In The Pink

BLM is currently accepting public input on a document titled, “Wild Horse & Burro Strategy Development Document”, an electronic nightmare of malfunctions, blank pages, hard to navigate systems and narrow lines of questioning that seem more interested in privatizing the Wild Horse and Burro Program and supporting Secretary Salazar’s out of touch initiatives than on actually listening or attempting to address the serious deficiencies of how BLM has managed the Wild Horse and Burro Program for the last forty years.

As I perused through BLMs electronic maze of carefully crafted “strategies”, I couldn’t help but wonder about the thousands of public comments already submitted to BLM that have disappeared into the bureaucratic vacuum of BLMs vaults.

In case you are wondering what I’m talking about, shortly after BLM Deputy Director Henri Bison announced to the National Wild Horse & Burro Advisory Board in June 2008 that BLM was now considering euthanizing thousands of now captive American mustangs to cut Program costs, BLM initiated a “Public Comment” format on their website that supposedly accepted public comments and input for consideration in future management strategies of our mustangs and burros.

This opportunity was available to the public for almost two years, (based loosely on my memory) and yet, looking at BLMs newest sales attempt for “public involvement”, I couldn’t help but wonder; where are all the previously submitted public comments and suggestions in the current “Strategy Development Document” BLM plans on parading around and using to show Congress how much they really do care. Really…

After all, BLM has cared so much about what the public had to say back then (and now) that all those comments just disappeared while BLM was able to create the illusion of doing something -but this time it’s different, right?

BLM also cares enough to limit the current line of questioning and obviously manipulated public responses to merely a handful of Salazar approved themes. And if that isn’t enough, not only did BLM make every public comment and suggestion disappear from the last round of public input, they intend to limit the scope of this round of public comments to merely summaries of our thoughts - rewritten at their discretion for the new Strategy Development document - in BLM’s latest updated version of the public involvement hoax.

Well here’s an idea to promote the BLM transparency they claim they are reaching for: How about someone submitting a FOIA to BLM regarding all the public comments, suggestions and ideas previously submitted in order to review how much they incorporate them in the “new” strategy.

So this is what I have to say to Congress and BLM about their management of the Wild Horse & Burro Program, Salazar’s Initiative, and what “we, the people” have received over the last forty years for their efforts….

> A loss of at least 21.7 million acres of supposedly “protected” wild horse and burro habitat with no call by Congress for initiating a serious investigation of where it went or for making any sincere efforts to initiate its rightful return. (But Congress certainly seems willing to seriously consider buying a whole bunch of private land to the tune of millions of dollars to stockpile sterile wild horse herds on without any additional review, right?)

> BLM admitting they can’t count the number of horses on the range within even a marginal degree of accuracy. (Editor's Note: Don't be fooled by BLMs reference to the GAO conclusion about their inability to count horses. The GAO's conclusion was reached after tallying survey responses sent back from BLM offices - that's the only "evidence" the GAO has...)

> BLM also being unable to even marginally count or report the number of wild horses and/or burros in the equally mysterious holding facilities as recently evidenced by Equine Welfare’s Alliance newest press release, "How Do You Make 2000 Horses Disappear? Let BLM Manage Them" (plus supporting documents), which clearly show how over 2,000 horses are now missing from BLM Holding Facility Chart Reports. (Editors Note: This is the second time massive discrepancies have been found in BLMs publicly reported Holding Facility numbers as a similar discrepancy of approximately 1,700 wild horses was found less than six months ago.)

> Last October, BLM also publicly released the Fiscal Year 2009 “Final” Gather Schedule that is suppose to detail all the removals BLM performed over the fiscal year; except it initially failed to included approximately 2,900 wild horses BLM had removed in October, November and December.

