tag:blogger.com,1999:blog-45623577492959997702024-03-13T15:41:35.445-07:00American HerdsUnknownnoreply@blogger.comBlogger190125tag:blogger.com,1999:blog-4562357749295999770.post-72579164330155294752011-06-03T14:48:00.000-07:002011-06-03T14:53:10.268-07:00In Conclusion<div align="justify">After much reflection and meditation of this five-year journey regarding my research and involvement in the Department of the Interior/Bureau of Land Management’s execution of the Wild Horse and Burro Program, I have reached a decision and am announcing my retirement.<br /><br />While I will no longer be involved in any new analysis, please continue to read, review and build upon the documents, links and prior postings in American Herds as sources of information, education, history, and interconnected relationships in what appears to be the ongoing perpetuation of a broken, inhumane and fraudulent Program whose criminal activities have been swept under the rug and covered up for decades.<br /><br />Over this time, I have accumulated a wide variety of environmental assessments, reports and related documents that I hope to periodically upload to American Herds in order to make them available for those who seek to know more of the truth about what has – and is – really occurring behind the scenes of the sound byte propaganda continually regurgitated by industry related enemies of America’s remaining “free” wild horse and burro populations. Please check back occasionally for new material that may be of assistance in learning and knowing more about these issues.<br /><br />I would also like to deeply thank the untold number of citizens and grass roots activists I have had the distinct honor and pleasure to work with during this time. Your dedication to the well being of our herds, pursuit of the truth, and infinite sacrifices has been truly humbling.<br /><br />Sincerely,<br />Cindy MacDonald </div>Unknownnoreply@blogger.com29tag:blogger.com,1999:blog-4562357749295999770.post-75092546381077410382011-04-02T15:01:00.001-07:002011-04-02T15:01:18.859-07:00<div align="center"><span style="font-size:180%;color:#993300;"><strong><a href="http://www.animallawcoalition.com/wild-horses-and-burros/article/1673">Call on Congress Now to De-Fund the Wild Horse Roundups</a></strong></span></div>Unknownnoreply@blogger.com2tag:blogger.com,1999:blog-4562357749295999770.post-7274108296676507892011-03-06T17:09:00.000-08:002011-03-09T18:27:05.059-08:00For High Crimes & Misdemeanors<div align="justify">Last week, Vivian Grant, founder and president of <a href="http://www.horsefund.org/about.php"><span style="color:#cc6600;">International Fund for Horses</span> </a>in conjunction with Michael Blake, screenwriter of "Dances With Wolves" and two-decade long wild horse and burro champion, released a powerful call to citizens and advocates across the country to exercise their Constitutional rights for the sake of our wild horses and burros.<br /><br />The timing of the call could not have been better as it coincided with the release of BLM Director Bob Abbey's approved "new" <a href="http://www.blm.gov/pgdata/etc/medialib/blm/wo/Communications_Directorate/public_affairs/news_release_attachments.Par.46571.File.dat/Proposed_WHBStrategy.pdf"><span style="color:#cc6600;">Wild Horse and Burro Proposed Strategy</span></a>; a regurgitated and misleading pack of cow manure that continues to promote an unyielding agenda of spin and bureaucratic "substantiation" for continuation of their crimes.<br /><br />"<em>I believe crimes are being committed against our wild horses</em>", says Grant. "<em>Crimes that must be prosecuted and the federal officials responsible removed. We are asking Congress to do just that, starting with BLM Director Bob Abbey</em>."<br /><br />"Article Two, Section 4, of the United States Constitution states that "<em>The President, Vice President, and all Officers of the United States shall be removed from Office on Impeachment for, and Conviction of Treason, Bribery, or other High Crimes and Misdemeanors</em>."<br /><br />International Fund For Horses then goes a step further by providing citizens and advocates alike an easy-to-follow, step-by-step guide to initiating <a href="http://www.horsefund.org/"><span style="color:#cc6600;">Impeachment proceedings</span> </a>against BLM Director Abbey.<br /><br />At a time when the BLM is extending its hand with promises of reform, why should those who are trying to implement change demand the Impeachment of Director Abbey?<br /><br />I'll tell you why.<br /><br />BLM has been promising reform and using their bureaucratic weight to generate these kinds of smoke and mirror tactics for decades now while our mustangs and burros have suffered and continue to suffer with no end in sight.<br /><br />How bad is it?<br /><br /><br /><strong>HISTORICAL</strong><br /><br />> After the Wild Free-Roaming Horse and Burro Act was passed to protect America's wild horses and burros from harassment, capture, branding and death, between 1971 and 1980 the BLM allowed over 69,000 animals to be taken off the range by private individuals claiming them as their own.<br /><br />> In 1986, 20,000 horses went to large-scale adopters and were sold to slaughter or abused as a result of weakened adoption standards, fee waiver programs and sanctuaries used as fronts for commercial exploitation; many of these while still owned by BLM employees.<br /><br />>In 1992, Michael Blake funded and organized an <a href="http://6336543617382734190-a-1802744773732722657-s-sites.googlegroups.com/site/americanherds2/Home/american-herds-docs/CensusSlashesBLMWild-HorseCount_KeithRogers_1.pdf?attachauth=ANoY7crUjh8u9e4llqq36vwHjdc8SMpFhjiRbStZuguzbEkRdAY3m6m5UFp5aSFVZY2gHbKNVfdgo8jzxG6H-OHPx8z_ggDGoDFmELv2rw2AiEWhX6z6g_EygDVZhDs0EW9EZ10g5gJFi4vZzZSP6lfEJB9RGf-EhWWPl9AtIFkr80lC7ta_dk0KaIepqFM9-eOriOLKG6kIM8mxVUltpC1blWz3LEqzm8hi0FB82mvRT0nGLB-Jab0YyvucKEIlWncb0w_kFhDKA3PCpZbLjlfdvbgpvjMMm_njjneogXnXomgjCStRzO4%3D&attredirects=1"><span style="color:#cc6600;">independent census</span> </a>of wild horses in Nevada conducted by the Public Lands Resource Council. At the time, the BLM was reporting over 33,000 wild horses were on Nevada rangelands but the independent found less than 8,300. The results of the census were dismissed by BLM officials based on the assertion that BLM used a superior method to count the animals via helicopter while the independent census used a fixed wing aircraft. Today, BLM is making "progress" on new census techniques using fixed wing aircrafts.<br /><br />> In 1992, an investigation by BLMs own law enforcement officials resulted in the accumulation over 3,000 pieces of evidence being compiled about what amounted to little more than a highly organized horse-to-slaughter trade run by the BLM now known as <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1ZTMzMWRhMDE2YTZkNzg5&pli=1"><span style="color:#cc6600;">Del Rio</span></a>. The DOI, Department of Justice and Office of the Inspector General were all implicated in a large-scale cover up at the highest level through a systematic dismantling of a Grand Jury convened to try the DOI for alleged crimes. After the successful shut down of the investigation and trial proceedings, those involved in uncovering the truth about the BLM's Wild Horse and Burro program pleaded with then Attorney General Janet Reno to re-open the case. This request was denied.<br /><br />> In 1997, Associated Press reporter Martha Mendoza began a series of articles filled with investigative research exposing more corruption within the DOI's BLM, which touched off a <a href="http://www.igha.org/BLM.html"><span style="color:#cc6600;">firestorm of press</span> </a>about the Program.<br /><br />>In 1998, a Congressional Field Hearing before the Subcommittee on National Parks and Public lands regarding <a href="http://commdocs.house.gov/committees/resources/hii50579.000/hii50579_0.HTM"><span style="color:#cc6600;">Range Issues And Problems With The Wild Horse And Burro Act</span></a>, which current BLM Director Abbey attended, quotes Congressional representative Faleomavaego raising the question: "<em>And is it true that some 32,000 horses cannot be accounted for since we implemented this program?"</em> Mr. Abbey failed to answer the question nor was an investigation ever initiated to determine their fate.<br /><br />> In efforts to placate public outrage, the National Wild Horse and Burro Advisory Board was re-established after a lengthy hiatus. Predominately stacked with those who had glaring conflict-of-interest, staunch pro-BLM supporters were reappointed time and time again as the list of their recommendations justified each new step in extinction of the herds that continues unabated to this day. Public requests for investigations and removals of Board members were denied.<br /><br /><br /><strong>THE NEW MILLENNIUM<br /><br />></strong> In March 2000, a Senate Subcommittee on Energy and Natural Resources held a hearing where long-time National Wild Horse and Burro Advisory Board member Larry Johnson submitted a statement in concert with BLM urging support for a mass cleansing campaign of wild horses and burros throughout the West under the "Restoration of Threatened Watersheds" proposal. Wild horses and burros, not livestock, were cited as one of the top three threats to watersheds in the West. The official testimony has since disappeared but was preserved <a href="http://mckatie.wordpress.com/2008/03/09/statement-of-larry-johnson-nevada-bighorns-unlimited/"><span style="color:#cc6600;">HERE</span></a> and was instrumental in launching the largest removal campaign of wild horses and burros since the passage of the Act, which is still ongoing today.<br /><br />> After four years of massive removals, Senator Conrad Burns slips an eleventh hour amendment in an Omnibus Appropriations Act, without public notice or review, which allows the unlimited sale of our American heritage. BLM officially launches the legal sale of wild horses and burros to undisclosed individuals, a practice that continues today. The original language of the For Sale Authority clauses were found in a <a href="http://americanherds.blogspot.com/2007/11/year-of-horse-part-i.html"><span style="color:#cc6600;">Nevada strategy document</span> </a>and linked to Nevada Senator Harry Reid. The majority of both advocates and citizens now consider the secret sales of wild horses and burros a legitimate function of the BLM and rarely call for its immediate repeal.<br /><br />> Over the next decade the BLM continues to remove wild horses and burros at record levels while simultaneously reducing appropriate management levels and accelerating the elimination of habitat without accountability or review. As the costs of warehousing the now captured animals' skyrockets, in 2008 the BLM announces the Program is broke and they no longer have the funding to feed the animals. Euthanasia of tens of thousands of animals is proposed and strategies are developed to kill wild horses and burros <em>en mass</em> and sterilize the remaining herds in documents titled <a href="http://www.equinewelfarealliance.org/uploads/BLM.Team.Euth.FOIA_Cover.letter.pdf"><span style="color:#cc6600;">BLM Team Conference Calls</span> </a>and <a href="http://4701694131163205874-a-1802744773732722657-s-sites.googlegroups.com/site/americanherds4/ah-docs-1/BLM-HorseAltManagementOptions.pdf?attachauth=ANoY7crw0SdCdl_PZIMrIAmxwa5eltxlA4IQOajCDCOSVkW5H4Vk4kIjFtP0qSAG7gcY_UTHRmQjPKXw6LWizkuH2ISQGtkE-RM5KN5dIIzCdOnGA4-uNnM0v9KWW89Z1m5Vp9umKM0dvzJpVNUap81of3a1pt-XfUwz5ZoJwOx8GYaGXO5mrHyPTSgpyvAUFl05LsroFYjZGp_nPuveFXnKxDftX62JXWxrIj3P9eNtAHkvUc2k00k%3D&attredirects=2"><span style="color:#cc6600;">Alternative Management Options</span></a>.<br /><br />> In response to the BLM's declaration of considering mass disposal of America's wild horses and burros, Congress orders the Government Accountability Office (GAO) to review of the BLM's Wild Horse and Burro Program and answer questions about the status of the land that has been removed from wild horse and burro use. The GAO comes back with a report <span style="color:#663333;">that freely admits the majority of the information and data used to compile </span><a href="http://www.gao.gov/new.items/d0977.pdf"><span style="color:#cc6600;">the report</span> </a>has not been independently verified by the GAO. Instead, the GAO relies on BLM survey data to evaluate the Program and issue their conclusions and recommendations based on BLM personnel responses. With respect to questions surrounding the large scale habitat loss, again the GAO defers answers to BLM instead. After three years, the BLM has still failed to provide a comprehensive overview of the lands status and there has been no independent review as to the accuracy of BLMs summary reports.<br /><br />> In response to Congressional demands for reform in September 2009, newly appointed Secretary of the Interior Ken Salazar responds with <a href="http://www.blm.gov/wo/st/en/info/newsroom/2009/october/salazar_seeks_congressional.html"><span style="color:#cc6600;">a new initiative</span> </a>a month later. A long-time cattle rancher with strong ties to the oil and gas industry, Salazar presents a vision that utterly fails to challenge the culture of corruption and history of abuse by pushing for so-called reforms that merely continue the trend of decimating America's herds.<br /><br /><br /></div><div align="justify"><strong>CURRENT</strong><br /><br />> In 2008, <a href="https://rtfitch.wordpress.com/2011/02/15/wild-horses-blm-backs-off-plan-to-zero-out-west-douglas-herd/"><span style="color:#cc6600;">U.S. District Judge Collyer rules the DOI/BLM has exceeded its authority</span> </a>by issuing decisions to declare all wild horses in the Colorado based West Douglas Herd Management Area as "excess" and zero the area out. After the ruling, the BLM proceeds to issue a bushel basket full of new Resource Management Plans that continue to eliminate at least 2 million acres of previously designated habitat and schedule the removals every wild horse and burro they can find.<br /><br />> In September 2009, the BLM launches <a href="http://www.thecloudfoundation.org/index.php/news-events-a-media/press-releases/101-press-release-planned-destruction-of-clouds-herd-please-distribute"><span style="color:#cc6600;">a roundup</span> </a>of the Pryor Mountain wild horses and The Cloud Foundation is instrumental in catapulting public awareness of the plight of the American mustang and burro into the spotlight. BLM responds to increases in public scrutiny by closing off public lands to conduct their activities and BLM Field Manager Jim Sparks tells the public, "<em>This is not a democracy</em>".<br /><br />> In December 2009, the BLM signs the decision to launch the largest wild horse removal operation of the year in the Nevada based Calico Complex. The public submits over 10,000 comments with questions about the legality of BLM's environmental review process, discovers recent increases in cattle authorizations and that the BLM <a href="http://americanherds.blogspot.com/2009/12/blm-photo-2004-warm-springs-hma-wild.html"><span style="color:#cc6600;">buried testimony and data</span></a> from their own rangeland specialist to justify the removals. <a href="http://www.idanews.org/ida-breaking-news/calico-wild-horse-lawsuit-05-24-2010/"><span style="color:#cc6600;">A lawsuit</span> </a>is filed by Bill Spriggs on behalf of In Defense of Animals, who argues that long-term holding is illegal. While the judge agrees this is most likely the case, the BLM moves operations on private land to keep the public at bay and almost 1,900 animals are removed before a verdict is rendered; the case loses on a technicality and answers about long term holding are left answered.<br /><br />> Advocates and citizens attempt to gain access to wild horses removed from Calico and are greeted by a barrage of law enforcement escorts and restrictions. Despite this, over 100 horses are <a href="http://www.wildhorsepreservation.org/pdf/death-report.pdf"><span style="color:#cc6600;">reported as dead</span> </a>as a result of the removals including known miscarriages and aborted foals. <a href="http://humaneobserver.blogspot.com/2010_01_01_archive.html"><span style="color:#cc6600;">Citizen based photos</span> </a>and <a href="http://artandhorseslauraleigh.wordpress.com/video-documentation/"><span style="color:#cc6600;">videos of the reality of roundups</span> </a>gain national media exposure and the BLM begins to scramble to find ways to justify how roundups are humane.<br /><br />> In June 2010, the BLM hosts <a href="http://www.thecloudfoundation.org/index.php/news-events-a-media/press-releases/382-media-advisory-workshop-meeting-and-public-protest-in-denver"><span style="color:#cc6600;">a public forum</span> </a>led by hired <a href="http://www.thecloudfoundation.org/index.php/news-events-a-media/press-releases/383-spindr"><span style="color:#cc6600;">spin-doctors</span> </a>to sell the Salazar Initiative. This event will culminate in the newly released strategy document referred to above, which coincidentally found three main topics worthy of consideration out of 9,000 public comments, two of which are almost identical to Salazar's new vision.<br /><br />> In July 2010, the BLM again closes all public lands during the Tuscarora roundup and is greeted by <a href="http://www.animallawcoalition.com/wild-horses-and-burros/article/1394"><span style="color:#cc6600;">a lawsuit</span> </a>by Laura Leigh and Gordon Cowan demanding public access. After filing a request for an injunction, the BLM suddenly announces the wild horses are dying of thirst and a BLM emergency response team is created to provide testimony to the judge. As a result, the judge rules in favor of the BLM and the horses are removed with little to no independent scrutiny.<br /><br />> In response to evidence of inhumane treatment and allegations of illegal activities, Congress sends <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1ZTFlMDQ1MzY4MzZiMzI3&pli=1"><span style="color:#cc6600;">a letter</span> </a>to BLM requesting a moratorium on the roundups and urges the initiation of a study by the National Academy of Science (NAS) to review the Program. Secretary Salazar and BLM Director Bob Abbey ignore the request and the roundups continue. While BLM did agree to a review of the program by NAS, signs are already becoming visible that the study will have strict controls on what it will be allowed to review and just last month, BLM refused to upload the prior NAS studies online for public access. (That's assuming NAS will actually be awarded the contract as it is currently up for <a href="https://www.fbo.gov/index?s=opportunity&mode=form&id=342aa6473b5f0f2628338dd558147061&tab=core&_cview=0"><span style="color:#cc6600;">Solicitation of Bid</span> </a>and may be awarded to another contractor based on a "<em>viable response</em>".)<br /><br />> On December 3, 2010, the BLM releases what it hails as an "<a href="http://www.blm.gov/wo/st/en/info/newsroom/2010/december/NR_12_03_2010A.html"><span style="color:#cc6600;">Independent Observers Report</span></a>" on the methods and procedures used to remove wild horses from public lands. Questions surface as to the allegiance of the observers and their "independent status" due <a href="http://horsebackmagazine.com/hb/archives/5191"><span style="color:#cc6600;">to long-standing ties</span> </a>to the BLM's National Wild Horse and Burro Advisory Board and <a href="http://www.wildhorsepreservation.org/news/?p=2800"><span style="color:#cc6600;">pro-horse slaughter industry supporters</span> </a>comprising the team.<br /><br />> On December 13, 2010, the DOI Office of the Inspector General (OIG) releases a report extolling the virtues of Secretary Salazar's initiative and asserts that roundups are humane and necessary. Though OIG inspections are generally conducted at the request of officials, the OIG reports they initiated the inspection themselves due to public concerns. Evidence of <a href="http://americanherds.blogspot.com/2011/01/report-two-congress.html"><span style="color:#cc6600;">a whitewash</span></a> surfaces one month later and suggests the large scale cover ups of the 1990's attributed to the DOI's OIG are ongoing. At the same time, a collaborative effort by advocates release an alternative report based largely on BLM published information and data that outlines the potential fraud and abuse of the Program and urges for the <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0NDFiYzY0NzRlYTU5YjU3&pli=1"><span style="color:#cc6600;">Defunding of Roundups</span> </a>through 2012. In response, the BLM ignores the report.<br /><br />> In January/February 2011, a coalition of advocates document and film multiple abuses of helicopter techniques used to drive wild horses to trapsites in the Antelope Complex in Nevada. ("<a href="http://www.thecloudfoundation.org/index.php/news-events-a-media/press-releases/563-release-2411"><span style="color:#cc6600;">Antelope Roundup a Disaster for Wild Horses</span></a>" by The Cloud Foundation, <a href="http://rtfitch.wordpress.com/2011/01/31/pictorial-essay-of-obamas-wild-horse-stampede-at-antelope-complex/"><span style="color:#cc6600;">"Pictorial Essay of Obama's Wild Horse Stampede at Antelope Complex"</span></a> by R.T. Fitch/Straight From The Horses Heart, "<a href="http://blog.grassrootshorse.com/2011/02/antelope-complex-wild-horse-roundups.html"><span style="color:#cc6600;">Antelope Complex Wild Horse Roundup's Final Days - Heavily Pregnant Mares and More Horse Abuse by Contractor</span></a>" by Herd Watch/Grass Roots Horse, "<a href="http://www.wildhorsepreservation.org/news/?p=3381"><span style="color:#cc6600;">Antelope Complex Ends With 1,368 Mustangs Captured</span></a>" by American Wild Horse Preservation Campaign).<br /><br /></div><p align="justify">> The <a href="http://www.blm.gov/pgdata/etc/medialib/blm/wo/Communications_Directorate/public_affairs/news_release_attachments.Par.63904.File.dat/AntelopeReport.pdf"><span style="color:#cc6600;">BLM reviews</span> </a>the Antelope Complex roundups, contractors, methods and treatment exposed by citizens to address allegations of impropriety. The BLM clears itself and the contractors of any significant wrong-doing.<br /><br />> Less than a month later, the BLM unveils its new plan and strategy for the future of America's Wild Horses and Burros filled with the same old rhetoric, misleading statements and craftily presented alternative "solutions". Promises of BLM's proposed reforms supported by well-heeled government lackeys ring hollow, both to America's wild horses and burros, as well as within every page of the strategy itself.<br /><br /><br />THE DOI AND BLM HAVE BEEN ALLOWED TO OPERATE THE WILD HORSE AND BURRO PROGRAM WITH VIRTUALLY NO ACCOUNTABILITY TO ANYONE BUT THEMSELVES AND THOSE WHO DEPEND ON GOVERNMENT SALARIES OR ARE CONNECTED TO GOVERNMENT STRINGS.<br /></p><div align="center"><br /><strong>THIS IS A LONG STANDING TREND<br />THAT HAS CIRCLED ITSELF REPEATEDLY<br />AND MUST BE STOPPED!<br /><br />AMERICA'S WILD HORSES AND BURROS NEED MORE<br />AND THEY MUST HAVE MORE<br />NOW!<br /><br />PLEASE VISIT<br />THE INTERNATIONAL FUND FOR HORSES WEBSITE TO<br />DOWNLOAD THE IMPEACHMENT PETITION<br />AND<br />SHARE IT WITH YOUR FRIENDS.<br /><br />IT'S TIME TO DEMAND ACCOUNTABILITY - NO MORE EXCUSES!<br /><br />DO IT TODAY! </strong><br /><br /><br /><strong><a href="http://www.horsefund.org/"><span style="font-size:180%;color:#ff0000;">CLICK HERE<br /></span></a></strong></div>Unknownnoreply@blogger.com7tag:blogger.com,1999:blog-4562357749295999770.post-13735499989838178842011-02-18T13:09:00.000-08:002011-02-18T13:11:22.775-08:00Thanks For Listening<div align="justify">Amy Hadden Marsh, publisher and producer of "<em>From Western Colorado</em>", recently aired a radio documentary titled "<em>Wild Horses Caught in the Crossfire</em>" on KDNK Community Radio in Carbondale, Colorado.<br /><br />Probing one of the most fundamental questions in how America's mustangs and burros are managed, she describes the focus of the documentary as:<br /><br /><em>"Over the past year, From Western Colorado looked into how the Bureau of Land Management, which oversees most mustangs and burros, counts the herds. The following radio documentary shows that after nearly 40 years, BLM still can't get the numbers right and some believe this could lead mustangs to extinction."<br /><br /></em><a href="http://amyhm.wordpress.com/2010/12/29/documentary-mustang-tally-or-how-the-blm-counts-wild-horses/"><span style="color:#cc6600;"><strong>Click Here</strong></span> </a>to listen to what "<em>From Western Colorado</em>" found.... </div><br /><a href="http://2.bp.blogspot.com/-hnpmlyW0aY4/TV7fr6uml8I/AAAAAAAACN4/EGP9ppm0jJM/s1600/Lone%2BHorse_North%2BStillwater_June%2B2007.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 265px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5575139334323345346" border="0" alt="" src="http://2.bp.blogspot.com/-hnpmlyW0aY4/TV7fr6uml8I/AAAAAAAACN4/EGP9ppm0jJM/s400/Lone%2BHorse_North%2BStillwater_June%2B2007.jpg" /></a>Unknownnoreply@blogger.com1tag:blogger.com,1999:blog-4562357749295999770.post-63513428438841010502011-01-22T15:41:00.000-08:002011-01-22T16:32:21.891-08:00REPORT TWO CONGRESS<div align="justify">Last month, Congress received two reports about the Department of Interior (DOI), Bureau of Land Management’s Wild Horse and Burro Program. One report was compiled by advocates and one report was compiled by the Office of the Inspector General’s Office (OIG), Department of the Interior division (yes, that means the DOI/OIG answers to the Secretary of the Interior).</div><br /><div align="center"><strong><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0NDFiYzY0NzRlYTU5YjU3&pli=1"><span style="color:#3333ff;">Report To Congress Regarding:<br />The Wild Horse and Burro Program, BLM/DOI,<br />Refuting FY2011 Budget Justifications and<br />Request To Defund Roundups and Removals<br />Through Appropriations for FY2011 and FY2012<br /></span></a></strong><br /></div><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/TTtWdkF99wI/AAAAAAAACNk/zw8a9Mez1r8/s1600/Report%2BTo%2BCongress_Cover%2BPg.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 294px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5565136830451283714" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/TTtWdkF99wI/AAAAAAAACNk/zw8a9Mez1r8/s400/Report%2BTo%2BCongress_Cover%2BPg.jpg" /></a> <div align="justify">With respect to the advocates report above, I have been told the following information – though must confess – I cannot verify a single bit of it.<br /><br />Advocates had been in communication with Senator’s aides regarding their concerns about the BLM Wild Horse and Burro Program for well over a month prior to the reports release in early December 2010. The focus of these communications centered around not allocating the BLM any more money for roundups during the appropriations process that funds government budgets.<br /><br />During this phase of the interaction, they were told by aides that they were very excited about seeing what evidence and proof the advocates could bring to the table and were anticipating its completion.<br /><br />On December 1, 2010, the report was finally released to Congress and the Senate. Daily phone calls were made for over two weeks, requesting feedback, urging aides to read and verify the information, requesting information and status on the appropriations process, trying to find out information about the Senate Subcommittee on Interior, Environment and Related Agencies, which Senator Feinstein chairs, and getting concrete answers as to when the Subcommittee had reviewed the BLMs Wild Horse and Burro Program’s budget in 2010.<br /><br />And guess what happened after the Congressional and Senator aides received the report?<br /><br />Nothing….. The aides fell silent. Phone calls were no longer returned, emails not answered, and nobody could or would answer questions as to why the Senate never even looked at the BLMs WH&B Budget once throughout the entire fiscal year. The few responses that were received all said the same thing, “<em>What does Feinstein’s Office say</em>”? Apparently, Senator Feinstein has been holding the financial keys to the wild horse and burro kingdom and has now become the Pied Piper for the rest of the Senate and staff….<br /><br />So, with no response from “our representatives”, the report was sent to at least 150 various news agencies and media publications. And guess what happened? Nothing…. Not one media outlet ever responded or even suggested they looked at the information in the report.</div><div align="center"><br /><br /><strong><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1MDAxMWY2ZGI5YWUzMGZj"><span style="color:#3333ff;">DOI/Office of the Inspector General:<br />Bureau of Land Management, Wild Horse and Burro Program<br />Report No.: C-IS-BLM-0018-2010</span></a></strong><span style="color:#3333ff;"><br /></span><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/TTtWpoWtyyI/AAAAAAAACNs/LqUYc49_7kw/s1600/OIG%2BReport_Cover%2BPg_12-13-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 306px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5565137037753699106" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/TTtWpoWtyyI/AAAAAAAACNs/LqUYc49_7kw/s400/OIG%2BReport_Cover%2BPg_12-13-10.jpg" /></a><br /><div align="justify">On December 13, 2010, the OIG released their report on the BLM Wild Horse & Burro Program. While the public will now find the OIG report plastered on every BLM website hailing its “findings” about the Wild Horse and Burro Program, which support in every possible instance both BLMs actions and overwhelming support for Secretary Salazar’s new initiative to decimate America’s herds, what the DOI won’t be telling the public about is what happened before the release of their final report.<br /><br />The information posted below is an effort to increase transparency about what occurred behind the scenes of the OIG report. Granted, the information is very limited and should be considered a starting point towards an investigation to uncover the truth, if such an animal even exists in the halls of D.C. anymore.<br /><br />It contains direct copies of emails received by me from the OIG during the time of their Inspection as well as personal notes regarding phone calls, information received second hand from others also involved during this process as well as some of my own comments and/or conclusions about what it all may mean.<br /><br />So without further ado, let the stripping of the whitewash begin…..<br /><br /><br /><strong>SENATOR DIANE FEINSTEIN<br /></strong>On February 9, 2010, I was contacted by a group of advocates and concerned citizens wanting my help in assembling a case to submit to the OIG’s office regarding the ongoing abuse and corruption occurring by the DOI in relation to the Wild Horse and Burro Program and multiple-use.<br /><br />This group stated that they had met with Senator Feinstein’s office in San Francisco and had a meeting with her head aide in California, James Molinari. They relayed that Mr. Molinari said “<em>that the office would facilitate a query to the Office of the Inspector General</em>” and “<em>They agreed to help us with this</em>”, and finally, “<em>We are invited to submit a list of questions and concerns and products of research to support an investigation</em>.”<br /><br />I never saw any official communication from Feinstein’s office nor from Mr. Molinari that verified these statements were true. However, I have no reason to believe that those involved in this request fabricated it out of thin air. As a result, I sent a long list of information, links and documents to be forwarded to those coordinating this effort. I never received a concrete follow up from any of those within this group as to what they did with it, what response was received by Feinstein’s office, if any, or how this effort eventually ended.<br /><br />In August, 2010, an advocate unrelated to the original group relayed to me that they had heard Feinstein’s Office had requested the OIG investigation. As a result, they asked James Molinari if this was true and Mr. Molinari denied Feinstein’s office had requested an OIG investigation.<br /><br /><br /><strong>THE FBI<br /></strong>On June 21, 2010, I filed a complaint with the Federal Bureau of Investigation (FBI) regarding all the complexities surrounding the Calico Complex wild horse removals. The focus of the complaint centered around reports that the BLM had removed approximately 400-500 more wild horses than they were authorized to remove and were now illegally auctioning off non-excess animals. I equated this with the unauthorized stealing of public property.<br /><br />During my interview with the FBI, I was asked why I was submitting the complaint to the FBI instead of DOI law enforcement officers. To this, I responded, “<em>Because the DOI has historically shown they are incapable of policing themselves and an outside, independent investigation needs to be conducted</em>.”<br /><br />I never heard from the FBI again, even though I sent a follow up request inquiring about the status of my complaint.<br /><br /><br /><strong>THE OIG<br /></strong>The following is the complete series of email correspondence between myself and Loralee Bennett, Deputy Regional Audit Manager, Department of the Interior, Office of the Inspector General.<br /><br /><br /><strong>JULY 28, 2010<br /></strong>I began communication with Loralee Bennett at the DOI Office of the Inspector General due to an email she initiated as a result of filing a complaint with the FBI. The following is Ms. Bennett’s correspondence.<br /><br /><strong>Sent:</strong> Wednesday, July 28, 2010 10:42 AM<br /><strong>Subject:</strong> Inspection of Bureau of Land Management’s Wild Horse and Burro Program<br /><br /><em>Ms. MacDonald,<br /><br />You filed complaints with the Federal Bureau of Investigations on the Bureau of Land Management's Wild Horse and Burro Program on June 21, 2010.<br /><br />Based on a Congressional Request, we opened an Inspection of that program on May 25, 2010. As a result, your complaint was forwarded to me for review as part of our overall Inspection. To get a better understanding of your concerns, we would like to set up a time to talk with you. In addition, we're interested in obtaining any additional information, documents, studies, etc. that you'd like us to take into consideration as we conduct our Inspection.<br /><br />I've included all my contact information below and I look forward to hearing from you.<br /><br />Thank You<br />Loralee Bennett<br />Deputy Regional Audit Manager<br />DOI / OIG Central Region<br />134 Union Blvd, Suite 510<br />Lakewood CO 80228<br />Voice: (303) 236-924x<br />Direct: (303) 236-913x<br />Mobile: (505) 249-151x<br />Fax: (303) 236-821x<br />Loralee_Bennett@doioig.gov<br /><br /></em><br /><strong>JULY 29, 2010<br /></strong>I sent Ms. Bennett the following unedited response:<br /><br /><strong>Sent:</strong> Thursday, July 29, 2010 11:23 AM<br /><strong>Subject:</strong> Re: Inspection of Bureau of Land Management’s Wild Horse and Burro Program<br /><br /><em>Dear Loralee-<br /><br />Thank you for contacting me regarding my concerns about the BLM Wild Horse & Burro Program and I appreciate the opportunity to share them with the Office of the Inspector General.<br /><br />Regarding scheduling a time when we can discuss these issues, I will make myself available any day next week, beginning Monday, August 2, 2010, from 12:00 p.m. p.s.t. through 3:00 p.m. p.s.t. Please pick a time that is equally convenient for you during this time frame and I will confirm.<br /><br />With respect to submitting additional documents, studies, data, etc., I have a vast amount of information I could potentially share with the OIG, so much so that I am concerned it could overwhelm you and/or your staff.<br /><br />Consequently, in order to best streamline our efforts and time, perhaps you could better define the purpose of the Inspection and what types of information you are seeking to help me narrow the scope of your interests.<br /><br />Also, I have a specific concern I would like you to address prior to any submissions, just so I am very clear as to what happens and the resulting status of any information submitted to the OIG.<br /><br />Based on my understanding of what happened last time the OIG was involved in an Inspection of the WH&B Program, the DOI/BLM was able to use the OIG Inspection as a blanket reason to withhold information from the public about their activities, evoking some sort of clause about not being able to disclose information until the investigation was complete.<br /><br />For the record, I have seen no evidence of the DOI/BLM doing this so far.<br /><br />However, I am working on a variety of issues affecting wild horses and burros and do not wish to compromise my ability to obtain additional information due to “partial” submissions to the OIG that could possibly result in an informational “lockdown” by DOI/BLM.<br /><br />Therefore, please address the issue of potential impacts, if any, of submitting information, data, documents, etc. to the OIG and either confirm or deny the possibility that the DOI/BLM may be able to use your Inspection of a particular subject as reason to withhold information from the public about their activities until the Inspection is complete.<br /><br />Finally, I would like to know the current deadline for submitting information and the approximate time frame the OIG is projecting they will release the results of the Inspection.<br /><br />The relevance of this question is, I was also involved in submitting information during the GAO inquiry in 2008. During the GAO process, they stopped accepting any additional input around May and spent the next three months preparing their report.<br /><br />Having a sense of how much information the OIG can absorb and sincerely review will give me a better idea of what to submit so as not to waste our time.<br /><br />For now, I have attached a few items for your review and consideration.<br /><br />Thank you again for contacting me and am looking forward to talking with you.<br /><br />Sincerely,<br />Cindy MacDonald<br /><br /></em><br /><strong>AUGUST 3, 2010</strong><br />Loralee sent the following unedited response. It was no longer addressed to me personally as two other advocates were now included in the correspondence, nor did she ever again reference speaking with me personally about my concerns that initiated the FBI complaint or address any of the questions I had posed above.<br /><br /><strong>Sent:</strong> Tuesday, August 3, 2010 7:48 PM<br /><strong>Subject:</strong> OIG Meeting on Wild Horse and Burro Program<br /><br /><em>The OIG has scheduled a meeting to hear concerns about BLM's Wild Horse and Burro Program and to obtain copies of any documents, studies, pictures, or other supporting documentation that individual's would like to share. The meeting is scheduled for:<br /><br />When:<br />Monday<br />August 23, 2010<br />from 10am -1pm<br /><br />Where:<br />Belmar Library<br />555 S Allison Parkway<br />Lakewood City Commons<br />Lakewood CO 80226<br /><br />If you have any questions, please let me know.<br /><br />Thanks,<br />Loralee Bennett<br />Deputy Regional Audit Manager<br />DOI / OIG Central Region<br />134 Union Blvd, Suite 510<br />Lakewood CO 80228<br />Voice: (303) 236-924x<br />Direct: (303) 236-913x<br />Mobile: (505) 249-151x<br />Fax: (303) 236-8211<br />Loralee_Bennett@doioig.gov<br /><br /></em><br /><strong>AUGUST 3, 2010<br /></strong>I immediately responded to Ms. Bennett’s newest email by sending the following:<br /><br /><strong>Sent:</strong> Tuesday, August 3, 2010 7:56 PM<br /><strong>Subject:</strong> Re: OIG Meeting on Wild Horse and Burro Program<br /><br /><em>Dear Loralee-<br /><br />Does this mean that you are no longer interested in setting up a time to talk with me about my concerns – unless I can fly to Colorado to meet you personally?<br /><br />Sincerely,<br />Cindy MacDonald<br /><br /></em><br /><strong>AUGUST 17, 2010<br /></strong>The next correspondence received by Ms. Bennett now included a handful of additional individuals and various organizations known to be involved in wild horse and burro advocacy and/or issues.<br /><br /><strong>Sent:</strong> Tuesday, August 17, 2010 7:13 AM<br /><strong>Subject:</strong> Inspection of BLM’s Wild Horse and Burro Program – and Meeting Cancellation<br /><br /><em><strong><span style="font-size:130%;">First ...<br /></span></strong>Michael Golembeski of the WindDancer Foundation provided me with each of your e-mail addresses and requested that I contact each of you related to our ongoing inspection of BLM's Wild Horse and Burro Program. I know I have e-mailed many of you, and spoken with a few of you on the phone, about concerns that you have with the Program (and I do have 3 phone messages I need to return). However, for some of you, this may be the first time you've heard from me so let me give you a little background. Based on an e-mail from a Senator's staffer and pending legislation, our IG decided to implement an inspection of BLM's Wild Horse and Burro Program. We are looking at every phase of the Program as it currently operates (visiting HMAs, attending gathers and adoption events, visiting both short term facilities and long term pastures, etc.) as well as evaluating the "studies," "science," and "other" support behind its current policies and procedures. While we are both (1) talking with BLM and reviewing the documentation, studies, etc. that it has and (2) performing as much independent research as possible, we want to be as fair, objective, and inclusive as possible. Therefore, we are also interested in hearing from each of you about any studies, research reports, scientific papers, etc. that you're aware of that provide insight into either how BLM currently operates - or how you think BLM should operate - the Program. We would also be interested in any suggestions you might have about improving the Program. Any such information and/or recommendations you'd like OIG to review and/or consider can be e-mailed to me at the address below.<br /><br /></em><em><strong><span style="font-size:130%;">Second ...<br /></span></strong>Unfortunately, we need to cancel the meeting we had scheduled in Denver CO for August 23. Despite being forced to cancel the meeting, we are VERY interested in your perspectives and in reviewing any documentation, studies, etc. that you have to ensure that we have the most complete and accurate picture of the Program as possible. We need to cancel the meeting because, as we enter the end of the fiscal year and face a possible continuing resolution, several competing priorities have arisen that have required us to take a serious look at what work can and cannot be completed on numerous ongoing reviews. Our priority on this Inspection is to attend as many gathers and visit as many holding facilities as possible in the time we have remaining to complete this inspection. Additionally, these competing priorities have required me to be in Washington DC extensively over the last several weeks (hence the reason I owe 3 of you return phone calls). I had thought I'd be back in Denver the week of August 23rd but, these trips to Washington DC are expected to be required until at least mid-September. Therefore, unfortunately, we have no one available to conduct a meeting before our report is scheduled to be completed.<br /><br />Thank you in advance for any information you can provide that will help us ensure this report is the most complete and accurate assessment of the Program possible. Given my extensive travel schedule and multiple priorities, it is often difficult to contact me on the phone. Therefore, the best way to contact me is via e-mail. Each day (sometimes not until mid-night but ...) I do my best to get through all the e-mails I received that day - something I can't always do with phone messages.<br /><br />Sincerely,<br />Loralee Bennett<br />Deputy Regional Audit Manager<br />DOI / OIG Central Region<br />134 Union Blvd, Suite 510<br />Lakewood CO 80228<br />Voice: (303) 236-924x<br />Direct: (303) 236-913x<br />Mobile: (505) 249-151x<br />Fax: (303) 236-8211<br />Loralee_Bennett@doioig.gov<br /></em><br /><br /><strong>AUGUST 19, 2010<br /></strong>I responded to Ms. Bennett’s email with the following:<br /><br /><strong>Sent:</strong> Thursday, August 19, 2010 6:44 AM<br /><strong>Subject:</strong> Re: Inspection of BLM’s Wild Horse and Burro Program – and Meeting Cancellation<br /><br /><em>Dear Loralee-<br /><br />Thank you for this additional info and update.<br /><br />Based on the information you have provided, I feel compelled to ask:<br /><br />How is it that the IG is expected to perform a thorough review of the complex and long standing issues concerning the Wild Horse & Burro Program when it is obviously understaffed and given too short of a deadline to accommodate a serious and in-depth investigation? Or is that perhaps the plan - to prevent an in-depth investigation from occurring?<br /><br />In my last email communication, I had asked you to address the issue of "the scope" of what the IG was mandated to review so that I would not inundate you with information that fell outside the parameters of the investigation.<br /><br />However, since this response seems to cover "everything", then that is what I will submit.<br /><br />I apologize in advance if these submissions may prove to be a bit overwhelming - but I have been studying this Program, day and night, for over four years now and have accumulated quite a bit of information that may have relevance.<br /><br />I will also try to organize them as best as possible but due to the sheer volume of documents I would like to submit, some may come in rather rag tag due to time constraints.<br /><br />Sincerely,<br />Cindy MacDonald<br /><br /><br /></em>From this point on, I submitted multiple documents, links, reports and information to Ms. Bennett totaling nineteen emails beginning on August 19th through 31st, 2010. A complete list of what I sent the OIG is included at the bottom of this post.<br /><br /><br /><strong>AUGUST 20, 2010<br /></strong>I received a "group" email from an advocate who introduced herself as Susan addressed to myself and others involved in wild horse and burro issues. Susan alerted us to the fact that the OIG was conducting an Inspection of the WH&B Program. The following quotes received during her alert have been edited for relevance.<br /><br />“<em>I have learned today that the OIG is preparing another investigation into the issue of inhumane handling by BLM, but they must amass a body of evidence---video, photos, testimony of observers, etc. and this must be submitted ASAP. They want the report ready for Sept. Mr Kris Kolesnik, associate inpector general for External Affairs, is the man I spoke with. He said no one has to have any 'professional' standing i.e. be a vet or official, just have personal or photographic documentation</em>”.<br /><br />“<em>Please, any of you I am writing, send whatever you have for conducting this expose' on BLM's lack of humane treatment. I am just a interested horse advocate, but I know the damning lack of scientific data to back up their claims and the exposure of their methods of handling are the weak spots to attack”.