted if BLM clears the questions through Public Affairs….
HOLDING FACILITY UPDATES – February 15, 2010
Currently, BLM has posted two sets of Holding Facility numbers on their website with remarkably different results. Posted on the Monthly Gather, Adoption, Holding, and Sales Statistics webpage, no amount of flattery or coaxing could convince the calculator that the numbers were suppose to equal 36,186 as BLM reports HERE.
Here’s what EWA researcher Valerie James Patton had to say when confronted with the “numbers”.“The preparation subtotal is correct, but I added up all the individual maintenance facility numbers, and the correct subtotal for the maintenance facilities is 10,604. Whether or not they meant to state the long term facility subtotatal was 36,186 or if they meant that to be the total number for all the facilities, after I added up all the individual long term facility numbers, the subtotal is 22,575. Even if you add up all the subtotals that BLM had listed, it still doesn't come out to 36,186, but the correct total number of all the facility horses is 37,892.”
Yes, that’s over a 1,700 animal discrepancy.
Fortunately, BLM posted another set of numbers HERE. Well, I guess that solves the mystery of which set of numbers is right, doesn’t it? Or does it?
Note: The BLM has recently responded that the Monthly Report was in error and will be corrected by tomorrow. In order to preserve the integrity of what they originally posted, a pdf verion of their Facility Chart numbers have been uploaded for public review HERE.
LAS VEGAS RESOURCE MANAGEMENT PLAN
Public Scoping Period
The BLM Southern Nevada District Office opened the public comment period regarding issues relating to the preparation of a new Resource Management Plan and Draft Environmental Impact Statement for the area. With a main focus on Renewable Energy, BLM provided various Summaries of the issues HERE.
Information made available regarding this process through the Federal Register Notice and online at BLMs websites made no mention of wild horses and burros impacted by the planning process, failed to identify wild horse and burro Herd Management Areas in any of the maps associated with the planning documents and failed to identify Wild Horse & Burro Specialists as being included in the consulting process.
However, in the February 5, 2009, Southern Mojave Great Basin Resource Advisory Council Meeting Minutes, a presentation was given to RAC Board Members by Pahrump Field Office Wild Horse and Burro Specialist Jerry Bertola and Southern Nevada District WH&B Specialist Krystal Johnson that stated, “There are five Herd Management Areas (HMAs). The proposed solar projects are located in the middle of the burro area.”
There are multiple HMAs in the planning area that contain wild burros, which include the Johnnie, Red Rock, Wheeler Pass and Gold Butte HMA. None of the HMAs are publicly identified on the maps for the affected regions of the LVRMP Scoping Process. The potential of the general public not even knowing these areas exist is high due to this omission.
There is no way to identify what “burro area” Ms. Bertola and/or Ms. Johnson were referring to in the RAC meetings, no way for the general public to identify what areas involved in the planning processes that are up for consideration for reclassification and how their input may impact the HMAs, what impacts other multiple uses will have to the HMAs, etc., and as a result, will potential significantly reduce the opportunity for public involvement, input, concerns, suggestions for potential mitigation measures, and support for successful management of the Southern Nevada District’s wild herds.
This leads to the question, how will BLM remedy this omission so that the general public is aware of the Herd Management Areas within the planning area and what proposals may impact them so that they can provide comments on the proposals?
But that’s not all the questions that surfaced. When it came to the comment deadlines and where the comments should be submitted too, apparently there was a great deal of confusion by BLM personnel as to just where and when public input would be accepted.
On BLMs website, the first public notice listed the public comment deadline as February 4, 2010, and stated, "All comments on issues to be addressed in the RMP must be received by the BLM Southern Nevada District Office by 4:30 p.m. February 4, 2010, to be considered for incorporation into the Draft RMP/EIS." Click Here.
The second public notice listed the comment deadline as February 28, 2010, and stated, "Public comments must be provided to the BLM by February 28th in order to be formally analyzed and included in the Scoping Report”. Click Here.
The Federal Register notice dated 1/05/10, stated, "To be most helpful, you should submit comments within 60 days of the last public meeting".
The LVDFO's last listed public meeting date was February 11, 2010. Based on the information available in the FR, the LVDFO will be required to accept comments through April 6, 2010.
So this leads to even more questions, such as:
a) By posting the comment deadline of February 4, 2010, in a prominent location, how many public comments failed to be submitted because the general public thought the public process was already closed?
b) Why didn't the Las Vegas District Office publish the same notice as was posted in the Federal Register, that public comments could be submitted up to 60 days after the last public meeting and still be included?
c) Which public notice is the highest legal notice that BLM and the public are bound too? The FR Notice or what BLM posted on their website?
d) How can BLM remedy these confusing multiple posts of comment deadlines for public involvement?
The BLM LVDFO provided two different addresses to send public comments to. The first was carolyn_ronning@blm.gov and the second was SNDO_RMP_Revision@blm.gov .