> Recently, BLM Public Relations Specialist JoLynn Worley explained via email that the population BLM had been reporting for Toano Herd Area since 2004 was merely another accounting “error”; despite Ms. Worley providing maps of the Toano Herd Area that now report BLM conducted aerial censuses in both 2006 and 2007 that found zero wild horses. (Editor's Note: The maps Ms. Worley provided to prove this were created on July 9, 2010 – the day before the Pilot Valley “estray” horses were sold at a livestock auction in Northern Nevada). Setting those questions aside for the moment, BLM now claims they went ahead and kept reporting and adding wild horse populations they “knew” didn’t exist to National totals. By my understanding, this kind of accounting practice is clearly defined as fraud. Of course, I’m sure BLM will be excused for their bad record keeping again (and again, and again, and again, and again, and again, and, well, you get the idea…)

> BLM cares so much about the integrity of their stewardship for our wild horses and burros that in their new Wild Horse and Burro Handbook, they refer to them as "feral" while the majority of established Appropriate Management Levels (AML) used to determine “excess” horses are so convoluted, filled with errors, omissions and manipulation of data, that the sheer audacity of their incredulous statements borders on the obscene. Still, BLM maintains these AMLs are accurate and horses exceeding these AMLs must be removed under an “excess” clause; despite the magical appearance of thousands of horses and burros they never knew were out on the range to begin with prior to the pre-gather aerial censuses. Click Here to view an updated chart on how often this has now happened.

> BLM cares so much that, throughout the course of its management of the Wild Horse and Burro Program, there have been extreme allegations of abuse, inhumane treatment, sanctuary schemes, selling wild horses for slaughter, using phony double branding systems, black booking operations and “slicks” (see 1997 PEER Report; Horses To Slaughter - Anatomy of a Cover Up) as well as reports surfacing that approximately 32,000 wild horses were already missing from BLM records as far back as 1998. (see 1998 Range Issues Field Hearing before the Subcommittee on National Parks and Public Lands).

> BLM cares so much that it has spent the last 8 years ramming through Resource Management Plans and AML decisions that completely zeroed out herds with little to no rangeland evidence to support those decision (for starters, see Ely Resource Management Plan or the West Douglas Herd Area) or choosing to bury monitoring data from their own Wild Horse & Burro Specialist that testified under oath that rangeland health objectives were being met - despite wild horse populations being significantly over BLMs mythical AMLs.

> The BLM also cares so much about their stewardship duties that they believe they are the supreme authority on all aspects of the Program and so, can ignore federal judges opinions, block public access to gathers, holding facilities and census flights as well as continuing to post multiple errors in their Wild Horse and Burro Statistics without any concern of accountability or oversight.

> And lately, BLM also seems to care quite a bit about “bad press” and has become concerned that the time honored tradition of successful sound byte regurgitation's of "overpopulation", "degraded ranges" and "emergency humane gathers" may be losing some of its iron grip acceptance by the masses due to grass roots efforts to expose the truth. In response, BLM has now launched an impressive cadre of upbeat, up-to-date, technologically savvy public “outreach” programs that include Twitter, Facebook and their very own YouTube Channel!

Too bad they couldn’t have devoted the same time, effort and money towards promoting wild horse and burro adoptions, huh? (see BLM's National Wild Horse Adoption Day).


Let’s face it, over the decades, the long string of Interior and Agriculture Secretaries have unequivocally failed both public and law on every level. Now, they want to know what we think about that fact….

Currently, BLM is soliciting public input on where to go with the Wild Horse & Burro Program – again.

The deadline to respond is August 3, 2010, and you can do this by either trying to jump through the BLM's insane website hoops or by sending a written letter to the Washington Office.

Right now, a lot of organizations and blogs are stressing the need for advocates to send their comments via the old fashion way, by snail mail. Why? Because if you mail your comments in, you won’t be as restricted as if you try to navigate the narrow canyon BLMs “input system” tries to herd the public through.

In Defense of Animals has put together a great response, including a letter that you can print and send to Washington, which include many key points that reflect the abysmal efforts of “Salazoo’s Initiative” he is hoping he and Obama will be able to smooze through Congress. So maybe you may want to use this method to speak up for our horses and burros. Or maybe, you’d just rather submit your own kind of input instead.