<br /><br /></em>“<em>Mr Kolesnik is doing a lot of stuff with the Gulf Oil spill indictment, too….Kris_Kolesnik@doioig.gov. This is the contact man.”<br /></em><br /><br />Because of this information, I also forwarded each email sent to Loralee about the Wild Horse and Burro Program to Kris Kolesnick as well. I also followed up by calling Loralee to ask for confirmation as to whether another Inspection had been initiated merely to focus on the gathers and humane treatment or if this was the same investigation that had been opened on May 25, 2010. I left a voice message and requested either a return phone call or an email to answer this question. I received no response.<br /><br />Throughout this process, Michael Golembeski of the <a href="http://www.wind-dancer.org/"><span style="color:#cc6600;">Wind Dancer Foundation</span> </a>and I communicated rather frequently about progress, questions and information related to the OIG Inspection. According to Michael, Deputy Bennett and he communicated quite regularly as well. He relayed to me around the end of August, early September that the OIG was in the process of completing their report and it was expected to be released before the end of the fiscal year, which would be on or before September 30, 2010. Michael’s information matched what Susan had said; the OIG intended for their report to be ready by September.<br /><br />As a result, I saw no further reason to send the OIG any additional information as, Loralee had already stated on August 17th that, “<em>Our priority on this Inspection is to attend as many gathers and visit as many holding facilities as possible in the time we have remaining to complete this inspection.”<br /></em><br />What these two pieces of information said to me was,<br />a) no matter what I had sent, the OIG didn’t have any time to review the information anyway so it was just a waste of time on my end and,<br />b) they were going to spend their remaining time in the field and not actually auditing the Program.<br /><br />I saw Ms. Bennett’s request for information as outlined in her last email - despite admitting they would not make its review a priority - as just a way for the DOI to get the advocates attention away from more meaningful work and to see what advocates might be holding in terms of information that the DOI could develop a counter strategy too.<br /><br />According to Michael, in the last phone communication he had with Deputy Bennett, she relayed that the OIG had begun to review the BLMs new Wild Horse and Burro Policy Manual and had run into some problems. What they were, she didn’t say. From this point on, Loralee became inaccessible and never returned his phone calls or emails again.<br /><br />Throughout September, Michael checked the OIG website and each day, no report was posted. As we now know, it wouldn’t be released for over two more months – just days before Congress and the Senate were to vote on the BLMs Wild Horse and Burro Program’s budget and whether they were going to give Salazar millions to purchase private lands for the Salazoos.<br /><br /><br /><strong>SEPTEMBER 29, 2010<br /></strong>This was the last and final communication from Ms. Bennnett, which included Michael, one other advocate and three individuals with oig.gov email addresses. It stated:<br /><br /><strong>Sent:</strong> September 29, 2010 1:08 PM<br /><strong>Subject:</strong> Wild Horse and Burro Program Inspection<br /><br /><em>With all the additional work associated with the Special Assignments put on my desk, management of the Wild Horse and Burro Program Inspection has been transferred from Central Region to our Western Region Office. Therefore, any questions on the Wild Horse and Burro Program Inspection should be directed to either the Western Region Regional Manager (Mike Colombo) or the Western Region Deputy Regional Manager (Chuck Wiebe). The number at the Western Region is (916) 978-565x.<br /><br />Thanks,<br />Loralee Bennett<br />HQ Operations, Special Assignments<br />Loralee_Bennett@doioig.gov<br /><br /></em><br /><strong>THE FOLLOW UP<br /></strong>From here, Michael reported he contacted the Western Region Office personnel provided by Loralee’s email. While I cannot verify this personally, Michael relayed to me that his contact with them was greeted by both surprise and criticism as they stated he was not to contact an OIG inspector directly. The Western Region then referred him to a Public Affairs Specialist in Washington D.C., to which all future public communication would be funneled.<br /><br />When Michael asked why the Inspection had suddenly been transferred to the Western Region, the response was something to the effect of, “<em>The Inspection was always being conducted by the Western Region and Loralee was just a point of contact.</em>” As to Michael’s concerns that everything formerly sent to Ms. Bennett was also included in the Western Region Office Inspection, he was assured all information had been received and would be considered.<br /><br />On December 13, 2010, the DOI/OIG publicly released their long awaited report. Instead of following the general outline described by Deputy Bennett in prior communications, which was to include all phases of the Wild Horse and Burro Program, what the pubic got was an official propaganda piece extolling the virtues of Salazar’s new Program and the parroting of an overpopulation problem that continues to be unsupported by the BLM’s own records and statistics.<br /><br /><br /><strong>THE FOIA OFFICE<br /></strong>According to the OIG, in the first page of their report titled, “Memorandum” and addressed to BLM Director Bob Abbey, the OIG’s “<em>objective was to determine if wild horse and burro gathers are necessary and justified, and if wild horses and burros are being mistreated</em>.”<br /><br />The “objective” now seemed a far cry from what its original purpose was as previously outline by former lead, Deputy Regional Audit Manager Loralee Bennett, whose last communication now sported a new title of “Head Quarters, Special Assignments”.<br /><br /><br /><strong>JANUARY 18, 2011<br /></strong>So in efforts to try and nail down a definitive answer to these two conflicting stories, I submitted a Freedom of Information Act Request (FOIA) to the DOI OIG requesting the source document of who initiated the Inspection.<br /><br /><strong>Sent:</strong> Tuesday, January 18, 2011 08:36 PM<br /><strong>Subject:</strong> FOIA Request<br /><br /><em>Dear FOIA Officer:<br /><br />This is a FOIA request for information related to the Office of the Inspector General, U.S.Department of Interior, Bureau of Land Management, Wild Horse and Burro Program,Report No.: C-IS-BLM-0018-2010, released December 2010.<br /><br />The specific request is limited to only include the document(s) or email communication(s) identifying the source of who officially requested an investigation be initiated into the BLM WH&B Program, including the date of submission, as well as their description of the parameters to be covered in the investigation.<br /><br />This request is being submitted by:<br />Cindy MacDonald (personal information has been deleted)<br /><br />Due to the limited size of the request, most likely spanning merely one or two documents and/or emails, it is believed this request will fall within the fee waiver parameters. However, if not, the fee I am willing to pay is up to $30.00 dollars.<br /><br />Also, I would prefer this request be provided in electronic format but will accept any format that is compatible with supplying the requested information.<br /><br />Upon receipt of this FOIA request, please provide a FOIA response number to the email address listed above.<br /><br />If you have any questions or issues you'd like to discuss, please feel free to contact me at any of the above provided contact information.<br /><br />Thank you.<br /><br />Sincerely,<br />Cindy MacDonald<br /><br /></em><br /><strong>JANUARY 19, 2011<br /></strong>The next day, the following response was received by the DOI/OIG FOIA Office….<br /><br /><strong>Sent:</strong> Wednesday, January 19, 2011 7:32 AM<br /><strong>Subject:</strong> FOIA Request<br /><br /><em>Good Morning Ms. MacDonald,<br /><br />I have received your FOIA request in which you state you are seeking a "specific request is limited to only include the document(s) or email communication(s) identifying the source of who officially requested an investigation be initiated into the BLM WH&B Program, including the date of submission, as well as their description of the parameters to be covered in the investigation." Normally with an investigative report there is a specific complainant that we use to justify an investigation, this particular report happens to be an audit report which was a general response to public outcry. Therefore there isn't a specific event, for example a singular letter, phone call, or e-mail that started this process.<br /><br />If there is anything else I can help you with please do not hesitate to contact me. For your convenience the link below will bring you to our electronic copy of the audit report you seek.<br /><br />http://www.doioig.gov/images/stories/reports/pdf//BLM%20Wild%20Horse%20and%20Burro%20Program%20Public.pdf<br /><br /><br />Thank you,<br />Patrick L. O'Boyle<br />Program Analyst<br />Office of Inspector General<br />Department of the Interior<br />(703) 487-544x<br />Patrick_O'Boyle@doioig.gov<br /><br /></em><br /><strong>A COVER UP?<br /></strong>So there it is.<br /><br />According to Loralee’s first email communication, the Inspection was initiated based on a Congressional request. She further added at a later time that the Inspection was, “<em>based on a Senator’s staffers email</em>”.<br /><br />Was that staffer James Molinari of Senator Feinstein’s Office? Senator Feinstein was the Chair of the Subcommittee responsible for overseeing the BLM WH&B Program and budget allocations, so it seems logical to me that she has a direct interest in obtaining a review by the OIG. And maybe that would explain why she never brought the budget issues of the WH&B Program to the floor once for discussion throughout 2010 - because she was waiting for its results first.<br /><br />But Mr. Molinari denied Senator Feinstein’s Office initiated the investigation. So who WAS the Senator’s staffer that requested this Inspection Deputy Bennett referenced?<br /><br />But now, it would appear that the DOI/OIG FOIA Office is denying the existence of either a Congressional request or a staffers email, claiming this was their own idea, a response to “public outcry”, and finally, that the parameters of the Inspection were only limited to the necessity of roundups and humane treatment.<br /><br />Well, based on what limited evidence I have seen, here is what I think the evidence points too.<br /><br />James Molinari DID submit a query to the OIG as indicated by the group of advocates in February 2010. This resulted in an Inspection being officially opened in May that Loralee attempted to revolve around the parameters she originally outlined; the whole WH&B Program was on the table for review.<br /><br />As information began coming in, Interior Secretary Salazar and various high ranking officials began blocking the Inspection, piling on additional workloads on Loralee in efforts to bury her, began manipulating the Inspection from behind the scenes and finally, took it out of her hands completely and transferred it to the more “friendly” Western Region. Here the process began of doctoring the OIG report to read like a Salazoo advertisement now officiated by “expert review".<br /><br />Why would James Molinari deny the Inspection was initiated by Feinstein? Well, maybe one of those famous Congressional deals was struck at the back of the House. Salazar gives Feinstein what she wants and Feinstein turns her head regarding both the budget and the OIG Report. There is currently a lot of DOI related proposals on the table in California….<br /><br />Perhaps it even went so far as a calculated strategy that always intended to assemble an official story strongly supporting the Salazar’s Initiative that would be strategically released just days before Congress and the Senate was to vote on the 2011 Budget. No time for advocates to counter that, right? And once BLM gets their money – no strings attached - well, sorry folks, but the roundups will still continue…<br /><br />Did this really happen? Did a conspiracy occur behind the scenes of this report to whitewash the truth, tamper with the Inspection and prevent a real audit of the Wild Horse and Burro Program? Go back and read these emails again and you tell me what YOU think happened here.<br /><br />Is this enough evidence to indicate an investigation should be opened regarding the DOI/OIG’s handling of this affair? And if so, who investigates the investigators?<br /></div><br /><div align="center"><br /><br /><strong>Submitted to the DOI Office of the Inspector General<br />Documents, Links and Information<br /><br />July 29, 2010<br /></strong>America's Mustangs and Burros: Summary: Alternative Populations Overview-Revised<br />The Wild Horses of Wyoming: A Tale of Tallies<br />The Jackson Mountains Wild Horses: A Case Study In The Mismangement of the BLM's Wild Horse & Burro Program<br /><br /><br /><strong>August 19, 2010<br /></strong>WH&B Capture Status Report<br />Facility Codes – Updated 10/15/07<br />Article: Dead of Winter<br />PEER: Horses to Slaughter – Anatomy of a Cover Up<br />America’s Mustangs and Burros: Appendix III<br />America’s Mustangs and Burros: Inflated Populations – Update 2004-2009<br />Article: Horse Rustlers: How Scam Artists Abuse a Federal Adoption Program for Wild Horses<br />Gold Butte Field Trip 2001<br />Gold Butte Key Monitoring Sites (KMS) Summary Photo Doc. 2007<br />2006 Gold Butte Capture Status Report – Draft<br />2007 Gold Butte Capture Status Report – Draft<br />Gold Butte Post-Gather Report 2007<br />Dr. Russ Mason, Chief Game Specialist, Nevada Department of Wildlife 6/04/08<br />Bob Ross, BLM Las Vegas Field Manager, Public Scoping Concerns, 5/05/10<br />NPS/BLM MOU: Lake Mead NRA 2005<br />Gold Butte Herd Management Area Plan (HMAP) Preliminary 2008<br />Gold Butte Census History 2005-2007<br />Lake Mead Complex Final Gather Environmental Assessment NV-052-2007-69, March 2007<br />BLM Post-Gather Report, March 2007<br />OIG: Burros II - Muddy Mountains HMA Document<br />Letter from California Senator Feinstein, 9/20/05<br />Threats to Desert Tortoise Populations: A Critical Review of the Literature, USGS, 2005<br />Clark Mountain Herd Management Area/Herd Area, Decision Record and Finding of No Significant Impact (FONSI) for the Clark Mountain Herd Areas Burro Removal, Fiscal Years 2007-2012, CA-690-EA04-27<br />Wild Burros of the American West: A Critical Analysis of the National Status of Wild Burros on Public Lands – 2006<br />Director Pool-First Letter, Clark Burro Response, 5/31/07<br />Protest Letter to BLM California State Director, 6/16/07<br />Director Pool-2nd Ltr, Denial of Analysis, 7/10/07<br />BLM State Wild Horse and Burro Lead Amy Dumas, Clark Mountain Burro Population, 6/01/09<br />Statement of Range Conditions: Ivanpah Valley, Laura Cunningham, 8/25/09<br /><br /><br /><strong>August 20, 2010<br /></strong>Map of August 2008 Caliente Field Office “Emergency Wild Horse Gather”<br />Wild Horse Herd Management Areas in the BLMs Ely District<br />Acreage Comparisons Prior To The New 2008 Resource Management Plan (RMP)<br />Wild Horse Herd Management Areas in BLMs Ely District Prior To The New 2008 Resource Management Plan (RMP)<br />Ely Districts New 2008 Wild Horse Herd Management Areas<br />Letter From BLM Nevada State Director Ron Wenker, June 13, 2007<br />Wild Horse Herd Management Areas in BLMs Ely District Prior To The New 2008 Resource Management Plan (RMP): Livestock Allotments<br />2005/2007 Ely District Wilson Creek: Grazing Allotment Key Numbers Legend, Pastures and Authorized Use<br />Interior Board of Land Appeal (IBLA) 172 IBLA 128<br />Protest Letter Submitted to BLM Re: Ely Resource Management Plan, December 29, 2007<br />Ely Protest_Supplemental_5-15-08<br />Dunn_RMP Interested Party List_2-22-07 (Email Communication)<br />Ely Response_Ben Noyes_No HMA Legal Description_1-13-08<br />Request for Documentation_BLM Director Abbey_9-29-09<br />Ely_FLMPA_BLM Response Lt_12-16-09<br /><br /><br /><strong>August 21, 2010<br /></strong>BLM California National Herd Statistics Fiscal Year 2004<br />BLM Surprise Field Office: Massacre Lakes Rangeland Health Assessment (RHA) 2010<br />Massacre Lakes Monitoring Evaluation Report 4/6/10<br />BLM California WH&B Lead Amy Dumas Email Comm. 8/04/09<br />CO_Sand Wash Gather_BLM Article_11-05<br />Sheepherder Springs Grazing Allotment_11-05-08<br /><br /><br /><strong>August 23, 2010<br /></strong>NWHBAB_PC_CRM_6-10-09<br />Solicitation of Opinion_NWHBAB_Use of Helicopters<br />NWH&BAB-Board Recommendations-7-25-07<br />WHB Planning & Strategy_CRM_PC_7-29-10<br />SOWH Point paper-1<br />AHDF_Salazar Plan_Pro-Con_10-21-09<br /><br /><br /><strong>August 27, 2010<br /></strong>Article: BLMs National Adoption Day (with Supporting Comments)<br />Article: Doing Everything We Can<br />Article: Serious Concerns<br />Article: BLM Budgets<br />Article: No Animal Police For Them<br />America's Mustangs & Burros: What's Left, The High Cost of Miscalculating and Will They Survive? Part II, Financial I. pg. 35.<br />Nevada Commission for the Preservation of Wild Horses, April 7, 2005 Meeting Minutes.<br /><br /><br /><strong>August 28, 2010<br /></strong>Article: For Everything Else<br />Article: The Thriving Natural Ecological Balance<br />The Thriving Natural Ecological Balance Report<br />Elk Management in 5 Western States (Montana, Wyoming, Idaho, Colorado, and Utah)<br />Nevada's Mule Deer, Population Dynamics: Issues and Influences by Tony Wasley<br />Nevada's Pronghorn Antelope: Ecology, Management and Conservation by George K. Tsukamoto 1983, First Revision Edited<br />NOTE: The 1999 Lincoln County Elk Management Plan is too big of a file to provide via email.<br /><br /><strong>August 31, 2010</strong><br />Article: Buried, American Herds, posted<br />BLM Winnemucca Wild Horse & Burro Specialist Glenna Eckle Court Testimony<br />BLMs Response to 1994 Protests of SMA FMUD<br />Article: Calico: Past, Present and Future. Part I-The Past<br />Article: Calico: Past, Present and Future. Part II<br />Public_Calico Complex_Request For Stay_12-18-0<br />IBLA Stay Granted To BLM_CM_TCF_1-13-10<br />RS_Motion To Dismiss_IBLA_2010-46_1-13-10<br />Appellant Response_Standing-Separate Appeal_1-22-1<br />IBLA_Calico Complex_Final Ruling_2-04-10<br />Soldier_Meadows_Preliminary_EA-5-07-07<br />NC_Soldier Meadows Allotment_Proposed Decision_7-11-07<br />Soldier Meadows_FONSI_1-14-08<br />Soldier_Meadows-BiologicalAssess_2007<br />Article: Calico: Past, Present and Future. Part V<br />Article: On Da Take<br />Draft Ruby Pipeline Migratory Bird Conservation Plan<br />Confidential Draft: Greater Hart-Sheldon Conservation Fund Agreement </div></div>Unknownnoreply@blogger.com4tag:blogger.com,1999:blog-4562357749295999770.post-1923628947025992262010-12-27T15:35:00.000-08:002011-01-06T12:16:32.172-08:00The Iron Curtain<div align="justify">Hey Bob, I thought about titling this post to you. I thought you might want to know. At first, I toyed with Dear Bob or Dear Director Abbey or something that would speak directly from one interested stakeholder to your ears, but as you can see decided against such a simple framing for the massive subject I wanted to tackle.<br /><br />See Bob, I’ve been a little busy examining your Program statistics again, combing through BLMs FY2011 Budget Justification report to Congress and making a few graphs of my own.<br /><br />I spent a month working with some great gals, Carla Bowers and Leslie Peeples, in trying to figure out ways to summarize one, giant oozing festering mess – something BLM and their support team are markedly proficient in coating with Teflon©.<br /><br />It’s an alternative perspective on the Wild Horse & Burro Program that uses almost exclusively the BLMs own publications and numbers to make its case to Congress about why you need to be cut off from any more money until some real answers are coughed up or you are allowed to peddle your sugar coated solutions based on a foundation of non-credible data and lies. If you haven’t already seen it, you can check the <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoyYzFiNGRmZDRlOTI1NmIz"><span style="color:#cc6600;">"Report to Congress: Refuting FY2011 Budget Justifications and Request to Defund Roundups and Removals Through Appropriations For FY2011 and FY2012" here</span></a><span style="color:#cc6600;">.<br /><br /></span>So as you might imagine Bob, I was a little busy when <a href="http://www.united-horsemen.org/summit-of-the-horse/featured-speakers/"><span style="color:#cc6600;">Sue Wallis & Co.’s Slaughter Summit</span> </a>agenda came out announcing you and other key BLM personnel and associates were invited guest speakers.<br /><br />I also wasn’t able to pay too much attention to your <a href="http://www.blm.gov/wo/st/en/info/newsroom/2010/december/NR_12_03_2010.html"><span style="color:#cc6600;">national public response</span> </a>now posted on the front page of BLMs website explaining why you have tentatively accepted the invitation because you are so “fair and balanced” as to meet with such diverse stakeholders – that now include a high dollar conference comprised of the Who's Who of the horse slaughter industry.<br /><br />After all, while BLM will post every letter of support, agreement and enthusiastic applause for BLMs actions by any group or agency who often has glaringly apparent conflicts-of-interest with wild horses and burros on public lands, <a href="http://www.blm.gov/wo/st/en/prog/wild_horse_and_burro/national/news.html"><span style="color:#cc6600;">“our” public website</span> </a>stays curiously silent, some would say almost censored, of any voice, argument or document that challenges or refutes what the BLM does.<br /><br />Which reminds me, will the BLM be posting our report on the Wild Horse & Burro website too so everyone can see what some of the "other" issues are because you are so “fair and balanced” towards all diverse stakeholders?<br /><br />So now I've finally made a little time to see what you’ve been up to and I’ve have a few questions for you Director Abbey.<br /><br />A few weeks ago, I sent an email to you and a whole list of key BLM employees expressing my concerns about a <a href="http://www.blm.gov/nv/st/en/fo/battle_mountain_field/blm_information/newsroom/2010/december/blm_to_begin_callaghan.html"><span style="color:#cc6600;">BLM Press Release </span></a>for the Callaghan/New Pass/Ravenswood roundup.<br /><br />Here is the portion of the Press Release I take issue with,<br /><br /><em>"NDOA brand inspectors must verify the animals are wild horses and burros as defined by the Wild Free-Roaming Horses and Burros Act of 1971. Once verified, the brand inspector will provide the BLM a certificate to transport the animals".<br /><br /></em>See, this is kind of a problem because it’s deceptive and reminiscent of one of the oldest tricks in BLMs sending-wild-horses-to-slaughter books. You remember, how BLM had been conspiring with state agriculture agency's or turning their heads so brand inspectors could send tens of thousands of wild horses to meat packing plants by citing state jurisdiction over federal law during the first years after the passage of the Wild Free-Roaming Horse and Burro Act?<br /><br />You do remember that, don’t you? It’s in your <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3YTM4YTc5YmY2NWQxMjBh"><span style="color:#cc6600;">own statistics.</span></a> How almost 70,000 horses counted as roaming free on the range were “privately claimed” between 1971 and 1980. You know, those “non-wild” horses who were carted off to slaughter due to new found private status, thanks to state brand inspectors working in “close coordination” with BLM personnel.<br /><br />So, I’m sure you remember this as well, how a big legal battle developed and the courts had to decide who was actually responsible for making the determination of what qualified as a wild horse/burro. And the courts said it was you Bob, the authorized agent of the Secretary, who had jurisdiction and ultimate responsibility to make that determination. If the state brand inspectors couldn’t verify the animals were privately owned, they fit the definition of a wild free-roaming horse and burro and were entitled to protection under federal law.<br /><br />Remember, I sent you those links to the federal court cases, <a href="http://scholar.google.com/scholar_case?case=16187787553954338267&q=Sheridan+v.+Andrus&hl=en&as_sdt=2000000002&as_vis=1"><span style="color:#cc6600;">American Horse Protection Institute v. US DOI (1977)</span></a> and <a href="http://scholar.google.com/scholar_case?case=2988783390674394657&q=Sheridan+v.+Andrus&hl=en&as_sdt=2000000002&as_vis=1"><span style="color:#cc6600;">Sheridan v. Andrus (1979)</span></a> that clearly outlined how state agriculture agencies jurisdiction only extended to verifying animals did not have brands, bills of sale or sufficient evidence to establish private ownership.<br /><br />See, it appears that BLM and Nevada Department of Agriculture (NDoA) recently pulled this jurisdictional shell game last June with respect to the <a href="http://equinewelfarealliance.org/uploads/Toano_Wild_Horse_Herd_Area.pdf"><span style="color:#cc6600;">Toana</span></a> “wild” a.k.a. the <a href="http://www.equinewelfarealliance.org/uploads/Pilot_Valley_estray_horses_FINAL.pdf"><span style="color:#cc6600;">Pilot Valley “feral/estray”</span></a> horses as each agency batted the ball back and forth until a “compromise” was reached. Finally, NDoA “verified” for BLM how those horses were not “wild” in the most suspicious manner possible in order to sell them at state livestock auction - but I’ll explain how that happened a little later in this post.<br /><br />Well anyway Bob, you didn’t bother to reply, much less address my concerns. In fact, neither did BLM Wild Horse and Burro Chief Don Glenn, BLM Nevada State Director Ron Wenker, Nevada Wild Horse and Burro Lead Alan Shepherd or Tony Lesperance of Nevada Department of Agriculture.<br /><br />However, I did get a phone call from the local field office promising to get back with me about my concerns but we ended up playing phone tag for so long that BLM re-issued the same statement again in the Clan Alpine round up press release; I guess I should consider that BLMs response.<br /><br />After all, BLM needs NDoA to issue a certificate of transport, right? Except I can find no such authority in the <a href="http://www.leg.state.nv.us/nrs/nrs-561.html"><span style="color:#cc6600;">Nevada Revised Statutes</span> </a>(NRS) requiring BLM to verify the status of a wild horse/burro with NDoA or needing NDoA to issue BLM a certificate to transport them.<br /><br />Given the historical abuses that have occured with state brand inspectors and how Congressional testimony during the passage of the Act clearly expressed <em>grave concern</em> about the lax and sometimes conflicted interest states had with respect to the livestock industry, I find it curious that neither you nor your authorized agents charged with protecting wild horses and burros nor NDoA itself didn’t feel this was important enough to respond to, couldn't be bothered to provide the NRS provisions supporting your newest press release statements about NDoA's power, or didn't feel the need to share any cooperative agreements granting NDoA this sort of jurisdiction over federally protected animals.<br /><br />Which leads me to the Slaughter Summit you will be speaking at - but I have to confess, I’m kind of confused. See, I thought the BLM was charged with protecting wild horses and burros from that kind of crowd, commercial exploitation and all. It’s all the BLM ever says, “<em>We don’t sell horses for slaughter</em>”, so I’m a little confused why there’s a veritable cornucopia of BLM’ers listed on the Horse Slaughter Industry’s Summit agenda.<br /><br />By the way Bob, you do know that American horsemeat is tainted and dangerous for human consumption but these people promote their own pocketbook at the expense of those who eat it anyway, don’t you? Could it be that is why you think the BLM and the horse slaughter industry is a perfect match? Do you think Sue & Co might be interested in acquiring mustang meat free of the drugs given to domestic equine?<br /><br />Tell me something, Bob. Before you decided to tentatively accept an invitation to Ms. Wallis’s shindig, did you ask her why she came out of nowhere and has made the commercial exploitation and slaughter of wild horses one of her number one goals in all she publishes, says and does?<br /><br />So this leads me to my next question. When BLM conducted the free and public forum in Denver last summer to discuss “management solutions”, Sue was there and never missed an opportunity to bring up wild horse slaughter as a humane and fiscally responsible alternative to BLMs primary management tool of roundups and removals. Except in the public forum, BLM’s MC poo-pooed Ms. Wallis and told her this kind of solution was neither appropriate nor on the table for discussion (pardon my pun).<br /><br />Yet here we sit just six months later and while you couldn't bother to make a guest appearance at the "free" public dog and pony show packed with "diverse stakeholders" interested in the Wild Horse & Burro Program, now Bob, you are going to personally speak at Sue’s Slaughter Summit. What’s that about? So what makes her and her cohorts so special and above the public arena? The privacy from prying public eyes? The fact that what you say will be "off the record"? Are you getting a fee for your attendance on top of your taxpayer funded salary that legitimizes your "expertise"? Or is this highly controversial and clear conflict of interest sales pitch going to allow you to meet "key" contacts over salsa in order to coordinate better with Secretary Salazar's "new direction"?<br /><br />So just to try and summarize how this works (and please feel free to set me straight if I have something wrong):<br /><br />If I attend a public forum on discussing wild horse and burro management, BLM will tell those trying to bring horse slaughter to the table that it's not appropriate and will not be allowed. But if I want to be part of the Slaughter Summit to hear what you have to say, to hear what other BLM and BLM affiliates recommend, I’m going to have to cough up $300-400.00 dollars to hear a discussion that BLM refused to allow in the “public arena” nor did you feel was worthy enough to attend.<br /><br />And after I write my check to United Horseman in order to attend your presentation, it will be deposited in an account that will be used for the lobbying and promotion of commercial exploitation and slaughter of wild horses and burros.<br /><br />So tell me Bob, how is the presence of BLM employees and affiliates as public representatives not considered indirectly contributing money for the promotion of commercial exploitation and slaughter of wild horses and burros or a serious breach of the public trust?<br /><br />Which leads me to my next line of questioning. I have heard BLM say that if advocates have evidence of BLM selling horses for slaughter, come forward with the proof.<br /><br />With no access to long term holding facilities, limited access to short term facilities, armed guard access to roundups, humane observers limited to a handful at a time on hand picked days, closely guarded or set back at a half a mile or more away, (by the way Bob, what are we spending to protect you from us and our camera’s these last few years – I couldn’t find that in the budget info), blanket closure of public lands, refusal to disclose gather locations in advance, and discussions in the 2008 Team Conference Calls about how to block access by the media, the citizenry and Congress through secret locations and sealing the deal by justifying such secrecy from those attempting to ascertain the whereabouts of horses and burros by labeling them potential eco-terrorists, with all that going for you Bob, when exactly do you think the public will be able to “get proof” from behind the BLM’s Iron Curtain?<br /><br />One a side note, this also leads me to ponder; Bob, are you and other BLM personnel and affiliates worried about your safety at the Slaughter Summit? After all, there will definitely be people in attendance who do not support the BLM’s “humane treatment “ of wild horses and burros via non-slaughter, do not believe wild horses and burros have any place as integral components of the public lands and who feel the BLM is failing to be fiscally responsible. Will you and other BLM affiliates be shadowed by armed escorts to protect you from them like the BLM does to the general citizenry who advocate for lawful, transparent and humane treatment of wild horses and burros?<br /><br />But back to that “proof” thing of the BLM selling wild horses for slaughter. Let me start by saying, as soon as the BLM starts letting advocates follow the wild horses and burros from the roundup pens through transport and from short term to long term holding, maybe we will have a chance. But then again, the BLM seems pretty adamant about not letting the public in to anything but the most carefully controlled slices of “management” they have yet to privatize and even much of that, advocates are having to fight tooth and nail to get.<br /><br />Since you called advocates out on the issue of proving the BLMs selling wild horses to slaughter, I have to confess - you are right. I don’t have photos from start to finish showing BLM gathering horses, transporting or selling them to killer buyers with follow up shots of killer buyers transporting them and making the trek to Mexico or Canada with their carcasses finally hanging from a meat hook. Is that the kind of proof you mean, Bob?<br /><br />But here are some interesting tidbits I have been pondering for a while that may have relevance and maybe you can provide some answers to.<br /><br />First, check out these photos. These were taken last spring on Highway 395 through Carson City to Reno. They are official BLM horse haulers and the advocate that spotted them was surprised to see BLM suddenly in the horse hauling business with such brand new, shiny trucks.</div><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TQFqJppwfdI/AAAAAAAACMc/eD0gtM0BVZU/s1600/IMGP1080.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 301px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5548832929929526738" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TQFqJppwfdI/AAAAAAAACMc/eD0gtM0BVZU/s400/IMGP1080.jpg" /></a><br /><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TQFqPOV27GI/AAAAAAAACMk/ejdI7iC10_Q/s1600/IMGP1085.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 301px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5548833025677519970" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TQFqPOV27GI/AAAAAAAACMk/ejdI7iC10_Q/s400/IMGP1085.jpg" /></a><br /><div align="justify">So we submitted a Freedom of Information Act (FOIA) to try and find out when they were purchased, how much BLM spent, and where they were headed too. And guess what Bob? The FOIA came back with “no records found”. Yep, that’s right, they couldn’t find any records of BLM purchasing these shiny new trucks. Actually, that’s not totally correct as the FOIA did add they were able to confirm the purchase of <em>trailers </em>(not the trucks) were made through the Eagle Lake office in Susanville, CA and if we wanted the info, we’d have to resubmit the FOIA to them. Go ahead and check out the FOIA response <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0M2YwMDEyZDA0Y2E3NGQ2&pli=1"><span style="color:#cc6600;">HERE</span></a>.<br /><br />While the FOIA response wouldn’t provide any significant info on the BLMs purchases, if you look closely, you’ll find they were able to provide a little info on the Model# of the horse trailer, which just happened to be brand spanking new in 2008.<br /><br />Hey, Bob, wasn’t that the year the BLM announced they had such a money crisis that they were now considering euthanizing all our stockpiled wild horses? But ya got enough money to buy brand new shiny horse trailers and semi-trucks? Wow, who knew….<br /><br />I also wanted to bring your attention to something else that provoked a great deal of curiousity for me about that FOIA response saying the trailers were purchased by the BLM in Susanville, CA. See, if you look at this <a href="http://www.cybercyclemag.com/enthusiasts/new_vehicle_detail.asp?VehicleCode=75333&st=CA&submit=Go"><span style="color:#cc6600;">website's advertisement for Featherlite trailers</span></a>, it says in bold letters that there are no Featherlite dealers in California. So, wouldn't that mean BLM had to purchase them outside of CA? So why did the FOIA response say the purchase records are being kept in CA even though they had to have been purchased out of state?<br /><br />What the FOIA also wasn’t able to provide is info on where that truck was headed. It informed us that the BLM isn’t required to keep logs of the drivers and destinations because the license numbers were registered to stock trailers only.<br /><br />It seems BLM is exempt from reporting requirements because “<em>driving logs are not established or maintained for trailers</em>”. Wow, how amazingly convenient. Except those stock trailers were connected to semi-trucks with a big fat BLM logo on their side driving down a public highway that BLM couldn't/wouldn't provide any information on. I wonder what the Department of Transportation has to say about no logs required when BLM hauls horses on public highways...<br /><br />So this led me to wonder, when BLM hired the Cattoors to remove <a href="http://www.aowha.org/activities/pilot_valley_rescue01.html"><span style="color:#cc6600;">the Pilot Valley horses</span></a> last June from the “old” Toano Herd Area and then transferred them to NDoA, who in turn dumped them at an auction house where <a href="http://www.wildhorserescue.org/july10.htm"><span style="color:#cc6600;">Jill Starr of Lifesavers Rescue</span> </a>spent a fortune saving them from killer buyers, whose trucks were used to transport the “non-wild” horses from the pens to the auction; BLMs or Cattoors?<br /><br />I guess it doesn’t really matter though because either way, the BLM has freely admitted they were responsible for their removals while admittedly working in “close coordination” with NDoA during the whole operation.<br /><br />So this in turn raised a few questions for me as well and here’s why.<br /><br />Turns out, there was this girl who lived in Pilot Valley back in 2007/2008 named Crystal. She fell in love with all those “non-wild” horses there and discovered yet another big, festering mess that ultimately revealed BLM was planning on removing them in 2010. This upset her so much, she started a campaign and a blog to try and stop BLM from wiping out the bands. You can check out her blog <a href="http://www.freewebs.com/pilotvalleywildhorses/"><span style="color:#cc6600;">HERE</span></a><span style="color:#cc6600;"> </span>that chronicles her story.<br /><br />Well Bob, I wanted to make sure I drew your attention to the last blog post Crystal made. It's titled, "<a href="http://pilotvalleywildhorses.blog.com/"><span style="color:#cc6600;">Whose Jurisdication Are The Horses Under</span></a>"?<br /><br />According to Crystal, it appears that BLM first denied they were under their jurisdication while NDoA insisted they were BLM horses after all. After some "close coordination" due to Crystal's questioning, it seems a solution was found; BLM claimed them as "feral or estray" and NDoA backed BLM up by verifying they weren't really wild horses -despite no proof of private ownership or claims - and this would allow them to be sold at a commercial livestock auction.<br /><br />Just to refresh your memory Bob, you might want to re-read that first court case I sent you the link for as you will find an amazingly similar description of the Toana/Pilot Valley jurisdictional issues playing out over thirty years ago. See, "private claims" were made about horses that were released so long ago, no owner could be identified back then - just like BLMs recent claims about the status of the Toana Herd Area horses they allowed to be sold at private auction....<br /><br />And guess what Bob? You know what else Crystal did when she was trying to get to the bottom of that Toana/Pilot Valley mess? She actually went out and took lots of photos of the Pilot horses too. She even went so far as to make a video filled with a whole bunch of photos she labeled as the Pilot Valley bands.<br /><br />Apparently, she was a little upset because the BLM was telling her that they were going to remove them because they were starving and so she posted all these great photos of fat, shiny horses on the range to prove this just wasn’t true!<br /><br />So, I’ve taken the liberty of embedding Crystal’s video here so that you can get a really good look at the “non-wild horses” she included in her video back in 2008. Pay particular attention to all the wonderful colors some of these “non-wild horses” have as she asks if they look they are starving.<br /></div><div align="center"><object width="425" height="344"><param name="movie" value="http://www.youtube.com/v/XaWzqKRx8Gc?fs=1&hl=en_US&rel=0&color1=0x234900&color2=0x4e9e00"><param name="allowFullScreen" value="true"><param name="allowscriptaccess" value="always"><br /><embed src="http://www.youtube.com/v/XaWzqKRx8Gc?fs=1&hl=en_US&rel=0&color1=0x234900&color2=0x4e9e00" type="application/x-shockwave-flash" allowscriptaccess="always" allowfullscreen="true" width="425" height="344"></embed></object><br /><br /><div align="justify">Now, here’s a video of the Pilot Valley horses that showed up at the Fallon Livestock Auction last June. These are the same horses that BLM/Cattoor were responsible for removing from the Pilot Valley area that Crystal had been photographing two years before. Notice anything different about these horses?<br /><br /><div align="center"><object width="425" height="264"><param name="movie" value="http://www.youtube.com/v/Amt3WuvZwg4?fs=1&hl=en_US&rel=0&color1=0x5d1719&color2=0xcd311b"><param name="allowFullScreen" value="true"><param name="allowscriptaccess" value="always"><embed src="http://www.youtube.com/v/Amt3WuvZwg4?fs=1&hl=en_US&rel=0&color1=0x5d1719&color2=0xcd311b" type="application/x-shockwave-flash" allowscriptaccess="always" allowfullscreen="true" width="425" height="264"></embed></object><br /><br /><div align="justify">Not only is anything with color gone but anything that might have resembled a distinctive wild horse on the range disappeared by the time they hit the feedlot. Now I’ve pondered this quite a bit Bob, as I’m sure you can imagine, trying to figure out; why did so many of the horses in Crystal's video fail to show up at the Fallen livestock auction?<br /><br />Could it be that BLM missed them during the round up and they are still out on the range? Except, the BLM’s Herd Area statistics for 2009 reported 168 horses in the Toano Herd Area and 172 showed up at the Fallen Livestock Auction; the numbers are so damn close, it can’t really account for how the horses of color or resembling “wild” horses disappeared.<br /><br />I have to admit, I haven’t been able to figure this one out yet so maybe you could help me Bob. How would you explain the difference that Crystal attributes to Pilot Valley back in 2008 and those that showed up at the livestock auction a little less than two years later?<br /><br />And this in turn brings me to another subject I have been pondering that perhaps you could answer. It’s about some of the questions raised when a FOIA by the Conquistador Program produced a document now called the <a href="http://www.equinewelfarealliance.org/uploads/BLM.Team.Euth.FOIA_Cover.letter.pdf"><span style="color:#cc6600;">2008 Team Conference Calls</span></a>, which revealed candid discussions between BLM personnel while they were discussing ways to kill wild horses.<br /><br />Here are some of my most immediate questions in relation to the BLM and slaughtering wild horses that maybe you would graciously address.<br /><br />***What was the BLM’s Wild Horse & Burro Chief’s response to this email exposed in the 2008 Team Conference Call Report, which stated: “<em>Sally had an e-mail from a person in Canada who wants 10,000 horses that he would slaughter the horses and send them to a third world country. Don is going to send the e-mail</em>”.<br /><br />***Why did the BLM guy from Oregon, Jim Johnson say, “<em>Jim said he has a demand for horses going to Denmark, but they are having a problem getting titled horses</em>”? Why would a BLM employee have knowledge of and personally reference that HE has a demand for horses to ship to Denmark for slaughter?<br /><br />***What did the Team mean when they said, “<em>Having</em> <em>horses rendered would need to be done instead of selling horses to slaughter</em>”?<br /><br />But maybe you’ll address my concerns at Sue’s Slaughter Summit, eh? And then all I’ll have to do is cough up hundreds of dollars to hear your answer that will then be used to promote slaughtering the very animals you were put in charge of protecting against this sort of thing.<br /><br />Then there’s this other thing that has really been bothering me too. Now granted, I really haven’t had much time to go through every HMA available because the BLM is so busy issuing new proposals to remove/zero out wild horses and burros that I can barely catch my breath, but me and a friend were able to go over of some of them and this is what we found so far.<br /><br />I made this graph below by cross-referencing the BLMs National Gather Schedules for <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzMnxneDoxMTkzNjhjYjM0NTBiNjA0"><span style="color:#cc33cc;">2006</span></a>/<a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzfGd4OjNiMTlhMGUwMWYzZjZhNw"><span style="color:#3333ff;">2007</span></a>, which reports how many wild horses/burros the BLM publicly reported they removed in each Herd Management Area (HMA) during the roundups, with those same horses/burros found in the <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzM3xneDo3ZDk5ZDZiY2I5YTU0YzJh"><span style="color:#cc6600;">Capture Status Report</span> </a>that was crowbarred out of the BLM by a FOIA submitted by American Horse Defense Fund. (Note: While AHDF had requested info on ALL captured wild horses and burros, the BLM would only release this information for a nine-month period.)<br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TRfVAqTDRdI/AAAAAAAACMw/FgHgdfYxP8E/s1600/Capture%2BStatus%2BComparison%2BChart_11-23-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 226px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5555142872715707858" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TRfVAqTDRdI/AAAAAAAACMw/FgHgdfYxP8E/s400/Capture%2BStatus%2BComparison%2BChart_11-23-10.jpg" /></a><br /><br />Notice how the numbers don’t match? In fact, most of them look like they would just about fill a load for a horse trailer. You know, the one’s the BLM doesn’t have to keep logs of.