And so this leads to even more questions, such as, why were two different addresses versus one provided to the public depending on which version they accessed of the public notices available for the RMP process? Will public comments for this proposal be accepted through both addresses and if so, for how long?
An inquiry has been submitted to the BLM with these exact same questions and I am currently waiting on their response.
And so it goes, a behind the scenes look at how the Wild Horse & Burro Program turns…..
MOJAVE-SOUTHERN GREAT BASIN RESOURCE ADVISORY COUNCIL MEETING (RAC) - February 18, 2010
While the rest of Las Vegas was holding up protest signs for Obama’s limo brigade, I was taking notes at the RAC meeting held in BLMs Las Vegas office.
Led by Chairman John Hiatt, Representative for Wildlife, most Board Members engaged in a lively conversation about wild horses and burros with a special emphasis on the advocates themselves. Generally denigrating, commentary was peppered by such choice tidbits as, “There’s no use talking to these people as they have already made up their minds” and “They don’t understand the problems”.
Following a general round of back patting and self congratulations for the Board helping to get letters of support submitted for BLMs removals in the Calico Mountains, Chairman Hiatt waved around a glossy, colored postcard of Pryor Mountain mustang Cloud on one side and captured wild horses on the other as Mr. Hiatt extolled upon the nature of ungrounded propaganda organizations use to excite ignorant horse and burro lovers across the county.
Not to be left out, a variety of BLM personnel ranging from National Program Office Chief Communications Office Doran Sanchez and District and Field Office Managers such as Mary Jo Rugwell, Thomas Seley and Rosemary Thomas, were also in attendance.
Rosemary reported to the Board that the Eagle HMA’s removal operations had been postponed due to guidance from the national level encouraging BLM to follow public processes instead of issuing Full Force and Effect decisions to remove the animals. No mention was made that safety considerations had been cited in BLMs press releases.
Chief Communications Office Doran Sanchez also reported that BLM was initiating a campaign to counter all the misinformation being spread by “bad blogs”.
As a result, last week a request was sent to Mr. Sanchez as well as National Program Office’s Wild Horse & Burro Lead Dean Bolstad to supply more information about what exactly that entails, what is the current allocated budget to launch and sustain this campaign, what is the projected time frame BLM will engage in this effort and will it be done “in house” or is BLM hiring a marketing firm to handle the efforts. So far, no response has been received but will keep you posted if BLM clears the questions through Public Affairs….
HOLDING FACILITY UPDATES – February 15, 2010
Currently, BLM has posted two sets of Holding Facility numbers on their website with remarkably different results. Posted on the Monthly Gather, Adoption, Holding, and Sales Statistics webpage, no amount of flattery or coaxing could convince the calculator that the numbers were suppose to equal 36,186 as BLM reports HERE.
Here’s what EWA researcher Valerie James Patton had to say when confronted with the “numbers”.“The preparation subtotal is correct, but I added up all the individual maintenance facility numbers, and the correct subtotal for the maintenance facilities is 10,604. Whether or not they meant to state the long term facility subtotatal was 36,186 or if they meant that to be the total number for all the facilities, after I added up all the individual long term facility numbers, the subtotal is 22,575. Even if you add up all the subtotals that BLM had listed, it still doesn't come out to 36,186, but the correct total number of all the facility horses is 37,892.”
Yes, that’s over a 1,700 animal discrepancy.
Fortunately, BLM posted another set of numbers HERE. Well, I guess that solves the mystery of which set of numbers is right, doesn’t it? Or does it?
Note: The BLM has recently responded that the Monthly Report was in error and will be corrected by tomorrow. In order to preserve the integrity of what they originally posted, a pdf verion of their Facility Chart numbers have been uploaded for public review HERE.
LAS VEGAS RESOURCE MANAGEMENT PLAN
Public Scoping Period
The BLM Southern Nevada District Office opened the public comment period regarding issues relating to the preparation of a new Resource Management Plan and Draft Environmental Impact Statement for the area. With a main focus on Renewable Energy, BLM provided various Summaries of the issues HERE.
Information made available regarding this process through the Federal Register Notice and online at BLMs websites made no mention of wild horses and burros impacted by the planning process, failed to identify wild horse and burro Herd Management Areas in any of the maps associated with the planning documents and failed to identify Wild Horse & Burro Specialists as being included in the consulting process.
However, in the February 5, 2009, Southern Mojave Great Basin Resource Advisory Council Meeting Minutes, a presentation was given to RAC Board Members by Pahrump Field Office Wild Horse and Burro Specialist Jerry Bertola and Southern Nevada District WH&B Specialist Krystal Johnson that stated, “There are five Herd Management Areas (HMAs). The proposed solar projects are located in the middle of the burro area.”