However, whatever way you decided to go, here’s a word of caution;

If you choose to mail your comments in to the Washington office, due to the high level of security hard copy mail must go through in the DC area, it may take several weeks before BLM finally receives your input.

Therefore, I would HIGHLY recommend you send any comments Return Receipt Requested so that,

a) You have a dated receipt and postmark that proves you submitted comments prior to the deadline and,

b) You know for sure BLM received your comments and if necessary, can prove that as fact in a court of law.

As for me, after what I have had to witness over these last four years of my “public involvement” with BLMs management of the Wild Horse & Burro Program, the only really sincere suggestion I have left to give is to tell Congress-

"Don’t wait for BLM to submit their resignation, give them the pink slip NOW!"

Click Here to review my personal input and submission.

~Mailing Address~

Wild Horse & Burro Strategy Development Document
BLM Washington Office
1849 C Stree NW, Rm. 5665
Washington, DC 20240

!NEW EMAIL ADDRESS!
wildhorse@blm.gov

With five days left of the public comment period, AWHPC has reported BLM finally released an easy to use, functional email address. Personally, knowing how BLM is, I wouldn't leave it to chance and recommend sending a hard copy via postal mail anyway just as a "back up" plan!

7/30/10...BLM Announces 30 Day Extension of Public Comment Period

7/31/10...BLM Extends Comment Period But For Who's Benefit,
Not The Wild Horses
Straight From The Horse's Heart: R.T. Fitch

What Judge?

The BLM is accepting public comments through Monday, July 19, 2010, for the planned removal of the entire West Douglas wild horse population. Click Here to review the Preliminary Environmental Assessment.

Having briefly scanned BLMs long list of arguments, reasons and legal citations regarding why they are authorized to decimate the West Douglas herds, I am still trying to pick my jaw up from the floor as I noticed BLM omitted one, tiny little significant fact about their authority to do so;

A FEDERAL JUDGE TOLD BLM LAST YEAR IT WAS ILLEGAL!

For those of you who may be unfamiliar with this case, Colorado Wild Horse and Burro Coalition, Inc., led by attorney Valerie Stanley had taken BLM to task regarding their authority to zero out the West Douglas herds.

On August 5, 2009, United States District Judge Rosemary M. Collyer ruled BLM had overstepped their authority by issuing a zero AML for the West Douglas herds and declaring ALL wild horses as “excessive”, in direct defiance of both intent and law as clearly spelled out in the Wild Free-Roaming Horse & Burro Act. Click Here to read Judge Collyer’s decision.

Yet, here we are, one year later, with BLM citing their authority as the only authority and completely failing to mention the Judge’s ruling as they continue to charge onward with nary a thought or concern.

With that in mind, its kind of hard to advocate for submitting public comments for BLM to “consider” about zeroing out the West Douglas herds if they don’t give a rats ass about what a federal judge had to say.

However, given the circumstances, obviously BLM is going to find themselves talking to the judge again to explain why they don’t care what she had to say last year about their “authority”, why they don’t believe they are bound by the Wild Free-Roaming Horse & Burro Act, and how the BLM has decided the West Douglas Herd Area is great habitat for livestock grazing, oil and gas, elk, bighorn sheep and other wildlife species – just not wild horses.

Therefore, having public comments on file about how insanely out of control this agency has become might be helpful when the judge is looking at BLMs lawyers and asking them why she has to decide on a case she has already decided on.

If you’d like to add your voice in protest of BLMs continued defiance of both law and judge, please submit comments by:

~PUBLIC COMMENT DEADLINE~
MONDAY, JULY 19, 2010
4:30 p.m. m.s.t.

Bureau of Land Management
White River Field Office
Attention: Melissa Kindall
220 E. Meeker, CO 81641
Phone: 970-878-3842
FAX: 970-878-3805
E-Mail: melissa_kindall@blm.gov

Be sure to include in your title, West Douglas Wild Horse Removal Plan, EA# DOI-BLM-CO-110-2010-0088-EA.