<br /><br />But Bob, I’m sure you are not too worried because after all, all you have to say is, “<em>The BLM doesn’t sell wild horses to slaughter”</em> and that seems to be all the “proof” that is required by the BLM, unlike the general public who are held to a completely different standard of credibility.<br /><br />Since you will be busy getting ready to make your pitch at the Slaughter Summit and I won’t get to hear it because I refuse to contribute money to an organization that is aggressively pursuing the legalization of slaughtering horses, wild and domestic alike, maybe after you get a break in your busy schedule you could take some time to publicly explain to interested stakeholders such as myself –<br /><br />***Why wild horses the BLM reported as being removed from the range failed to make their way into the Capture Status Records.<br /><br />***Or better yet, why animals BLM failed to report they had removed ended up in holding facilities after all.<br /><br />But of course, that will just lead to more questions, wouldn’t it? Questions whose answers BLM will continue to try and deflect with public affairs specialists while hiding behind an iron curtain of a Program now run more like a classified military operation than a natural resource issue.<br /><br />And one last question Bob, since I have you on the line. Will you and <a href="http://americanherds.blogspot.com/2009/03/mustang-meat-patties.html"><span style="color:#cc6600;">Ms. Wallis</span> </a>be pleased when Salazar's "new direction" privatizes the Program and partners with organizations such as hers and neither of you will have to answer to the public anymore? </div></div></div></div>Unknownnoreply@blogger.com30tag:blogger.com,1999:blog-4562357749295999770.post-61280962964890840412010-12-03T16:44:00.000-08:002010-12-03T16:45:58.741-08:00Horse Photography: The Dynamic Guide<a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TPmNNzNHocI/AAAAAAAACMU/-jDkR90uLME/s1600/Horse%2BPhotography_CWalker.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 300px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5546619684306526658" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TPmNNzNHocI/AAAAAAAACMU/-jDkR90uLME/s400/Horse%2BPhotography_CWalker.jpg" /></a><br /><div align="justify">Carol Walker of <a href="http://www.livingimagescjw.com/"><span style="color:#cc9933;">Living Images</span> </a>and the author of the multi-award winning <span style="color:#cc9933;">“</span><a href="http://www.wildhoofbeats.com/order.html"><span style="color:#cc9933;">Wild Hoofbeats: America’s Vanishing Wild Horses</span></a><span style="color:#cc9933;">”</span> recently handed me her newest book, “<a href="http://www.livingimagescjw.com/photographer-carol-walker-shares-secrets-of-successful-horse-images"><span style="color:#cc9933;">Horse Photography: The Dynamic Guide for Horse Lovers</span></a>” and asked me what I thought.<br /><br />Well, to be honest, the only real talent I’ve discovered I have with respect to photography is an uncanny knack of taking great shots of my thumb! So, as you might imagine, a world-class photographer like Carol asking me for MY feedback about her new book came as a bit of a shock.<br /><br />It got worse too - but let me not jump ahead of the story here…<br /><br />So as always, the first thing that reaches out and riveted me was Carol’s unbelievably gorgeous photos. Stunning show horses, overflowing manes and tales, glistening coats, big, beautiful eyes, arching necks, gaits, stances, running, rearing, domestic horses, wild horses, you name it, she made sure to cover it all.<br /><br />But unlike your average coffee table book, which may or may not capture the magnificence and spirit Carol’s horse photography is renown for, there’s actually a purpose behind these photos and suddenly, I realized why I WAS the perfect person to get feedback from about this book – but I’ll get back to that shortly as well.<br /><br />The second thing that stirred me, once I could take my eyes off the photos, was the way she introduced the book. It was immediately apparent that she just absolutely loved horses, all horses, any kind of horse and this love had grown out of a working knowledge and understanding of these unique and special beings who are so inspirational to so many.<br /><br />It was the following quote that touched me deepest and in my opinion, epitomized the essence of the book:<br /><br />“<em>Why photograph horses? Because they fill my heart. Capturing them on film or digital allows me a way to express that relationship. It also gives me a way to show their spirit, their joy in life, and their beauty so that others can see it too</em>.”<br /><br />To simplify it even further, it was her explanation of how photography is a tool to express: The Relationship Between….<br /><br />Anyone who has developed a relationship with an animal knows exactly what she is saying here. As you spend time together, you learn about all their little quirks (and they, yours!), their likes and dislikes, crazy antics and definitive character. They make you laugh, uplift your heart, cause you to melt like butter when they strike that certain pose that is uniquely them and yes, even teach you a lot about yourself and the world around you. Let me also add as testimony to the power of the horse, those who have chosen equine companions and spent the time to develop a loving relationship with them are some of the most profoundly affected people I know!<br /><br />Simply put, that is the purpose behind Carol’s book; to show and share her relationship with equines and by extension, to help all of us formally condemned to a world of thumb shots to grasp the art and basic techniques for immortalizing the best of our companions and our relationships with them.<br /><br />“Horse Photography: The Dynamic Guide for Lovers” is amazingly simple, helpful, easy to understand, not overly technical and covered a wide range of topics. Through comparison photos, she shows what to do and what not to do, what to look for and how to adapt to situations such as unflattering environments, proper angles, lighting, backgrounds, horse color, how to bring out the best and what to avoid to prevent highlighting the worst.<br /><br />Which leads me to how things got worse from my thumb blocked world.<br /><br />I have to confess, twice I found myself looking at photos and thinking, <em>“Wow, what a cool shot. I really like the way it…..”</em> only to discover, it was a photo of what NOT to do! Oops!<br /><br />After the initial embarrassment was over, I couldn’t help but think, “<em>That was really clever</em>.” Why? Because she included photos of what might qualify to the untrained eye as a “good photo”. Then she clearly and simply explains why it failed to bring out the best of the subject and suddenly, I could see! Imagine that!<br /><br />That’s why I was the perfect person to have review this book and must say, it’s a great book. Not just because of the non-stop pages of vividly dynamic breath taking horse photos, but because it opened up a world of possibilities and offered easy to grasp tools that anybody can immediately use.<br /><br />Truly, this is a gift given from Carol to us; a gift of a lifetime of expertise, experience and knowledge generously shared and simply given to those who love horses.<br /><br />For those who just might find themselves wanting to learn how to capture their companions and inspirations through photographs that hone in on what the heart sees, I would highly recommend “<a href="http://www.livingimagescjw.com/photographer-carol-walker-shares-secrets-of-successful-horse-images"><span style="color:#cc9933;">Horse Photography: The Dynamic Guide for Horse Lovers</span></a>”, as you just can’t help but come away feeling inspired and confident that the world of framing “all things equine” is now within reach.<br /><br />For those who might be interested, there’s also a variety of outstanding special packages now being offered on her previous multi-award winning book, <a href="http://www.wildhoofbeats.com/order.html"><span style="color:#cc9933;">"Wild Hoofbeats: America's Vanishing Wild Horses"</span></a> that include The Cloud Foundation’s new 2011 Wild Hoofbeats Calendar showcasing the McCullough Peak wild horses as well as Screensavers, DVDs, Slideshows and lots of other cool wild horse stuff.<br /></div><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/TPmH_mrmeCI/AAAAAAAACME/ArahFt1eeQU/s1600/Wild%2BHoofbeats_2011%2BCalendar.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 175px; DISPLAY: block; HEIGHT: 175px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5546613942868408354" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/TPmH_mrmeCI/AAAAAAAACME/ArahFt1eeQU/s400/Wild%2BHoofbeats_2011%2BCalendar.jpg" /></a><div align="center"><span style="font-size:130%;"><strong>NEW<br />2011 Calendar<br /></strong></span><em>The Cloud Foundation </em></div><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/TPmJiM3ULcI/AAAAAAAACMM/MwrgdLdMxXY/s1600/Cloud%2BFoundation%2BLogo.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 319px; DISPLAY: block; HEIGHT: 192px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5546615636745268674" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/TPmJiM3ULcI/AAAAAAAACMM/MwrgdLdMxXY/s400/Cloud%2BFoundation%2BLogo.jpg" /></a>Unknownnoreply@blogger.com1tag:blogger.com,1999:blog-4562357749295999770.post-21812413539619122062010-10-30T13:59:00.000-07:002010-10-30T14:00:20.948-07:00THE FUDGE FACTOR<div align="justify">On July 9, 2010, the BLM issued a <a href="http://www.blm.gov/or/news/files/Tri-State_WHB_Inventory_Prelimary_Results_7-10.pdf"><span style="color:#cc6600;"><strong>press release </strong></span></a>announcing the results a massive aerial census called the Tri-State Survey. It’s purpose was to count wild horse populations over a two million acre area utilizing a new census method being developed by <a href="http://www.npwrc.usgs.gov/resource/wildlife/telemtry/white.htm"><span style="color:#cc6600;"><strong>U.S. Geological Survey</strong></span> </a>(USGS) in partnership with BLM over the last several years.<br /><br />The methodology uses several observers from different vantage points of the plane (or helicopter as the case may be), silently recording what they see individually and afterwards, the observers determines the reliability of their “sightability” by comparing notes to verifying accuracy of what each observer had seen in relation to what the other observers had seen for a cumulative total. This then becomes the basis for “animals missed” by one observer from another to determine the error rate of each individual observer from the total count.<br /><br /><br />“<em>This improved population survey methodology…incorporates peer-reviewed techniques that have been used for decades to estimate wildlife populations around the world</em>”. <div align="right"><span style="font-size:78%;">BLM Press Release #2010-22<br />July 9, 2010<br /></span><br /><div align="justify"><br />The direct “raw” counts of wild horses are then fed into a computer modeling software program called <a href="http://warnercnr.colostate.edu/~gwhite/mark/mark.htm#Introduction"><span style="color:#cc6600;"><strong>Program MARK</strong></span> </a>developed by Gary C. White and Kenneth P. Burnham of Colorado State University. The original paper used for scientific citation outlining MARKs capabilities was developed for a <a href="http://warnercnr.colostate.edu/~gwhite/mark/euring.PDF"><span style="color:#cc6600;"><strong>conference in 1997</strong></span></a> so I guess this must be the “decade” of peer-reviewed work BLM is now referring too.<br /><br />In reviewing the literature on Program MARK, it discusses how its parameters were created to estimate populations of wildlife survival rates based on marking an animal (such as a bird band or tag) and “re-encountering” the marked animal at a later date. MARK then incorporates multiple analysis of a variety of factors and data to determine a broad spectrum of potential possible outcomes with a strong focus on survival rates.<br /><br />Program MARK also seems to be a work in progress as the programmers have been adding additional options and fixing bugs in the software since 1998 with the most recent updates added in June 2010. It is described as “<em>a large, complex program, and in general it is not an application that can be learned by simply browsing the helpfile</em>.” The recommended starting point in beginning to grasp its application is a 800+ page (and growing) online book hailed as the “<em><a href="http://www.phidot.org/software/mark/docs/index.html"><span style="color:#cc6600;"><strong>first step</strong></span></a></em>” in learning to use it.<br /><br /><br />“<em>A statistician cooperating with USGS will analyze the preliminary data obtained during the inventory flights to provide population estimates with a 95 percent confidence interval”</em><br /><div align="right"><span style="font-size:78%;">BLM Press Release #2010-22<br />July 9, 2010</span><br /><div align="justify"><br />To summarize my current understanding of BLMs newest incorporation of this decades long peer-reviewed method they have recently begun waving around to try and explain the unexplainable with respect to their historical crazy population estimates is – it’s really just a very complicated computer modeling program the average Joe hasn’t got a chance of sorting out. We are just going to have to take their word for it. Swell….<br /><br />Yet, sometimes even the most seemingly complicated subjects can be boiled down to the simple basics, so let’s take a look at the numbers USGS and BLM have released so far.<br /><br />The results of the “raw” direct counts of wild horses found in the Tri-State Survey area were reported by BLM on July 9, 2010 in the following chart:<br /><br /></div><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/TMxvjwRHA6I/AAAAAAAACLM/7mBQWU2K0dA/s1600/Tri-State+Survey_Direct_7-09-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 368px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5533920702174266274" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/TMxvjwRHA6I/AAAAAAAACLM/7mBQWU2K0dA/s400/Tri-State+Survey_Direct_7-09-10.jpg" /></a><br /><div align="justify">After merely a month and a half of BLM releasing the Tri-State direct count results shown above, USGS and the "cooperating statistician" published Program MARKs results for the <a href="http://www.blm.gov/pgdata/etc/medialib/blm/nv/wild_horse___burro.Par.46894.File.dat/TriState_Horse_Survey_Results_08252010.pdf"><span style="color:#cc6600;"><strong>Tri-State Survey on August 25, 2010</strong></span></a>, with just a few, tiny adjustments.<br /><br />If you compare the two charts, (the direct count numbers along side the modifications yielded by Program MARK), besides noticing a variety of complicated official columns that include coefficient variations and upper and lower confidence levels, there’s couple of interesting numbers that stand out.<br /><br />The first is, the direct count of the wild horses seen in the Fox Hog Herd Management Area reported in July were adjusted “upward” from 172 to 300 in the August version of the data. No need for complicated programs here, just a little “tweaking” of the supposedly directly counted numbers as suddenly 128 wild horses were moved into the Fox Hog HMA.<br /><br />The other change to the July direct count numbers occurred between wild horses reported “Outside” the California HMAs, adjusted from 430 in July to 302 in August. However, a little cross referencing between the “CA Outside the HMA” numbers and the Fox Hog numbers revealed the shift between the two perfectly matched the increase in the Fox Hog HMA numbers. In other words, USGS moved 128 wild horses from “outside” the California HMAs to “inside” the Fox Hog HMA and the results put the Fox Hog wild horse population from under their appropriate management level to significantly over it with removals now scheduled for the fall of 2011.<br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TMxvc2Gdu1I/AAAAAAAACLE/Id14cpuj5Xc/s1600/Tri-State+Survey_USGS_8-25-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5533920583481146194" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TMxvc2Gdu1I/AAAAAAAACLE/Id14cpuj5Xc/s400/Tri-State+Survey_USGS_8-25-10.jpg" /></a><br />The other thing that the “average Joe” can also deduce from the newly adjusted numbers is, the computer modeling determined only a 98 horse difference between what was directly counted in the raw data and adding estimations for wild horses that were missed by the observers in the plane. This equates to only a 2.3% difference between the direct counts and the added estimates, at least during this particular survey.<br /><br /><br />“<em>The modeling and analysis to be completed will make adjustments to the preliminary data to account for animals not observed during the flight. The simultaneous double-count/sightability bias correction technique will provide more valid population estimates than the standard uncorrected aerial inventory method</em>.”<br /><div align="right"><span style="font-size:78%;">BLM Press Release #2010-22<br />July 9, 2010</span><br /><div align="justify"><br /><br />While I will save questions for the accuracy of the raw count data for the Tri-State area for a later date, I would like to draw everyone’s attention to the BLMs unofficial “fudge factor” that is being slipped into this new, highly touted, state-of-the-art, “more-valid-population-estimate-than-ever-before” public relations campaign phony baloney.<br /><br />After BLM receives the Tri-State area’s “direct count” data from the July 9, 2010 aerial census, less than a month later they issue a <a href="http://thecloudfoundation.files.wordpress.com/2010/09/roundup-fy-2011_9-1-10.pdf"><span style="color:#cc6600;"><strong>Preliminary Gather Schedule for Fiscal Year 2011</strong></span></a> on August 5, 2010, which includes a tentative plan to gather some of the HMAs inventoried in the Tri-State Survey.<br /><br />Here we watch BLM mushroom the 172 wild horses from the Fox Hog HMA to an estimated 726 – and this was before USGS made the little “tweak” to revamp the estimate to 300 wild horses.<br /><br />But it doesn’t stop there. The High Rock HMA goes from a direct count of 300 to BLMs “new” number of 747 and Massacre Lakes jumps from 148 to 220 as well. All totaled, BLM reports they are projecting to gather 1,735 wild horses from the High Rock, Fox Hog, Massacre Lakes and Wall Canyon HMAs next fall.<br /><br />So, I tried to see if there were any way to make BLMs numbers work with real world math and big surprise, no matter what I tried, it just didn’t fly!<br /><br />First, I totaled the Tri-State wild horse population (just from the July raw count data as BLM had yet to see the results of Program MARKs estimation when they released the Preliminary FY11 Gather Schedule). The results from the survey of the four HMAs were merely 707 wild horses.<br /><br />So then I padded the “official” HMA populations by adding the entire 430 wild horses the Tri-State Survey cited as “outside CA HMAs” to this total. Yes, <em>all the wild horses</em> from the entire CA area. This brought it up to 1,137 wild horses.<br /><br />Next, I subtracted what BLM was projecting to gather (1,735 wild horses) from what the Tri-State Survey had counted for these same HMAs (but also included all wild horses reported in the survey as “outside” now totaling 1,137 wild horses).<br /><br />Then I tried adding a 20% reproduction rate to the original raw count of 1,137 wild horses because next spring will cause populations to go up - but the 20% reproduction rate couldn’t even come close. Okay, how about a 25% reproduction rate? Still not even in the ballpark. The fact of the matter is, the only way BLMs numbers would “jive” is by adding a 52% reproduction rate to the wild horses found in the Tri-State Survey. And don’t forget, BLMs estimate includes foals and weanlings that aren’t even capable of reproducing yet!<br /><br />The methods BLM is now touting as bringing “more valid” population estimates to the Wild Horse and Burro Program resulted in merely a 2.3% adjustment by USGS and Program MARK. But by the time BLM got a hold of them, populations moved into the realm of pure fantasy.<br /><br />And can’t ya just hear Salazar now. “<em>Common Congress, ya just gotta believe us and give us the money to keep rounding em up – no questions asked! JUST LOOK AT THESE NUMBERS! Why, the wild horses are just positively overrunning the range! And they are based on the newest, most technologically advanced peer-reviewed census methods available!”<br /></em><br />Anybody else wondering what the population of America’s mustangs and burros would really look like if USGS used Program MARK as it was originally intended – to estimate survival rates - but used BLMs removal numbers instead?<br /><br /><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/TMx2zwlDu6I/AAAAAAAACLU/un0wCievyCg/s1600/East+Fork+High+Rock+Canyon_BLM+Photo.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5533928673717238690" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/TMx2zwlDu6I/AAAAAAAACLU/un0wCievyCg/s400/East+Fork+High+Rock+Canyon_BLM+Photo.jpg" /></a> <div align="center"><span style="font-size:78%;">East Fork High Rock Canyon<br />Home of wild horses overrunning the range.<br />Photo courtesy of BLM. </span></div></div></div></div></div></div></div></div>Unknownnoreply@blogger.com7tag:blogger.com,1999:blog-4562357749295999770.post-85576899822796520752010-10-22T07:45:00.000-07:002010-10-22T07:46:18.619-07:00For The Future<div align="justify">The Bureau of Land Management’s Winnemucca Field Office is accepting public comment, input, suggestions and recommendations for the development of their new Resource Management Plan. This is a crucial framework that will guide BLM in future decisions affecting the area for the next 10-30 years.<br /><br />This Winnemucca Field Office is the responsible district for the Calico Complex and many other wild horse and burro use areas in Northern Nevada.<br /><br />Please take a few moments out to submit your ideas, comments, input and suggestions for incorporation in the final plan as the number of comments BLM receives, as well as the kinds of recommendations, are critical to the future of wild horses and burros.<br /><br />Listed below are some of my own ideas and recommendations. Feel free to use them for inspiration or incorporation in your own comments. </div><div align="center"><br /></div><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TMGdoa8ZHNI/AAAAAAAACK8/ZTgZYvGa3ZA/s1600/IMG_1038.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5530875135140633810" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TMGdoa8ZHNI/AAAAAAAACK8/ZTgZYvGa3ZA/s400/IMG_1038.jpg" /></a> <div align="center"><span style="font-size:78%;">Wild Horse from the Calico Herd Management Area<br />Courtesy of BLM - 2004</span></div><div align="center"><br /><br /><strong>Winnemucca Draft Resource Management Plan</strong> <div align="justify"><br />I support Alternative C as well as the incorporation of the following recommendations in all Alternatives and analysis in the Final Environmental Impact Statement and Record of Decision.<br /><br /><strong><span style="font-size:130%;">></span></strong> Include legal land descriptions for all Herd Areas and Herd Management Areas.<br /><br /><strong><span style="font-size:130%;">></span></strong> Review all Herd Areas within the planning area for reintroduction to Herd Management Status as required by CFR 4700.3-1. Provide a detailed analysis and reasons for previous withdrawals as well as potential mitigation measures that may reinstate wild populations on legally designated Herd Areas.<br /><br /><strong><span style="font-size:130%;">></span></strong> Identify wild hose and burro use areas as suitable for designation as wild horse and burro “ranges” to be devoted principally as sanctuaries for their protection and preservation as per Section 1333(a) of the Wild Free-Roaming Horse and Burro Act and 43 C.F.R 4710.3-2.<br /><br /><strong><span style="font-size:130%;">></span></strong> Develop Alternatives that incorporate the designation of ACECs (Areas of Critical Environmental Concern) for all remaining wild burro herds and the critical habitat and resources if necessary to insure self-sustaining genetically viable populations within the planning area as per the FLMPA, Section 202 [43 U.S.C. 1712] (a)(3) for long-term sustainability.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Identify Herd Areas, Herd Management Areas and Ranges that provide unique opportunities to develop public viewing opportunities and/or development of ecotourism based on the promotion of wild herds as well as including an analysis of potential economic benefits this would bring to local communities.<br /><br /><strong>></strong> Identify any bands or herds that use two or more Herd Management Areas to secure suitable year-long habitat and resources based on environmental conditions, migratory patterns or seasonal movement.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Base wild horse and burro resource allocations on scientific and rational principles. Incorporate suitability criteria be established within the framework of the RMP as recommended by the National Academy of Science over 30 years ago to better reflect actual use and available forage for free-roaming populations to achieve accurate appropriate management levels and “excess” determinations.<br /><br /><strong><span style="font-size:130%;">></span></strong> Develop and incorporate within the framework of the RMP the methodology used to distinguish wild horse and burro impacts from livestock and other rangeland users. One potential method is to mandate monitoring and utilization levels be measured prior to the introduction of livestock in a given area order to distinguish class use and impacts.<br /><br /><strong><span style="font-size:130%;">> </span></strong>In all Herd Management Areas, assure management plans will provide allocations and resources adequate to maintain a minimum of 150 animals at all times on the range per individual HMA as necessary to maintain long-term genetic viability according to the best available science. This will prevent inbreeding or population crashes as required by CFR 4700.0-6(a) and to ensure that populations are being managed as an integral part of the natural systems of the public lands.<br /><br /><strong>></strong> In individual Herd Management Areas, prohibit management plans and strategies that fail to provide for self-sustaining wild horse and burro populations lower than a minimum population of 150 animals based on the concept of “genetic interchange” between bands or herds from different Herd Management Areas. The only exception to this could be if BLM can conclusively document known population interchanges by photographs or other identifiable markings of animals on a multiple and consistent long-term basis.<br /><br /><strong><span style="font-size:130%;">></span></strong> If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury, invoke BLMs authority to reduce or close areas of public lands to grazing use by all or a particular kind of livestock as established by C.F.R. 4710.5 (a), with the goal of maintaining self-sustaining genetically viable wild horse and burro populations through allocations assuring resources are adequate to maintain a minimum of 150 animals at all times on the range per individual HMA.<br /><br /><strong><span style="font-size:130%;">></span></strong> Prohibit the use of “blanket” management options that allow for wild horse and burro reductions without supporting data to make excess determinations, i.e., “in the absence of species specific data, equitable reductions in livestock and wild horse and/or burros authorizations will be implemented.” The historical problem with the management approach of authorizing “equitable reductions” is there is no accountability or consequence to BLM if they fail to reduce the livestock portion of the projected reductions. Traditionally, BLM has removed wild horses and/or burros or reduced their population objectives while making no changes or increasing livestock authorizations shortly after applying changes exclusively to free-roaming populations.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Prohibit the issuance of non-renewable grazing permits in any wild horse and burro Herd Area, Herd Management Area or Range in order to allow maximum long-term rangeland health due to year long grazing pressure in these designated areas.<br /><br /><strong><span style="font-size:130%;">></span></strong> Establish criteria within the RMP framework for incorporating periodic monitoring at “key” times to establish data on available water. This should include mandatory flow rates, water quality data, status of historic sources (in order to collect trend data on water availability) and photographic evidence to establish credibility in BLMs data.<br /><br /><strong><span style="font-size:130%;">></span></strong> Various related multiple use decisions issued by the Winnemucca Field Office as well as surrounding areas indicate the potential for significant and cumulative impacts to underground aquifers and water sources due to drawdown. Incorporate provisions within the RMP that provide mitigation measures for water loss, increase available habitat, disperse consolidated grazing pressures, and insure supplemental low cost water sources are available in times of drought or harsh environmental conditions for wild horses and burros as well as other wildlife species within the planning area.<br /><br /><strong><span style="font-size:130%;">></span></strong> Prohibit the use of any sterilization measures on populations that fall below the minimum genetic threshold of 150 animals or less and assure balanced gender structures to preserve natural herd behaviors and social dynamics.<br /><br /><strong><span style="font-size:130%;">></span></strong> Prohibit the inclusion of foals one year and under in population inventories and calculations occurring on the range for “excess” population determinations.<br /><br /><strong><span style="font-size:130%;">></span></strong> Establish population objectives and thresholds for big game species within the planning area to insure habitats support a “thriving natural ecological balance” between all species. The current policy to omit critical information on species populations, increased pressure on resource requirements and their resulting impacts fails to conform to federal law mandating scientifically sound management decisions and quality data to determine suitable habitat for all rangeland users. As public stewards, BLM needs to recognize and honor their position to preserve and protect all resources for the American people, both now and for future generations. State wildlife agencies have a vested interest in increasing big game populations to increase revenue. As such, studies, data, recommendations and management objectives may contain inherent “conflicts of interest” and biased towards the balanced management of resources on public lands.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Provide for public review a detailed examination and analysis of all current multiple use applications within each Herd Area and Herd Management Area within the planning area. This is to include current livestock authorizations, the percentage each allotment overlaps existing wild horse and burro areas as well as maps clearly showing the relationship and resource allocations between livestock and wild equids within the planning area. The purpose of this information is to help the public be reasonably informed as to BLMs compliance with the Act’s mandate to accomplish the protection of wild free-roaming horses and burros through their consideration as an integral part of the natural system of the public lands as well as their relationships with other uses of the public and adjacent private lands as outlined in CFR 4710.3.<br /><br /><strong><span style="font-size:130%;">></span></strong> With respect to wildlife impacts to critical resources required by wild horse and burro populations, provide current estimated big game populations such as elk, pronghorn, mule deer and bighorn, populations affecting the wild horse and burro areas within the planning district, reasonably foreseeable future big game population objectives for these same areas that may impact management strategies to maintain self-sustaining genetically viable herds.<br /><br /><strong><span style="font-size:130%;">></span></strong> All other multiple use authorizations within Herd Areas and Herd Management Areas such as current mining, oil and gas operations as well as renewable resource projects such as solar, wind or geothermal impacting or reasonably projected to impact habitat and/or resources in the Winnemucca Herd Areas and Herd Management Areas as well as projects or proposals that can be expected to be implemented in the reasonably foreseeable future. This should include a detailed map of each Herd Area and Herd Management Area in the planning area to allow the interested public to assess the impacts of other multiple uses to wild horse and burro habitat and populations in a site-specific manner.<br /><br /><strong><span style="font-size:130%;">></span></strong> Include detailed analysis of the miles, kinds and locations of fencing within each HA/HMA within the planning district. Reaffirm strict limitations on fencing in wild horse and burro Herd Areas, Herd Management Areas or Ranges in order to preserve their free-roaming behaviors and to prevent entrapment, injury, death or undue degradation of resources due to limitations on seasonal or migratory movement.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Incorporate protections for predators in and around herd management areas as a management tool for low cost population control and to support the “thriving natural ecological balance”.<br /><br /><span style="font-size:130%;">> </span>Prohibit management strategies that are based on “adoption criteria” as the primary consideration. This policy fails to conform to both the intent and the mandates of the Act. Incorporate management strategies that support historical herd traits and local community values for the bands/herds.<br /><br /><strong><span style="font-size:130%;">></span></strong> Utilize range management to address wild horses and burros who wander across the borders of Herd Management Areas (HMAs), instead of permanently removing them.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Removals of any kind should be rare and minimal. Other methods of management must be employed first and given a fair opportunity to succeed. If a limited removal is necessary, it must be done in a humane manner that respects horse social structure and keeps families intact.<br /><div align="center"><br /><br /><strong>~DEADLINE~<br /><span style="color:#ff0000;">MONDAY, OCTOBER 25, 2010<br /></span>4:30 P.M. PST<br /></strong><br /><br />SUBMIT TO:<br />Winnemucca RMP<br />c/o Bob Edwards<br />Attn: Winnemucca RMP<br />Bureau of Land Management<br />Winnemucca District Office<br />5100 E. Winnemucca Blvd.<br />Winnemucca, NV 89445<br />Fax: (775) 623-1503<br />Email: wdrmp@blm.gov<br /><div align="justify"><br /><span style="font-size:85%;"><em>Please be aware that your submissions will become part of the public record, including personally identifying information. Though you may request BLM keep this information private, they may not be able to guarantee it in all instances.<br /></em></span><div align="center"><br /><br /><strong>RELATED LINKS<br /></strong><br /><a href="http://www.blm.gov/nv/st/en/fo/wfo/blm_information/rmp.html"><span style="color:#cc6600;"><strong>WINNEMUCCA DRAFT RESOURCE MANAGEMENT PLAN<br /></strong></span></a><br /><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxODIxMjQ1MzRmYzViNjNi&pli=1"><span style="color:#cc6600;"><strong>Public Comment Submission<br /></strong></span></a><p><a href="https://secure2.convio.net/ida/site/Advocacy?pagename=homepage&page=UserAction&id=1669&autologin=true&AddInterest=1022&JServSessionIdr004=m97w9akh23.app246b"><strong><span style="color:#cc6600;">In Defense Of Animals - Alternative Comments</span></strong></a></p></div></div></div></div></div>Unknownnoreply@blogger.com2tag:blogger.com,1999:blog-4562357749295999770.post-39787361682448944632010-10-16T04:17:00.000-07:002010-10-16T04:18:12.623-07:00Gubmint Cheese<div align="justify">The following article is solely an opinion piece of the author and does not reflect the thoughts, feelings, opinions, attitudes or beliefs of any other wild horse, burro or equine enthusiast across the globe.<br /><br />Due to the large body of evidence regarding the ability of western stockman whose paths are crossed to retaliate in often unyielding and brutal fashions, (regardless of their stature in society), if you are a western stockman reading this, please remember that you are suppose to look like you value individual freedom, which includes opinions such as mine. Also, may I throw out for your consideration; it’s just not good business to bite the working class hand that feeds you. <div align="center">#<br /><br /><div align="justify">“<em>Despite the lack of data, BLM has proceeded with horse removals using targets based on perceived population levels dating back to 1971 and/or recommendations from BLM advisory groups comprised largely of livestock permittees.”</em> <div align="right"><span style="font-size:78%;">Improvements Needed In Federal Wild Horse Program<br />Government Accounting Office<br />Report RCED-90-110, August 1990</span> <div align="justify"><br /><br />Well, it’s that time again for the Nevada Cattleman’s Association (NCA) to hold their annual convention in good ole (as in Good Ole Boy) Elko, Nevada, November 10-12, 2010, first announced in the NCA’s Executive Director’s September Monthly Message titled, “<a href="http://www.nevadacattlemen.org/execdirmessagese.html"><span style="color:#cc6600;"><strong>75th NCA Convention Nears; Wild Horse Gathers: Let Your Voice Be Heard</strong></span></a>”.<br /><br />Included in the message was how NCA coordinated with a cozy coalition to send letters of opposition to the same Congressional representatives who signed on to <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1ZTFlMDQ1MzY4MzZiMzI3&pli=1"><span style="color:#cc6600;"><strong>a July 30, 2010, letter</strong></span> </a>urging a moratorium on round ups until a scientific study by the National Academy of Science (NAS) could be completed.<br /><br />While the Director ignored the Congressional call for science-based management as the reason for the moratorium, an inaccurate but easy-to-read summary was presented to NCA members by merely stating, “<em>The letter was filled with misinformation and half truths</em>”.<br /><br />The NCA Monthly Message also encouraged members to submit a long list of unsubstantiated talking points to cattleman conspirator Secretary Salazar in support of continued wild horse stampedes. These included crocodile tears for starving and dehydrated mustangs, lack of humane treatment by leaving them on the range to die and what fabulous stewards permittees are of biodiversity, wildlife and rangeland health on public lands.<br /><br />As I read through the pile of cow patties being served on a golden platter, I was struck at how the public lands Welfare Queens showed no shame in their desperate defense of their government cheese.<br /><br /><br />“<em>A <a href="http://en.wikipedia.org/wiki/Welfare_queen"><span style="color:#cc6600;"><strong>welfare queen</strong></span> </a>is a pejorative phrase used in the United States to describe people who are accused of collecting excessive welfare payments through fraud and manipulation</em>.” <div align="right"><span style="font-size:78%;">Wikipedia, 10/15/10</span> <div align="justify"><br /><br />The rural ranching community in Nevada has been shown to be predominately Republican, a party characterized by propaganda touting fiscal responsibility, belief in a free-market equals a free society and demands for reduced government regulations and involvement.<br /><br />The GOP front for the GOB (Good Ole Boys) network was actually the first to create the image of an inner city Welfare queen, a stereotype and name coined by none other than self-proclaimed Sage Brush Rebel and GOB hero, Ronald Reagan himself.<br /><br />With Reagan’s help, the New Right of the early 90’s targeted many of the welfare programs through derogatory connotations singling out women (and American African women in particular), for engaging in lazy, immoral behavior and using children to increase their government sponsored incomes. Not surprisingly, most of the stories used to create this stereotype - including Reagan’s - turned out to be false.<br /><br />Apparently, the welfare queens of the inner city had a lot to learn from the original Welfare Queens of public lands. While inner city queens waited on lists for months to access government housing on postage stamps butted back to back in run down neighborhoods, the public lands Welfare Queens commanded tens of thousands of acres for their backyard with demands this right be passed down from generation to generation with no questions asked.<br /><br />Pushing out children by the dozen to receive government subsidies was no match for pushing out cattle numbering in the thousands and food stamps paled in comparison to the $1.35 p/month ranchers are forced to pay to feed a 1,200 lb. plus animal. This equates to the total weight of an inner city queen, her entire diaper bound brood, her current partner found sneaking out of the bedroom during welfare inspections with hundreds of pounds still left over.<br /><br />To the GOB Welfare Queens, fiscal responsibility only applies to any government program that’s not supporting them while the free-market is invoked only after they transport their government gorged beef to livestock auctions to sell to the highest bidder.<br /><br /><br />THE MYTH: “<em>Over time, <a href="http://en.wikipedia.org/wiki/Cowboy"><span style="color:#cc6600;"><strong>the cowboys</strong></span> </a>of the American West developed a personal culture of their own, a blend of frontier and Victorian values that even retained vestiges of chivalry. Such hazardous work in isolated conditions also bred a tradition of self-dependence and individualism, with great value put on personal honesty</em>.” <div align="right"><span style="font-size:78%;">Wikipedia, 10/15/10</span> <div align="justify"><br /><br />The modern Western rancher grew from the frontier work of the American “cowboy” (literal meaning - a boy who tends cows) but in reality, the majority of today’s ranchers are far removed from their historical roots.<br /><br />Bloated by government subsidies, giveaways and handouts, the self-dependence of their ancestors is only a dim memory of prodigy who now ferociously suckle the government teat while the individualism of yesteryear has been reduced to a battle cry masking childish tantrums thrown by spoiled brats who don’t get their way.<br /><br />Don’t me wrong, just because they are cow <em>boys</em> doesn’t prevent them from being dangerous!<br /><br />The western cowboy now turned rancher also shares many common themes illustrated in William Golding’s “<a href="http://en.wikipedia.org/wiki/Lord_of_the_Flies"><span style="color:#cc6600;"><strong>Lord of the Flies</strong></span></a>”. This is a story of how a group of boys stranded on a deserted island descended into primitive and savage behavior. They eventually turned lazy and idle as struggles for power and domination became the central theme of their daily existence, much like the Western stockman of today.<br /><br />To me, the most notable difference between the boys in Lord of the Flies and today’s modern cow boys is, the boys in the book were rescued and returned to civilized behaviors; the modern day rancher sprouted from a culture developed by boys who continued to stay isolated and so, never really learned how to grow up.<br /><br />While the GOB Welfare Queens of the NCA speak of half-truths and misinformation about wild horses and burros on public lands, I reflected on Nevada’s proud ranching heritage. Here, on almost exclusive owned public lands, many ranchers hide out in remote areas and demand their names be kept secret lest the taxpaying public actually catch wind of who is turning our landscapes to waste for a pittance.<br /><br />One of Nevada’s proudest heritage moments was when a Nevada consulting firm (with absolutely no affiliation with the Nevada Cattleman’s Association, I’m sure) issued a report titled, “<em>A Technical Review of U.S. General Accounting Office Rangeland Management and Public Rangelands Reports 1988-1990”</em> in response to the GAO’s findings about the truth of public lands livestock grazing.<br /><br /><br />“<em>Despite lack of adequate data on the number of wild horses the land can support, BLM has proceeded with removing horses. For example, BLM’s Nevada State Office concluded that available data were not adequate to justify removing wild horses; however, in both instances BLM’s responsible district and resource area offices chose not to revise their plans to remove horses in their areas. In contrast, BLM has frequently used the lack of detailed carrying capacity and range monitoring data to explain why it has not taken action to reduce widely recognized overgrazing by domestic livestock</em>.” <div align="right"><span style="font-size:78%;">Improvements Needed In Federal Wild Horse Program<br />Government Accounting Office<br />Report RCED-90-110, August 1990<br /></span><div align="justify"><br /><br />Apparently, the GAO was forced to defend then recently released rangeland reports as cow boys ran balling to Congress and waiving the consulting firms report to demand retractions from a “biased” GAO. The list of Congressional requesters demanding the GAO review their own methodology included Senators Harry Reid, Conrad Burns, Larry Craig, Orrin Hatch, and John McCain to name a few.<br /><br />What were some of the main bones of contentions the Nevada consulting firm had with what the GAO had to report?<br /><br />They screamed about how the problems of riparian area destruction, overstocked grazing allotments and the resulting declining and potentially permanent range conditions were mostly attributed to livestock grazing. They cried about the GAO’s recommendation that more aggressive enforcement of trespass livestock be addressed, more comprehensive data on land conditions and trends be made available, and of course, they had a hissy fit when the GAO reported the range issues stockman continue to attribute to wild horses and burros fell squarely on the suckling livestock industry instead.<br /><br />The GAO’s review and response to the consulting firms report, not surprisingly for those of us living in a state controlled by these Hand-Out Harry’s was, “<em>the consulting firm’s critique is not valid…contained little factual data to substantiate its assertions [and] misrepresented our reports’ findings to support its position</em>”. <div align="justify"><br /><br />“<em>GAO found that despite congressional direction, BLM’s decisions on how many wild horses to remove from federal rangelands have not been based on direct evidence that existing wild populations exceed what the range can support. Moreover, wild horse removals often have not been accompanied by reductions in authorized livestock grazing levels or effective range management to increase the land’s capacity. As a result, range conditions have not demonstrably improved….”