There are multiple HMAs in the planning area that contain wild burros, which include the Johnnie, Red Rock, Wheeler Pass and Gold Butte HMA. None of the HMAs are publicly identified on the maps for the affected regions of the LVRMP Scoping Process. The potential of the general public not even knowing these areas exist is high due to this omission.
There is no way to identify what “burro area” Ms. Bertola and/or Ms. Johnson were referring to in the RAC meetings, no way for the general public to identify what areas involved in the planning processes that are up for consideration for reclassification and how their input may impact the HMAs, what impacts other multiple uses will have to the HMAs, etc., and as a result, will potential significantly reduce the opportunity for public involvement, input, concerns, suggestions for potential mitigation measures, and support for successful management of the Southern Nevada District’s wild herds.
This leads to the question, how will BLM remedy this omission so that the general public is aware of the Herd Management Areas within the planning area and what proposals may impact them so that they can provide comments on the proposals?
But that’s not all the questions that surfaced. When it came to the comment deadlines and where the comments should be submitted too, apparently there was a great deal of confusion by BLM personnel as to just where and when public input would be accepted.
On BLMs website, the first public notice listed the public comment deadline as February 4, 2010, and stated, "All comments on issues to be addressed in the RMP must be received by the BLM Southern Nevada District Office by 4:30 p.m. February 4, 2010, to be considered for incorporation into the Draft RMP/EIS." Click Here.
The second public notice listed the comment deadline as February 28, 2010, and stated, "Public comments must be provided to the BLM by February 28th in order to be formally analyzed and included in the Scoping Report”. Click Here.
The Federal Register notice dated 1/05/10, stated, "To be most helpful, you should submit comments within 60 days of the last public meeting".
The LVDFO's last listed public meeting date was February 11, 2010. Based on the information available in the FR, the LVDFO will be required to accept comments through April 6, 2010.
So this leads to even more questions, such as:
a) By posting the comment deadline of February 4, 2010, in a prominent location, how many public comments failed to be submitted because the general public thought the public process was already closed?
b) Why didn't the Las Vegas District Office publish the same notice as was posted in the Federal Register, that public comments could be submitted up to 60 days after the last public meeting and still be included?
c) Which public notice is the highest legal notice that BLM and the public are bound too? The FR Notice or what BLM posted on their website?
d) How can BLM remedy these confusing multiple posts of comment deadlines for public involvement?
The BLM LVDFO provided two different addresses to send public comments to. The first was carolyn_ronning@blm.gov and the second was SNDO_RMP_Revision@blm.gov .
And so this leads to even more questions, such as, why were two different addresses versus one provided to the public depending on which version they accessed of the public notices available for the RMP process? Will public comments for this proposal be accepted through both addresses and if so, for how long?
An inquiry has been submitted to the BLM with these exact same questions and I am currently waiting on their response.
And so it goes, a behind the scenes look at how the Wild Horse & Burro Program turns…..
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3 comments:
For those of us who live in the middle of this mess, this is just the tip of the iceberg. Nonetheless we're grateful that you continue to point out that the iceberg exists!
Now that's just what the BLM needs to spend money on, hiring someone to do Public Relations to counter "bad blogs." Wish they could comprehend that honesty and transparency would wipe so much of this disdain away. Thank you for keeping us posted.
As for the BLMs failure to list the exsistance of the WFHBs in the land managment plans, I am not suprized at all that they got it backwards. FLPMA requires that any special use of land designated before its passage would have to have land-use management plans of its own drawn up indicating the special use of those lands. If and when there are other activities or plans for an area in or near the specially designated area,...the new land use plan would have to make mention of the previously exisitng land use plan of which also CANNOT be changed but must be managed in accordance with the relevant law of the time....in this case the relevant law citing the special designation is the WFHBA of 1971. In other words, managment of our WFHB herds CANNOT be (or are not supposed to be) managed through land use plans!
Another provision of FLPMA the BLM is ignoring is the EXCEPTION clause that clearly states any lands specially designated for a certain purpose prior to the enactment of FLPMA shall be exempt from any mandatory "multi-use" or "sustainability of yield" considerations or requirements. In other words, any other use of the land MAY be permitted (discretionary) as long as the new use didnt interfere with the "principality" of the land as wild horse and burro historic range." The law is pretty clear on this so I left wondering why have they been getting away with ignoring (nullifying)these very important federal statutues for so many years? The WFHBA of 1971 and FLMPAs exception for "previously designated" lands were enacted to protect our wild equines, and to keep them forever free and principal users of their historic lands NO MATTER WHAT OTHER USE may be planned for the land at a later time. BLM is ignoring the laws alright, but it is the LAwyers who are letting them get away with it. How long before a wfhb laywer will write out a "statutory nulification" charge against the DOI and/or the BLM? Then you will have your winner. Then all the round-ups will stop. What R they waiting 4?
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