Also, please be aware that submitting comments to the BLM becomes part of the public record and as such, all personally identifying information may be available for public review. While you can request BLM withhold this information, BLM may not be able to, depending on the circumstances of some requests.

Pilot Valley or Toano?

The following press release was sent out on 7/07/10 by The Equine Welfare Alliance, a dues free, umbrella organization with over 100 member organizations. The organization focuses its efforts on the welfare of all equines and the preservation of wild equids and Animal Law Coalition, a coalition of pet owners and rescuers, advocates, attorneys, law students, veterinarians, shelter workers, decisionmakers, and other citizens, that advocates for the rights of animals to live and live free of cruelty and neglect.

Doubt Cast On Pilot Valley “Estray” Horses Rounded-Up By BLM

CHICAGO, (EWA) – On June 23, 2010, the Bureau of Land Management (BLM) Elko District office buried on its website a notice that approximately 175 “abandoned, domestic, estray” horses located within Pilot Valley, NV, were scheduled for impoundment beginning June 25. The round up was expected to take 3 - 4 days with corrals set up on nearby private land owned by Simplot Land and Livestock until the horses could be transported and placed under the jurisdiction of the State of Nevada.

According to Nevada laws, an estray is a horse that is found running loose on public lands but shows signs of domestication and the owner is unknown. A horse is considered “feral” under Nevada law if the animal was domesticated or is the offspring of domesticated horses and has become wild with no physical signs of domestication. The state of Nevada owns estray and feral horses. Wild horses and free-roaming Mustangs are protected by the BLM under the 1971 Wild Free Roaming Horses and Burros Act.

Nevada authorities plan to sell the horses rounded up by the BLM at auction on July 10. The horses will be available to all buyers and are therefore at risk of ending up at slaughterhouses in Mexico or Canada.

But serious questions are being raised as to whether these horses are, in fact, estray or feral. After investigating the history and location of the Pilot Valley area, wild horse advocates found Pilot Valley sits at the edge of a known wild horse territory called the Toano Wild Horse Herd Area. BLM wanted to make this area "horse free" in 1993, but according to BLM's Program statistics, approximately 168 wild horses were reported as still residing in the Toano range as of last year.

The proximity and near identical number of horses has lead mustang advocates to speculate that the horses the BLM rounded up as estray might actually be wild horses from the Toano range that are entitled to roam free under federal protection. How, they ask, does BLM know these horses are estray or feral and not wild horses?

Suspicions are further fueled by the unusual suddenness of the roundup, just 48 hours after notice of the removal was posted. "These horses will go from free roaming to sold in fifteen days or less with tight security at the facilities where they are now being held," said Valerie James Patton, Vice President of Equine Welfare Alliance (EWA).

"Even BLM's own news release stated those horses had been there a long time, long enough to grow in size", Patton added. "So now the question becomes, how long is a long time? Since 1993 when BLM filed papers to zero out the Toano Herd Area?"

“Given the long history of abuse and impropriety that has characterized the Wild Horse & Burro Program, I have to ask,” said EWA’s Vicki Tobin, “Did BLM openly remove federally protected wild horses from the range to sell them for slaughter because they have no fear of being held accountable? It would be illegal for BLM to round up wild horses declaring them estray and turn them over to the State. The BLM is prohibited from sending wild horses to slaughter, whether directly or indirectly.”

While questions have begun surfacing as to the true status of the Pilot Valley horses, Laura Allen of Animal Law Coalition and EWA points out, "Before selling estray horses, the state is supposed to use reasonable diligence to try to find the owner including placing a notice about the estray with a full description in the local paper. BLM's news release states these are domestic estray horses abandoned by local residents. So why isn’t an effort being made to find the local owners and hold them responsible to care for these horses instead of rushing these horses off for instant sale?"

"Another concern is, there are very specific definitions as to how to determine estray and feral livestock from federally protected wild horses and so far, the only thing we've seen is a take-our-word-for-it position from officials", she said.