<br /></em><div align="right"><span style="font-size:78%;">Improvements Needed In Federal Wild Horse Program<br />Government Accounting Office<br />Report RCED-90-110, August 1990<br /></span><div align="justify"><br /><br />However, the NCA made nary a peep when the DOI’s new grazing regulations came out in 2006, despite long-time BLM employees Erick Campbell and Bill Brookes claims of <a href="http://www.ucsusa.org/scientific_integrity/abuses_of_science/cattle-grazing.html"><span style="color:#cc6600;"><strong>doctored environmental analysis</strong></span></a> and suppression of scientific information supporting how the cattle industry would have “<em>slow, long-term impact on wildlife and biological diversity in general</em>”.<br /><br />Campbell also called the DOI’s approval of the Bush Era grazing regulations a “<em>white wash</em>” and “<em>a crime</em>” as well as adding, “<em>They took all of our science and reversed it 180 degrees</em>”. Brookes added, “<em>Everything I wrote was totally rewritten and watered down</em>”.<br /><br />Apparently, that’s the kind of misinformation and half-truths NCA can support!<br /><br />The NCA’s Monthly Message also showcases Past President Boyd Spratling, currently masquerading as a Representative of Veterinary Medicine on the National Wild Horse and Burro Advisory Board. Dr. Spratling (or is it Past President Spratling?) has been busy providing testimony on wild horses in the Interim Public Lands Committee and recently met with Senator Ensign to discuss wild horses and the “<em>El Paso/WWP</em>” situation. (It would seem Senator Ensign is incapable of recognizing a conflict of interest situation even if it is sitting on his lap....)<br /><br />This is the same Boyd Spratling who refused to address, much less develop, humane handling guidelines for helicopter rounds ups back in 2007 and who stated the deaths of almost 200 wild horses from the Jackson Mountain were the results of “<em>The very people that claim to care the most about those horses were actually the ones driving the death nail in their coffin</em>”.<br /><br />This same ex-President Spratling also developed the current BLM approved on-the-range stallion castration policy, refused to participate in repeated requests regarding review of BLM management plans and AML decisions for our wild herds, ignored evidence indicating BLMs on the range wild horse and burro population data is in error and failed to address critical issues found within new census techniques now being used to substantiate biologically impossible populations.<br /><br /><br />“<em>BLM also sometimes deferred its horse removal decisions to advisory groups comprised primarily of livestock permittees. In Nevada, BLM established target wild horse population levels on this basis in eight herd areas. Since livestock permittees have a vested interest in keeping wild horse populations low to reduce competition for forage for their livestock, setting horse removal levels on the basis of their views may not be appropriate</em>.” <div align="right"><span style="font-size:78%;"><br />Improvements Needed In Federal Wild Horse Program<br />Government Accounting Office<br />Report RCED-90-110, August 1990</span> <div align="justify"><br /><br />While the NCA relies on old-time mythology of the cow boys “great personal honesty” to sell its hypocritical contortions of rangeland reality, copied below is one of the NCAs talking points about why a moratorium on wild horse gathers must not be allowed:<br /><br /><blockquote><em>Elevating one species over another, particularly a species which demands more forage than can be replaced, jeopardizes other users of public lands, and threatens native plants and wildlife species. Finding and keeping Appropriate Management Levels is the key to the balance of management and impacts on public lands. Tipping the scale towards the domination of wild horses does not correlate with the directive of the Bureau of Land Management</em>.</blockquote>.<br />Yes, at long last NCA has finally issued a statement the American public and wild horse and burro enthusiasts can finally agree on; “<em>The elevation of one species over another…jeopardizes other users of public lands</em>.”<br /><br /><br /></div><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TLlPC96oekI/AAAAAAAACKs/stkgCVLma8M/s1600/09+Forage+Chart_Photos-2.jpg"><em><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 167px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5528536929972812354" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TLlPC96oekI/AAAAAAAACKs/stkgCVLma8M/s400/09+Forage+Chart_Photos-2.jpg" /></em></a><em> </em><div align="justify"><br />And why doesn’t the GOB Welfare Queens want to tell the truth about the reality out on the range?<br /><br />Because as you peruse the Nevada Cattleman’s Association’s website and see all those smiling faces under their Welfare crowns (a.k.a., the cowboy hat), know those grins weren’t just from saying “<em>Cheese</em>” like the rest of us suckers do, they were saying “<em>Gubmint Cheese!</em>”<br /><br /><br />“<em>Wild horse and burro populations consume forage on the public rangelands and consequently contribute to the overgrazing problem. However, as we have noted in previous testimony, the primary cause of the degradation in rangeland resources is poorly managed domestic livestock (primarily cattle and sheep) grazing. When more animals are allowed to graze in an area than the land can support, forage consumption exceeds the regenerative capacity of the natural vegetation, resulting in erosion, watershed damage, and other deterioration. Although recognizing that overgrazing was occurring, BLM range managers reported that no adjustments in the authorized livestock grazing levels were scheduled in 75 percent of the allotments threatened with further damage. These managers cite insufficient data on specific range conditions and resistance by livestock permittees as the primary reasons why action had not been taken</em>.” <div align="right"><span style="font-size:78%;">Improvements Needed In Federal Wild Horse Program<br />Government Accounting Office<br />Report RCED-90-110, August 1990</span> <div align="center"><br /><br /><br /><strong><span style="font-size:130%;">RELATED LINKS<br /></span></strong><br /><em>Historical GAO Rangeland Management Reports<br /><br /></em><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo2ZTA5ZWI4NTU4MGQ1Njg4"><strong><span style="color:#cc6600;">Improvements Needed In Federal Wild Horse Program<br /></span></strong></a><em>(GAO/RCED-90-110, August, 1990)<br /></em><br /><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxZjVmNDQwNTU1ZmI5Mzk2"><strong><span style="color:#cc6600;">Observations on Management of Federal Wild Horse Program<br /></span></strong></a><em>Testimony and Statement by James Duffus III, Director<br />(GAO/T-RCED-91-71, June 20, 1991)<br /><br /></em><strong><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxY2QwNTkyNWI0MzgxNjE4"><span style="color:#cc6600;">Current Formula Keeps Grazing Fees Low<br /></span></a></strong><em>(GAO/RCED-91-185BR, June 1991)</em><br /><br /><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoyMmIwMDU2M2YwZDBiNWJj"><strong><span style="color:#cc6600;">Assessment of Nevada Consulting Firm’s Critique of Three GAO Reports</span></strong></a><br /><em>(GAO/RCED-82-178R, May 4, 1992)<br /><br /></em><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo2MmYzMWVkMTRmMGFmZTY3"><strong><span style="color:#cc6600;">Congressional Requesters/Contacts and Documents Reviewed<br /></span></strong></a><em>(GAO/RCED-92-193R, May 4, 1992)<br /><br /></em><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0NWQzMWNhNjk5NzhiYWY5"><span style="color:#cc6600;"><strong>Results of Recent Work Addressing the Performance of Land Management Agencies</strong></span> </a><br /><em>(GAO/RCED-92-60, May 12, 1992)</em><br /><br /><br /><strong><span style="font-size:130%;">OTHER LINKS<br /></span></strong><br /><strong><a href="http://www.taxpayer.net/search.php?kw=public+lands+grazing+program&slct_option=-+Match+All+-&src_kw=1"><span style="color:#cc6600;">Public Lands Grazing Program<br /></span></a></strong><em>Taxpayers For Common Sense</em><br /><br /><a href="http://articles.cnn.com/1998-01-21/us/9801_21_oprah.beef_1_cattle-prices-mad-cow-disease-howard-lyman?_s=PM:US"><strong><span style="color:#cc6600;">Oprah Accused Of Whipping Up Antibeef Lynch Mob<br /></span></strong></a><em>CNN/1998</em><br /><br /><strong><a href="http://alanburkhart.blogspot.com/2006/09/nightmare-in-old-west.html"><span style="color:#cc6600;">A Nightmare In The Old West<br /><br /></span></a></strong><strong><a href="http://alanburkhart.blogspot.com/2006/09/nightmare-in-old-west.html"><span style="color:#cc6600;">OBITUARY: KENT RANDOLPH KNUDSON<br /></span></a></strong><em>November 11, 1949 - September 25, 2010</em></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div>Unknownnoreply@blogger.com6tag:blogger.com,1999:blog-4562357749295999770.post-2128106468434188612010-10-02T17:10:00.001-07:002010-10-03T12:24:25.700-07:00A Similar Vaccine<div align="justify">Recently, I have seen some interesting new trends developing in BLM wild horse & burro proposals.<br /><br />While certainly not as horrifying as the recent <a href="http://news.discovery.com/animals/mass-grave-containing-horse-remains-reportedly-found.html"><span style="color:#cc6600;">discovery</span></a> at Sheldon National Wildlife Refuge of scattered horse bones, a mass grave or the terrifying events experienced by the courageous <a href="http://rtfitch.wordpress.com/2010/09/26/feds-and-contractor-caught-conducting-covert-wild-horse-stampede/"><span style="color:#cc6600;">Leslie Peeples</span></a>, the ramifications of these trends are certainly disturbing.<br /><br />As the accelerated Obama/Salazar meat machine continues to grind up America’s wild horses and burros behind closed doors while contemptuously spitting them back out into the publics face, here is one of the latest trends BLM may be about to foist on our herds.<br /><br /></div><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TKe5-5luc0I/AAAAAAAACKc/eVyNXjdCcTw/s1600/Warm+Springs_Wild+Horse.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 320px; DISPLAY: block; HEIGHT: 322px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5523587958255285058" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TKe5-5luc0I/AAAAAAAACKc/eVyNXjdCcTw/s400/Warm+Springs_Wild+Horse.jpg" /></a> <div align="center"><span style="font-size:78%;">Captured wild horse.<br />Oregon Warm Springs Canyon HMA (2006).</span> <div align="justify"><br /><br />On September 15, 2010, the BLM Burns District Office in Oregon announced the opening of a public comment period on a fourth alternative being added to an already released <a href="http://www.blm.gov/or/districts/burns/plans/files/WS_EAWithNewAlternative_9152010.pdf"><span style="color:#cc6600;">Environmental Assessment</span> </a>regarding the removal of wild horses in the Warm Springs HMA.<br /><br />The summary of this new alternative is, “<em>The BLM has subsequently added a fourth alternative to the EA analyzing the application of a 2-year Porcine Zona Pellucida (PZP-22), or similar, vaccine to approximately 43 horse mares. At this time, the BLM is soliciting comments on the additional alternative of injecting mares with PZP-22</em>.”<br /><br />Public comments were restricted to input only pertaining to the addition of this new alternative and were limited to twelve days; the comment period ended on September 27, 2010.<br /><br />Perhaps some of you caught all that was transpiring in the two tiny sentences BLM posted in the proposal but for those of you who didn’t, let me elaborate. There are two key phrases here that should have supporters of self-sustaining wild herds on public lands and open public processes extremely alarmed.<br /><br />The first issue is based on BLMs strategic wording, public comments are limited to ONLY injecting mares with PZP-22. Yet, that’s is not all BLM is proposing here, is it? The sentence states, “or similar vaccine” and that’s the second issue.<br /><br />What does “similar” vaccine mean?<br /><br />According to two BLM internal reports generated in 2008 and obtained by advocates under the Freedom of Information Act, the <a href="http://www.equinewelfarealliance.org/uploads/BLM.Team.Euth.FOIA_Cover.letter.pdf"><span style="color:#cc6600;">BLM’s Team Conference Calls</span> </a>(July 2008) and <a href="https://4701694131163205874-a-1802744773732722657-s-sites.googlegroups.com/site/americanherds4/ah-docs-1/BLM-HorseAltManagementOptions.pdf?attachauth=ANoY7cr0ig422Imego_PkYcDCq9pcKQS7OgAHtykENYp1HwrY6caSSTlK5H8iqhykqTdKi1VLcU9vbDEKzCXECfFEQz_RDxUOkc3cuQHdb6MjKwvv8baROied3kkw1QIE0HzVljMokb_JTIYMETHhcycgVrUm189M-rbGU05MnWzZIqOemfREzQMLTxqZyWemKJjTxqX1JpuKA-5UwhJGJweF0SFhajo20Zo62s_50ig_ltf_PmKhxM%3D&attredirects=2"><span style="color:#cc6600;">Alternative Management Options</span></a> (October 2008), wide spread sterilization measures were aggressively explored throughout as is also now included in Salazar’s proposed new direction for the Wild Horse & Burro Program.<br /><br />The following quotes were taken from these two reports and BLM has had two years to follow through on the discussions and recommendations regarding “similar vaccines” BLM was then putting on the table for our wild herds future.<br /><br /></div><br /><div align="center"><strong>STERILIZATION OF MARES USING SPAYVAC™ OR GONACON™</strong></div><br /><div align="justify"><strong>SpayVac™</strong><br />“<em>Spavac™ was used in the Virginia Range horses with the testing being done at the Carson City Prison.”</em> With respect to what the Team called<em>, “The Carson City horses”,</em> they stated <em>“11 out of 15 have not gotten in foal</em>”.<br /><br />“<em>A captive trial of estray horses in Nevada indicates it may be a more effective, longer lasting fertility control agent than conventional PZP</em>.”<br /><br />“<em>A single vaccination of SpayVac™ could maintain a high level of contraception within wild mares for at least 4 years or could be permanent.”<br /><br />“Based on the Nevada estray horse trials (Killian et al in press 2008), SpayVac™ exhibits the ability to reduce population growth in wild horses. If it proves to be permanent, it may be a valuable tool for use on specific mares in non-reproducing herds.”<br /><br />“The captive trial in Nevada showed 100% contraception in Year 1, 83% in Years 2 & 3 & 4 (Killian et al. in press 2008). This rate of efficacy exceeds previously reported efficacy rates for PZP use in wild mares.”<br /><br />“If proven to be permanent, SpayVac™ could be used to create non-reproducing herds of mares.”<br /><br />“There is no SpayVac™ product currently available for use and no one is making it” </em>and <em>“it is barely available as a research product”.<br /><br />“Additional research on the duration and long term effects of SpayVac™ are needed. These research trials could begin shortly after vaccine production resumes.”<br /><br />“To date, there is no projected dosage cost for SpayVac™ as no inventory is available. Costs may be similar to the one-year PZP vaccine BLM is currently using (about $200 per dose and an estimated $500-1,000 to capture and mark treated mares).”<br /><br />“A study for the research and development of SpayVac™ would require approximately $250,000 for captive trials over a five year period”.<br /><br />“SpayVac™ could be ready for experimental use in one to two years and for management use in free-roaming horse populations in approximately six years if the above issues are resolved.”<br /><br />“There is no regulatory approval for the management or investigation use of SpayVac™ through EPA or FDA. The Researcher/developer would need to obtain written permission from EPA or FDA for its investigational use or a letter saying that isn’t necessary.”<br /><br />“If SpayVac™ proves to be permanent it could potentially threaten the genetic viability of the treated population by limiting the genetic contribution to fewer animals.”<br /><br />“Data is not available that describes the impact of SpayVac™ on the behavior and physical health of the mares.”<br /><br />“It may be several years before SpayVac™ is ready for field use on an experimental basis. An investigational approval or exemption needs to be obtained from the EPA to develop SpayVac™ for management use. The vaccine would also have to be brought into production again (about a one year waiting period). Additional research trials could begin shortly after vaccine production resumes. Based on these projections, it will be about six years before SpayVac™ could be a usable management tool for fertility control in free-roaming populations of wild horses.”<br /><br />“Based on the Nevada estray horse trials (Killian et al in press 2008), SpayVac™ exhibits the ability to effectively reduce population growth in wild horses. If it proves to be permanent, it may also be a valuable tool for use on specific mares as individuals in non-reproducing herds.”<br /><br /></em><br /><strong>About GonaCon ™</strong><br /><br /><em>“GonaCon™ is also a product that needs to be re-looked at for sterilization of mares.”<br /><br />“GonaCon™ is an experimental gonadotropin-releasing hormone (GnRH) immunocontraceptive vaccine developed for deer by scientists at the U.S. Department of Agriculture’s (USDA) Wildlife Services’ (WS) National Wildlife Research Center (NWRC).”<br /><br />“GonaCon™ reduces or eliminates the production of sex hormones (e.g., estrogen, progesterone, and testosterone) within the target animal.”<br /><br />“Efficacy rates after the first year appear to be similar to or somewhat lower than the PZP-22 BLM currently uses.”<br /><br />“It may be several years before GonaCon™ is ready for field use on an experimental basis in wild horses and even longer before it is available for management use.”<br /><br />“The developer of GonaCon™ must first obtain the necessary documentation and approvals from the EPA to use the product outside of research trials like the Nevada estray horse trials.”<br /><br />“NWRC has received Environmental Protection Agency (EPA) authorization for the investigational use of GonaCon™. This permit allows NWRC researchers and their collaborators to ship and test the vaccines on both captive and free-ranging animals. Tests for the GNRH vaccine are ongoing in several states and countries, involving a wide range of wildlife and feral species, including horses”.<br /><br />“GonaCon™ is currently not available for management use under the authority of the EPA and the registration is in process for deer only.”<br /><br />“GonaCon™ will be registered as a “Restricted Use” product. Although final label language has not been negotiated with EPA, NWRC anticipates the product will be labeled for use by State or Federal wildlife or natural resource management personnel or persons working under their authority. GonaCon™ users will need to follow State authorization processes.”<br /><br />“The National Park Service is planning field trials with wild horses to investigate the efficacy of GonaCon™ as a tool to control population growth. However, it may be several years before GonaCon™ is ready for field use on an experimental basis in wild horses. The developer of GonaCon™ must obtain the necessary documentation and approvals from either EPA or FDA to investigate the vaccine on a broader scale than currently with the Nevada estray horse trials.”</em><br /><br /><br />So, tell us Secretary Salazar, if the proposed action is “<em>soliciting comments on the additional alternative of injecting mares with PZP-22</em>”, why is “<em><strong>similar vaccine</strong></em>” included? And “what” similar vaccines are being referenced here that the public is suppose to on comment in the Warm Springs HMA “fourth alternative” with no further explanation or analysis?<br /><br />To add fuel to the fire of what the Oregon BLM staff is doing behind Salazars iron curtain of secrecy, in the 2010 Post-Gather Report for the South Steen’s wild horses BLM listed 59 mares as treated with PZP. However, at the end of the Post-Gather Report in the notes section, in bold capitol letters, they added “<strong>NO PZP ADMINISTERED</strong>”.<br /><br />I contacted Oregon BLM to request clarification as to what this meant. The response never really answered the question. Mr. Hopper merely stated that a new Post-Gather Report “<em>was being revised</em>” and when it arrived, BLM re-wrote history by “eliminating” the No PZP Administered and replaced it with “<em>59 mares were treated with PZP</em>.”<br /><br />Now, it would seem to me that if someone took the time to write in bold, capitol letters, “<strong>NO PZP ADMINISTERED</strong>” in the field notes while still entering 59 mares being treated, there’s a bit of a clue about the possible fertility control experiments going on in the field.<br /><br />Now we have “similar vaccine” craftily inserted in the Warm Springs “fourth alternative”.<br /><br />As for whether this similar vaccine is SpayVac™ or GonaCon™ or some other Frankenstein concoction BLM has managed to whip up since 2008, the potential “permanent sterilization” of mares through their use, combined with an unknown number of castrated stallions they intend to return to the range as described (kind of) in the EA, BLMs "Proposed Action" yielded a projected median population growth (the one BLM always uses) of 50 wild horses over an 11 year period. (<em>Appendix E, 2010 Warm Springs HMA Gather, Win Equus Population Modeling, July 16, 2010, Proposed Action, pg. 51</em>).<br /><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TKe51QwjMvI/AAAAAAAACKU/wsMHm_DZqik/s1600/Warm+Springs+HMA_Population+Modeling_2010.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 366px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5523587792676008690" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TKe51QwjMvI/AAAAAAAACKU/wsMHm_DZqik/s400/Warm+Springs+HMA_Population+Modeling_2010.jpg" /></a><br />Will these be some of the last foals the Oregon Warm Springs Herd Management Area will ever produce after BLMs newest proposed gather?<br /><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/TKe5vljAiMI/AAAAAAAACKM/1gQYpisI6Wk/s1600/OR_Warm+Springs+Foals.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 222px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5523587695177140418" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/TKe5vljAiMI/AAAAAAAACKM/1gQYpisI6Wk/s400/OR_Warm+Springs+Foals.jpg" /></a> <div align="center"><span style="font-size:78%;">Photo of foals representing the Warm Spring HMA. Courtesy of BLM.</span> <div align="justify"><br /><br />Probably not as BLM states part of the Proposed Action is "<em>To ensure genetic viability, two to three horses with similar traits from another HMA would be returned to the West Warm Springs HMA</em>" (pg. 7)<br /><br />That's right, the fertility control measures are going to be so strong after BLM gets through with the Warm Springs wild horses in the upcoming round up, they are going to have to import wild horses from other areas to keep the populations from genetically crashing. <div align="center"><br />###<br /><div align="justify"><br />For an additional excellent article that provides summary examinations of everything BLM discussed and presented in their 2008 internal reports, check out Animal Law Coalitions, “<a href="http://www.animallawcoalition.com/wild-horses-and-burros/article/1120"><span style="color:#cc6600;">BLM’s Final Solution For Wild Horses and Burros</span></a>” by Laura Allen.<br /><br />To learn more about the “et al” mentioned in BLMs referencing of (Killian et al press 2008) used as the supporting study to move forward on BLMs fertility control alternatives, read “<a href="http://www.kbrhorse.net/news/vre-bcs01.html"><span style="color:#cc6600;">Crooks and Liars: Nevada Agriculture Director Scuttles Birth Control Study</span></a>”, October 17, 2008, by Willis Lamm of KBR Horse. <div align="center"><br /><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0OGRlYTI0YmE1NzA2OThh&pli=1"><span style="color:#cc6600;">Click Here</span> </a>for BLMs original South Steens 2010 Post-Gather Report.<br /><br /><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1MzE0Nzc3MDc0NGNjZGJk"><span style="color:#cc6600;">Click Here</span> </a>for BLMs edited version of the South Steens 2010 Post-Gather Report. </div></div></div></div></div></div></div>Unknownnoreply@blogger.com6tag:blogger.com,1999:blog-4562357749295999770.post-89002113962210065162010-09-13T06:43:00.000-07:002010-09-13T06:44:42.539-07:001941 vs 1971<div align="justify"><strong>Historical Livestock Grazing Authorizations</strong><br />In 1934, Congress passed the Taylor Grazing Act in response to overwhelming abuses and rangeland degradation caused by unregulated grazing.<br /><br />Over the last several months, BLM has attempted to counter advocates claims that BLM is wiping out America’s wild horse and burro herds in order to increase livestock production on public lands by reporting there has been a 57% decrease in Authorized livestock use; down from 22 million AUMs allocated for livestock in 1941, to only 12,800,000 for 2008, with actual use being lower still and reported at 8,600,000 AUMs.<span style="font-size:78%;">(1)</span><br /><br />While BLM fails to provide annual records of livestock authorizations and actual use data to support this claim, alternative grazing statistics available from <a href="http://rangenet.org/tools/blmgrazing/blm.html"><span style="color:#cc6600;">Range Net</span> </a>report, by 1947, BLM was only authorizing 14,993,597 AUMs for grazing, a difference of 7,006,403 AUMs less (-31.8%) than BLM claims was authorized six years earlier.<br /><br />In 1971, when the Wild Free-Roaming Horse & Burro Act was passed, these alternative grazing statistics report livestock had consumed 10,286,574 AUMs in all BLM managed states. The actual reduction between 1971 and 2008 for livestock “actual use” is merely 1,686,574 AUMs, a decline of only 16.4%.<br /><br />In 1976, Congress passed the Federal Lands Management Policy Act (FLMPA) in efforts to address continued widespread declines in range conditions. At this time, Range Net reports livestock actual use data on all BLM managed lands totaled 10,227,730 AUMs, a decline of less than 1% between this five-year period.<br /><br />Despite FLMPA’s passage, many felt it didn’t go far enough to protect Western rangelands from the ongoing desertification attributed to overgrazing by the livestock industry. Due to these concerns, in 1978 Congress passed the Public Range Improvements Act (PRIA) in efforts to provide even stronger measures to halt the accelerated degradation readily apparent throughout the West.<br /><br />From PRIA, Sec. 1901.(a) The Congress finds and declares that -<br />"<em>vast segments of the public rangelands are producing less than their potential forlivestock, wildlife habitat, recreation, forage, and water and soil conservation benefits,and for that reason are in an unsatisfactory condition;…unsatisfactory conditions on public rangelands present high risk of soil loss, desertification, and a resultantunderproductivity for large acreages of the public lands</em>;<br /><br />At the time Congress passed PRIA in 1978, records indicate that 9,384,978 AUMs were actually used by livestock, a further reduction of 842,752 AUMs (-9%) since the passage of FLMPA.<br /><br />However, despite BLMs current claims that livestock allocations are down, historical records show that actual use by livestock ranged from 8.1 million to 8.9 million AUMs annually between 1991-2000 with the 8.6 million AUMs BLM reports as actually used by livestock in 2008 falling within the same AUM average as the previous decade.<br /><br /></div><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/TI4apmGdHkI/AAAAAAAACKE/9h34ITObviA/s1600/BLM+Livestock+Use+Chart_1991-2000.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 324px; DISPLAY: block; HEIGHT: 313px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5516375895480016450" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/TI4apmGdHkI/AAAAAAAACKE/9h34ITObviA/s400/BLM+Livestock+Use+Chart_1991-2000.jpg" /></a><br /><div align="justify"><strong>Historical Wild Horse & Burro Populations<br /></strong>In 1971 when the Wild Free-Roaming Horse and Burro Act was passed, BLM estimated approximately 17,300 wild horses and 8,045 wild burros were still left on public lands. The AUM consumption rate for both wild horses and burros was 207,600 AUMs for wild horses and 48,270 AUMs for burros totaling 255,870 AUMs.<span style="font-size:78%;">(2)<br /></span><br />At this time, BLM’s census of wild horse and burro populations was achieved by ground observations only (in other words, BLM/USFS drove around in cars to record populations) and official records did not distinguish any “domestic” horse or burro populations from wild ones at this time.<br /><br />In 1974, after BLM had completed and compiled data from their first aerial censuses on wild horse and burro populations across the West, BLM reported a total horse population of 42,666 horses on public lands equating to 511,992 AUMs of annual forage consumption and 14,374 burros consuming approximately 86,244 AUMs; all combined, horse and burro forage consumption for 1974 totaled 598,236 AUMs on BLM managed public lands.<br /><br />However, BLM also reported that by 1974, a total of 17,165 horses (40.2%) of the horse populations and 123 burros found on public lands were unauthorized “domestic” animals. These animals were reported by BLM as claimed under a private ownership clause granted by Congress during an interim period given to ranchers to remove their private stock from public ranges before the protections of the Wild Free-Roaming Horse and Burro Act became enforced.<br /><br />Though this interim period was only suppose to extend for one year after the passage of the 1971 Act, BLM allowed and reported 69,000 wild horses and 330 burros to be privately claimed and removed from public ranges due to the private ownership clause between 1972 and 1980. No one knows how many animals “disappeared” during this time that went unreported.<br /><br />Therefore, though horse and burro consumption on public lands totaled 598,236 AUMs in 1974, BLM maintained that only 25,501 horses and 14,374 burros were actually “wild” and entitled to this forage under the auspices of the 1971 Act. Based on this assertion, BLM historical population records for 1974 indicate wild horses consumed approximately 306,012 AUMS while wild burros consumed 86,244 AUMs – a total of 392,256 AUMs.<br /><br />While BLM claimed the other 17,165 horses found on public lands were actually domestic livestock and the 205,980 AUMs of forage they consumed remained unaccounted for in BLMs annual livestock authorizations, BLM was able to use these “domestic numbers” to bolster their claims of excess wild populations on public lands – even while they were being removed under private ownership clauses by the tens of thousands.<br /><br />At the passage of FLMPA in 1976, BLM reported horses and burro populations on public ranges totaled 60,100 for both species; 53,310 horses (639,720 AUMs) and 6,790 burros (40,740 AUMs) equating to 680,460 AUMs being consumed annually.<br /><br />Yet again, of these reported populations, BLM claimed 11,023 horses and 84 burros were privately claimed and removed from public lands equating to 132,276 AUMs of “unauthorized” forage consumption.<br /><br />As a result, BLM reported for 1976 that the actual “wild” horse and burro populations totaled 49,077 animals; 42,287 wild horses consuming 507,444 AUMs and 6,790 wild burros consuming 40,740 AUMs for a total of 547,680 AUMs.<br /><br />Another interesting note regarding BLM historical population records during this time period is, according to BLM data, the wild burro populations totaled 14,374 in 1974 with merely 70 burros removed by BLM and 207 burros claimed through the private ownership clause over the next two years. However, by 1976, BLM’s “wild” burro population estimates had plummeted to 6,583 (minus the 207 burros claimed under the private ownership clause), a loss of 7,791 burros (-54%) that have never been accounted for during this two-year period.<br /><br />In 1978 at the passage of PRIA, BLM estimated total horse and burro populations on public lands were 63,190 animals consuming 703,320 AUMs of forage; 44,380 horses (532,560 AUMs) and 9,160 burros (54,960 AUMs).<br /><br />But again, BLM claimed 9,650 of these horses consuming 115,800 AUMs failed to be “wild” and were privately claimed while 147 burros joined the private ranks of BLM authorized removals.<br /><br />As a result, BLM’s wild horse and burro population estimates were limited to 44,380 horses consuming 532,560 AUMs and 9,013 wild burros consuming 54,078 AUMs for a total of 586,638 AUM’s.<br /><br />In the year 2000, BLM went to Congress and reported that the drought stricken West could no longer support the current wild horse and burro overpopulation and lobbied Congress to fund what became known as the “Healthy Watersheds Initiative” passed in 2001. A this time, wild populations were estimated at 42,113 wild horses and 5,263 burros for a combined total population of 47,376 animals. Based on the 2000 population estimate, forage consumption by wild horses and burros equated to 565,356 AUMs for wild horses and 31,578 AUMs for burros totaling 596,934 AUMs.<br /><br />As of fiscal year 2009, BLM reports public rangelands can only support 23,633 wild horses requiring 283,596 AUMs and 2,915 wild burros requiring 17,490 AUMs for a national population total of 26,578 of animals with a maximum forage consumption need of 301,086 AUMs annually.<br /><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TI4afT70quI/AAAAAAAACJ8/v4vlavY0tys/s1600/WH%26B+Key+Historical+Population+Chart_9-12-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 350px; DISPLAY: block; HEIGHT: 199px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5516375718804892386" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TI4afT70quI/AAAAAAAACJ8/v4vlavY0tys/s400/WH%26B+Key+Historical+Population+Chart_9-12-10.jpg" /></a><br /><strong>Current Issues<br /></strong>There are many that argue the reason actual use by livestock is down from the historical levels issued in 1941 is rangeland productivity continues to decline due to decades of overstocking and failures to inventory forage production and/or provide even reasonably current carrying capacity analysis.<br /><br />Also, another consideration that fails to be incorporated in much of today’s current grazing dialogue is, according to a statistical analysis on livestock grazing titled “<a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0NzIxN2QzMDYxNmVlMjAw&pli=1"><span style="color:#cc6600;">Updating The Animal Unit Month” by John G. Carter</span></a> published on March 17, 2008, USDA market statistics revealed, “<em>The USDA National Agricultural Statistics Service data for average live weight cattle slaughter in 2004 was 1,242 pounds compared to 1,072 pound in 1984, or an increase of 15.8% in those 20 years.”</em><br /><br /><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/TI4aVFEweXI/AAAAAAAACJ0/uTwb_SL6RBw/s1600/Carter+AUM_Livestock+Live+Weight+Increase.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 239px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5516375543017142642" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/TI4aVFEweXI/AAAAAAAACJ0/uTwb_SL6RBw/s400/Carter+AUM_Livestock+Live+Weight+Increase.jpg" /></a><br />As a result, total forage consumption by cattle grazing on public rangelands has most likely increased proportionally due to these new “super sized” cows, which would require a 15.8% annual increase in forage consumption to support them.<br /><br />Based on BLMs 2008 reported livestock use, this could mean that up to 1,358,800 AUMs were consumed by cattle that remained unaccounted or unbilled for in BLMs actual use grazing data reports for 2008. If this hidden forage consumption were added to BLMs 2008 grazing totals, actual grazing use on BLM managed public rangelands may have reached as high as 9,958,800 AUMs consumed by livestock alone.<br /><br />This would indicate that while forage consumption by livestock on BLM managed public lands in 2008 had declined by 327,774 AUMs (-3.1%) since 1971 when the Wild Free-Roaming Horse and Burro Act was passed, it is a far cry from the 57% reduction BLM has been using to counter wild horse and burro advocate claims that BLM is removing wild horses and burros to increase livestock production on public lands.<br /><br />Of further significance, despite recorded drought conditions plaguing much of the West over the last two decades, actual livestock forage consumption may have potentially increased by as much as 573,822 AUMs (+6.1%) when comparing the year 2008 against 1978, when Congress passed the Public Rangelands Improvement Act in order to rein in the obvious and ongoing desertification being attributed mainly to overgrazing by the livestock industry.<br /><br /><strong><em>As a result, more forage may have been consumed by livestock on BLM managed lands in 2008 than when the Public Rangelands Improvement Act was passed thirty years ago!<br /></em></strong><br />Yet, today, just as back in 1978, the Department of the Interior continues to target wild horse and burro populations as the sole contributor to “degraded rangelands” – even though BLM’s dubious current estimate of 38,400 horse and burro population still grazing on public lands (33,700 wild horses and 4,700 wild burros) is now 24,790 animals less than what was estimated as grazing throughout the West at the passage of PRIA.<span style="font-size:78%;">(3)<br /></span><br />Also, according to Carter’s analysis, there is another serious factor in computing livestock actual use data and true forage consumption related to the cow/calf pair BLM and USFS bills for as, current live weight slaughter statistics indicate the AUM formulas still being applied for authorization and billing purposes are based on outdated weight averages that fail to reflect actual use.<br /><br />With respect to the cow/calf pair issue, Carter states; “<em>BLM and the Forest Service should update their 800 lb/month forage consumption rates (26 lb/day) to current forage consumption rates based on this best available information. Based on these figures, BLM and the Forest Service are generally underestimating forage consumption for a cow/calf pair by 732 lb/month, or nearly 50%. To account for this in grazing permits and annual billings, stocking rates must be reduced by a corresponding amount.</em>”<br /><br />While another potential 50% increase in unaccounted forage consumption formulas would obviously weigh in heavily with respect to more “hidden” consumption and the corresponding rangeland degradation being foisted on public lands by the livestock industry, because BLM has always allowed calves to graze “for free” (unlike wild horses and burros where BLM now uses a 20-25% “projected” increase due to foaling season to bolster their excess population percentages before they are even born), I have decided to omit calculating the calves potential impacts for now as they have always been hidden component of public lands grazing statistics since BLM’s inception.<br /><br />In addition to all the potential increases and hidden livestock consumption on western rangelands over the last thirty years, big game populations have also continued to expand throughout the West during much of this same time period and as a result, have caused additional “hidden” increases in forage consumption rates that today, BLM refuses to even include or analyze within the context of the “thriving natural ecological balance”.<br /><br />To illustrate this point, elk numbers have grown by 44 percent, from about 715,000 (5,148,000 AUMs annually) to over 1,031,000 (7,423,200 AUMs annually), between 1984 through 2009<span style="font-size:78%;">.(4)</span> Pronghorn antelope, estimated at approximately 26,604 animals (63,849 AUMs annually) between 1922-1924, are currently estimated at a minimum of 780,800 (1,873,920 AUMs annually) in just the nine states affecting wild horses and burros<span style="font-size:78%;">(5)</span>, while the national bighorn sheep population for 2008 is estimated at 70,000 adults (168,000 AUMs)<span style="font-size:78%;">(6)</span>. (<em>Note: As for national deer populations or those within the states affecting wild horses and burros, while some state statistics are available, too many gaps in current population estimates prevent a credible total analysis of either their populations or forage consumption impacts.</em>)<br /><br /><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 372px; DISPLAY: block; HEIGHT: 164px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5516375322441218402" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TI4aIPXW-WI/AAAAAAAACJs/9Y8sVutr6i4/s400/2008+Big+Game+Forage+Consumption+Chart_9-12-10.jpg" />Based on the current information available, combined big game species (minus deer populations) are estimated at consuming a minimum of 9,465,120 AUMs of forage annually. This also equates to 96.8% more forage allocation and consumption rates for these species than BLM’s national “appropriate” management level for wild horses and burros.<br /><br /><strong>The Final Forage Breakdown</strong><br />BLM’s current national management strategies aim to allocate 1.5% or less of available forage for wild horses and burros than is being used by livestock or big game. Even at the totally unsubstantiated current population estimate of 38,400 wild horses and burros BLM reports still remain on public lands, this equates to 404,400 annual AUMs for horses and 28,200 annual AUMs for burros, a combined total of 432,600 AUMs and merely 2.2% of what livestock and big game consumed in 2008.<br /><br />While Secretary Salazar and BLM Director Bob Abbey continue to insist it’s a “no-can-do” on stopping the round ups, wild horse and burro forage consumption rates are still the less than at any other “key” time in their legislative history - except of course when Congress declared they were “fast disappearing” due to decades of prior BLM extermination tactics that many argue continue today - unabated and without consequence.<br /><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/TI4Zy0ycZFI/AAAAAAAACJk/GRzWx-nJ5qI/s1600/2008_Forage+Consumption+Chart_9-12-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 381px; DISPLAY: block; HEIGHT: 120px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5516374954529809490" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/TI4Zy0ycZFI/AAAAAAAACJk/GRzWx-nJ5qI/s400/2008_Forage+Consumption+Chart_9-12-10.jpg" /></a><br /></div><div align="center"><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3YTM4YTc5YmY2NWQxMjBh"><strong><span style="color:#cc6600;">CLICK HERE FOR BLM'S 2007<br />WILD HORSE & BURRO PROGRAM HISTORY</span></strong> </a></div><br /><br /><span style="font-size:78%;">(1)BLM Grazing Fact Sheet http://www.blm.gov/wo/st/en/prog/grazing.html<br />(2) BLM History of the Wild Horse and Burro Program - Fiscal Year 2007<br />(3) BLM Wild Horse & Burro Program Quick Facts, Updated 8/25/10, downloaded 9/11/10, available at: http://www.blm.gov/wo/st/en/prog/wild_horse_and_burro/wh_b_information_center/Fact_Sheet.html(4) Elk Population Reflects Success of RMEF’s First 25 Years, Rocky Mountain Elk Foundation, Press Release, April 27, 2009, http://www.rmef.org/NewsandMedia/NewsReleases/2009/ElkPopulations.htm<br />(5) (a)2002 Pronghorn Antelope populations obtained from Pronghorn Population Totals as of 2002, Nevada’s PronghornAntelope: Ecology, Management and Conservation, Nevada Department of Wildlife, 2003, Table 2, available at: http://www.ndow.org/about/pubs/pdf/reports/pronghorn.pdf<br />(b) 2006 Pronghorn antelope population estimates for MT, WY were obtained from Conservation of the Northern Yellowstone Pronghorn: A Report and Possible Approach for NPCA’s Involvement, Blank, Intern, Stevens, July 2006,National Parks Conservation Association, pg. 1, MT/WY average.<br />(c) 2009 NM pronghorn antelope population obtained from NM Fish & Game at:<br />http://www.wildlife.state.nm.us/commission/presentations/documents/PronghornManagement.pdf(d) 2009 NV pronghorn antelope population estimates obtained from Nevada Department of Wildlife at: http://www.ndow.org/<br />(6) 2008 National bighorn sheep population estimates found at: “Bighorn Facing Smaller Habitat, Federal agency wantsto reduce protected area by more than 50%”, Mike Lee, Union-Tribue [San Diego], March 23, 2008, http://theguzzler.blogspot.com/search/label/Anza-Borrego%20Desert%20State%20Park<br /></span>Unknownnoreply@blogger.com6tag:blogger.com,1999:blog-4562357749295999770.post-72647340250155513882010-08-23T12:48:00.000-07:002010-08-23T12:49:06.253-07:00DEAR SUE<div align="justify"><em>Since mailboxes seem to be a hot topic with me these days, there was something else I found in it that was as completely unexpected as the ONDA/Ruby Conservation Agreement I received last month.<br /><br />It was a letter from Sue Cattoor inviting me to watch Cattoor Livestock Roundups, Inc. remove wild horses in the Red Desert of Wyoming.<br /><br />Her letter spoke of us finding common ground on the subject of wild horse and burro removals, how the services her company performs protected wild horses and burros from dying on drought striken and barren ranges and she offered encouragement for us to begin a dialogue about how to best help the wild horses and burros still left.<br /><br />While I could not accept her invitation to stand witness to more removals of the Red Desert wild horses, I was able to respond to her offer to begin a dialogue about what is REALLY going on in the Wild Horse & Burro Program.<br /><br />Though my response is now a year old, with more wild horses being removed from the Adobe Town/Salt Wells HMA in Wyoming and BLM gearing up to sweep the last of the Moriah herds forever from the range – one of the last legs of the Ely Districts progressive march towards the wild horse and burro cleansing campaign they began so many years back – I couldn’t help but feel my letter to Sue was just as valid today as it was a year ago.<br /><br />It also seems that Sue wasn’t really interested in us beginning a dialogue after all as she never did respond….</em><br /><br /></div><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/THLJqhqs6wI/AAAAAAAACJU/T-pIi9AG2xE/s1600/Ely+Round+Up_2006-GAO+Report.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 186px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5508687026656701186" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/THLJqhqs6wI/AAAAAAAACJU/T-pIi9AG2xE/s400/Ely+Round+Up_2006-GAO+Report.jpg" /></a> <div align="center"><span style="font-size:78%;">BLM Ely District - Wild Horse Round Up<br />Source: 2008 GAO Report on WH&B Program</span> <div align="justify"><br /><br />Cattoor Livestock Roundups, Inc.