“The Department of Interior has an almost unblemished reputation as a consistent source of scandal, mismanagement and corruption,” explained EWA president John Holland, “starting with Teapot Dome in the Harding Administration through to the current disaster in the Gulf. So when things look this suspicious, questions are bound to arise.”

In fairness to the BLM, EWA contacted them on July 1, to ask how they determined the horses were estray and is still awaiting a response.

EWA calls for a federal investigation to find out how BLM determined these horses are not the federally protected wild horses from the Toano range, which should include genetic testing and an accounting of the Toano wild horses.

Contacts

Valerie James-Patton
Equine Welfare Alliance
530-474-1128
valerie_jamespatton@yahoo.com

Laura Allen
Animal Law Coalition and Equine Welfare Alliance, general counsel
607.220.8938
lauraallen@animallawcoalition.com

#

What evidence indicates the Pilot Valley estray horses may instead
be federally protected wild horses from the Toano range?
Click Here to view.

**********************************************************************************

The following additional information was supplied by Willis Lamm of Alliance of Wild Horse Advocates regarding current rescue efforts for these horses now being made by Jill Starr of Lifesaver’s Wild Horse Rescue.

Jill Starr has organized a rather comprehensive rescue effort for the 174 Pilot Valley horses that BLM rounded up late last month and turned over to the Nevada Department of Agriculture to sell off at a livestock sale in Fallon on July 10th.

Photo of horses slated for auction on Saturday, July 10, 2010
Courtesy of Willis Lamm and AOWHA

Advocates are concerned that these horses were not privately owned as BLM is claiming, but actually may have strayed off one of the nearby BLM wild horse herd areas and therefore should be protected from going to the kill buyers. Starr's Lifesavers Wild Horse Rescue, with assistance from several other organizations, will bid against the kill buyers for these horses and Lifesavers has a local facility ready to receive them.

This effort is not intended to exclude any qualified and caring private individuals from acquiring some of these horses.

Complete details are posted in the

Alliance of Wild Horse Advocates' War Room at -
http://www.aowha.org/activities/pilot_valley_rescue01.html

Calico: Past, Present & Future VII

This is the last in a series of articles that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond….

Over the last few months, after all these facts, figures, history and legalese, what does all this really mean in relation to the Tri-State Mega Complex?

Well, no one can predict the future. Therefore, ultimately what comes next must be confined to the world of conjecture, speculation, hypothesis, assumption and guesswork. By its very nature, the future is potentially fluid, only molded into existence by the actions of the present.

Yet, too often, the future is equally molded by the actions of the past, especially when the choices of each moment continue to be made from the same narrow paradigm that only lead down the same old road.

However, like a crime scene investigator able to gather evidence to piece together what led up to the crime, often signs of what was to come were already well in place before the crime was finally committed.

While you can’t convict someone because of “signs”, you can certainly be aware of them, recognize the road they are leading down and acknowledge the potential consequences and danger if a change in course is not taken.

Therefore, the following potential future for the Tri-State Mega Complex is not based on something as obscure as consulting a crystal ball. It is based on the roads the Department of the Interior has chosen in the past and the choices they continue to make – despite the current rhetoric and propaganda being churned out by the Public Relation firms and specialists.

It’s been two years since BLM first announced they had run the Wild Horse and Burro Program into the ground and that the situation had become so dire, the lives of tens of thousands of captured mustangs were now on the table for mass disposal. Oh yeah, and that the choices made in the past were in desperate need of change.

Yet, in the trenches of wild horse and burro management during this same two year period, decisions continued to be issued by the DOI that reveal no signs of change, no reversal of course, only evidence of an acceleration of more the same, broken system.

In this case, it is not a stretch to predict a possible future for the horses and burros still being held captive by an unyielding agency showing all the signs of being hell bent on finishing the job. Equally so, there are very few indications that the Tri-State Mega Complex is now being proposed to serve either the good of the animals or those members of the public who support their wild presence.

And so, without further ado, this is where I think it is going and why….

The first part of this series presented an extensive analysis of the history as to how BLM had set the wild horse and burro AML in many of the Calico Complex areas, especially in the Soldier Meadows Allotment. Why?