<br />Dave and Sue Cattoor<br />P.O. Box 289<br />Nephi, Utah 84648<br /><br />July 25, 2009<br /><br />Dear Sue:<br /><br />Thank you for contacting me regarding wild horse and burro management and removals from public lands performed by your company, Cattoor Livestock Roundups, Inc.<br /><br />First, I must apologize for taking so long to respond to your gracious invitation to witness “what you do”. I would also like to sincerely thank you for your willingness to open up the lines of communications and exchange ideas regarding the management, protection, and preservation of America’s mustangs and burros.<br /><br />With respect to your invitation to attend the upcoming Wyoming gather, I must politely decline as both the expense and ability to take time off from my job would be impossible to coordinate at this time.<br /><br />However, barring these personal facts, I must say that after spending the last three years studying almost every aspect of public resource management and the BLMs Wild Horse & Burro Program, of which your company is an integral part of, I am gravely concerned about many aspects of the Program. Because of this, I strongly support an immediate moratorium on any further round ups until an independent count of wild horses and burros both on and off the range is conducted.<br /><br />With over 80,000 wild horses and burros removed from public lands in the last eight years as well as the reported 33,000 whose lives are now at stake because of it, I believe the public deserves answers to serious fundamental questions about the Program and what the Department of the Interior has historically done that has brought us to the current sad state of affairs.<br /><br />Regarding your offer to “reach across the aisle”, so to speak, and share ideas on how to improve the Program, I am more than willing to open the lines of communications and exchange information towards that end.<br /><br />With that said, I thought we might first start with one of the most important issues in wild horse & burro management that your letter made reference too. Specifically, the fact that without your services, wild horses and burros can potentially suffer and die on the range due to lack of food and/or water.<br /><br />Let me start off by saying, I understand public resource management is a complicated issue, one that you or your company may only be involved with “after the fact”. The short version is, BLM tells you they need X amount of wild horses and/or burros removed and you show up with the trucks.<br /><br />However, have you ever really spent much time reading or researching how BLM comes up with these decisions? What other things they have authorized, approved of and implemented in these areas you only show up to remove wild horses and burros in?<br /><br />While you and your company may not feel this is within the scope of your contracts, perhaps if you really spent time reviewing what “BLM does”, you may not feel as confident, both from a company point of view as well as that of an American taxpayer, about what you do without getting some answers yourself!<br /><br />Also, if you are under the assumption as your letter implied, that I don’t believe wild horses and burros can overpopulate an area, let me clearly state that I know - no wildlife species left unchecked is immune from the effects of “overpopulation” and the resulting habitat degradation. I have seen reports, even from BLM themselves, which cite bighorn sheep, elk and mule deer all exceeding the carrying capacity of the range or destroying riparian areas at one time or another<br /><br />As you will see, my concerns are generally focused more on government accountability to the public and some of these issues concern both what your company or others like you, do or have done - but I do not try to argue or deny biological facts.<br /><br />To help give you an example of what I’m talking about, let’s take the emergency gather performed at the Nevada Wild Horse Range during the weekend of July 6-8 in 2007, during some of the hottest days on record in the State of Nevada. At the time, BLM cited these wild horses would have died if water hadn’t been hauled to sustain them. Despite this, water trapping was not utilized – helicopter driving was. In this instance, BLMs choice to drive them via helicopter made no sense whatsoever, either from a humane perspective or that of a taxpayer as the wild horses were already concentrating around the water BLM was hauling to them. Running horses or any animals during some of the hottest days on record was inexcusable, especially so when they had a viable alternative so readily available.<br /><br />Furthermore, the water situation at Nellis is a great example of the “behind the scenes” BLM management that you and your company may not be very aware of. Records indicate for over a decade, BLM knew the few water sources still remaining on the range, the ones that hadn’t been completely fenced off from any wild horse access over the years, had fallen into extreme disrepair. Rather than fix them, they spent all their funding towards round ups and reducing the AMLs to accommodate the continuing decline in water.<br /><br />Did you know that, when BLM reduced the AML of the Nellis wild horses in 2004, water availability was cited as the “key factor” they used to justify this, even though in their calculations they left out over 100 water sources found listed for the area?<br /><br />Between 2004 and 2008, BLM also failed to apply for water rights as they promised they would back in 2004 to help mitigate all the water sources that had been lost over the years. Then in 2008, they lied to the public when they presented their “No Action Alternative” in the new Nellis Wild Horse Range Herd Management Area Plan by omitting the fact that the “No Action Alternative” actually required them to apply for additional water rights and establish wells for the Nellis wild horses. Finally, they also “re-drew” management boundaries that excluded a whole bunch of former water sources wild horses use to use. My guess is they did this so they wouldn’t have to include them in their analysis and this helped them justify issuing lower AMLs.<br /><br />If that wasn’t enough, when BLM was “examining the impacts” of fencing other riparian areas on the Nevada Wild Horse Range, they described cutting off water sources to cattle as “being inhumane and causing them to suffer”. Yet, when it came time to talk about wild horses, they merely said how beneficial this would be to the riparian areas and plants – no mention of inhumane treatment or suffering for wild horses – only cattle! Doesn’t that strike you as a little unfair and indicative of gross prejudice?<br /><br />Here’s another example of on-the-range management going on behind the scenes that you and/or your company may not be aware of.<br /><br />While you may or may not be assigned to this round up, the BLM Ely District in Nevada has recently approved zeroing out almost 1.6 million acres for any future wild horse use on multiple HMAs. Currently, BLM is going through their paperwork process to schedule removals in the coming year. This area has had repeated round ups, sometimes annually, since BLM convinced Congress that a mass wild horse and burro cleansing campaign was necessary. Yet since then, BLM records show livestock authorizations have been continually going up even while wild horse AMLs keep going down and wildlife populations, or at least big game species in the areas, just continue to grow – all in areas BLM claims can no longer support any wild horses at all, despite these other increases.<br /><br />In addition to just wanting to share with you some of the things going on “behind the scenes” of the gathers you might be involved in, another reason I wanted to bring these examples up is, after reading your letter about removing wild horses and burros to protect the range and prevent them from suffering, I had some questions for you with respect to specific issues, such as;<br /><br />If your company gets assigned the contract to perform the final removals of these herds in the Ely District, will you care that BLM lied, omitted crucial information and just bullied their way through zeroing out the areas and authorizing their final removals? Or will you just scoop them up anyway and send them to holding – knowing what a precarious position that is these days?<br /><br />Has you or your company ever tried to bring attention to BLM about pitfalls you see on the range about what they have authorized, such as the decade long broken water systems in Nellis? Or have you ever considered refusing a job until BLM does the “right thing” to protect the wild horses and/or burros on the range too?<br /><br />According to federal contract records, Cattoor Livestock Roundups, Inc. has received over $12 million dollars since the year 2000 for your services of “Wild Horse & Burro Control”. I don’t believe anyone has made more money than Cattoor Livestock Roundup, Inc. when it comes to on-the-range management of wild horses and burros.<br /><br />Now I realize these next questions may be a bit forward but given the current crisis, I see no reason to tap dance around the issues, as these days, time is of the essence.<br /><br />What I was wondering is, how much you have you given back to these magnificent national icons that have given you and your family so much?<br /><br />Have you sponsored any range improvements such as solar pumps on wells or any other water developments, looked into negotiating with local ranchers to keep the water turned on once the livestock are removed, or perhaps funded fence removals to prevent their entrapment during times of poor range conditions, maybe contributed towards re-seeding programs in areas damaged by wildfires, helped support the adoption program somehow or maybe donated to a local rescue that specializes in wild horses and burros or contributed anything to short or long term holding facilities?<br /><br />The Palomino Valley Holding Facility in Northern Nevada has failed to comply with BLMs own rules about the kinds of facilities required for adopters to adopt a mustang or burro. Specifically, BLMs own rules mandate a certain amount of shade must be provided for protection from the elements before someone can take them home. However, when it comes to their own facilities, BLM has placed this as a bottom priority and during my visit there last year, there was no cover or shade provided anywhere in the large holding pens.<br /><br />Did it ever occur to you and your company to perhaps help sponsor the water developments so desperately needed in Nellis for all those years or to sponsor some shelter for those whom you continually truck in to Palomino Valley?<br /><br />Can you understand what I am driving at? You and your company often express concern about range conditions needing to be able to support wild horses and burros, range conditions that are often degraded due to BLMs or other agencies actions and decisions.<br /><br />Sometimes it’s adding more fencing for more pasture rotations for more livestock or increasing livestock authorizations to such a point that the range is no longer capable of sustaining anything else.<br /><br />Sometimes it’s allowing increases in both habitat and populations for big game that couldn’t normally expand into these areas without a whole lot of help from wildlife agencies (such as guzzlers for bighorn or pronghorn antelope), which in turn places additional stress on wild horse and burro resources too. BLM often fails to examine or report on these impacts all the while citing they “don’t manage wildlife” and therefore, don’t have to acknowledge what is really going on out there with respect to resource competition and the “natural thriving ecological balance” they are lawfully charged with protecting. The only thing they will cite in their environmental assessments is, it is important to remove wild horses and burros to protect wildlife but they never address the issue of these expanding wildlife populations and what may be necessary to protect wild horses and burros or the critical resources they need to survive as well.<br /><br />BLM often authorizes fencing off the majority of springs in an area or critical pieces of land that contain the natural water sources get transferred to “other agencies” that don’t manage for wild horses and burros or maybe were once in the original Herd Area but are removed when BLM drew up the new HMA boundaries; then BLM cites the lack of “natural water sources” in the area to again reduce or remove populations even more.<br /><br />In plans that will shut wild horses and burros out from historical water sources or migratory routes or trap them in livestock depleted pastures after the livestock have been removed, they rarely try to actively explore or pursue sincere alternatives to mitigate the impacts of these proposals.<br /><br />Sometimes plans have been approved that shut them out from what is often the most abundant areas - now fenced for exclusive livestock use while the forage is available and often these exclusions have devastating effects during drought years or during the hottest or coldest parts of the year when they, and all wildlife, need those resources the most to survive.<br /><br />I know we both agree that these are critical issues and I was just wondering what you have personally done to try and help mitigate all the things BLM has approved of over the years that have, and continue to effect healthy populations and habitat with respect to wild horse and burro protection and preservation.<br /><br />Also, there is another question I feel compelled to ask that I would really like an answer to.<br /><br />I have read both in published interviews as well as on your website that you and your husband are active supporters of slaughtering mustangs and burros vs. allowing them to languish in long term holding pens. One of the things I’m scratching my head about is; your recent letter and website often reference Wild Horse Annie’s name as well as her letter of recommendation posted on your website as support for “what you do”.<br /><br />Yet Wild Horse Annie did not support rounding up wild horses and burros for slaughter, government sanctioned or not – it was what she was trying to save them from! She knew it wasn’t just the way they were being rounded up but also what horrible treatment they endured during transport and the kind of death they could expect at the slaughterhouses. How do you reconcile the fact that you only support removals in her name but justify slaughtering them once your services have been performed?<br /><br />The last issue I would like ask you about is; BLMs numbers of the wild horse and burro populations continue to make no sense whatsoever, year after year. They remove them, they tell the public they have reasonably achieved AML and then a few years later, population reports defy any discernable logic as to how they got so large in such a limited amount of time. (Think hundreds of percentage increases!) And these reports just keep coming from the same areas, over and over and over again. How is that possible?<br /><br />BLM has recently been leaning on their inability to accurately census wild herds by a large margin to explain these continuous “population explosion” reports. Yet, I cannot find credible sources that state the historical counting techniques BLM has used over the years are really this inaccurate. In fact, quite the contrary as many people I have talked to with on the ground experience say BLM is pretty darn good at predicting about how many wild horses are out on the range, both before and after the gathers.<br /><br />Based on your long history with the Wild Horse & Burro Program and your own hands on experience, can you provide any feedback on this? Do you agree with BLMs reports, which in essence reflect on your company’s ability to locate wild horses and burros on the range during the gathers, that the methods used over all these years are really completely inaccurate and amount to little more than guesswork by all those involved?<br /><br />Is your company really prone to missing dozens and dozens, if not hundreds of horses, on a consistent basis during the gathers?<br /><br />Again, I would like to thank you for taking the time and making the effort to contact me as well as your invitation to the Wyoming round ups. I am looking forward to your response and continuing dialogues about how best to preserve and protect America’s mustangs and burros and the critical habitat they need to survive.<br /><br />Sincerely,<br />Cindy MacDonald </div></div>Unknownnoreply@blogger.com6tag:blogger.com,1999:blog-4562357749295999770.post-76634402932281996652010-08-06T14:55:00.001-07:002010-08-06T15:00:03.996-07:00ON DA TAKE<div align="justify">It showed up in my mailbox with no return address. Its title was marked “Confidential”and its contents provided the only explanation necessary.<br /><br />It was a Draft agreement bought for the humble price of $5 million dollars; the price tag put on the final elimination of the wild horses and burros – or what’s left of them - now residing in the Sheldon National Wildlife Refuge and whom had done so for centuries.<br /><br />The executioner will be Secretary Salazar, who will mumble something about the Refuge having another “mission” within the Department of the Interior. He will ignore the facts; that the Wild Free-Roaming Horse and Burro Act charged him with their care on public lands “where presently found”, that the <a href="http://americanherds.blogspot.com/2010/04/calico-past-present-future-iii.html"><span style="color:#cc6600;">Sheldon wild horses and burros</span> </a>were once protected under the umbrella of the Act until a policy change stripped them of any future protections - and he will ignore the fact that both BLM and US Fish & Wildlife Service have repeatedly stated that “protected” wild horses and burros from BLM managed lands wander in and out of Sheldon.<br /><br />Salazar will hide behind a sea of bureaucracy, despite being named by Congress as the ultimate authority in the protection and preservation of America’s wild horses and burros.<br /><br />And finally, he will claim their blood is not on his hands – that’s what the henchman are for.<br /><br />On May 26, 2010, American Herds posted the fifth in the “<a href="http://americanherds.blogspot.com/2010/05/calico-past-present-future-v.html"><em><span style="color:#cc6600;">Calico: Past, Present & Future</span></em></a>” series that outlined how a draft plan between multiple agency’s had been developed and submitted to the owners of the Ruby Pipeline and was to be slid under the table through the deceptive title, “<strong><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1YWNmY2FjMmQ0ZjcwZWVj&pli=1"><span style="color:#cc6600;">Draft Ruby Pipeline Migratory Bird Conservation Plan</span></a></strong>”.<br /><br />Approximately $17 million dollars of conservation and mitigation measures were outlined within its pages – though much, much more was planned - with what appeared to be many open-ended “undisclosed” purchases that didn’t needed to be committed to on paper.<br /><br />One of these undisclosed “conservation measures” turned out to be $20 million dollars Ruby would hand out to two environmental organizations who had previously been opposing Ruby’s habitat ripping path; Western Watershed Project (WWP) and Oregon Natural Desert Association (ONDA) as outlined here in the July 26, 2010, article, “<a href="http://www.newwest.net/topic/article/groups_trade_gas_pipeline_approval_for_20_million_conservation_fund/C35/L35/"><em><span style="color:#cc6600;">Groups Trade Gas Pipeline Approval for $20 Million Conservation Fund</span></em></a>”.<br /><br />What else did Ruby’s $20 million dollars buy?<br /><br />Well,it also bought them a new three member Board for each organization from which a Director from Ruby Pipeline would now be entrenched in order to make decisions on how the funds could be spent.<br /><br />And it bought them the confidential document that showed up in my mailbox, the “<strong><a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1YTEzYTUxMGJmZWY4OGNk"><span style="color:#cc6600;">Greater-Hart Sheldon Conservation Fund Agreement</span></a></strong>” made between ONDA and Ruby, which outlines how the funds can be expended, which include “the removal or improvement in management of feral horses”. <span style="font-size:78%;">(pg. 4)</span><br /><br />One has to wonder, how can Ruby and ONDA’s partnership incorporate funding “<em>the removal and management</em>” of feral horses when supposedly, they have nothing to say about how the DOI and Secretary Salazar handle our public resources. That’s U.S. Fish & Wildlife Services (USFWS) job, right?<br /><br />Right! And that’s exactly what USFWS is doing right now, putting forth three “alternatives” to the public that we can comment on as they move to the next phase of their <a href="http://www.fws.gov/pacific/planning/main/docs/NV/docssheldon.htm"><span style="color:#cc6600;">Comprehensive Conservation Plan</span></a> for the Sheldon NWR in <a href="http://www.fws.gov/pacific/planning/main/docs/NV/Sheldon/Sheldon%20PU%203%20-%20crop%20_whole.pdf"><span style="color:#cc6600;">Planning Update 3</span></a>.<br /><br />The choices USFWS have crafted?<br /><br /><strong>> Alternative 1: No Action<br /></strong>This would allow a maximum of 125 horses and 60 burros to inhabit the Refuge throughout the life of the Plan.<br /><br /><strong>> Alternative II: Intensive Management (Preferred Alternative)<br /></strong>Eliminate all horses and burros from the Refuge within 5 years and include the option for sale or auction if other methods of population control are ineffective.<br /><br /><strong>> Alternative III: Low Intensity Management</strong><br />Eliminate all horses and burros from the Refuge within 15 years and include the option for sale or auction except more gradual annual population reductions.<br /><br />And who is going to fund these removals and other “management” options such as population control methods on herds they intend on eliminating anyway? Yes, who indeed…<br /><br />While Ruby’s PR people are sputtering eloquent quotes about their total lack of involvement in the management and removal of America’s horses and burros and BLM is publishing <a href="http://www.blm.gov/wo/st/en/info/newsroom/2010/july/NR_07_21_2010.html"><span style="color:#cc6600;">News Releases</span> </a>calling Ruby’s involvement “a myth”, it will be Ruby’s Director – and Ruby’s cash – that quietly sit in a partnership account waiting behind the scenes.<br /><br />As for ONDA, after the confidential anonymous packet showed up and I could finally scrap my jaw up off the floor, I wrote ONDA’s Executive Director, <a href="http://onda.org/about/staff/staff-1#brent-fenty"><span style="color:#cc6600;">Brent Fenty</span> </a>to ask him to verify rumors about ONDA making deals with USFWS to remove wild horses and burros from Sheldon.<br /><br />On July 20, 2010, Mr. Fenty kindly wrote back and stated no deals were being made with USFWS and the rumors were completely false. What a relief, huh?<br /><br />Can we call him a liar since I didn’t directly ask him if ONDA made a deal with Ruby instead? After all, what if he actually had some integrity and would tell the truth?<br /><br />While Mr. Fenty shied away from telling the truth about the new Ruby/ONDA partnership deal, he was certainly not shy about expressing ONDA’s position on wild horses and burros inhabiting Sheldon and offered a courtesy copy of the comments ONDA and WWP submitted to USFWS in June 2008 during the last public phase of the planning process. <a href="https://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxODY3M2M0NzNhNmI4MWYw"><span style="color:#cc6600;">Click Here</span> </a>to view.<br /><br />Welcome to the fabulous world of partnerships, privatization of public resources and the Obama/Salazar vision of “Change”.</div><div align="center"><br /><br />As for the historical wild horses and burros of Sheldon<br />(and maybe some wandering BLM “managed” horses too)?<br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TFx6e2OFqSI/AAAAAAAACJM/2GroTdj-PhI/s1600/Sheldon+Horses-1.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 344px; DISPLAY: block; HEIGHT: 247px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5502407515109173538" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TFx6e2OFqSI/AAAAAAAACJM/2GroTdj-PhI/s400/Sheldon+Horses-1.jpg" /></a><br />Kiss their ruby red blood goodbye... </div>Unknownnoreply@blogger.com13tag:blogger.com,1999:blog-4562357749295999770.post-80856269536905477862010-07-28T03:37:00.001-07:002010-07-31T15:49:18.423-07:00In The Pink<div align="justify">BLM is currently accepting public input on a document titled, “<a href="https://www.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&projectId=4900"><span style="color:#cc6600;">Wild Horse & Burro Strategy Development Document</span></a>”, 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.<br /><br />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.<br /><br />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.<br /><br />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 <em>do</em> care. <em>Really…</em><br /><br />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 <em>doing something</em> -but this time it’s different, right?<br /><br />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.<br /><br />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.<br /><br />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….<br /><br /><strong><span style="font-size:130%;">></span></strong> 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. (<em>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?)</em><br /><br /><span style="font-size:130%;"><strong>></strong></span> BLM admitting <a href="http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/national_page.Par.92329.File.dat/Counting_Wild_Horses_and_Burros.pdf"><span style="color:#cc6600;">they can’t count the number of horses on the range</span> </a>within even a marginal degree of accuracy. (<em>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...)</em><br /><br /><strong><span style="font-size:130%;">></span> </strong>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 <a href="http://www.equinewelfarealliance.org/"><span style="color:#cc6600;">Equine Welfare’s Alliance</span> </a>newest press release, "<a href="http://www.equinewelfarealliance.org/Press_Releases.html"><span style="color:#cc6600;">How Do You Make 2000 Horses Disappear? Let BLM Manage Them"</span></a> (plus supporting documents), which clearly show how over 2,000 horses are now missing from BLM Holding Facility Chart Reports. (<em>Editors Note: This is the <a href="http://americanherds.blogspot.com/2010/03/tidbits-toadstools.html"><span style="color:#cc6600;">second time</span> </a>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.</em>)<br /><br /><span style="font-size:130%;"><strong>></strong></span> 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.<br /><br /><strong><span style="font-size:130%;">> </span></strong>Recently, BLM Public Relations Specialist JoLynn Worley explained via email that the population BLM had been reporting for <a href="http://americanherds.blogspot.com/2010/07/pilot-valley-or-toano.html"><span style="color:#cc6600;">Toano Herd Area</span> </a>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. (<em>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</em>). 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 <em><strong>fraud.</strong></em> 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…)<br /><br /><span style="font-size:130%;"><strong>></strong> </span>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. <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDozOWEzNTk2MjMzZTkzNzM&pli=1"><span style="color:#cc6600;">Click Here</span> </a>to view an updated chart on how often this has now happened.<br /><br /><span style="font-size:130%;"><strong>></strong></span> 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 <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1ZTMzMWRhMDE2YTZkNzg5&pli=1"><span style="color:#cc6600;">1997 PEER Report; Horses To Slaughter - Anatomy of a Cover Up</span></a>) as well as reports surfacing that approximately 32,000 wild horses were already missing from BLM records as far back as 1998. (see <a href="http://commdocs.house.gov/committees/resources/hii50579.000/hii50579_0.HTM"><span style="color:#cc6600;">1998 Range Issues Field Hearing before the Subcommittee on National Parks and Public Lands</span></a>).<br /><br /><span style="font-size:130%;"><strong>></strong> </span>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 <a href="http://americanherds.blogspot.com/2008/11/slight-of-hand.html"><span style="color:#cc6600;">Ely Resource Management Plan</span> </a>or the <a href="http://americanherds.blogspot.com/2010/07/what-judge.html"><span style="color:#cc6600;">West Douglas Herd Area</span></a>) or choosing to <a href="http://americanherds.blogspot.com/2009/12/blm-photo-2004-warm-springs-hma-wild.html"><span style="color:#cc6600;">bury monitoring data</span> </a>from <em>their own Wild Horse & Burro Specialist</em> that testified under oath that rangeland health objectives were being met - despite wild horse populations being significantly over BLMs mythical AMLs.<br /><br /><span style="font-size:130%;"><strong>></strong></span> 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.<br /><br /><span style="font-size:130%;"><strong>></strong></span> 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 <a href="http://www.blm.gov/wo/st/en/prog/wild_horse_and_burro.html"><span style="color:#cc6600;">Twitter, Facebook and their very own YouTube Channel!</span> </a><br /><br />Too bad they couldn’t have devoted the same time, effort and money towards promoting wild horse and burro adoptions, huh? (see <a href="http://americanherds.blogspot.com/2009/10/blms-national-wild-horse-adoption-day.html"><span style="color:#cc6600;">BLM's National Wild Horse Adoption Day</span></a>).<br /><br /><br />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….<br /><br />Currently, BLM is soliciting public input on where to go with the Wild Horse & Burro Program – again.<br /><br />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.<br /><br />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.<br /><br /><a href="https://secure2.convio.net/ida/site/Advocacy?cmd=display&page=UserAction&id=1567"><span style="color:#cc6600;">In Defense of Animals</span> </a>has put together a great response, including <a href="http://www.idausa.org/campaigns/horses/BLM_Strategy_Action_Alert_LETTER.pdf"><span style="color:#cc6600;">a letter</span> </a>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.<br /><br />However, whatever way you decided to go, here’s a word of caution;<br /><br />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.<br /><br />Therefore, I would HIGHLY recommend you send any comments Return Receipt Requested so that,<br /><br />a) You have a dated receipt and postmark that proves you submitted comments prior to the deadline and,<br /><br />b) You know for sure BLM received your comments and if necessary, can prove that as fact in a court of law.<br /><br />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-<br /><br />"<strong><em>Don’t wait for BLM to submit their resignation, give them the pink slip NOW!"</em></strong> </div><br /><div align="center"><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoyNjE0MzUxYjk5NTNkMTUy&pli=1"><span style="color:#cc0000;">Click Here</span> </a>to review my personal input and submission. </div><br /><div align="center"><br /><strong>~Mailing Address~<br /></strong><br />Wild Horse & Burro Strategy Development Document<br />BLM Washington Office<br />1849 C Stree NW, Rm. 5665<br />Washington, DC 20240<br /><br /><strong>!NEW EMAIL ADDRESS!<br /></strong>wildhorse@blm.gov<br /><div align="justify"><br />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!</div></div><br /><div align="center"><br /><a href="http://www.blm.gov/wo/st/en/info/newsroom/2010/july/NR_7_30_2010.html"><strong><span style="color:#cc6600;">7/30/10...BLM Announces 30 Day Extension of Public Comment Period</span></strong> </a><br /><br /><a href="http://rtfitch.wordpress.com/2010/07/31/blm-extends-comment-period-but-for-whos-benefit-not-the-wild-horses/"><strong><span style="color:#cc6600;">7/31/10...BLM Extends Comment Period But For Who's Benefit,<br />Not The Wild Horses</span> </strong></a><br /><em>Straight From The Horse's Heart: R.T. Fitch<br /></em></div>Unknownnoreply@blogger.com3tag:blogger.com,1999:blog-4562357749295999770.post-44935071014371875202010-07-15T06:47:00.000-07:002010-07-15T06:56:10.708-07:00What Judge?<div align="justify">The BLM is accepting public comments through Monday, July 19, 2010, for the planned removal of the entire West Douglas wild horse population. <a href="http://www.blm.gov/pgdata/etc/medialib/blm/co/field_offices/white_river_field/2010_completed_eas.Par.48066.File.dat/DOI-BLM-CO-110-2010-0088-Preliminary%20EA.pdf"><span style="color:#cc6600;">Click Here</span> </a>to review the Preliminary Environmental Assessment.<br /><br />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; <div align="center"><br /><strong>A FEDERAL JUDGE TOLD BLM LAST YEAR IT WAS ILLEGAL! </strong><div align="justify"><br />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.<br /><br />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. <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzM3xneDo0ZjAwNTVhMGVlNjNiZGU4&pli=1"><span style="color:#cc6600;">Click Here</span> </a>to read Judge Collyer’s decision.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />If you’d like to add your voice in protest of BLMs continued defiance of both law and judge, please submit comments by: <div align="center"><br /><strong>~PUBLIC COMMENT DEADLINE~<br />MONDAY, JULY 19, 2010</strong><br /><strong>4:30 p.m. <em>m.s.t.</em><br /></strong><br />Bureau of Land Management<br />White River Field Office<br />Attention: Melissa Kindall<br />220 E. Meeker, CO 81641<br />Phone: 970-878-3842<br />FAX: 970-878-3805<br />E-Mail: melissa_kindall@blm.gov<br /><div align="justify"><br />Be sure to include in your title, West Douglas Wild Horse Removal Plan, EA# DOI-BLM-CO-110-2010-0088-EA.<br /><br />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. </div></div></div></div></div>Unknownnoreply@blogger.com2tag:blogger.com,1999:blog-4562357749295999770.post-66622472269501217322010-07-08T13:08:00.001-07:002010-07-08T13:08:46.572-07:00Pilot Valley or Toano?<div align="justify"><em>The following press release was sent out on 7/07/10 by <a href="http://equinewelfarealliance.org/"><span style="color:#cc6600;">The Equine Welfare Alliance</span></a>, 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 <a href="http://www.animallawcoalition.com/"><span style="color:#cc6600;">Animal Law Coalition</span></a>, 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.</em></div><p align="justify"><br /><strong>Doubt Cast On Pilot Valley “Estray” Horses Rounded-Up By BLM</strong><br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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?<br /><br />Suspicions are further fueled by the unusual suddenness of the roundup, just 48 hours after notice of the removal was posted. "<em>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</em>," said Valerie James Patton, Vice President of Equine Welfare Alliance (EWA).<br /><br />"<em>Even BLM's own news release stated those horses had been there a long time, long enough to grow in size</em>", Patton added. "<em>So now the question becomes, how long is a long time? Since 1993 when BLM filed papers to zero out the Toano Herd Area</em>?"<br /><br />“<em>Given the long history of abuse and impropriety that has characterized the Wild Horse & Burro Program, I have to ask</em>,” said EWA’s Vicki Tobin, “<em>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.</em>”<br /><br />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, "<em>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?</em>"<br /><br />"<em>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</em>", she said.<br /><br />“<em>The Department of Interior has an almost unblemished reputation as a consistent source of scandal, mismanagement and corruption</em>,” explained EWA president John Holland, “<em>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.</em>”<br /><br />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.<br /><br />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.<br /><div align="center"><br /><strong>Contacts<br /></strong><br />Valerie James-Patton<br />Equine Welfare Alliance<br />530-474-1128<br />valerie_jamespatton@yahoo.com<br /><br />Laura Allen<br />Animal Law Coalition and Equine Welfare Alliance, general counsel<br />607.220.8938<br />lauraallen@animallawcoalition.com<br /><br />#<br /><br />What evidence indicates the Pilot Valley estray horses may instead<br />be federally protected wild horses from the Toano range? <a href="http://equinewelfarealliance.org/uploads/Toano_Wild_Horse_Herd_Area.pdf"><span style="color:#cc6600;"><br />Click Here</span> </a>to view.</div><div align="justify"><br /><br />**********************************************************************************<br /><br /><em>The following additional information was supplied by Willis Lamm of <a href="http://www.aowha.org/activities/pilot_valley_rescue01.html"><span style="color:#cc6600;">Alliance of Wild Horse Advocates</span> </a>regarding current rescue efforts for these horses now being made by Jill Starr of <a href="http://www.wildhorserescue.org/"><span style="color:#cc6600;">Lifesaver’s Wild Horse Rescue</span></a>.<br /></em><br />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. <div align="center"><br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TDYrie9p7mI/AAAAAAAACI8/Y2TF-oVnxVk/s1600/pilot_valley_horses01.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5491624667052109410" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TDYrie9p7mI/AAAAAAAACI8/Y2TF-oVnxVk/s400/pilot_valley_horses01.jpg" /></a><span style="font-size:85%;">Photo of horses slated for auction on Saturday, July 10, 2010<br />Courtesy of Willis Lamm and AOWHA</span><br /><div align="justify"></div></div><br />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.<br /><br />This effort is not intended to exclude any qualified and caring private individuals from acquiring some of these horses. <div align="center"><br />Complete details are posted in the </div><div align="center">Alliance of Wild Horse Advocates' War Room at -<br /><a href="http://www.aowha.org/activities/pilot_valley_rescue01.html">http://www.aowha.org/activities/pilot_valley_rescue01.html</a> </div></div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-4562357749295999770.post-90642182309774017962010-07-04T16:37:00.000-07:002010-07-04T16:39:29.189-07:00Calico: Past, Present & Future VII<div align="justify"><em>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….<br /></em><br />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?<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />And so, without further ado, this is where I think it is going and why….<br /><br />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?<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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?<br /><br />Well, a new plan could reset the bureaucratic clock and again initiate the same “processes” filled with more promises for the future…<br /><br />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.<br /><br />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.<br /><br />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.<br /><br />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?<br /><br />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?<br /><br />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?<br /><br />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.<br /><br />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?</div><div align="justify"><br />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).<br /><br />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?<br /><br />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.<br /><br />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.<br /><br />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….<br /><br />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”.<br /><br />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.<br /><br />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.<br /><br />How will BLM continue to justify these crazy population numbers? Well, a new plan might be really useful…<br /><br />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.<br /><br />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, “<em>Oh, the horses must have moved - over there</em>” and I know this as fact because I have seen it used at least a dozen times before.<br /><br />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.<br /><br />Mega Complex, indeed….<br /><br />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.</div>Unknownnoreply@blogger.com1tag:blogger.com,1999:blog-4562357749295999770.post-37495948858993586232010-06-19T16:38:00.001-07:002010-06-19T16:38:53.555-07:00Calico: Past, Present & Future VI<div align="justify"><em>This is the sixth in a series of articles that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond….<br /></em><br />The beginning of this series originally presented a forward stating, “<em>To understand the magnitude of what has occurred here – as well as to grasp where it is going and why – first, we must travel back in time to witness what BLM did, how they got away with it and how they plan to continue harvesting the bitter crops they began cultivating over two decades ago</em>”.<br /><br />The Calico Complex is just a piece of a larger plan for the area by BLM and US Fish & Wildlife Service (USFWS) currently being hailed as the <a href="http://www.examiner.com/x-25094-LA-Equine-Policy-Examiner~y2010m4d6-BLM-envisions-tristate-mega-complex-for-wild-horses"><span style="color:#cc6600;">Tri-State Mega Complex</span> </a>as reported on April 6, 2010, by Carrol Abel of the LA Equine Policy Examiner.<br /><br />Here, officials reported the “<em>conceptual stages of creating a two million acre management complex for wild horses in Southeast Oregon, Northeast California, Northwest Nevada and the Sheldon National Wildlife Refuge also in Northeast Nevada</em>”, is now on the table.<br /><br />As a result, this series of posts has done in depth research and historical backgrounds for each of the areas still containing wild horses affected by the Tri-State proposal, which have included the Calico Complex, Massacre Lakes, Nut Mountain, Wall Canyon and the Sheldon National Wildlife Refuge. That just leaves the wild horses of Southeast Oregon…<br /><br /><br /><strong>THE BEATY BUTTE HMA</strong><br /><br />The Beaty Butte HMA is located at the southern tip of Oregon and is in the vicinity of the Sheldon National Wildlife Refuge.<br /><br />The National Program Office reports both the Herd Area (HA) and Herd Management Area (HMA) is identical at 399,185 public acres and 38,837 “other” acres totaling 438,022 acres.<br /><br />The wild horse AML has been set at a high of 250 horses or another way of saying it is, wild horse populations cannot exceed more than one horse per 1,752 acres. This AML was established in 1983 in the High Desert Management Framework Plan and has obviously been rubber-stamped every since….<br /><br />Also, when I say “high AML”, I am referring to a policy change by BLM made about ten years ago when they decided to start using a “range” of AML that contains both a low and a high end. This range is based on the theory that if BLM maintained a 4-5 year removal schedule, the “low” would allow wild horses to grow during that 4-5 year time frame before they exceeded the “high”. Based on this criteria, the AML range is suppose to follow a percentage method that usually cuts the “high” AML down by 60% to allow for normal growth between scheduled removals before the “high” is exceeded.<br /><br />In the case of the Beaty Butte HMA, BLM has set it the AML range at a 100-250 horses, which should allow for a five-year span between each round up. However, according to BLM in the 2009 Beaty Butte EA, these wild horses double in population every three years, not five, indicating a 33% reproduction rate.<br /><br />With respect to forage, according to the 2009 EA, the current forage allocations for the Beatys Butte HMA are:<br /><br />> Livestock: 26,121 AUMs Active Preference<br /><br />> Wild Horses: 3,000 AUMs<br /><br />> Deer: 500 AUMs<br /><br />> California Bighorn Sheep: 240 AUMs<br /><br />> Pronghorn Antelope: 22 AUMs<br /><br />> Elk: 0 AUMs<br /><br />BLM also stated that, “<em>pronghorn antelope, mule deer and California bighorn sheep use the HMA for summering and wintering ranges</em>”.<br /><br />In September 2009, BLM conducted a round up of the Beaty Butte wild horses. In the Post-Gather Report, BLM reported a pre-removal population estimate of 485 wild horses of which they gathered 423, removed 379 - including four reported deaths - and treated 30 mares with PZP who were returned to the range with an estimated 102 wild horses remaining.<br /><br /><br /><strong>THE MALE COMPONENT</strong><br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TB081KurVdI/AAAAAAAACIw/vEYD33tWr60/s1600/Beatys+Butte_11-25-09.jpg"><img style="MARGIN: 0px 0px 10px 10px; WIDTH: 196px; FLOAT: right; HEIGHT: 320px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5484606805317998034" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TB081KurVdI/AAAAAAAACIw/vEYD33tWr60/s320/Beatys+Butte_11-25-09.jpg" /></a>In September 2009, when BLM signed off on the environmental assessment to remove wild horses from the Beaty Butte HMA (and Paisley Desert HMA), they also slid in a ten-year plan authorizing “<em>adjusting the ratio of males to females to approximately 60/40 and returning geldings to the HMA as part of the male component, in combination with treatment of all breeding age mares released back to the range with PZP to further slow population growth</em>”.</div><div align="right"><span style="font-size:78%;"><br />Beatys Butte wild horse.Captured 11/25/09</span></div><div align="justify"><br />The criteria BLM has established to trigger these “additional” population control measures cited above is, “<em>if population inventory indicates an average herd growth rate greater than 10% following the September 2009 gather.”</em> In other words, if the PZP injections after the 2009 gather don’t drop the reproduction rate to 10% or less, BLM will take more drastic actions until it does – including adding castrated stallions to PZP’d mares and returning them to these HMA’s as well <div align="justify"><br />I also have to comment on an anomaly with respect to BLM’s Final Decision on that EA as something very unusual happened I had never seen before. Specifically, BLM signed the decision and then rescinded it and wrote a new one. Why?<br /><br />Well, as near as I can figure, the first decision authorized the castration of stallions immediately while the second decision put it off for “future” management. It also appeared that there were some legal issues BLM was attempting to circumvent in order to establish a new precedent for returning castrated stallions to the range.<br /><br />Also, that first decision that was later rescinded was not only sent to the “usual” stakeholders (meaning the public, various organizations and agency’s), it was also sent to the Interior Board of Land Appeals and BLM’s lawyers, who apparently bounced it back with a few “changes” to push it on through….<br /><br /><br /><strong>SOUTH STEENS HMA<br /></strong><br />The South Steens HMA is also located in Oregon north of the Beatys Butte HMA and the South Steens wild horses are held in high regard by those who know them.<br /><br />“<em>South Steens, like Calico, is one of those really special herds that ought to be national treasures</em>”, states Nancy Kerson of <a href="http://www.mustangs4us.com/index.htm"><span style="color:#cc6600;">Mustangs 4 Us</span></a>.<br /><br />The original Herd Area BLM reported in 2004 for the South Steens HMA totaled over 280k acres while the HMA BLM determined could still be “managed” for wild horses totaled over 163k acres. By 2009, BLM reports the South Steens wild horses are only managed on 134k acres – a loss of over 146k acres of supposedly protected habitat.<br /><br />The BLM removed the South Steens horses in November 2004 and conducted yet another round up in late November of 2009. In 2009, <a href="http://www.blm.gov/wo/st/en/prog/wild_horse_and_burro/wh_b_information_center/monthly_review_of/completed_gather_schedule.html"><span style="color:#cc6600;">BLM reported</span> </a>482 wild horses were gathered, 369 removed and 59 mares were treated with PZP fertility control. BLM also reported that approximately 135 wild horses still remained on the range after the removals; all totaled, this equates to 504 wild horses.<br /><br />However, in February 2009, prior to the gather, BLM only reported 329 horses in the South Steens HMA. After the spring foaling season, the population should have only increased by 66 foals to total 395 horses. Yet BLM reported they found over one hundred more horses on the range than they should have during the 2009 November removal operations.<br /><br />Even more disturbing is, the <a href="http://www.blm.gov/or/resources/whb/files/popdata_092909.pdf"><span style="color:#cc6600;">BLMs Oregon WH&B Website</span> </a>reported the South Steens population was censused in July as totaling 584, not 504. Based on this, approximately 80 censused horses remain unaccounted for that were either left on the range and BLM failed to report them or BLMs census methods overcounted them, they “disappeared” somewhere during the round up process or perhaps they migrated somewhere else between July and November.<br /><br /><br /><strong>HORSES: COMING AND GOING</strong><br /><br />The 2009 Beaty Butte EA also stated that, “<em>A long history of horses drifting into and out of the Beatys Butte HMA exists. There is movement between Sheldon and Hart National Wildlife Refuge, private land and the Burns District HMAs including Warm Springs and South Steens</em>.”<br /><br />So what are the implications of a long-history of movement between all these areas?<br /><br />For one, it means that most likely, the chances of Beaty Buttes PZP’d mares isn’t going to be sufficient to slow population growth down to 10% or less if many bands of wild horses can mix with other, untreated herds – including those residing in Sheldon.<br /><br />Another thing that makes this statement of herds moving back and forth between other HMAs and Sheldon very interesting is, according to the 2007 EA released by U.S. Fish & Wildlife Service (USFWS) about the Sheldon wild horse reproduction rates, managers reported that, “<em>The herd’s growth rate is very strong, averaging between 17-23% net increase per year”</em>. The 2007 Sheldon EA also provided a chart to illustrate the Sheldon herd’s growth over the years. Also, according to managers, the Sheldon horses stopped being routinely removed around 1994, which in turn resulted in a progressive increase in their populations, until 2005, when the first new series of round ups began.<br /><br />However, if you follow the increase as charted below or take at face value that managers have accurately assessed the reproduction rates of 17-23%, there appears to be no sudden declines or jumps in populations to indicate wild horses may be moving in or out of Sheldon in any significant numbers – at least, not of their own accord…<br /><br /></div><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TB074cqhKEI/AAAAAAAACIo/U60Cnc00pHw/s1600/Sheldon+WH%23+Graph_1979-2007.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 221px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5484605762160371778" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TB074cqhKEI/AAAAAAAACIo/U60Cnc00pHw/s400/Sheldon+WH%23+Graph_1979-2007.jpg" /></a> <div align="justify"><br />Also, in examining BLMs National Herd Statistics for the Warm Springs, South Steens and Beatys Butte HMAs, generally, BLMs own data fails to support any significant movement between any of these areas either – but I did say generally, didn’t I?<br /><br />I created the following Table using BLM’s own National Herd Statistic data reported for 2004-2009 as well as data provided by the BLM Oregon Wild Horse & Burro webpages . I have added the reproductive % rates for each year based on BLMs reported populations to help determine any anomalies that might be due to horses moving back and forth between any of these areas.<br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/TB07bRUOd_I/AAAAAAAACIg/Tg1XkWAfnjk/s1600/OR_HMA+Population+Graph_6-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 356px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5484605260897875954" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/TB07bRUOd_I/AAAAAAAACIg/Tg1XkWAfnjk/s400/OR_HMA+Population+Graph_6-10.jpg" /></a></div><div align="justify"><br />Based on this information, there are five potential reports that could support BLMs claim that there is a “long history of drift” between the herds.<br /><br />> In 2004, BLM conducted a round up in the Beatys Butte HMA and the Warm Springs HMA saw a 41% increase instead of 20%. This could indicate that approximately 34 horses moved over to the Warm Springs HMA because of the removal activities.<br /><br />> In 2008, the Warm Springs HMA population report indicated only a 9.1% increase versus the normal 20% while the Beatys Butte HMA reported a 293% increase. This could indicate a marginal amount of the Warm Springs horses – about 15 – moved into the Beatys Butte HMA.<br /><br />> Between 2007 and 2008, BLM reported a 293% increase in reported wild horse population for the Beatys Butte HMA, which jumped from 151 to 474.<br /><br />> Despite BLM reporting no wild horses were removed between 2008 and 2009, the Beatys Butte population declined from 474 animals in February 2008 to 419 animals in February 2009. If one adds a 20% reproduction rate for the 2008 spring foals (an increase of 95 additional foals), the actual wild horse decline was approximately 150 horses.<br /><br />> In February 2009, BLM reported the South Steens HMA population was estimated at 329. A 20% increase due to foaling season would add an additional 66 horses to equal 395 by July 1st. Yet, a July 2009 census reported 584 wild horses were found instead, an unexpected increase of approximately 189 horses.<br /><br />These numbers indicate it is possible that approximately 150-200 wild horses moved from Beatys Butte HMA to South Steens HMA.<br /><br />Is your head startng to hurt yet? I know mine is!<br /><br /><br /><strong>BUT WAIT, THERE’S MORE!<br /></strong><br />While BLM’s National Program Office (NPO) was reporting the Beaty Butte wild horse population was merely 151 in February 2007, what you don’t see when you just look at just the NPO Herd Statistics between 2007 and 2008 is - BLM conducted a round up in late July, early August 2007, after they reported the 151 horses but before they reported 474 wild horses still remained in February 2008 – with no foaling season in between.<br /><br />According to BLM’s 2007 National Gather Schedule, BLM reported removing 260 wild horses between July 29 and August 11 from the Beatys Butte HMA. Seems impossible after reporting there were only 151 horses there (even adding a 20% increase for the spring foals would only add up to 180, not 260).<br /><br />Yet, the 2007 National Gather Schedule goes on to report that after removing 260 wild horses, BLM estimates another 300 are left. Yet, by the time it gets to the National Program Office “Herd Statistic Division” - somewhere between August 2007 and February 2008 - BLM now reports the wild horse population jumps again; instead of 300 being left, now BLM reports 474 wild horses are left in the Beaty Butte HMA after the 2007 summer round up.<br /><br />All totaled, it would appear that somewhere between February 2007 and February 2008, the wild horse population shot up from 151 wild horses to 734 wild horses instead, which is now a 388% increase. (474 remaining plus 260 removed in July/August). Yet none of the other HMAs BLM propose contain “drifting” population reports to show similar declines to account for these numbers.<br /><br />In fact, it's Beaty Butte that seems to be supplying the wild horses to other HMAs, not the other way around as by July 2009, BLM reports Beatys Butte loses approximately 150 horses while the South Steens HMA picks up 189 horses.<br /><br />Despite BLM removing 260 horses in 2007 and potentially 150-190 horses also moving across many miles to relocate in the South Steens HMA, BLM continues to report there were still 534 wild horses in the Beatys Butte HMA by September 2009!<br /><br />So where are all these horses coming from?<br /><br />BLMs September 2009 EA stated that, “<em>The last census in the HMA and surrounding area was done on July 24, 2009. The population within the Beatys Butte HMA was 256 including 204 adults and 51 foals under one year</em>.”<br /><br />It also went on to say that, “<em>189 horses were counted on the Hart Mountain National Wildlife Refuge; of these 157 were adults and 39 were foals under 1 year of age</em>”. (pg. 16)<br /><br />If these two areas are added together, they total 445 horses – the exact amount BLM states they intend to gather in the first paragraph of the Beatys Butte 2009 Finding of No Significant Impact Decision.<br /><br />However, according to BLMs publicly posted “<a href="http://www.blm.gov/or/resources/whb/files/popdata_092909.pdf"><span style="color:#cc6600;">Oregon BLM Wild Horse and Burro Population Data</span></a>”, posted for September 29, 2009, BLM lists a census conducted on July 29, 2009, in the Beatys Butte as counting 534 horses - not 455 wild horses as listed in the FONSI, or the 485 wild horses estimated in the Post-Gather Report or even the 256 listed as officially residing in the Beatys Butte HMA. Instead, the Oregon population data posts an additional 79 more wild horses than any other BLM document, even though all of these documents were supposedly done in the same month by the same personnel!<br /><br />And based on the July census, we are now missing 79 horses from Beatys Butte and 80 horses from South Steens the September and November removals!<br /><br />It gets even more questionable as, the only way BLM could come up with these sort of numbers in both the census, the population reports and the post-gather reports is, they had to include the number of wild horses reported on the Hart Mountain portion of the Sheldon National Wildlife Refuge. So that means BLM had to be rounding up wild horses in Hart Mountain and adding them to the Beatys Butte numbers.<br /><br />One other note that may be of interest to those of us who are trying to sort out the truth from the lies in the BLMs management of the Wild Horse & Burro Program; because BLM removed wild horses from the Beaty Butte HMA in 2007, their removal numbers were also cross-referenced with the <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzM3xneDo3ZDk5ZDZiY2I5YTU0YzJh&pli=1"><span style="color:#cc6600;">2007 Capture Status Records </span></a>obtained by American Horse Defense Fund via FOIA.<br /><br />According to the Capture Status Report, 272 horses were removed from the Beatys Butte HMA in 2007 – but 23 of them weren’t removed in August; 18 wild horses were reported as removed on March 29, 2007, 1 wild horse was reported as removed on May 30, 2007 and 4 more horses were reported as removed on June 8, 2007 - right in the middle of foaling season when BLM isn’t suppose to be conducting removals. Furthermore, no record of these removals is listed on BLM’s 2007 National Gather Schedule or in the 2009 Beaty Butte Wild Horse Capture EA.<br /><br />So where are all these horses coming from – or going too - if BLM continues to report that all the HMAs in the area are experiencing huge population explosions, not declines?<br /><br /><br /><strong>BACK TO SHELDON</strong><br /><br />Could the source of all the Beatys Butte wild horses be part of the mysterious disappearance of 700 Sheldon horses right after Refuge managers were threatened with a lawsuit about removing them in the summer of 2007?<br /><br />Is it possible the Sheldon horses were deliberately run into the Beaty Butte HMA and surrounding areas to account for all these “population explosions” now being found by BLM?<br /><br />With respect to BLM reporting that, “<em>189 wild horses, 157 adults and 39 foals, were counted on the Hart Mountain portion of Sheldon National Wildlife Refuge</em>”, here we find another place now reporting unprecedented wild horse populations and presence; the Hart Mountain portion of the Sheldon-Hart National Wildlife Refuge.<br /><br />According to Dr. Steven G. Herman, who began teaching on Hart Mountain National Antelope Refuge in 1976 as a Member of the Faculty at The Evergreen State College and who has visited Hart Mt. every year since then, wild horses have never been observed in the Hart Mountain portion of the Refuge in over thirty years of annual tours. Well, not until 2008, which is the first time Dr. Herman ever noted wild horse presence at Hart Mountain…<br /><br />So why, after over thirty years, did almost two hundred horses show up at Hart Mountain?<br /><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/TB06-1SHWFI/AAAAAAAACIQ/mHBECJEZ3MQ/s1600/BLM_Sheldon-Hart+Mt_Refuge_Map.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 343px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5484604772336490578" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/TB06-1SHWFI/AAAAAAAACIQ/mHBECJEZ3MQ/s400/BLM_Sheldon-Hart+Mt_Refuge_Map.jpg" /></a> </div><div align="justify"><br />Other BLM managed HMAs with dramatic population increases between 2007 and 2008 that surround the Sheldon portion of the National Wildlife Refuge include; the High Rock HMA, which jumped from 124 to 356, the Calico Mountains HMA going from 264 to 549, the Warm Springs Canyon HMA skyrocketing from 139 to 607, Black Rock Range East swinging from 74 to 215, and Black Range West reported as catapulting from 76 to 399.<br /><br />BLM also reported in the 2009 Calico Complex EA that, “<em>Data compiled by the Surprise Field Office during the March 2008 inventory of those HMAs also revealed higher populations than anticipated in the adjoining HMAs. Overall, the population levels of the Surprise Field Office HMAs exceeded natural recruitment by more than 400 wild horses (representing approximately 80% more wild horses than anticipated).”</em><br /><br />However, despite reporting “<em>a 80% increase in the adjoining HMAs</em>” during a March 2008 aerial survey, BLM’s National Program Office only reported one HMA as having any significant increase - the High Rock HMA. The other adjacent HMAs of Bitner, Nut Mountain and Wall Canyon had all been “gathered” in September 2007 prior to the February 2008 reporting date and BLM failed to report any significant change in the populations for the “other” adjoining HMAs in either 2008 or 2009 National Herd Statistics reports.<br /><br />Because of BLM not reporting any increases in these HMAs, as well as Massacre Lakes HMA, only those HMAs with sudden reported population explosions will be analyzed further.<br /><br /><br /><strong>A MATH GAME<br /></strong><br />So, let’s play a little math game here…<br /><br />In the spring of 2007, Sheldon managers reported there were approximately 1,500 wild horses living in the Sheldon National Wildlife Refuge. Then USFWS were threatened with a lawsuit in August 2007 and lo and behold, they reported in September 2007 that “a new census” conducted in June by Nevada Department of Wildlife counted only 800 horses were actually on the Refuge, not 1,500.<br /><br />Now if we add up all the population reports for those HMAs who had unexplained population explosions between February 2007 and February 2008 that are in the vicinity of Sheldon, which include the Beatys Butte, High Rock, Calico Mountains, and Black Rock Range East and West HMA’s, here’s what we find.<br /><br />In February 2007, the total wild horse population for all the HMA’s listed above was 828. Add a 20% reproduction rate to this (an increase of approximately 165 foals) and by July 2007, the population should be about 993.<br /><br />Yet, by February 2008, these same HMAs are now reporting a population of 2,600 horses (but this doesn’t include the 260 that BLM removed during the August 2007 Beatys Butte round up or the South Steens population explosion going from 329 to 584 between 2008 and 2009 or the 189 reported on Hart Mountain National Wildlife Refuge, as some of these population reports occurred <em>after</em> the 2007 reporting dates).<br /><br />So for the first time ever, according in both BLM’s and USFWS’s wild horse population reports as shown above, some of the HMAs surrounding Sheldon shot up by approximately 1,600 to 1,800 wild horses - right about the same amount Sheldon was trying to get rid of back in 2007.<br /><br />Meanwhile, Sheldon’s current manager, Paul Steblien, refuses to release any population reports on the number of wild horses USFWS has removed since 2008, the results of any aerial or ground surveys or what the current population on Sheldon is now estimated to be.<br /><br /><br /><strong>ON A FINAL NOTE<br /></strong><br />For those discerning readers, here’s some additional food for thought….<br /><br />According to <a href="http://www.equinewelfarealliance.org/uploads/BLM.Team.Euth.FOIA_Cover.letter.pdf"><span style="color:#cc6600;">BLM’s Team Conference Call Report</span></a>, Sheldon managers began castrating stallions and returning them to the range in 2008. A year later, BLM approves of the same plan for an HMA that is very close to Sheldon and tries to get it rammed through immediately - but BLMs lawyers kicked it back with a few tweaks.<br /><br />So, if one were to entertain the outrageous idea that managers from different agency’s (who both answer to Secretary of the Interior) are conspiring to push wild horses around like livestock to avoid lawsuits, artificially increase populations to justify budgets, round ups and/or herding them from place to place for discrete “disposal”, wouldn’t it be easier to hide a castrated Sheldon horse on a BLM HMA if BLM approved of castrating a few stallions of their own? </div></div>Unknownnoreply@blogger.com4tag:blogger.com,1999:blog-4562357749295999770.post-10988969311370939782010-05-26T03:37:00.001-07:002010-06-01T22:26:21.936-07:00Calico: Past, Present & Future V<div align="justify"><em>This is the fifth in a series of articles that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond….<br /></em><br /></div><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/S_zcR46oH0I/AAAAAAAACII/kQPv0gFxrxo/s1600/LA+Oil+Spill_Boot.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 291px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475493446869851970" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/S_zcR46oH0I/AAAAAAAACII/kQPv0gFxrxo/s400/LA+Oil+Spill_Boot.jpg" /></a> <div align="center"><span style="font-size:78%;">A Greenpeace activists trudges through oil on a beach near<br />Venice, Louisiana,on May 20, 2010. </span><a href="http://www.huffingtonpost.com/2010/04/30/louisiana-oil-spill-2010_n_558287.html"><span style="font-size:78%;color:#cc6600;">Huffington Post</span></a></div><div align="justify"><br /><strong>NO RETURN TO FREEDOM<br /></strong>Yesterday, the Honorable Judge Friedman issued his verdict for the Calico Complex wild horses and all those now warehoused in BLMs many long-term holding facilities by dismissing all counts of the complaints filed by plaintiffs In Defense of Animals, Craig Downer, and Terri Farley, through the pro-bono legal services of William Spriggs of Buchanan, Ingersoll & Rooney.<br /><br />First, Judge Friedman issued the opinion that though he refused to stop the round up back in December, because he didn’t, any prayer for relief was now moot because the round up had already taken place.<br /><br />He also chastised the plaintiffs for not appealing his initial refusal to stop the round up when he failed to grant the injunction back in December. In my opinion, when Friedman issued yesterday's legal opinion about his ruling to not grant a halt to the round up, he presented a legal argument that shared some twisted semblance of logic used by other kinds of rapists; that “No” didn’t really mean no and the plaintiffs should have asked again.<br /><br />Judge Friedman also cited several other legal technicalities the plaintiffs failed to overcome such as standing – better known as the right to sue due to a legally cognizable interest, actual injury and harm, and failure to establish more than a causal connection between, well, everything that has gone on. <a href="http://www.animallawcoalition.com/wild-horses-and-burros/article/1119"><span style="color:#cc6600;">Click Here</span> </a>to learn more.<br /><br />While it is generally accepted that the almost 100 now dead horses, 40 or more aborted and/or miscarried foals and dozens of injuries sustained by the Calico herds who DID suffer irreparable harm and injury had no legal voice in the matter, turns out, neither does any of the American citizens whom are shoved aside with the only rights still guaranteed is merely to act as witnesses to the decimation of our American herds - well, that and of course, to fund it.<br /><br />The ruling also reminded us that Judge Friedman found the Safari Club and Nevada Department of Wildlife (NDOW) to have sufficient standing to sign on as defendants in the Calico case due to their “vested interests”.<br /><br />As we saw in the last post, BLM and NDOWs cozy relationship spurred the Surprise Field Office to approve a land use plan that “<em>no longer manages for a reasonable number of wildlife</em>” – that concept is only reserved for wild horses and burros.<br /><br />NDOW is one of the most active and aggressive supporters of “protecting habitat” for the ever-burgeoning big game populations and their influence can be found behind the scenes of every major and most minor management decision being pushed through on public lands in Nevada; NDOW also often targets the easy pickens of wild horse and burro resources to further their goals. After all, who is there to defend the wild horses and burros? Only BLM….<br /><br />However, NDOWs involvement in wild horses and burro management isn’t limited to just BLM as we will soon see.<br /><br />Though <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDpiMjg0ODUwYjJkYzViNTY&pli=1"><span style="color:#cc6600;">Nevada Bighorns Unlimited claimed financial sponsorship</span> </a>of the Sheldon National Wildlife Refuge fence repair and census of wild horses, according to Sheldon manager Paul Steblien, it was NDOWs planes that “discovered” 700 wild horses were missing from the Refuge back in June 2007.<br /><br />It would appear that NDOW also maintains an equally cozy relationship with U.S. Fish and Wildlife Service (USFWS), as not only were they consulting with lawyers and Judge Friedman about their unconditional support for the removal of the Calico wild horses, they have also been very busy behind the scenes working with USFWS managers at Sheldon, BLM, the U.S. Energy Regulatory Committee and yes, the Ruby Pipeline….<br /><br />“<em>The FWS has expressed concern that certain measures proposed by Ruby (i.e., facilitation of horse and burro movement around construction areas, fence line manipulation, and opening of gates for construction activities) could result in additional wild horses or burros entering the Sheldon NWR. The FWS could then be required to increase its expenditures to manage the wild horse and burro populations, which could detract from the funds necessary to manage other NWR resources. Ruby has committed to coordinating with the Sheldon NWR to implement and maintain access restriction controls to prohibit the migration of wild horses and burros onto the Sheldon NWR. Ruby would coordinate with the FWS to repair or replace any cattle guards on the Sheldon NWR damaged by construction, and install new fencing, gates, <strong>or cattle guards at key areas</strong>. Finally, <strong>Ruby would erect fences to restrict animal movement out of the HMAs</strong>.”</em></div><div align="right"><a href="http://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20100108-4001"><span style="font-size:85%;color:#cc6600;">Ruby Pipeline Final EIS<br /></span></a><span style="font-size:85%;">Chapter 4, page 4-114<br />January 8, 2010</span> ,</div><div align="justify"><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/S_zcGxZ0JGI/AAAAAAAACIA/_pr4Q3P3D_w/s1600/Horse+Dead+At+Cattle+Guard_Craig+Downer_3-29-10.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 267px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475493255874618466" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/S_zcGxZ0JGI/AAAAAAAACIA/_pr4Q3P3D_w/s400/Horse+Dead+At+Cattle+Guard_Craig+Downer_3-29-10.jpg" /></a> <div align="center"><span style="font-size:78%;">Dead Calico Wild Horse due to round up entrapment by non-compliant cattle guard.<br />Photo courtesy of Craig Downer,copyright 3/29/10 available at<br /><a href="http://humaneobserver.blogspot.com/"><span style="color:#cc6600;">Elyse Gardner-The Humane Observer</span></a>, Craig Downer's <a href="http://humaneobserver.blogspot.com/2010/04/craig-downers-report-on-calico-complex.html"><span style="color:#cc6600;">Report On<br />The Calico Complex In The Helicopter's Wake: The Aftermath And<br />Another Roundup Casualty? BLM Abdicates Responsibiity<br />For Pre-Roundup Safety Precautions.</span></a></span><a href="http://humaneobserver.blogspot.com/2010/04/craig-downers-report-on-calico-complex.html"><span style="color:#cc6600;"><br /></span></a></div><div align="justify"><br /><br /><strong>THE COST OF DOING BUSINESS</strong><br />While the DOI’s Minerals Management Services has been bilking the American people out of billions in royalties owed to the nation by the oil and gas industry for decades with a slew of scandals recently heightened by DOI employees in bed – literally – with industry executives, no amount of investigative reporting, scathing exposes, Congressional involvement or promises of reform from current Secretary of the Interior seems to be making a dent in the lucrative sales of our resources through backroom deals. <a href="http://www.revenuewatch.org/news/news-article/usa/project-government-oversight-receives-sunshine-award-investigation-u"><span style="color:#cc6600;">Click Here</span> </a>to learn more.<br /><br />While questions continue about what legally constitutes a bribe with respect to making deals with government employees and public resources, what The Ruby Pipeline’s parent company El Paso Gas is now doing to pave the way for their $3 billion dollar pipeline is not only considered totally legal – it is required.<br /><br />Hailed as “mitigation measures” versus good old fashioned bribery, in order for Ruby to lay down its massive pipe, they have to provide compensation to the agencies overseeing state and public resources to ease the impact of the project in order to protect the public trust. At least, that’s how the story goes…<br /><br />Though the general public gets to review two documents released by the U.S. Energy Regulatory Committee on what erecting the Ruby Pipeline will entail, behind the scenes agencies of all sorts have been involved with intimate “consultation” processes about what they want, what they need and how to negotiate the best deal they can out of El Paso’s war chest before they seal the deal.<br /><br />As BLM was releasing the first environmental assessment to remove the wild horses in Calico in late October, at the exact same time another document was being submitted to Ruby in what can only be described as a gold plated Draft Wish List, which included hefty requests by none other than NDOW itself.<br /><br />This document is titled, “<a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1YWNmY2FjMmQ0ZjcwZWVj"><span style="color:#cc6600;">Draft Ruby Pipeline Migratory Bird Conservation Plan</span></a>” and was recently obtained via extensive FOIA requests submitted by Western Watersheds Project (WWP) on the Ruby Pipeline. According to the FOIA records obtained by WWP, this Migratory Bird Conservation Plan was submitted to Ruby on October 26, 2009.<br /><br />Though it is plain to see it was originally written to include open and transparent coordination with BLM, U.S. Forest Service and state fish and game departments, this Wish List is now being slid through exclusively under USFWS’s jurisdiction – though all agencies will continue to be consulted and will include “<em>joint ventures, project interests from private landowners, corporations, non-profit groups, and non-governmental organizations in making any decisions about what migratory bird habitat projects should be completed under this agreement</em>.”<br /><br />According to this document, in response to various agency demands for compensatory conservation measures, “<em><strong>Ruby acknowledges its responsibilities</strong> and conservation measures that have been identified <strong>to provide additional conservation benefits that go beyond typical </strong>avoidance, minimization and <strong>compensatory measures</strong></em>” (emphasis added)<br /><br />The Plan goes on to state that, “<em>In order to accomplish this, Ruby will deposit funds in an account (or accounts, if necessary) to be used for the protection of migratory bird habitat through the acquisition of lands, implementation of habitat restoration, and long-term management of the lands for the benefit of migratory birds. Habitat enhancement and improvement projects will also be considered as legitimate uses of these funds.”</em><br /><br /><br /><strong>THE WISH LIST</strong><br />So what does the Wish List cover? Just about everything any and all agencies involved could wish for with a starting price tag of almost $17.1 million dollars when the sum of all the disclosed projects are added together.<br /><br />There are also a mountain of other projects the agencies are asking Ruby to “mitigate”, many whose total costs were undisclosed, which include:<br /><br />> $2,000 per acre for fencing in the Little Humboldt Allotment, Castle Ridge, Spanish Ranch Allotment, North Fork Group Allotment, Eagle Rock Allotment, Taylor Canyon, Tuscarora, Diry Peaks, Delano Mountains, Bluff Creek, Mill Creek and 25 additional unnamed allotments in order to protect aspen stands - as well as “other” identified aspen stands throughout the life of the project.<br /><br />> Purchase property or water rights associated with the Brunea Wildlife Management Areas, which includes Stowell property match for NDOW funding and a seed storage facility that would be secured by NDOW and other agency partners with $1.5 million requested for initial construction of the facility and $375k for staffing it for the next 5 years – including benefits.<br /><br />> Undisclosed cost of restoring native grasses on 10,400 acres.<br /><br />> Removal of 92 miles of roads insides WSA’s at undisclosed costs.<br /><br />> Purchasing the Soldier Meadows Ranch – home of the Soldier Meadows Allotment that overlaps three wild horse HMAs where the Calico Complex round up began. The Wish List reasons why buying the ranch outright is such a great idea by stating, “<em>With the proposed pipeline route traversing most of this allotment along the head of the hydrologic watershed for Warm Springs Canyon and the northern reaches of the High Rock drainage; a substantial list of projects have been proposed to mitigate or attempt to offset the construction and pipeline footprint. The sum of those related projects in conjunction with a 3 year payout to take non-use could approach the assessed value of the ranch. In so much as this ranch is the pivotal base property for much of the grazing issues within the Black Rock Wilderness area, the High Rock Wilderness and associated NCA (National Conservation Area), this purchase would have the support and possible buy in from a number of partner conservancies with Ruby. The inclusion of all private parcels scattered throughout the allotment such as the springs south of the ranch, Wall Canyon, Cottonwood Canyon, Stanley Camp, Summer Camp, Slumgullion, etc. would all be windfalls for the public and remove a number of current conflicts</em>”. (<strong>Editors Note: It would only be considered a windfall for those interested in seeing the circumvention of federal law regarding the protection of wild horses and burros and livestock grazing in what would then be private and/or state protected lands held partnership with Ruby, a.k.a., El Paso Natural Gas Corporation</strong>.)<br /><br />> At least 20 miles of fencing was also included for lands adjacent to Sheldon National Wildlife Refuge in the Wall Canyon Allotment to separate allotments and “<em>would control trespass livestock and feral horse use on critical wildlife habitat between the Sheldon NWR and the Warm Springs and High Rock drainages.”</em><br /><br />> And at least 42 springs, seeps and various water sources are identified in the document as being targeted for fencing with several references to “feral horses” being excluded from these areas including:<br /><br />- The only two remaining springs left for wild horse use in the Massacre Lakes HMA (located in the Juniper Pasture on the Massacre Lakes Allotment), Post Springs and Indian Springs.<br /><br />- Fencing of the 40 acres Miller and Lux Springs in the Nut Mountain Allotment that overlaps the Nut Mountain HMA.<br /><br />- Fencing Idaho Canyon Springs that overlaps the Calico HMA.<br /><br />- Rock Springs in the Wall Canyon HMA, where BLM Winnemucca photo files from 2008 obtained via FOIA cites Rock Springs as exclusively used by wild horses and is specifically marked as “No Livestock Use” by BLM. Meanwhile, the Draft Migratory Bird Conservation Plan states “<em>the replacement and/or repair of fencing around Rock Springs would control trespass livestock”</em> and in another section titled <em>“Rock Springs Spring Enhancement”,</em> the plan is to fence <em>"approximately 40 additional acres of the spring and meadows and pipe water to a trough outside for livestock, feral horses, and big game species</em>”. So much for exclusive use by wild horses….<br /><br />> Other springs found in the BLM Winnemucca photo files being used by wild horses and targeted for exclosures on the Wish List that can initially be identified include Clear Springs, Tin Trough Springs, Summit Spring and Santa Clause Spring in the Black Rock West HMA, and the Antelope Springs, Cherry Springs and Mustang Springs in the Warm Springs Canyon HMA,<br /><br />However, in the spirit of fairness, some of the proposed exclosures are allowing for pipelines to carry water to troughs that would be located outside the fenced springs for continued wild horse and/or burro use. <div align="center"><br /><br /><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/S_zbMpqE0hI/AAAAAAAACH4/yeOTMDVgNJk/s1600/Empty+Trough_Summit+Springs_7-29-08.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475492257362924050" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/S_zbMpqE0hI/AAAAAAAACH4/yeOTMDVgNJk/s400/Empty+Trough_Summit+Springs_7-29-08.jpg" /></a> <span style="font-size:78%;">Summit Springs, Empty Trough, BLM Winnemucca photo files. 7-29-08<br /></span><br /><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/S_zaw5gz_-I/AAAAAAAACHw/N_v9KFu8J8g/s1600/Rock+Springs_Water+Found+On-1_7-10-08.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475491780582703074" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/S_zaw5gz_-I/AAAAAAAACHw/N_v9KFu8J8g/s400/Rock+Springs_Water+Found+On-1_7-10-08.jpg" /></a><span style="font-size:78%;"> Rock Springs, titled "Faucet found open, water loss, troughs dry".<br />BLM Winnemucca photo files. 7-10-08</span><br /><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S_zaLWZI0xI/AAAAAAAACHo/Y1ew_qemrtc/s1600/Rock+Springs_Water+Found+On-2_7-10-08.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 300px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475491135500112658" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S_zaLWZI0xI/AAAAAAAACHo/Y1ew_qemrtc/s400/Rock+Springs_Water+Found+On-2_7-10-08.jpg" /></a><span style="font-size:78%;"> Rock Springs titled, "Faucet open, water loss, troughs dry".<br />BLM Winnemucca photo files. 7-10-08</span><br /><br /><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/S_zZrUe1TVI/AAAAAAAACHg/F85PQzNLqEM/s1600/Rock+Springs_Water+Shut+Off_Troughs+Full_7-29-08.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 300px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475490585231314258" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/S_zZrUe1TVI/AAAAAAAACHg/F85PQzNLqEM/s400/Rock+Springs_Water+Shut+Off_Troughs+Full_7-29-08.jpg" /></a><span style="font-size:78%;">Rock Springs, titled, "Troughs after turning off faucet found open".<br />BLM Winnemucca photo files. 7-29-08</span><br /><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S_zZHTNknCI/AAAAAAAACHY/jGjlE3Mk22A/s1600/Rock+Springs_Troughs+Have+Water_10-23-08.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475489966415191074" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S_zZHTNknCI/AAAAAAAACHY/jGjlE3Mk22A/s400/Rock+Springs_Troughs+Have+Water_10-23-08.jpg" /></a> <span style="font-size:78%;">Rock Springs, titled, "Troughs full". BLM Winnemucca photo files. 10-23-08</span><br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S_zYqTEbypI/AAAAAAAACHQ/vnUQFkulRQE/s1600/Rock+Springs_Empty+Troughs_7-18-09.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5475489468160658066" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S_zYqTEbypI/AAAAAAAACHQ/vnUQFkulRQE/s400/Rock+Springs_Empty+Troughs_7-18-09.jpg" /></a> <span style="font-size:78%;">And one year later? Rock Springs, merely titled,"Troughs Empty".<br />BLM Winnemucca photo files. 7-18-09</span> </div><div align="justify"><br /><br /><strong>RUBY, EL PASO AND HALLIBURTON</strong><br />As Colorado based El Paso Gas Corporation was backpedaling earlier this year about their involvement with wild horses and burros affected by the Ruby Pipeline by pointing out that everything they would do would be according to “BLM policy”, one of the issues the astute reader of Ruby’s Final EIS will note is that all Ruby’s proposed mitigation measures for access to water by wild horses and burros involves <em>hauling water</em>, not the establishment of long-term water sources – those are being considered for fencing during the four year mitigation and reclamation process.<br /><br />However, while El Paso’s public affairs specialists were recently citing their complete objectivity regarding the issue of wild horse management to calm any further public speculation about their potential prejudices, less than a year earlier, a letter sent by <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0ZmUxNjlmMzczY2RlMDRl"><span style="color:#cc6600;">Ruby Pipeline LLC to Nevada Associate BLM State Director Amy Lueders on March 31, 2009</span></a>, belies Ruby’s true feelings about feral horses as they proceed to make a claim so bold and ludicrous, not even the strongest anti-wild horse opponent has had the audacity to try and fabricate as fact what Ruby does when they blame wild horses for habitat fragmentation in the letter, which states, “<em>Further, the introduction of non-native species, in this case wild horses, can have a fragmenting effect upon the landscape</em>” (pg. 4) </div><br />BLM also fired back at the suggestion of Ruby’s behind the scenes involvement in the Calico Complex round ups by posting a <a href="http://www.blm.gov/nv/st/en/fo/wfo/blm_programs/wild_horses_and_burros/calico_mountains_complex/media_inquiries.html"><span style="color:#cc6600;">Press Release on January 22, 2010</span></a>, which essentially poo-pooed the idea that Ruby and BLM were doing anything less than honorable with respect to the management of wild horses and burros affected by the pipeline.<br /><br />However, a press release doesn’t hold water in the legal arena – just ask Judge Friedman – and the legally established BLM “policy” that Ruby will follow has lots and lots of loopholes managers from a variety of agencies can evoke at their discretion.<br /><br />“<em>HMAs would be managed individually in four of the eight herd management areas; however, the Nut Mountain, Bitner, Massacre Lakes, and Wall Canyon HMAs would be managed as a complex. This would facilitate recovery of degraded or threatened ecosystem components by providing sufficient management flexibility to (temporarily) <strong>remove horses from an entire HMA</strong> (or portion thereof) <strong>in order to permit</strong> recovery following wildfire, <strong>resource improvement projects,</strong> or overgrazing by horses….”</em> </div><div align="right"><span style="font-size:85%;"><br />BLM Surprise Resource Management Plan<br />Section 2.21 Wild Horses, pg. 2-82<br />Record of Decision, December 2008</span></div><div align="justify"><br />As the Ruby Final EIS proposes to formalize a blanket agreement to “<em>erect fences to restrict animal movement out of the HMAs</em>” for undisclosed miles at equally undisclosed locations and BLM’s Tuscarora and Winnemucca Field Offices are working hand in hand with Nevada Department of Wildlife and USFWS to feed Ruby a Wish List that will fence miles more of critical water sources, meadows and habitat away from wild horses and burros – as well as possibly just unloading public lands to be managed by corporate partnerships with anyone but BLM - we, the public can rest assured that BLM will be as open, honest and humane about what they are really doing behind the scenes as they have been with the handling of the Calico Complex wild horses over the last several months.<br /><br />For a more detailed accounting of the daily death tolls, restriction on public access and BLMs transparent operations of the Wild Horse and Burro Program, visit the <a href="http://humaneobserver.blogspot.com/"><span style="color:#cc6600;"><strong>Humane Observer by Elyse Gardner,</strong></span></a> who has chronicled the on-the-ground realities faced by the Calico Complex wild horses since their removals began.<br /><br />As for El Paso Gas Corporation, they have lots of on-board experience with those who know how to pass the buck of responsibility to anyone but themselves as in early December, <a href="http://investor.elpaso.com/phoenix.zhtml?c=97166&p=irol-newsArticle&ID=1362692&highlight="><span style="color:#cc6600;">Timothy J. Probert</span> </a>was named to their Board of Directors. Mr. Probert also is currently serving as the President of Halliburton, Global Business Lines, which includes both Drilling and Evaluation and Completion and Production divisions and their respective service lines.<br /><br />Wonder if Mr. Probert’s division of Halliburton had anything to do with all the scandals involved in the Minerals Management Services or the currently unfolding tragedy now being played out in the Gulf Coast, thanks to all those “cozy relationships” between corporations, government employees and multi-billion dollar projects that allow the by-pass of environmental protection laws such as NEPA in favor of doing business at the national expense. </div><div align="center"><br /><object width="425" height="344"><param name="movie" value="http://www.youtube.com/v/hou_h7T3VDw&hl=en_US&fs=1&rel=0&color1=0x5d1719&color2=0xcd311b"><param name="allowFullScreen" value="true"><param name="allowscriptaccess" value="always"><embed src="http://www.youtube.com/v/hou_h7T3VDw&hl=en_US&fs=1&rel=0&color1=0x5d1719&color2=0xcd311b" type="application/x-shockwave-flash" allowscriptaccess="always" allowfullscreen="true" width="425" height="344"></embed></object></div><div align="justify"><br /><br />While <a href="http://www.cbsnews.com/8301-503544_162-20005013-503544.html"><span style="color:#cc6600;">President Obama recently slammed British Petroleum, Transocean and Halliburton</span> </a>for “<em>falling over each other to point the finger of blame at somebody else</em>” at recent Congressional hearings over the gulf oil horror, what the public hasn’t seen is any real reform or change under Obama’s pick for Secretary of the DOI as the Colorado based Salazar has a long, long history of support for the energy industry, including the approval last year of the British Petroleum’s exemption from doing the required detailed environmental analysis at the Deep Water Horizon site now hailed as fast becoming an unprecedented ecological disaster.<br /><br />As Judge Friedman ruled that any prayer for relief to the public and the Calico horses is now moot and Gulf Coast residents are learning the dirty truth about the greasy realities of the DOI, Secretary Salazar pushes onward in his determination to ram through his Wild Horse & Burro Initiative in this BLM sponsored <a href="http://www.blm.gov/wo/st/en/info/newsroom/2010/may/nr_05_13_2010.html"><span style="color:#cc6600;">Denver Public Workshop on June 14, 2010</span></a>, which will focus exclusively on Salazar's brainchild of leaving merely a few treasured herds of wild horses and burros on public lands while the rest are sterilized to achieve reproduction cycles that match fluctuating adoption demands or carted off to mostly private Sanctuaries in the Mid-West or Eastern states far removed from their native, "protected" ranges.<br /><br />Wonder what the $42 million dollars Salazar has requested from Congress to purchase land back East for warehousing our wild horses would do if it was dangled in front of state Fish & Game Departments and Sheldon NWR instead to ensure “mitigation measures” for the long-term management of wild horses and burros too.<br /><br />But then, Secretary Salazar has publicly stated there is no longer any “room” for wild horses and burros out West anymore and apparently, President Obama and his administration continue to support Secretary Salazar 110% - no matter what the cost.<br /><br />So, we the public are left to live with the mess, stand witness to the dying and deceased while simultaneously being herded down the Obama/Salazar canyon of “work shopping” on how we believe the DOI can best implement the final destruction of our American herds under Salazar’s Initiative.