Because it showed how BLM was able to fudge “the science” by perpetuating promises that were never kept for over three decades, the extensive legal timetable set up to keep the public, and sincere answers, at bay, and how BLM was able to fend off every protest, every error found in their methods, and every question about their data, because they were able to perpetuate decisions with promises of resolution – in the future.

It also illustrated the road BLM followed when they set a “new” plan in motion and how they were able to use this “process” as an excuse to justify decisions rooted in promises for the future to postpone any real evaluations for today, tomorrow, or even for decades.

Finally, it highlighted how one Wild Horse and Burro Specialist at the Winnemucca Field Office had actually been doing her job and monitoring the area, which revealed the “starting” AMLs were way off base and that many areas could support a great deal more wild horses and burros than BLM continued to affirm as “appropriate” – even while livestock authorizations and big game populations kept going up.

It also illustrated how we, the public, would have never known that fact if Western Watersheds Project hadn’t taken BLM to court. BLM made no mention in the Calico Complex EA that current monitoring data revealed utilization levels did NOT support those abysmally low and arbitrary AMLs - but just the opposite – and it became very clear that BLM’s concern was not about reporting the new monitoring data but merely about scrambling to cover it up.

As for the promises themselves? There is no official authority reviewing agency promises, if they are eventually kept and no system set up to demand accountability if they don’t follow through.

So what will it take to cover up the recently emerged monitoring data which challenges those clearly arbitrary AMLs in the Calico Complex if someone gets that information to a federal court? Or perhaps, other data the public doesn’t know about that might also somehow get exposed?

Well, a new plan could reset the bureaucratic clock and again initiate the same “processes” filled with more promises for the future…

The second in this series explored how BLM released radical new information that was rarely, if every publicly documented about the Calico Complex area before, as BLM claimed wild horses were now migrating all over the place for tens of miles - despite decades of “in depth monitoring” used to rubber stamp those old AML decisions; radical new information used to explain the unexplainable with respect to unfounded population reports - but still made legally whole by more promises of “future” study.

The article also covered legal challenges to BLM’s decisions, how addresses given by BLM for public involvement in the Calico Complex suddenly become “defunct”, how public comments “disappeared”, how a BLM employee swore under oath that no comments were received (while the court disagreed), yet the employee received no reprimand, no penalty, no repercussions due to her protected status as a government official, as well as skimming the surface of the judicial farce still being billed as the public appeal process.

Finally, it also highlighted the up coming mega projects for the area while illustrating how the clock was ticking on all those “promises” BLM and USFWS made so long ago.

So what would it take to erase the past and give fresh, new legal authority to parade in front of the courts for indefinite extensions to buy time to implement new management? A new plan?

The third in the series explored neighboring Sheldon National Wildlife Refuge with its own sordid history, promises, undercover footage of nightmarish round ups conducted by BLM’s #1 contractor for wild horse and burro “control services”, questionable adoption and transport contracts, public lock downs on releasing information about what has been going in the Refuge for the last two years, reports of experimental gelding and spaying of mares, questionable populations, reproduction rates and the very serious legal issue of; has Sheldon been transporting and selling federally protected wild horses and burros illegally for all this time?

With still no answers yet, what will it take for USFWS to avoid all the potential legal penalties for doing so if this were found to be the case? A new plan?

The fourth in the series was an in depth analysis of a recent Rangeland Health Analysis released by BLM employees regarding the Massacre Lakes HMA, complete with graphs provided by BLM themselves showing record livestock use during the evaluation period, manipulation and omission of data, and calculated insertions about all the trigger levels BLM’s new Resource Management Plan (RMP) set up as “indicator” signs of wild horse overpopulation to justify further reductions in AMLs.

Since that new RMP also set up and approved the entire elimination of one or multiple wild horse populations in several HMAs, how would BLM be able to do this without letting the public know what they have done and avoid a firestorm of public protest? A new plan?