</div><div align="center"><br /><object width="425" height="344"><param name="movie" value="http://www.youtube.com/v/egsJGsqQcys&hl=en_US&fs=1&rel=0&color1=0x402061&color2=0x9461ca"><param name="allowFullScreen" value="true"><param name="allowscriptaccess" value="always"><embed src="http://www.youtube.com/v/egsJGsqQcys&hl=en_US&fs=1&rel=0&color1=0x402061&color2=0x9461ca" type="application/x-shockwave-flash" allowscriptaccess="always" allowfullscreen="true" width="425" height="344"></embed></object></div><div align="justify"><br />Secretary Salazar, do you really want to try something new in the Wild Horse & Burro Program? Why don’t you demand the DOI start following the spirit and intent of the Wild Free-Roaming Horse and Burro Act instead of devoting all its resources to circumventing it.<br /><br />Now that would be a change for sure! </div></div>Unknownnoreply@blogger.com3tag:blogger.com,1999:blog-4562357749295999770.post-22225317968977200762010-05-06T01:16:00.000-07:002010-05-06T01:17:17.683-07:00Calico: Past, Present & Future IV<div align="justify"><em>This is the fourth in a series of articles that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond…</em></div><div align="center"><br /><br /><strong>MASSACRE LAKES HERD MANAGEMENT AREA</strong></div><div align="justify"><br />I first jumped into the issues surrounding the Massacre Lakes Herd Management Area (HMA) due to a BLM Scoping Notice issued on May 18, 2007, to remove wild horses from the Wall Canyon East, Nut Mountain, Massacre Lakes and Bitner HMA’s.<br /><br />Turns out, the Massacre Lakes HMA is one of the few areas left that BLM hasn’t “officially” set an AML for wild horses. By that I mean, they DO have an AML, but it wasn’t set as a result of any official monitoring, environmental assessments or multiple use decisions.<br /><br />It was plunked down in the middle of an allotment management plan in 1982 as a “starting point” – no actually forage via AUMs were issued for wild horses at this time but there were lots of promises of monitoring to determine “appropriateness”. This AML was recently re-approved with a slight increase through the BLMs Surprise Field Office’s new Resource Management Plan (RMP) with more promises of monitoring in the future.<br /><br />Well, after several false starts, postponements, and “we'll get back to you”, the future has arrived and BLM has released a Rangeland Health Assessment (RHA) and Monitoring Evaluation Report (MER), which determined <em>adjustments</em> need to be made to wild horse AMLs and livestock authorizations.<br /><br />If you are wondering why Massacre Lakes HMA is now being included in posts about the Calico Complex, the Sheldon National Wildlife Refuge and yes, more information that is coming about the Ruby Pipeline and Tri-State Mega-Complex, it's because it sits smack dab in the middle of all this action….<br /><br />According to the Final Environmental Impact Statement (FEIS) for the Ruby Pipeline, Table 4.5.7-1, five HMAs will be directly affected by the proposed route: Black Rock Range West, Warm Springs Canyon, Wall Canyon, Nut Mountain, and Massacre Lakes HMAs totaling 298,000 acres of wild horse and burro habitat. The Massacre Lakes and Bitner HMAs are at the top and to the left of Sheldon.<br /><br /></div><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/S-Jieh9CASI/AAAAAAAACHI/Rq02_iEDMMg/s1600/HMAs_Surprise+FO_Sheldon.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 292px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5468041174231154978" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/S-Jieh9CASI/AAAAAAAACHI/Rq02_iEDMMg/s400/HMAs_Surprise+FO_Sheldon.jpg" /></a> <div align="justify"><br />However, BLM is not too concerned with Ruby’s impacts to the Massacre Lakes wild horses as they claim the proposed route will only cross the south end of the HMA were wild horses don’t generally go.</div><div align="center"><br /><strong>THE ISSUES</strong></div><div align="justify"><br /><strong>About Acreage</strong><br />In BLMs National Herd Statistics for Fiscal Year 2004, the Massacre Lakes Herd Area actually encompassed a single Herd Area totaling 115,937 acres of BLM managed lands and 11,791 acres of “Other” managed lands for a total of 127,728 acres.<br /><br />Then, BLM decided to create artificial boundaries by separating the area into two Herd Management Areas, the Massacre Lakes and Bitner HMAs. During this process, a total of 34,166 acres were removed from wild horse use.<br /><br />Cross-referencing records from BLMs FY04 and FY07 Herd Statistics, the original Herd Area also saw a “magical disappearance” of 17,125 acres in 2007 from their original HA records posted in 2004.<br /><br />Furthermore, according to the April 2010, Rangeland Health Assessment (RHA) and Monitoring Evaluation Report (MER), wild horses are generally only found in the Juniper Pasture, which totals 7,653 acres. (<em>This leads me to ponder, is it possible BLM has so manipulated the original Herd Area acreage of 127k acres over the years that merely 7,600 acres is all that is actually left that wild horses can still use and/or are still allowed on?</em>)<br /><br /><br /><strong>About Populations</strong><br />The Massacre Lakes wild horses haven’t been removed since 1988. The recent BLM Monitoring Evaluation Report (MER) states;<br /><br />“<em>Excess wild horses were gathered from the Massacre Lakes HMA in 1984 and 1988. In 1988, 25 wild horses were gathered and 11 head (3 studs and 8 mares) were released back into the HMA. Since 1988 Massacre Lakes HMA has had four helicopter population inventories (direct counts) completed. The 1997 population inventory showed 27 wild horses in the HMA. In 2001 the population inventory showed 54 wild horses in the HMA. Between 1997 and 2001 the average herd growth rate was between 18 and 20%. The September 2007 population inventory showed 110 wild horses in the HMA. Between 2001 and 2007 the average herd growth rate was between 12 and 13%. In March 2008 (before foaling season) another population inventory showed 108 wild horses in the HMA. The current population estimate for 2009 is between 136 and 202 wild horses</em>.”<br /><br />Yes, the BLM notes that in the four years between 1997 and 2001, wild horse growth rates were 18-20%, when populations doubled from 27 to 54. Then, the next six years indicated a 12-13% average growth rate. Yet despite their own published reproduction rates, the 2008 population census of 108 wild horses is now estimated at up to 202 wild horses, as populations are projected as potentially doubling in merely two years – though BLM has absolutely no records of this ever occurring here before….<br /><br />BLM issued a decision in the RMP to manage the Massacre Lakes with additional HMAs as a “Complex”, which includes: Bitner HMA(AML-25), Nut Mountain HMA (AML-55) and Wall Canyon HMA (AML-25). Here is the reasoning used to support “Complex Management” of these HMAs, which established the following legal management plan for the life of the RMP (10-30 years):<br /><br />“<em>HMAs would be managed individually in four of the eight herd management areas; however, the Nut Mountain, Bitner, Massacre Lakes, and Wall Canyon HMAs would be managed as a complex. This would facilitate recovery of degraded or threatened ecosystem components by providing sufficient management flexibility <strong>to (temporarily) remove horses from an entire HMA (or portion thereof) in order to permit recovery following wildfire, resource improvement projects, or overgrazing by horses.</strong> Grazing rest would allow rapid and dramatic improvements in land health. <strong>Once the area recovers, an appropriate AML would be determined and wild horses reintroduced</strong></em><strong>.”</strong> <span style="font-size:78%;">(Section 2.21 Wild Horses, pg. 2-82)</span><br /><br /><br /><strong>About Livestock</strong><br />Here's what BLM had to say about livestock grazing in the development of the Surprise RMP approved in 2008.<br /><br /><strong>> On total livestock authorizations:</strong><br />“<em>Livestock grazing on lands administered by the BLM Surprise Field Office (SFO) includes 49 grazing allotments within 1,445,443 total acres. The SFO authorizes 89,618 cattle, 2,671 sheep, and 176 horse AUMs annually on 59 permits issued to 51 permittees. Average annual use for the 10-year period between 1994 and 2003 was approximately 64,550 AUMs.</em>” (<span style="font-size:78%;">Pg. 2-34)<br /></span><br /><strong>> On adverse effects:<br /></strong>“<em>The analysis considered effects on livestock grazing <strong>adverse</strong> if they would do any of the following: 1) reduce the area authorized for livestock grazing, 2) restrict the amount of forage (AUMs) available for livestock grazing, or 3) create higher costs to livestock operators using public land grazing permits”.</em> (<span style="font-size:78%;">Pg. 4-46)<br /></span><br /><strong>> On wild horses and livestock:<br /></strong>“<em>Wild horses can affect livestock grazing both directly and indirectly. Grazing by horses directly reduces the amount of forage and water available for livestock…. Wild horse grazing, even at AML, would continue to result in moderate direct and indirect adverse impacts to livestock grazing in the planning area”</em>. (<span style="font-size:78%;">Pg. 4-46)<br /></span><br />What BLM has to say about livestock in the April, 2010, Monitoring Evaluation Report (MER):<br /><br />>Authorized use for the Massacre Allotment is 3,215 AUMs for up to 582 cattle grazing five months out of the year on an even-odd pasture rotation schedule.<br /><br />>“<em>From 1988 to 2009 cattle actual use averaged 64% of the 3,215 permitted AUMs</em>.”<br /><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S-JiJ73Q1II/AAAAAAAACG4/U8ZtHU1DpWY/s1600/Massacre+Lakes+Allotment+AUMs_1988-2009.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 304px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5468040820409029762" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S-JiJ73Q1II/AAAAAAAACG4/U8ZtHU1DpWY/s400/Massacre+Lakes+Allotment+AUMs_1988-2009.jpg" /></a><br />While BLM cites a 64% average for actual cattle use, according to the Animal Unit Month (AUM) Chart provided in the MER above, livestock grazing was authorized at an all time high in 2008 and the third highest in 2009 since 1988 – right at the time BLM needed to snap lots of photos of rangeland degradation, which of course is now being attributed mostly to wild horses…<br /><br /><br /><strong>About The Juniper Pasture</strong><br />“<em>Based on population inventory and distribution information, wild horses mainly occupy the mid and upper elevations of the Juniper Pasture and rarely use other pastures except during unusual winters when the snow is too deep for them to find forage</em>.”<br /><br />"<em>Figure 2 (below) depicts annual livestock AUMs used in the Juniper Pasture based on Actual Grazing Use Reports since 1988 and estimated wild horse use (AUMs) based on helicopter population inventories (direct counts) in 1997, 2001, 2007, and 2008. During 1989, 1992, 1994, 1996, 1998, 2000, 2003, 2004, 2006, and 2007 the Juniper Pasture was rested from cattle use</em>."<br /><br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S-JiQ3D_q6I/AAAAAAAACHA/pvqDmcnvvbE/s1600/Massacre+Lakes_Juniper+Pasture+AUMs_1988-2009.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 297px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5468040939379338146" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S-JiQ3D_q6I/AAAAAAAACHA/pvqDmcnvvbE/s400/Massacre+Lakes_Juniper+Pasture+AUMs_1988-2009.jpg" /></a><br /><br />Again, we find that since 1988, the highest recorded livestock grazing occurring in the Juniper Pasture was authorized by BLM in 2008 during “drought, low precipitation, lack of forage production and degraded rangeland conditions” that are resulting from this lack of water – unless you need to graze livestock heavily to support a new rangeland health assessment that will determine new wild horse AMLs.<br /><br /><strong>Question:</strong> If BLM states that the Juniper Pasture is authorized for an even-odd pasture rotation system, meaning, Year 1 - Cattle graze, Year 2 - the Pasture is rested <span style="font-size:78%;">(BLM April 2010 MER, pg. 5)</span> and the Juniper Pasture was rested in 2007, then cattle were allowed to graze in 2008, <strong>why does the chart above show approximately 1,200 AUMs being used by cattle in 2009?<br /></strong><br />BLM also states in the accompanying RHA about the Juniper Pasture that, “<em>In 2009, the wild horse estimated actual use was greater than the livestock actual use within this pasture</em>”.<br /><br />Hmmm… actual use, huh?<br /><br /><br /><strong>About Rangeland Health<br /></strong>In the April 2010, RHA and MER, BLM states,<br /><br /><strong>> </strong>“<em>Field observations indicate that wild horses are currently contributing the most negative impacts to riparian sites within the Allotment/HMA, especially those in the vicinity of Sage Hen Springs. Based on staff observations, wild horses appear to be the sole contributor to the degraded conditions and non-functional status of Sage Hen Springs</em>”.<br /><br /><strong>></strong> “<em>The poor condition of riparian areas in the northeast portion of the Juniper Pasture are generally due to year-round use by wild horses rather than seasonal use by livestock</em>.”<br /><br /><strong>></strong> “<em>In the northern most portions of the allotment, negative impacts to Sage Hen Spring and smaller un-named springs in the vicinity are reducing the water holding capacity for riparian habitats. The degraded conditions of riparian areas in the northeast portion of the Juniper Pasture are generally due to year-round use by wild horses rather than seasonal use by livestock.</em>”<br /><br /><strong>></strong> “<em>Sustainable forage utilization levels (that consider the combined impacts of livestock, wild horses, and wildlife) will be set for key grass, forb, and shrub species in order to maintain healthy native plant communities</em>”. <span style="font-size:78%;">(Surprise RMP, Final EIS, pg. 2-64)<br /></span><br />> “<em>Forage allocation for wild horses would be managed equitably (i.e., neither having precedence over the other).</em>” To learn more about additional stipulations for wild horse and burro management affecting the Massacre Lakes HMA , <a href="http://americanherds.blogspot.com/2009/06/on-massacre-lakes.html"><span style="color:#cc6600;">Click Here</span></a>.<br /><br /><br /><strong>About Water</strong><br />> “<em>Several of the natural water sources have been developed and some of these developed waters have been fenced</em>” (MER, pg. 6.)<br /><br /><strong>></strong> BLM only monitored 12 springs occurring in the Massacre Lakes Allotment/HMA, all of which occur in the Juniper Pasture. Of these, only one is listed by BLM as used by livestock, Post Canyon Seep #2 – despite authorizing up to 582 head of cattle 5 months out of the year. The rest of the “noted impacts” to 7 of these water sources is attributed solely to wild horses in a Riparian Table provided in the RHA <span style="font-size:78%;">(pg. 7),</span> including Un-named Seep # 4.<br /><br /><strong>> </strong>In the detailed descriptions of Seep #4, BLM states livestock were found using the riparian site. This fact was omitted when they were filling out the boxes in the Riparian Table attributing use exclusively to wild horses.<br /><br /><strong>></strong> Though other water sources are listed for the Lake Field, West Seeding, East Seeding and Sand Spring Pasture, all of them are cited as not containing any “public springs or springs” with the exception of Sand Spring Pasture, which has been developed. (MER, pg. 6.)<br /><br /><strong>></strong> The BLM provides no water flow rates or gallons per minutes within either assessment in order to help determine water availability for wild horse use. One would think this information would be considered a critical issue in the drought stricken West as it is the harbinger of “emergency round ups” and yet this information is totally absent in the RHA.<br /><br /><strong>></strong> BLM also excuses itself for failing to provide any water quality data throughout both the RHA and MER by checking of N/A on all of the required questions.<br /><br />“<em>Extensive experience monitoring livestock impacts from cattle to surface water quality has shown that livestock, especially cattle, must be excluded from surface waters if fecal coliform standards are to be met…..The BLM relies primarily on the Water Quality Control Board to identify impaired waters or high probability of impaired waters (page A-36). However, if BLM is sampling these waters and Lahontan staff does not receive the data, how is Lahontan staff to determine if waters are impaired or not? There clearly needs to be a formal process for sharing of monitoring data</em>.”</div><div align="right"><em>Lahontan Regional Water Quality Board<br />Public Comment/Surprise RMP Planning Process</em></div><div align="justify"><br /><br /><strong>></strong> Post Spring, Indian Spring and Sage Hen Spring appear to be the major water sources for wild horses, two of which have been fenced. In 2007, BLM noted that the exclosure fence for Post Spring was down and received heavy grazing use by wild horses. The fence was fixed in 2008 to exclude wild horses again.<br /><br />> The Sage Hen Spring appears to be the only unfenced spring in the area and as can be expected, is receiving a high degree of wild horse use. Four other un-named seeps were also included in the evaluation, all of which are located between ½ to 1 mile from Sage Hen Spring. Of these, BLM noted “<em>impacts were generally from wild horses</em>” on three of them while the fourth found evidence of wild horses, cattle and antelope “<em>but trampling impacts were not noted</em>” within the one Un-Named Seep cattle were found using.<br /><br /><strong>></strong> A total of 2,590 acres of lakes have been identified as occurring in the area, some of which overlaps the Massacre Lakes HMA. However, the map provided by BLM indicates fencing has probably been erected to prevent any access by wild horses to this abundant water source. This is further evidenced by the fact that BLM reports no wild horse populations are found in these areas.<br /><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/S-Jh3W7At_I/AAAAAAAACGw/KX3VBjwhp5s/s1600/MassacreLakes_Water%2BWH%23_Overlay_Close+Up.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 252px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5468040501254993906" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/S-Jh3W7At_I/AAAAAAAACGw/KX3VBjwhp5s/s400/MassacreLakes_Water%2BWH%23_Overlay_Close+Up.jpg" /></a></div><div align="center"><span style="font-size:78%;">Overlay of BLM Maps of Water Sources and 2008 Wild Horse Populations<br />Blue dots are water sources, purple are wild horse populations.</span></div><div align="justify"><br /><br /><strong>About Soils</strong><br /><strong>></strong> In the Surprise RMP, BLM sets the following standard for all future management plans for wild horses: “<em>An AML will be reduced if soil degradation is attributable to wild horse use at the existing AML.”</em> <span style="font-size:78%;">(pg. 2-44)<br /></span><br /><strong>></strong> In the April 2010, RHA, BLM states, “<em>Results from soil stability tests indicated that three of the five sites were unstable</em>”. BLM also checked off the box for Standards of Upland Soils Not Being Met and Not Progressing Towards meeting these standards; all three of these “unstable sites” are identified as occurring in the Juniper Pasture, exclusive home to the Massacre Lakes wild horses.<br /><br /><br /><strong>About Wildlife</strong><br /><strong>> </strong>“<em>The Massacre Lakes Allotment is entirely within NDOW’s Hunt Unit 011</em>”<span style="font-size:78%;"> (BLM April 2010, MER pg. 19)<br /></span><br /><strong>></strong> In the 1982 Revised Allotment Management Objectives, BLM approved forage allocations that, “<em>Ensure sufficient browse for <strong>90 deer</strong></em>” and “<em>Provide habitat is satisfactory condition for <strong>150 antelope</strong></em>”. “<em><br /><br /><strong>></strong> BLM went on to state, "The following allotment objectives [from the 1982 report] are no longer consistent with RMP objectives….<strong>BLM no longer manages for reasonable numbers of wildlife populations.</strong> The RMP replaced reasonable numbers with habitat condition</em>”. <span style="font-size:78%;">(BLM April 2010 MER, pg. 28)</span><br /><br /><strong>></strong> “<em>According to NDOW‘s 2008-2009 big game status report, estimates of <strong>mule deer</strong> populations for 2008 and 2009 were <strong>2,400 animals</strong> in units 011-013 for each year</em>.” <span style="font-size:78%;">(BLM April 2010, MER pg. 19)<br /></span><br />> “<em>In 2008 and 2009, the <strong>pronghorn antelope population</strong> estimate for unit 011 <strong>ranged from 1,100 to 1,200 animals</strong>.”</em> <span style="font-size:78%;">(BLMs April 2010, MER, pg. 19.)<br /></span><br /><strong>></strong> “<em>Nevada’s statewide pronghorn population remains at a record high level of 24,500 animals.”</em> <span style="font-size:78%;">(Nevada Department of Wildlife [NDOW] 2009-2009 Big Game Status Book, pg. SS-2)</span><br /><br />> “<em>Recruitment rates remained strong n hunt Units 011 and 015….Buck ratios remain strong in hunt Units 011…However, the higher buck ratios observed in these hunt units are somewhat inflated by the preceeding year’s strong recruitment values.”</em> <span style="font-size:78%;">(Nevada Department of Wildlife [NDOW] 2009-2009 Big Game Status Book, pg. 27)<br /></span><br />“<em>Pronghorn populations in Units 011 and 015 continue to do well. Recruitment values have been very strong in both of these units for several years. The pronghorn populations in these units are expanding. Unit 011 was slightly drier this year than what has been observed in the recent past, however, habitat conditions were still markedly better than what was observed in the surrounding hunt units."</em> <span style="font-size:78%;">(Nevada Department of Wildlife [NDOW] 2009-2009 Big Game Status Book, pg. 28)<br /></span><br />> “<em>Competition for food and water between pronghorn, feral horses, cattle and domestic sheep continues to be an issue in Western Nevada. The current drought conditions have only made things worse, especially during the warmer months as animals seek out the areas with better forage and concentrate close to water sources. Once again, numerous complaints were received from hunters who had observed feral horses chasing and harassing pronghorn near water sources. The competition between horses and pronghorn occurs in most units but appears to be especially high in Unit 012 where water sources are somewhat limited.”</em> <span style="font-size:78%;">(Nevada Department of Wildlife [NDOW] 2009-2009 Big Game Status Book, pg. 27)</span><br /><br />> “<em>According to NDOW, big game animals are experiencing declines due to drought conditions (7 of the last 10 years) affects on vegetation, and competition with wild horses.”</em> <span style="font-size:78%;">(BLMs April 2010, MER, pg. 10.)</span><br /><br />As NDOW continues to cite numerous complaints of harassment by wild horses and drought conditions creating intense competition between rangeland users, wildlife populations continue to soar with strong recruitment rates, record pronghorn populations, and average mule deer populations now tallied at 800 deer p/hunt unit versus the old days when “reasonable numbers” were actually set by BLM to protect habitat for all rangeland users.<br /><br />Based on these reports, mule deer populations have increased by almost 900% and pronghorn have increased by at least 733% in the Massacre Lakes Allotment – but BLM doesn’t consider these dramatic increases in the “thriving natural ecological balance” in the RHA and MER analysis. Why? Because they wrote themselves a “get out of jail free card” in the new Surprise RMP…<br /><br />“<em>Sportsman and hunters contribute over $200 million per year in excise taxes to help the State agencies develop habitat and improve the hunting and fishing opportunities for everyone. Coordinating the BLM and USFWS efforts to utilize these funds to improve habitat and wildlife populations must be a first priority of the Resource Management Plan.”</em></div><div align="right"><em>James L. Easton/Public Comment<br />Surprise RMP Planning Process</em></div><div align="justify"><br /><br /><strong>About Nevada Department Of Wildlife (NDOW)</strong><br />How does NDOW feel about “feral horses”? Well, it depends on who you ask and what kind of hot seat they may be sitting on at the time. Generally, NDOW’s stated position is, they are strong supporters of BLM keeping wild horses and burros within the established AMLs.<br /><br />And then they go after the AMLs….<br /><br />Here some are excerpts from NDOW’s comments to BLM during the development of the Surprise RMP about the management of wild horses (<em>Editors Note: These comments were NOT site specific to the Massacre Lakes area but to the entire area managed by the Surprise Field Office.</em>):<br /><br /><strong>></strong> “<em>The Preferred Alternative must determine the Standard Operating Procedures that affect the determination of carrying capacities and allocation of forage to ungulates. Specie specific rangeland monitoring studies must be identified to deal with wild horses and pioneering elk. Without meaningful studies and fair evaluations, the resources will remain a political issue.”</em><br /><br /><strong>> </strong>“<em>Monitoring studies must distinguish ungulate use and impacts for proper adjustments. Failure to properly monitor utilization limits or Guidelines will result in arbitrary allocation of available forage. Studies will be required to adjust and manage for pioneering elk.”</em><br /><br />> “<em>Genetic viability and self-sustaining populations are requirements of the Act. In specific herd management areas where the appropriate management level cannot support a self-sustaining population the herd should be eliminated. In herd areas that do not have adequate water, cover and forage, these herds should be eliminated. Costs of artificially managing herds dependent on private landowners are an excessive cost to limited budgets for wild horse and burro management.”</em><br /><br /><strong>></strong> “<em>Appropriate Management Levels on isolated herds that are below 120 adults are deemed below a genetic threshold. Recent studies show these herds cannot survive over the long term and should be considered for elimination in the new RMP.”</em><br /><br /><br /><strong>About Migration</strong><br />According to BLMs objectives in 1985, they were suppose to “<em>assess the amount of interchange between the Massacre Lakes wild horses and the surrounding HMA’s in the Surprise Resource Area and the Bitner Butte Herd of the Sheldon National Wildlife Refuge</em>” <span style="font-size:78%;">(BLMs April 2010, MER, pg. 27.)<br /></span><br />When one reviews BLMs population inventories and reports for the Massacre Lakes wild horses since 1988, populations seem relatively stable for many of those years (except recently). It is from these numbers that BLM determines reproduction rates and estimated forage consumption, all of which appear relatively stable with no large population swings.<br /><br />Except, BLM has determined these wild horses will be managed as a “Complex”, though no evidence is presented in the RHA or MER that would even suggest wild horse numbers are fluctuating from interchanges and migratory patterns, does it?<br /><br />BLM even states in their RMP objectives that, “<em>Once the area recovers, an appropriate AML would be determined and wild horses reintroduced.”</em> So why would wild horses need to be “reintroduced” if they are a migrating between these HMA’s or even Sheldon?<br /><br />Not a single report, excerpt or mention is made in the April 2010, RHA or MER of wild horses migrating to anywhere or if any follow up whatsoever was ever completed regarding interchanges between BLM horses and Sheldon horses.<br /><br />This raises some interesting questions, such as:<br /><br /><strong>></strong> What about BLM’s current assertions in their April 2010 RHA/MER that state wild horses generally aren’t found anywhere outside of the Juniper Pasture with the rest of the HMA and pastures only receiving occasional, incidental use?<br /><br /><strong>></strong> Did BLM know this all along and that’s why the “approved” of a management plan in the RMP that would allow them to wipe out a herd with promises of future “reintroductions”, knowing full well there was no interchange going on whatsoever?<br /><br /><strong>></strong> Is that why NDOW was arguing that if a herd was not issued a self-sustaining AML such as the 35 for Massacre Lakes, 24 for Bitner, 55 for Nut Mountain, and 25 for Wall Canyon, that those herds should be eliminated in the RMP? But wouldn’t such an straightforward plan as NDOW suggests cause protests, spark controversy, and violate BLM’s requirement to maintain wild horses and burros “where presently found” at the passage of the 1971 Act?<br /><br /><strong>></strong> Or can the answer be found in why BLM has not conducted an official round up of wild horses in the Massacre Lakes HMA since 1988? Have they known all along that wild horses moved on to Sheldon and were “disposed of” according to USFWS policy – no questions asked?<br /><br />********************************************************************************<br /><br />The BLM is now accepting public comments on the Massacre Lakes Allotment, which will determine the future of livestock grazing and wild horse populations in the Massacre Lakes Herd Management Area. BLM will use comments received from interested parties to identify issues for the recommended management action. Please provide detailed comments if identifying an alternative for consideration. A copy of the EA and related documents will be available when completed.</div><div align="center"><br /><br /><strong>~Public Comment Deadline~<br />FRIDAY, MAY 7TH, 2010, 4:30 P.M. PST<br /></strong><br />Bureau of Land Management-Surprise Field Office<br />Attn: Steve Surian<br />PO Box 460, Cedarville, CA 96104<br />Fax: (530) 279-2171<br />Email: casrpubcom@blm.gov<br /><br /><br /><strong>ADDITIONAL LINKS</strong><br /><br />BLM DOCUMENTS<br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3NGU3NDhiYzdlNjQyMWVm&pli=1"><span style="color:#cc6600;">Capture Plan/EA CA-370-05-28<br />Wall Canyon East, Nut Mountain and Bitner HMAs<br />September 2005<br /></span></a><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo2MDFjZDdjMmZkYzJkNTdj"><span style="color:#cc6600;">FONSI/DR EA CA-370-05-28<br />2005<br /></span></a><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxNTYzNWY1NWQxOGNhODkz"><span style="color:#cc6600;">Notice of Proposed Action (NOPA)<br />May 18, 2007</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1MjlmZDNhMWFmNjMwODY1"><span style="color:#cc6600;">Massacre Lakes Scoping Letter<br />May 17, 2009</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3ZDNjNTRjOTBhNGM1Nzgz"><span style="color:#cc6600;">Massacre Lakes Allotment & HMA<br />Monitoring Evaluation Report (MER)<br />April 26, 2010</span></a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoyNzg5MzlmMTY3OGM4NTBh"><span style="color:#cc6600;">Massacre Lakes Allotment & HMA<br />Rangeland Health Assessment (RHA)<br />April 7, 2010<br /></span></a><br /><br />My Public Comment Submissions<br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo2ODgwYmEyZDVlMzBhMDQ4"><span style="color:#cc6600;">October 10, 2007</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxOTRiNjA4ZWM0MTdlMTAy"><span style="color:#cc6600;">June 17, 2009</span> </a><br /><br /><br /><a href="http://www.ndow.org/about/pubs/reports/09_bg_status_bk.pdf"><span style="color:#cc6600;">Nevada Department of Wildlife<br />Big Game Status Report: 2008-2009</span></a> </div>Unknownnoreply@blogger.com1tag:blogger.com,1999:blog-4562357749295999770.post-17150787499847153082010-04-29T10:24:00.000-07:002010-04-29T10:26:02.400-07:00Calico: Past, Present & Future III<div align="justify"><em>This is the third in a series of articles that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond…</em></div><br /><br /><div align="center"><strong>SHELDON NATIONAL WILDLIFE REFUGE</strong></div><br /><div align="justify">Sitting on the edge of the BLM managed lands of some of the wild horse Herd Management Areas that comprise the Calico Complex is the Sheldon National Wildlife Refuge, also under the jurisdiction of the Secretary of the Interior but home to a very different set of rules regarding the management of horses and burros.<br /><br />This home on the range where the antelope play calls wild horses and burros feral and sportsman openly lobby Congress to eradicate their populations completely. <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDpiMjg0ODUwYjJkYzViNTY&pli=1"><strong><span style="color:#cc6600;">Click Here</span></strong> </a>to learn more.<br /><br />Public awareness of the Sheldon wild horses and burros sky rocketed after American Wild Horse Preservation Campaign (AWHPC) released an explicit and shocking undercover pictorial report of a June 2006 round up titled <strong><span style="color:#cc6600;">“</span></strong><a href="http://www.wildhorsepreservation.com/roundups/witness/sheldon.html"><strong><span style="color:#cc6600;">The Reality of Round Ups: Attempt At A Cover Up</span></strong></a><span style="color:#cc9933;"><strong><span style="color:#cc6600;">”.</span></strong><br /></span><br />Included were graphic photos of dead foals found littered across the landscape, hog-tied foals, dead and injured horses in the holding pens and a veterinarian report citing the extreme trauma documented to foals as a result of the gather; some of whom survived and some whom did not.<br /><br />Questions also exploded around the methods used by long-time BLM contractor Dave Cattoor of Cattoor Livestock Inc., to drive wild horses and burros to the traps and again evoked controversy as to whether helicopter driving could ever be considered humane or safe considering it was outlawed before due to its known detrimental results. (<em>Editor’s Note: Despite criminal charges filed against Dave Cattoor in 1990 for “</em>conspiracy and use of aircraft to capture wild horses and aiding and abetting….”, <em>which led to the</em> “said wild, unbranded horses to be sold and shipped by truck to Great Western Meats in Morton, Texas, to be slaughtered and processed<em>”, BLM has continued to insist he does excellent work for them and excuses AWHPC’s shocking Sheldon report by citing it didn’t happen during a BLM gather…)</em><br /><br />As public awareness grew about the Sheldon wild horses and burros, so did the conflict. Between 2006 and 2008, comments and protests poured into Refuge managers about continuing plans to round up all of the almost 2,000 estimated wild horses and burros. Of additional concern was how the now captured horses were being disposed of as some of the 2006 Sheldon horses were eventually found in Canadian livestock auctions headed for slaughter.</div><div align="center"><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S9m6bk8lg1I/AAAAAAAACGo/PFIo9VK-lEw/s1600/sheldon5d.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 264px; DISPLAY: block; HEIGHT: 255px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5465604605727834962" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S9m6bk8lg1I/AAAAAAAACGo/PFIo9VK-lEw/s400/sheldon5d.jpg" /></a><span style="font-size:78%;">2006 Sheldon Round Up<br />Courtesy of American Wild Horse Preservation Campaign</span><br /><br /><br /><strong>HISTORY OF SHELDON</strong></div><br /><div align="justify">According to U.S. Fish & Wildlife Service (USFWS), wild horses were documented in the area before Sheldon became a wildlife refuge in 1931. Local ranchers managed horses there by mixing domestic horses with the original Spanish horses of the area (who have a documented presence dating back to the 1600’s) as Sheldon became a stocking and Calvary Re-Mount location during the late 1800’s and early 1900’s.<br /><br />In 1971, when the Wild Free-Roaming Horse and Burro Act was passed, Sheldon was co-managed by both USFWS and BLM. For a brief five years, the Sheldon wild horses and burros were protected from “capture, branding, harassment, or death” under the auspices of the Act until Congress amended the National Wildlife Refuge Administration Act with the Game Range Bill in 1976 and USFWS became the sole managing agency. As a result, the Secretary of the Interior and all subsequent USFWS policies deny any protections under the Act are entitled to these wild horses and burros.<br /><br />In 1977, Refuge managers created The Sheldon Horse Management Plan, which still stands as the guiding framework for how wild horses and burros would be handled. At that time, a herd size of 75-125 horses was established. USFWS estimated approximately 800 wild horses inhabited the Refuge at the time but were initiating plans for the immediate round up of 700 wild horses due to officials stating they were causing severe impacts to wildlife habitat which required “emergency removals”.<br /><br />USFWS also reported 3,600 cattle grazed the Refuge then and used about 24,000 AUMs annually. It is interesting to note that a letter submitted by Friends of the Earth during the public comment process stated, “<em>Friends of the Earth support this proposal [the removal of 700 wild horses]. However, last year’s onsight tour of Refuge and Range confirmed our suspicions that the major problem at Sheldon is not caused by the wild horses but rather by the overgrazing of cattle, particularly on the range portion of the complex</em>.”<br /><br />Unlike the recent revelations by BLM in the Calico Complex EA last fall, which speculated on wild horses migrating back and forth between Sheldon and BLM managed lands, in 1977, USFWS wrote, “<em>Nearly all of the exterior boundary of the Sheldon Range is fenced…so in all practicality, the horses found within the Range are separate and distinct populations</em>.”<br /><br />In 1980, USFWS issued their Renewable Natural Resource Management Plan and Final Environmental Impact Statement for the Refuge, which continues to be the guiding management plan for the Refuge in its entirety. Included within its framework was the approval of allowing a range of 75-125 horses and 30-60 burros to continue to exist on the Refuge in conformance with The Sheldon Horse Management Plan.<br /><br />In 1982, the Secretary of the Interior approved a new policy outlining the role and management of “feral horses and burros” within the National Wildlife Refuge System, (7 RM 6.1). The policy specifically states that, “<em>It is the policy of the Service that feral horse and burro populations will not be maintained on Sheldon, Hart Mountain, and Kofa NWR’s. Feral horses and burros on these refuges will be removed in accordance with the provisions of 50 CFR 30.12 and Section 6.9, below. Feral horses and burros shall not be introduced, established, or allowed to become established on any national wildlife refuge</em>.”<br /><br />However, due to the 1980 decision, prior officials had legally authorized wild horses and burros at Sheldon. Until a new Record of Decision is signed, management of the equids is in a legal quagmire as the current Service policy demanding wild horses and burros be totally eliminated on Sheldon conflicts with the 1980 decision to allow them to be maintained.<br /><br />In 1982, USFWS also developed policies for management of wild horses and burros in areas where animals may wander back and forth between refuge lands and public lands. Some of these policies state;<br /><br />a) “<em>In the case where horses and burros wander back and forth between refuge lands and public lands, cooperative management planning will occur with the appropriate agency (e.g., BLM) and a joint management plan must be developed</em>".<br /><br />b) "<em>Close coordination with the Bureau of Land Management is necessary to assure refuge objectives receive consideration when population goals are set on adjacent public lands</em>".<br /><br />c) “<em>Appropriate population levels are to be determined by the following criteria: vegetation conditions and trend; availability of water; degree of conflicts with all wildlife forms; compatibility with refuge objectives; and BLM horse/burro management policy on adjoining lands</em>” and,<br /><br />d) USFWS is required to <em>“comply with the Wild Free-Roaming Horse and Burro Act of 1971, where applicable</em>.”<br /><br />In 1994, USFWS officially closed the Refuge to livestock grazing as a result of the private purchase of the grazing permits, which were then donated to the USFWS for retirement.<br /><br />In 1996, a Memorandum of Understanding (MOU) was signed with BLM regarding cooperative management of wild horses and burros that range between BLM and USFWS managed lands. The MOU stated that, "<em>BLM State Directors and FWS Area Managers will develop agreements and, as appropriate, joint plans for the management of wild horses and burros which range interchangeably upon the lands of the other</em>".<br /><br />The question now becomes, how do officials determine which wild horses stay exclusively on Sheldon to be managed solely under USFWS regulations and those who “<em>range interchangeably upon the lands of the other</em>”.<br /><br />In 2001, USFWS issued a Memorandum, which gave them authority to contract out or broker the disposal of horses and burros removed from the Refuge. The Memo stated that, “T<em>he chosen contractor will be required to arrange for adoption or otherwise provide for disposition of the horses captured in a manner that prevents slaughter for the meat market to the maximum extent possible and also prevent humane on-site euthanasia except in cases of debilitating injury or disease</em>.” Prior to this, removed wild horses and burros were disposed of via auctions and any unsold animals were destroyed.<br /><br />Since then, USFWS has been working on an adoption program for horses and burros removed from Sheldon and coordinates with “<em>organizations or individuals acting as adoption agents for the refuge</em>.” However, currently horses and burros are not required to be branded upon leaving the Refuge nor is there a system established to track them or follow up with adopters.</div><br /><div align="center"><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S9moDZViA4I/AAAAAAAACGg/wgGZ9s6fzSM/s1600/sheldon3.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5465584399085077378" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S9moDZViA4I/AAAAAAAACGg/wgGZ9s6fzSM/s400/sheldon3.jpg" /></a> <span style="font-size:78%;">Capture horses from Sheldon's 2006 round up.<br />Courtesy of American Wild Horse Preservation Campaign</span><br /><br /><br /><strong>THE BATTLE</strong></div><br /><div align="justify">According to USFWS records, approximately 3,000 horses and 300 burros have been removed from the Refuge between 1980 and 2006.<br /><br />A population graph provided by Sheldon officials reports horse populations were kept relatively stable between 1979 and 1996 but due to funding limitations, removals stopped and managers claimed populations exploded from 600 to 2,200 in just eight years when 772 horses and 99 burros were finally removed in 2004.<br /><br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S9mn7EsozQI/AAAAAAAACGY/ynzKkYjoJHg/s1600/Sheldon+WH%23+Graph_1979-2007.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 221px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5465584256105893122" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S9mn7EsozQI/AAAAAAAACGY/ynzKkYjoJHg/s400/Sheldon+WH%23+Graph_1979-2007.jpg" /></a><br />In 2006, the Service went back for more with over 330 horses being captured and removed. This round up became the source of AWHPC’s “Attempt At A Cover-Up”, a story that first broke by a <a href="http://www.nwha.us/issues/Sheldon%20Range%20Mustangs.pdf"><strong><span style="color:#cc6600;">Special Research Group</span></strong> </a>who uncovered a slew of disturbing information, some of which included:<br /><br />> 16 to 18 mares were found in the pens showing signs of recently giving birth but had no foals with them. Despite USFWS requiring the public to stay at least two miles away from the gather operations, it is estimated at least nine foals died or were aborted in the pens and about fifteen foals were probably left to die a slow death in the high desert. Three of these foals survived days of abandonment, and one foal that arrived with the adults survived trampling in the pens.<br /><br />> USFWS “adoption program” prohibited individuals or organizations from adopting directly from the Refuge. Only three “carefully screened” contractors were allowed to take the horses and only in mass truckloads. USFWS also paid the contractors $300.00 p/horse to haul them away.<br /><br />> Two of these contractors, Forever Free Mustangs and Gary Graham, caused serious concerns as to what was happening to the horses once they arrived. Background checks revealed the Graham address was virtually a Grand Central Station of horseslaughter while Forever Free Mustangs were able to unload truckload after truckload of horses to “local adopters” that defied even the best sanctuary’s adoption average. To learn more, <a href="http://tech.dir.groups.yahoo.com/group/US_againsthorseslaughter/message/1374"><strong><span style="color:#cc6600;">Click Here</span></strong></a>.<br /><br />In response to the disastrous June 2006 round up, Congressional Representative Nick Rahall wrote USFWS Director Dale Hall on July 19, 2006, requesting a “cease and desist” on any further horse and burro removals and cited 26-year old management plans that failed to even remotely provide current information on the Refuge. <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDozNzBkMDcwMmM4Zjg2MGNm"><strong><span style="color:#cc6600;">Click Here</span></strong> </a>to view Representative Rahall’s letter.<br /><br />In April 2007, Sheldon released a Preliminary EA proposing to remove horses and burros from the Refuge “<em>at the fastest rate possible</em>”. A fire storm of protests from wild horse and burro advocates flooded the desks of officials due to what many considered a less-than-honest evaluation and continuing concerns for safe and humane treatment of the horses; both during the round ups as well as where they would end up.<br /><br />Two months later, Refuge managers issued their final decision in June with virtually no changes to the original proposal and little concern for addressing Rahall’s requests.<br /><br />In response, on July 18th, In Defense of Animals (IDA) and attorneys at Meyer Glitzenstein & Crystal, a Washington D.C. based pubic interest firm specializing in environmental litigation, sent an urgent letter to USFWS warning of several documented NEPA violations in the proposed removals and warned USFWS that pushing ahead with the round ups would violate federal law.<br /><br />So in September 2007, USFWS issued a new EA and a new plan to manage horses and burros until they completed their Comprehensive Conservation Plan, which is projected for release sometime in 2010.