The fifth in the series covered extensive behind-the-scenes plans being laid out behind the publics back while BLM was authorizing the removal of wild horses in the Calico Complex area by the thousands (they were also running off with Sheldon and Oregon horses around this same time too).

While there are plenty of official’s hands outstretched to the Ruby Pipeline’s deep pockets, tall dollars and wishes for gold plated troughs being submitted to “mitigate” Ruby’s impacts, who was asking for money to help the wild horses and burros?

The only plans mentioned for them were “temporary” water hauling and more fencing to be erected during the “construction phase” to create a barb-wire wonderland that would eventually crisscross every conceivable place that still had a drop of water or a blade of grass, including fencing off each HMA itself to prevent them from “migrating” anywhere else. And of course, lots of sales pitches to privatize those same ranges the remaining wild horses and burros in Ruby's path can still call home.

As for the all-precious, life-giving water in the area? If the agencies get everything they ask for, water will be generally limited to whoever turns on the facet – or not – as the case may be.

So what would it take to implement all these potential changes to the environment without violating BLM’s mandates and public notification process on wild horse and burro management under multiple use laws? A new plan that concedes BLMs jurisdictional authority to USFWS instead may prove useful and there is evidence to suggest this may be the way the DOI is heading….

Of course, BLM could not legally be left out of the loop or the laws they are required to follow but just study what happened when BLM “partnered” with other agency’s in the Desert Managers Group. Suddenly, all of BLM’s mandates on wild horses and burros were sent to the bottom of the consideration-totem-pole. With respect to BLM’s “authority” in relation to everything else, when the smoke cleared from the jurisdictional war that had ensued between all the partners, BLM came out of the fray resembling the old cliché of “beaten like a red-headed stepchild”.

The sixth in the series covered the Oregon section of the Tri-State Mega Complex, which mirrored unexplainable and consistently inconsistent population reports BLM continues to flaunt with no sincere oversight.

It also discusses extreme fertility control plans that included adding geldings to free-roaming populations, which mirror the same fertility control plans already implemented in Sheldon by USFWS, and generally, more of the same ole same ole dusty road we’ve been down way too many times before.

How will BLM continue to justify these crazy population numbers? Well, a new plan might be really useful…

A new plan erases the past, resets the bureaucratic clock, absolves the agencies from accountability, clears the legal obstacles and hurdles that otherwise, they may not be able to jump, and allows them to justify crazy reports on wild horse and burro populations that will now span nearly four million acres, according to BLM’s latest press release.

In case anyone’s noticed, BLM already uses the half a million acre excuse to fend off how the “large expanse” explains why the public can’t find any horses, why THEY can’t answer any population questions and why any pubic testimony isn’t credible if no one can find more than a handful of wild horses across a span of hundreds of thousands of acres. For the officials, the blow off technique is as simple as, “Oh, the horses must have moved - over there” and I know this as fact because I have seen it used at least a dozen times before.

A new plan could be the answer to all their problems. It can create an even wider bureaucratic web to immobilize the public even further, add more complexity to an already overly complex situation, clear the legal quagmire they are fast approaching, allow a bureaucratic “hot potato” game between BLM and USFWS (no, they are in charge, no, they are in charge), further their ability to perpetuate omissions and manipulations of data, prevent the narrowing of reporting in any given management proposal (think broad, general strokes, not site-specific analysis), set up “new” AMLs as “new” starting points, and by the time the bureaucratic clock runs out again with all its usual empty, unfilled promises, the majority of us won’t be around to tell the next generation what BLM was suppose to do way back when and they won’t be old enough to even remember how “self-sustaining” bands of wild horses and burros once roamed free on now sold out public lands.

Mega Complex, indeed….

However, I can see at least one advantage to combining Sheldon and BLM HMA’s into one management unit under the Tri-State Mega Complex umbrella (assuming USFWS even allows a wild horse or burro to continue to remain legally in the Refuge) and that is, at least the Sheldon wild horses and burros will again be granted their rightful federally protected status such as they once had in 1971 at the passage of the Act.