<br /><br />The crux of September's new plan centered around aerial surveys USFWS and Nevada Department of Wildlife (NDOW) conducted in June of 2007, which found 50% less horses on the Refuge; USFWS now reported horses magically dropped from the April estimate of 1,500 to just 800 horses two months later.<br /><br />USFWS then told the public they could only speculate as to where the horses had gone but theorized approximately 700 horses had “migrated” to BLM lands over the winter and fence repairs completed in the spring prevented their return to Sheldon.<br /><br />According to Jim Nelson, then President of Nevada Bighorns Unlimited (NBU), both the aerial surveys and fence repairs were paid for by NBU, who refer to wild horse and burro advocates as “the opposition”, despite NBU Board Member Larry Johnson still currently serving on the National Wild Horse & Burro Advisory Board. <a href="http://americanherds.blogspot.com/2008/02/what-nbu-is-doing-for-you.html"><strong><span style="color:#cc6600;">Click Here</span></strong> </a>to learn more.<br /><br />As a result of so many horses now reported as missing from the Refuge, USFWS postponed all further round up plans for 2007.<br /><br />In an attempt to discover where the Sheldon horses may have “migrated too”, follow up emails were sent to Paul Steblein, Supervisor of Sheldon, BLMs National Program Office Wild Horse & Burro Lead Dean Bolstad and BLM Wild Horse & Burro Leads from Nevada, California and Oregon on 9/14/07, 9/18/07 and 10/26/07 requesting where officials believe the most likely places the Sheldon horses had gone too. To date, not one of them ever responded….<br /><br />In April 2008, a revised EA was released as Sheldon officials proposed an interim management plan for horses and burros until the Comprehensive Conservation Plan was finalized. The proposal was to allow the population to stay stable at about 800 horses and 90 burros with round ups only conducted to remove the equivalent of the projected foaling increase at about 140-180 horses and 15-20 burros a year.<br /><br />Sheldon managers also approved utilizing fertility control at the request of advocates. However, officials did not go in the direction advocates had assumed, specifically, by using reversible pzp on mares. Instead, they began implementing permanent sterilization measures.<br /><br />According to a <strong><a href="http://www.equinewelfarealliance.org/uploads/BLM.Team.Euth.FOIA_Cover.letter.pdf"><span style="color:#cc6600;">BLM Team Conference Call Report</span></a></strong> in 2008 obtained via FOIA, Sheldon managers began spaying mares and currently, we can confirm at least 30 mares were permanently spayed with 3 dying in the process. Geldings of stallions returned to the range has also been reported but Sheldon Supervisor Paul Steblein has so far refused to provide any further information about what has been happening at Sheldon over the last two years.<br /><br />Round ups have transpired with little to no public notices and no information provided as to how many have been removed, when they were removed or how many have been sterilized. Questions to Sheldon officials continue to go unanswered.<br /><br />On September 2, 2009, a lawsuit was filed by Laura Leigh and Cowan Law Offices against continuing Sheldon’s horse and burro management plans, which also requested an injunction to halt any further round ups or shipments of horses. Some of the issues listed in the complaint included sordid histories of contractors, lack of tracking systems such as brands or microchips on horses, horses previously removed found headed to slaughter, illegal seizure of Nevada State property and illegal transportation of horses across state lines. <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoyNjM1MmYwMzZhZjk3Zjgw"><strong><span style="color:#cc6600;">Click Here</span></strong> </a>to read the full complaint.<br /><br />On April 15, 2010, Equine Welfare Alliance (EWA) issued a press release titled, <strong><a href="http://www.equinewelfarealliance.org/uploads/Sheldon_Lawsuit_FINAL.pdf"><span style="color:#cc6600;">In The Spirit of Compromise,</span></a></strong> which stated that Laura Leigh had dropped the lawsuit “<em>in a gesture of support for the concept of cooperative dialogue</em>” with hopes of being able to move forward in a constructive relationship with officials after announcing they are in “<em>the planning states of creating a two million acre management complex for wild horses in Southeast Oregon, Northeast California, Northwestern Nevada and the Sheldon NWR located in Northeast Nevada</em>”, currently coined as the Tri-State Mega-Complex.<br /><br />While Steblein, the current Complex Manager for the Sheldon Refuge was saying, “<em>In general I am very happy about this. This is an opportunity to create constructive ways to manage horses across the landscape” </em>to EWA and, “<em>This is the time where we stop pointing fingers and figure out how to solve this</em>”, he continued to stonewall questions about what was happening on the ground.<br /><br />First, early this year, questions were submitted to USFWS's general website requesting numbers about horse and burro removals over the last two years – but no one responded. So, a month later on February 26, 2010, I called the office and merely left my first name requesting Mr. Steblein call me back. And what do you know? He did!<br /><br />I asked Mr. Steblein questions about gathers, removals, contraceptives, and census methods, all of which he kept stating that since he didn’t have the records in front of him, he couldn’t quote exact numbers. He promised to follow up via email with both numbers and reports so, I sent a follow up email repeating the same questions I asked him via phone. And it went unanswered. So I asked again on April 10, 2010, and it too has gone unanswered.... (<em>Apparently, it's important to not identify yourself completely or what you are interested in talking about or you won’t receive a reply.</em>)<br /><br />If Mr. Steblein is really interested in creating constructive ways to solve problems, why isn’t he or anybody from USFWS for that matter, answering questions about what has been happening to the Sheldon wild horses and burros for the last two years?<br /><br />Well, my guess is because there is a plan in the works….</div><br /><br /><div align="center"><br /><span style="font-size:130%;"><strong>~ADDITIONAL LINKS~</strong></span><br /><br /><br /><strong>USFWS DOCUMENTS</strong><br /><br /><strong><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1M2Q3ZTkzNTdhYWI4YjRl"><span style="color:#cc6600;">November 1977: Sheldon Horse Management Plan<br /></span></a></strong><br /><strong><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoyZjNkZDM1YjExZmVkNTBj"><span style="color:#cc6600;">April 2007: Draft EA<br /></span></a></strong><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1Y2JkMGQ5MmYyNWNhNjlh"><strong><span style="color:#cc6600;">June 2007: Final EA</span></strong> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxMDQwNGE1NjkwNzkyYTZj"><strong><span style="color:#cc6600;">June 2007: Decision & FONSI</span></strong> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0MjRiYTIyYTBiYzBiODZj"><strong><span style="color:#cc6600;">September 2007: Revised Draft EA</span></strong> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo2NmRlMTc0MjRjZGI1YjY4"><strong><span style="color:#cc6600;">April 2008: Revised/Final EA</span></strong> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxYjA4NjlkZjA2NzBkMDcx"><strong><span style="color:#cc6600;">April 2008: Decision & FONSI</span></strong> </a><br /><br /><br /><strong>MY PUBLIC COMMENTS SUBMITTED TO USFWS</strong><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0OGU3YmIxODRhN2JkZDQy"><span style="color:#cc6600;"><strong>May 2007</strong></span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxZDliYzU5MmIyZTEwOWI0"><strong><span style="color:#cc6600;">September 2007</span></strong> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDozOGM3MDdlNGY3MDA1MWIx"><strong><span style="color:#cc6600;">June 2008: Scoping - Comprehensive Conservation Plan</span></strong> </a><br /><br /><br /><strong>RESEARCH MATERIAL</strong><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxZWU4NGM2NWE0ZjdjNmQx"><strong><span style="color:#cc6600;">Sheldon Analysis: Unknown Advocate</span></strong> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0Zjk2YjI1NTRhYjcyZDBm"><strong><span style="color:#cc6600;">Intragency Policies for Wild Horse & Burro Management</span></strong> </a><br />Valerie Pfeiffer, December 12, 2005<br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo0OTg2YjdlY2RhYWY0Y2Jk"><strong><span style="color:#cc6600;">Hart Mountain: Livestock Analysis</span></strong> </a><br />Rangenet, Steve Herman, 2004<br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3NzgyNTg4YjdlYzc0YWRk"><strong><span style="color:#cc6600;">Sheldon Horse Impact Study</span></strong> </a><br />Barnet 2002 </div>Unknownnoreply@blogger.com0tag:blogger.com,1999:blog-4562357749295999770.post-68634505738692136162010-04-21T11:17:00.000-07:002010-04-21T11:26:20.401-07:00Calico: Past, Present & Future II<div align="justify"><em>This is the second in a series of articles that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond…<br /></em><br /></div><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/S83q4SAphJI/AAAAAAAACFw/pWwf77ZkHt8/s1600/Calico+Complex_Bl+Rock+Range-West_2005.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5462280175698412690" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/S83q4SAphJI/AAAAAAAACFw/pWwf77ZkHt8/s400/Calico+Complex_Bl+Rock+Range-West_2005.jpg" /></a> <div align="center"><span style="font-size:78%;">Calico Complex Wild Horse Captures - 2005<br />BLM Winnemucca Field Office Photo Files<br /></span></div><div align="justify"><br />When BLM released the first environmental assessment (EA) to remove wild horses from the Calico Complex in late October 2009, they didn’t even bother to address – much less try to explain - how the wild horse population shot up 500%, increasing from 575 estimated horses still remaining after the early 2005 round up (and all released mares treated with fertility control drugs) to a whopping 3,000+ in just five years.<br /><br />Eight to ten thousand public comments later, many of which questioned how BLMs population estimates could even be remotely correct, BLM was finally compelled to at least GUESS how this happened. Specifically, the Final round up EA stated:<br /><br />“<em>The discrepancy between the expected 2008 wild horse population and the actual wild horse count in March 2008 may be due to several factors. First, inventory data used to estimate excess wild horse population prior to the 2004-2005 gather was potentially incomplete due to poor weather conditions during the population inventory, which could have contributed to horses being missed and a population estimate that was lower than actual. Second, it is likely that more horses than anticipated were actually left in the Complex post-gather in 2005 due to the under-counting of horses prior to the gather. Third, movement has been documented between the Complex and HMAs administered by the BLM Surprise Field Office, CA and the Sheldon Wildlife Refuge. Data compiled by the Surprise Field Office during the March 2008 inventory of those HMAs also revealed higher populations than anticipated in the adjoining HMAs. Overall, the population levels of the Surprise Field Office HMAs exceeded natural recruitment by more than 400 wild horses (representing approximately 80% more wild horses than anticipated).”</em><br /><br />A BLM footnote also stated: “<em>10) The March 2008 population inventory included both the Calico Complex HMAs and HMAs managed by BLM’s Surprise Field Office in California. The horses counted in the Complex were separate and distinct from those simultaneously counted within the adjoining Surprise Field Office managed HMAs.”</em><br /><br />While In Defense of Animals (IDA) and attorney William Spriggs filed a request for an Injunction in federal court attempting to stop the Calico Complex round up, another legal challenge was quietly filed by The Cloud Foundation, Bob Bauer and myself with the Interior Board of Land of Appeals (IBLA).<br /><br />It arrived on the BLM’s Winnemucca Field Offices desk on Christmas Eve and targeted a completely different set of legal arguments than what IDA and Mr. Spriggs presented to the federal judge in their now pending lawsuit.<br /><br />Specifically, this legal appeal focused on:<br /><br />a) The wild horse AMLs set so long ago had no rangeland or monitoring data to support them – including recent court testimony from their own Wild Horse & Burro Specialist stating “monitoring objectives were being met” at the reported “high” population levels and therefore, the wild horses could not be deemed "excessive" - or at least not nearly that many of them! (for more detailed information on this part of the Calico Complex issues, <a href="http://americanherds.blogspot.com/2010/04/calico-past-present-future.html"><span style="color:#cc6600;">Click Here</span> </a>to read, "Calico: Past, Present and Future, Part I – The Past") and,<br /><br />b) That BLM had presented so much new information in their Final EA in their attempts to explain away all the questions, (which only raised more questions) that requirements of the National Environmental Protection Act (NEPA) mandated BLM must make an attempt to reasonably answer these questions by preparing an Environmental Impact Statement (EIS) <em>before</em> they were allowed to proceed.<br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S83po3aE-xI/AAAAAAAACFo/aWWvcdDWeM8/s1600/Calico+Complex_Bl+Rock+Range-West_Captured+Foal-1_2005_BLM+Photo+File.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5462278811347647250" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S83po3aE-xI/AAAAAAAACFo/aWWvcdDWeM8/s400/Calico+Complex_Bl+Rock+Range-West_Captured+Foal-1_2005_BLM+Photo+File.jpg" /></a> </div><div align="center"><span style="font-size:78%;">Wranglers Bring In a Separated Foal From Its Mother<br />Calico Complex Capture, Black Rock Range West - 2005<br />BLM Winnemucca Field Office Photo Files</span></div><div align="justify"><br />“<em>An agency must prepare an EIS if the environmental effects of a proposed action are highly uncertain. <strong>See Blue Mtns., 161 F.3d at 1213.</strong> Preparation of an EIS is mandated where uncertainty may be resolved by further collection of data, see id. at 1213-14 (lack of supporting data and cursory treatment of environmental effects in EA does not support refusal to produce EIS); or where the collection of such data may prevent “speculation on potential . . . effects. The purpose of an EIS is to obviate the need for speculation by insuring that available data are gathered and analyzed prior to the implementation of the proposed action.” <strong>Sierra Club v. U.S. Forest Serv., 843 F.2d 1190, 1195 (9th Cir. 1988)</strong></em>.”<br /><br />As a result of what BLM published in the Calico Complex Final EA, some of these new "unknowns" now include:<br /><br />> The possibility that wild horses from five additional Herd Management Areas (HMAs) managed from the Surprise Field Office, which are Bitner, Massacre Lakes, High Rock, Wall Canyon and Fox Hog HMAs AND the Sheldon National Wildlife Refuge, were affected by the round up - since BLM couldn’t explain where exactly all the wild horses had come from. <br /><br />Would the Calico round up inadvertently gut migrating wild horses from these areas too and leave populations so low they might now be at risk of crashing or left incapable of being self-sustaining herds as required by law?<br /><br />> BLM added almost a million more acres potentially affected by the removal operations than they had originally projected or told the public about (and the corresponding wild horse populations), which was <em>never analyzed at all</em>.<br /><br />> BLM has for the first time ever, suddenly stated that wild horses may be moving back and forth between “protected” BLM lands and the “non-protected lands” of Sheldon managed by U.S. Fish and Wildlife Service. Unlike BLM, USFWS is not bound by the Wild Free-Roaming Horse and Burro Act. Their policies regarding “feral” horses allows for, <em>“§ 30.12 Disposition of feral animals; Feral animals taken on wildlife refuge areas <strong>may be disposed of by sale on the open market, gift, loan to public or private institutions for specific purposes, and as otherwise provided in section 401 of the act of June 15, 1935 (49 Stat. 383, 16 U.S.C. 715s)”</strong></em><br /><br />If what BLM was suddenly claiming about “migrating horses” between the Sheldon Refuge and BLM HMA’s is true, how many BLM wild horses have been or will be rounded up in the future when they are on non-protected land and “disposed of” through this feral animal policy?<br /><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S83rP5C0bBI/AAAAAAAACF4/QxVmbXePVCE/s1600/Calico+Complex_Bl+Rock+Range-West_Captured+Foal-2_2005_BLM+Photo+File.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 400px; DISPLAY: block; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5462280581313489938" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S83rP5C0bBI/AAAAAAAACF4/QxVmbXePVCE/s400/Calico+Complex_Bl+Rock+Range-West_Captured+Foal-2_2005_BLM+Photo+File.jpg" /></a></div><div align="center"><span style="font-size:78%;">Wranglers Bring In a Separated Foal From Its Mother<br />Calico Complex Capture, Black Rock Range West - 2005<br />BLM Winnemucca Field Office Photo Files</span></div><div align="justify"><br />On top of this, large-scale plans are currently in the works throughout this entire area. Due to the questions BLM themselves have now raised, getting answers before they take any further action has become critical. Some of the publicly known plans include:<br /><br />> U.S. Fish & Wildlife Services Comprehensive Conservation Plan (CCP) for the Sheldon National Wildlife Refuge scheduled for release in 2010, which will address all future management plans on wild horses and burros residing in the Refuge.<br /><br />> The Ruby Pipeline Project, which has already been asked by the Federal Regulatory Commission to discuss how they propose to address appropriate mitigation measures to protect wild horse and burro populations within the area.<br /><br />> The establishment of Appropriate Management Levels for wild horses in the Massacre Lakes HMA managed by the Surprise Field Office, also included as one of the six wild horse areas that might have been affected by wild horses “free-roaming behaviors” and the Calico Complex round ups.<br /><br />But of course, BLM wasn’t worried about having to answer any of these questions because the Interior Board of Land Appeals (IBLA) had their back!<br /><br />After BLM received our Appeal, they submitted a request for an extension to file their response, which IBLA finally granted to them – but not until AFTER the required 10 day deadline had passed!<br /><br />Turns out, the legal requirements the Department of the Interior has set for itself allow for zero penalties if <em>they</em> fail to meet the deadlines; that only applies to the public. My appeal of the Soldier Meadows Livestock Grazing Decision back in 2008 was thrown out by IBLA because it arrived on the judge’s desk one day late.<br /><br />When IBLA finally did rule in favor of BLM's decision to remove the Calico wild horses almost two months later, despite the fact that we filed an Expedited Emergency Request for a Stay, the judge cited the issue of granting a Stay as “moot” since the round ups had already begun and coincidentally, the judge issued his decision the day before BLM announced the round ups were now over. Hmmm...<br /><br />What was taking IBLA so long to rule on the case was, the BLMs attorney submitted an affidavit from Winnemucca Field Office employee Amanda Deforest, who swore under penalty of perjury that fellow appellant, Bob Bauer, never submitted comments to BLM about the Calico Round Up.<br /><br />So we had to submit extensive evidence time and time again to prove Bob did submit comments, which IBLA finally ruled in our favor and agreed, yes, Bob <em>had</em> submitted comments.<br /><br />I guess that was the only victory IBLA would allow “we, the people” and never mind that Ms. DeForest lied under oath - as we all know, there seems to be no consequences for what BLM says or does. What would have happened if we could not have proved beyond a shadow of a doubt that Bob did indeed submit multiple comments and phone calls to BLM? To learn more about this phase of the legal battle, <a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3MDhiOWQ0MjBkNzg4YTZj"><span style="color:#cc6600;">Click Here</span></a>.<br /><br />To back up for a moment, I want to explain another legal ruling IBLA slapped me with early on in my “Wild Horse & Burro” legal challenge adventures - because it has relevance.<br /><br />One time, I tried to file an appeal of a round up <em>before</em> BLM had issued a Final Decision as, just like the Calico case, it was a god-awful mess right out of the gate. IBLA shot back the public cannot appeal a decision if a decision hasn’t been issued and threw it out. In retrospect, I have to agree with this as it makes sense - because no one can know what BLM is going to actually do until they do it – anything else is just speculative. So, with that former ruling in mind, check out what they did in the Calico case…<br /><br />First, BLM only allowed the public to comment on the PRELIMINARY EA.<br /><br />However, it was the <em>Final EA</em> BLM added all kinds of speculative stuff about where the wild horses may have come from and all these other areas that may be affected by the round up. Except, NO PUBLIC COMMENTS WERE ALLOWED ON THE FINAL EA.<br /><br />Then, while IBLA finally ruled that Bob <em>did</em> indeed have a right to appeal because we proved he submitted comments, the judge limited his considerations and based his decision ONLY on the issues Bob raised in his public comments during the Preliminary EA – not anything that was submitted in the appeal after BLM issued their Final Decision.<br /><br />The judge refused to address any of the questions raised in the appeal about what BLM had published in the Final EA - which never allowed any public comments – and the judge justified these limitations because Bob’s public comments never addressed those issues.<br /><br />Why didn’t Bob’s comments ever address those issues? Because BLM only publicly published those issues AFTER the public comment period had closed on the Prelimary EA but never allowed any public comments on the Final EA.<br /><br />Furthermore, IBLA refused to acknowledge or address the full scope of the appeal because it was collectively filed, even though Bob's signature was on it, Bob filed no separate appeal of his own, and Bob submitted extensive follow up evidence, affidavits and declarations during the appeal process.<br /><br />Obviously, the judge accepted the appeal as Bob's because he didn't throw it out. Yet while the judge acknowledged Bob <em>did</em> file an appeal (after all, what other document could the judge rule on?), the judge simultaneously excluded almost everything presented in the appeal and only addressed the statements submitted by Bob to BLM during the Preliminary EA's public comment process.<br /><br /><em>So bascially, "we, the people", can't appeal a decision before it is issued and we can't appeal any issue that we haven't already submitted comments to BLM on. As a result, BLM can present any new information they want to "after the fact" and by just refusing to allow the public the opportunity to comment, they get to circumvent any legal challenge - because no one could possibly comment on information they didn't know about!<br /></em><br />Finally, the judge refused to consider the appeal in context of the National Environmental Protection Act’s mandates and to paraphrase here, ruled that once BLM stated the wild horses were excessive, there were no further requirements they had to adhere too. Pretty sweet, huh?<br /><br /><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/S83ryenVq4I/AAAAAAAACGA/YTbP2hU_gRg/s1600/Calico+Complex_Bl+Rock+Range-West_Captured+Foal_Close+Up_2005_BLM+Photo+File.jpg"><img style="TEXT-ALIGN: center; MARGIN: 0px auto 10px; WIDTH: 244px; DISPLAY: block; HEIGHT: 400px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5462281175514327938" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/S83ryenVq4I/AAAAAAAACGA/YTbP2hU_gRg/s400/Calico+Complex_Bl+Rock+Range-West_Captured+Foal_Close+Up_2005_BLM+Photo+File.jpg" /></a></div><div align="center"><span style="font-size:78%;">Close Up: Wranglers Bring In A Separated Foal From Its Mother<br />Calico Complex Capture, Black Rock Range West - 2005<br />BLM Winnemucca Field Office Photo Files<br /></span></div><div align="justify"><br />Except, BLM and U.S. Fish & Wildlife Service might now have a bit of a problem...<br /><br />Even if IBLA, which is an Administrative Court under the Department of the Interior, was able to squash this information and refused to demand a sincere NEPA review this time, a federal judge might not see eye to eye with IBLA’s unconditional support for BLM’s actions sometime in the future.<br /><br />The agencies also know they are in the clear as far as the In Defense of Animals and Mr. Spriggs lawsuit because the currently pending legal challenge never touches these issues (at least this time).<br /><br />But while BLM has been able to string the public and courts along for 27 years with promises of monitoring, evaluations, and still not having a clue about what is really going on with the wild horses and burros throughout the entire area – with a large stack of evidence now assembled to prove this - BLM is running out of excuses and out of time.<br /><br />So with plenty of opportunities for legal challenges looming on the immediate horizon, such as the Ruby Pipeline, the soon to be released US Fish & Wildlife Services Comprehensive Conservation Plan and issuing AMLs for the Massacre Lakes HMA, what can the agencies do to try and cover their butts now and are they scrambling to come up with a plan to do just that? </div><div align="center"><br /><br /><strong>ADDTIONAL LINKS</strong><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDplZTAxMzEyZGE2ODQwNDQ&pli=1"><span style="color:#cc6600;">12/21/09: Calico Complex Appeal-Request For Stay To IBLA</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo2YjE2MjQ5MGNhYzMzY2Y1"><span style="color:#cc6600;">12/29/09: BLM Request For Response Extension</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3M2I5YjFhY2I0OTYwZjBl"><span style="color:#cc6600;">1/12/10: BLM - First Motion To Dismiss</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDoxMjJiZDVhZGQ4ZTMwNThi"><span style="color:#cc6600;">1/13/10: IBLA Grants BLM Extension</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDpmYmFlZWEwNmRlM2RmNGQ"><span style="color:#cc6600;">1/15/10: Appellants First Response - Motion To Dismiss<br /></span></a><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDozZWFiMzY3NjI5OThiNWJk"><span style="color:#cc6600;">1/19/10: BLM - Second Motion To Dismiss</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDozNDYwOWIzMGZjYjRiNjc0"><span style="color:#cc6600;">1/22/10: Appellants Second Response - Motion To Dismiss</span> </a><br /><br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo1YzFmN2QyNjVmNzliZjQy"><span style="color:#cc6600;">2/04/10: IBLA's Order - Final Ruling</span> </a></div>Unknownnoreply@blogger.com2tag:blogger.com,1999:blog-4562357749295999770.post-23918833204470787522010-04-15T09:24:00.000-07:002010-04-15T09:43:13.448-07:00Calico: Past, Present & Future<div align="justify"><em>With the death toll still rising from the now captured Calico Complex wild horses while a bereft public stands outside locked gates, plans have been laid and continue to be made to perpetuate the crimes against these wild ones that began so long ago.<br /><br />To understand the magnitude of what has occurred here – as well as to grasp where it is going and why – first, we must travel back in time to witness what BLM did, how they got away with it and how they plan to continue harvesting the bitter crops they began cultivating over two decades ago.<br /><br />This is the first in a series that attempts to disclose some of the known issues playing behind the scenes in the Calico Complex and beyond…<br /></em></div><br /><br /><div align="center"><strong>PART I – THE PAST<br /><em>WILD HORSE & BURRO AMLs: WHERE THEY BEGAN</em><br /></strong></div><div align="justify"><br />In 1993/1994, BLM issued Final Multiple Use Decisions (FMUDs) for the Buffalo Hills, Leadville, Paiute Meadows and Soldier Meadows Livestock Allotments. These FMUDs established initial levels of use for livestock and some of the wild horses or burros found within the Calico Complex.<br /><br />On December 10, 1993, the BLM issued a Full Force and Effect Decision to implement the FMUD for the Soldier Meadows Allotment. This decision received multiple protests by concerned members of the public and various organizations including the Nevada Commission for the Preservation of Wild Horses, Dawn Lappin of Wild Horse Organized Assistance and the Nevada Department of Wildlife.<br /><br />On January 24, 1994, BLM responded to the Protest Points filed against the new Soldier Meadows decision, some of which have been highlighted below.<br /><br />The Commission for the Preservation of Wild Horses and Wild Horse Organized Assistance (WHOA) asserted the BLM arbitrarily allocated forage to wild horses and livestock - an allegation BLM did little to dispute.<br /><br />BLM’s response to the Commissions/WHOA’s Protest Point #4 stated that “<em>It was recognized in the Management Framework Plan (MFP) <strong>that the forage allocation made for livestock and wild horses/burros was only a starting point</strong> and that numbers would be adjusted to appropriate levels based on monitoring</em>”. (<em>emphasis added</em>)<br /><br />BLMs response also stated, “<em>The 1988 evaluation for this allotment documented that livestock numbers were too high so they were adjusted downward, <strong>but wild horses/burros numbers were not addressed</strong>. The re-evaluation for this allotment established the total carrying capacity for livestock and wild horses/burros based on monitoring data. <strong>The AUMs were then divided between livestock and wild horses/burros on a proportional basis (based on the ratio established in the Management Framework Plan-MFP)</strong> in accordance with MFP decision Range 1.1 and Wild Horse/Burro 1.1. I felt this was the appropriate and most equitable way to divide the total carrying capacity between livestock and wild horses/burros. We will continue to monitor to determine if these new stocking rates are appropriate, and if not make future adjustments</em>”. (<em>emphasis added</em>)<br /><br />Of additional relevance and concern are the issues raised in Protest Point #1 by the Commission/WHOA, which stated, “<em>The Proposed Decision extends the land use plan short term objectives in excess of 14 years. Range Management-Management Framework III Decision RM-1 set a five year schedule to accomplish wild horse herd management area plans, and other approved activity plans, to establish appropriate management levels to assure viable herds in balance with their habitat by 1987. Short term objectives of the Proposed Decision adjusts the land use plan short term objectives to the year 2001</em>.”<br /><br />In BLMs response to Protest Point #1, BLM stated that, “<em>Objectives are developed in site specific documents that implement the goals of the MFP. <strong>The short term objectives…were established in 1988 in the Livestock Agreement with the permittee.</strong> We look at the short term objectives in our re-evaluations and if our monitoring indicates we are not achieving these, then we conclude that we will not be able to achieve our long term objectives, so adjustments must be made. A new decision is issued with the necessary changes and we continued to monitor to see if those changes allow us to meet our short term objectives….<strong>This is a process</strong></em>”. (<em>emphasis added</em>)<br /><br />However, once those initial starting point AMLs were set, BLM has never again revisited them nor continued to pursue the “process” - despite their admission that these goals were short term and required additional review to determine if they were appropriate or not.<br /><br />Furthermore, no separate NEPA analysis of those AMLs has ever been produced. When BLM has done Final Multiple Use evaluations, officials just continued to reaffirm and perpetuate those initial stocking rates; no actual analysis or NEPA review of their appropriateness for wild horse or burro use required - even though BLM also admits wild horse populations have never actually been within the established parameters of these same AMLs since they were first set.<br /><br />As noted above, the current wild horse AMLs for these areas are a perpetuation of general objectives established 27 years ago that had no site-specific public NEPA process, have continued to evade appropriate data collection, monitoring, analysis and/or reporting and in at least one known instance, BLM officials buried recent monitoring data that indicated wild horse AMLs could be adjusted upwards by a large margin. (<a href="http://americanherds.blogspot.com/2009/12/blm-photo-2004-warm-springs-hma-wild.html"><em><span style="color:#cc6600;">Click Here</span> </em></a><em>for BLM Winnemucca Field Office’s Wild Horse & Burro Specialist court testimony regarding wild horses being five times over the established AMLs but Rangeland Health Objectives were still being met.</em>)</div><div align="center"><br /></div><p align="center"><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S8ZJGZIqqpI/AAAAAAAACE4/-xlTgH8rNT8/s1600/Rock+Spring_Meadow+Area_5-27-04.jpg"><img style="WIDTH: 400px; HEIGHT: 399px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5460131972408584850" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S8ZJGZIqqpI/AAAAAAAACE4/-xlTgH8rNT8/s400/Rock+Spring_Meadow+Area_5-27-04.jpg" /></a><br /><span style="font-size:78%;">Rock Spring Meadow Area. According to BLM Winnemucca file photos<br />obtained via FOIA, this area of Rock Springs is used exclusively by wild horses.<br /></span><div align="justify"><br />A Protest was also filed by the Nevada Division of Wildlife (NDOW) and in Protest Point #5, NDOW asserted, “<em>The Proposed Decision <strong>establishes a carrying capacity by flawed assumptions</strong> without consideration of critical wildlife habitat</em>.” and, “<em>The Proposed Decision carrying capacity computation is based upon Example C of Appendix 2 of the "Rangeland Monitoring Analysis, Interpretation and Evaluation (TR 4400-7)'·. Example C assumes rangeland production is not uniform and utilization is uniform. Utilization data confirms the conclusions of the Re-evaluation that livestock distribution problems are causing heavy and severe utilization of critical wildlife habitat; thus the Proposed Decision's use and rationale for Example C is flawed for a carrying capacity computation</em>.” (<em>emphasis added</em>)<br /><br /><strong>BLMs response failed to address NDOWs wildlife and rangeland specialists concerns regarding errors and flaws they found within BLM’s carrying capacity computations.<br /><br /></strong>BLM evaded addressing the flaws and errors noted by NDOW rangeland specialists by switching the focus too and agreeing with NDOWs assertions that poor livestock distribution was the primary cause of concern through heavy and severe riparian degradation noted throughout all years of monitoring at key sites.<br /><br />Under NDOWs Protest Point #3, BLM responded to concerns regarding management plans and actions that continue to be fluid and without accountability through the year 2024 by stating, “<em>The evaluation of monitoring identified livestock distribution as the primary management action to improve resource conditions; not a carrying capacity problem</em>.”<br /><br />BLM then referenced a new modification technique to former rangeland carrying capacity methods, which they began to explore in 1992, that omitted slight and light utilization categories and only considered moderate, heavy, and severe utilization categories to determine carrying capacity instead. BLM went on to state, “<em>We felt this would cause the calculations to better emphasis the problems of poor distribution and over stocking. Using this <strong>modified technique for calculating carrying capacity</strong> and requiring the movement of livestock based on acceptable utilization limits we feel we will solve the problems identified in this re-evaluation</em>”. (<em>emphasis added</em>)<br /><br />This “modified technique” to measure grazing distribution patterns was then implemented as a new standard and BLM began substituting a monitoring technique for the original methods used to determine total carrying capacity, which is a critical method and tool to provide valuable data for areas <em>in their entirety</em>, not just at a few key or selective sites.<br /><br />While this modification technique may be appropriate for monitoring grazing distribution patterns in order to make adjustments to livestock authorizations and/or seasons of use, it fails to address the entire scope of rangeland productivity for all multiple users by eliminating data on the full range of forage production.<br /><br />Specifically, total carrying capacity computations are essential for determining forage available for wild horses, wild burros and wildlife species as their migratory distribution patterns and forage utilizations are often much wider in scope than domestic livestock. This data is necessary to adequately determine appropriate stocking levels for use outside the “<em>poor grazing distribution</em>” livestock zones and variances in utilization patterns from other grazers such as wild horses, burros and other large wildlife species.<br /><br /><strong>These errors and flaws in carrying capacity computations noted by NDOW range and wildlife specialists in 1994 have never been addressed. Neither has the effectiveness or accuracy of substituting this technique to determine rangeland health been revisited, especially in context with its ability to appropriately designate the “optimum number” of wild horses and/or burros.<br /></strong><br />The BLM has substituted a monitoring technique used to identify poor grazing distribution as the primary tool to allocate forage, a technique that has an inherent biased towards forage utilized by wild horses/burros who historically demonstrate wider migratory and grazing distribution patterns than domestic livestock.</div><div align="center"><br /><br /><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/S8ZIyWpPMcI/AAAAAAAACEw/oBiOCTRwmL8/s1600/Burnt+Springs_Heavy+WH+%26+Livestock+Use_7-31-08.jpg"><img style="WIDTH: 400px; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5460131628142506434" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/S8ZIyWpPMcI/AAAAAAAACEw/oBiOCTRwmL8/s400/Burnt+Springs_Heavy+WH+%26+Livestock+Use_7-31-08.jpg" /></a><br /><span style="font-size:78%;">In the 2009 Calico Complex Wild Horse Capture Preliminary EA, BLM shows a photo of Burnt Springs (photo 8) titled, “<em>Heavy riparian utilization</em>”. Yet photos obtained from the Winnemucca Field Office via FOIA show this same photo in BLMs photo log but with the additional title of “<em>Several spring sources, riparian/meadow complex, heavy horse <strong>and livestock use</strong></em>”.<br /></span></div><div align="justify"><br />The exclusive use of monitoring techniques that focus solely on utilization levels can also be affected by and/or used to manipulate data to support a foregone conclusion include the following factors: 1) location of monitoring sites; distance to water, terrain, near rockier areas, etc., 2) Key species (grass types) being monitored, 3) Difficulty of separating wild horse and/or burro use from livestock use, and 4) Trespass by livestock attributed to wild horses due to BLMs predominate reliance on grazing permit dates to distinguish impacts versus timely physical site-specific monitoring.<br /><br />Also remember that in BLM’s response to the Commissions/WHOA’s Protest Point #4, BLM stated that adjustments to forage allocations between livestock and wild horses and burros were required by the Management Framework Plan to be “<em>on a proportional basis based on the ratio established in the Management Framework Plan-MFP</em>”.<br /><br />So had BLM been allocating resources on a proportional basis since 1994?</div><br /><div align="center"><strong><em>LIVESTOCK<br /></em></strong></div><div align="justify"><br />While the 1982 Management Framework Plan required forage allocations between livestock and wild horses/burros be based on proportional ratios, it doesn’t look like recent managers are familiar with this requirement.<br /><br />In BLMs response to the 1994 Protest Points for the Soldier Meadows FMUD, BLM stated that stocking rates of livestock, wild horses and burros were being established as initial levels contingent on future monitoring and rangeland health data collection.<br /><br />Yet in the Calico Complex Preliminary Capture EA, BLM reported that all wild horse/burro Herd Management Areas within the Complex have yet to be assessed for conformance with Standards of Rangeland Health. <span style="font-size:78%;">(Calico Complex Wild Horse Capture Plan, Preliminary EA, Section 1.5, Conformance with Land Health Standards pg.6)<br /></span><br />The fact that no Rangeland Health Assesments have still not been done over 15 years later hasn't stop BLM from increasing livestock authorizations. Since the initial 1994 decision for the Soldier Meadows allotment affecting three of the HMAs within the Calico Complex, BLM has changed the livestock authorizations for Soldier Meadows at least twice, and Paiute Meadows at least once.<br /><br />The most current Final Multiple Use Decisions (FMUD), which continued to re-affirm the initial AMLs for wild horses and burros that were originally set by an agreement between BLM and the 1988 livestock operator were re-issued for the Soldier Meadows Allotment in 2003, Paiute Meadows Allotment in 2004, and the Pine Forest Allotment in 2005, which established a 0 AML for wild horse use.</div><div align="center"><br /></div><p align="center"><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S8ZHVSt6vmI/AAAAAAAACEo/Wr8LoqfrCpw/s1600/Big+Summit+Spring_Wild+Horses_7-29-08.jpg"><img style="WIDTH: 400px; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5460130029360561762" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S8ZHVSt6vmI/AAAAAAAACEo/Wr8LoqfrCpw/s400/Big+Summit+Spring_Wild+Horses_7-29-08.jpg" /></a><br /><span style="font-size:78%;">Summit Springs Wild Horse Area dated 7/29/08.</span> <div align="justify"><br />In the Calico Complex Preliminary EA, BLM shows a photo of Summit Springs in the Black Rock Range HMA (photo 7) to indicate low water flow and heavy wild horse use (above). Yet photos obtained from the Winnemucca Field Office via FOIA show the Summit Springs “Pipeline” leading to the Pine Forest Allotment contains a full reservoir and troughs – no wild horses allowed (below). The decision to issue an AML of 0 for wild horse use in the Pine Forest Allotment was implemented by BLM on 9/30/05.</div><div align="center"><br /></div><p align="center"><a href="http://1.bp.blogspot.com/_rEtijg9Zriw/S8ZC_-pZY4I/AAAAAAAACEg/Al4GHEH0wFk/s1600/Summit+Spring+Pipeline_Pine+Forest+Allotment_No+HMA_7-29-2008.jpg"><img style="WIDTH: 400px; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5460125265149125506" border="0" alt="" src="http://1.bp.blogspot.com/_rEtijg9Zriw/S8ZC_-pZY4I/AAAAAAAACEg/Al4GHEH0wFk/s400/Summit+Spring+Pipeline_Pine+Forest+Allotment_No+HMA_7-29-2008.jpg" /></a><br /><span style="font-size:78%;">Summit Springs Pipeline-Pine Forest Allotment dated 7/29/08.</span> <div align="justify"><br />In November 2005, Kudrna, Ltd. purchased the Soldier Meadows Ranch and acquired the grazing privilege for the Soldier Meadows Allotment. Kudrna then requested BLM modify the existing grazing system in order to acquire and maintain a stable herd size. In response, BLM issued a new grazing decision on January 14, 2008, for the Soldier Meadows Allotment, which adjusted cattle authorizations upward from a former initial stocking rate of 7,680 to a new initial stocking rate of 8,784 AUMs to support 800 head of cattle with a season of use authorized from 1/16 through 12/15. This authorization also included increases up to 12,168 AUMs for livestock consumption based on two year monitoring intervals as well as authorizing 3,092 AUMs of “suspended use” for temporary non-renewable grazing permits for a total of 16,070 AUMs - the entire AUM amount BLM had determined was available for all grazers in the area.<br /><br />The January 2008 Final Decision for the Soldier Meadows Allotment also combined two key elements from different Alternatives evaluated throughout the public consultation process, that being; the Proposed Action to increase livestock allocations based on a 30% utilization level and the No Action Alternative, where no increase in livestock allocations would be authorized but would maintain a 50% utilization level.<br /><br />Specifically, BLM chose to combine two of the most controversial components of both Alternatives into one, which were; increasing both livestock numbers and utilization levels simultaneously. No evaluation or analysis was ever done with respect to combining these two factors into one proposal or their potential impacts.<br /><br />In 2004, BLM authorized an increase in the Paiute Meadows Allotment for exclusive livestock use by an additional 750 AUMs. (To learn more about the Paiute Meadows, <a href="http://americanherds.blogspot.com/2010/01/katie-on-calico.html"><span style="color:#cc6600;">Click Here to read, “Katie on Calico”</span></a>.</div><div align="center"></div><p align="center"><a href="http://2.bp.blogspot.com/_rEtijg9Zriw/S8ZCbzfCDaI/AAAAAAAACEY/j2rRm1ZQnjw/s1600/Fenceline_Soldier+Meadows-Pine+Forest+Allotment_SMA-Left_WH+Use+Only_7-29-08.jpg"><img style="WIDTH: 400px; HEIGHT: 300px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5460124643677572514" border="0" alt="" src="http://2.bp.blogspot.com/_rEtijg9Zriw/S8ZCbzfCDaI/AAAAAAAACEY/j2rRm1ZQnjw/s400/Fenceline_Soldier+Meadows-Pine+Forest+Allotment_SMA-Left_WH+Use+Only_7-29-08.jpg" /></a> <div align="center"><span style="font-size:78%;">Fenceline between Soldier Meadows and Pine Forest Grazing Allotments.<br />Soldier Meadows side (left) is cited as used exclusively by wild horses<br />while the Pine Forest side (right) is grazed by livestock only. BLM<br />Winnemucca photo file dated 7-29-08 obtained via FOIA.</span><br /><br /><br /><strong><em>SUMMARY</em><br /></strong></div><div align="justify"><br />To recap what BLM did in the past to determine the current wild horse and burro AMLs for a portion of the Calico Complex:<br /><br />> The 1988 allotment evaluation and Livestock Agreement failed to analyze or include wild horse/burro populations and/or their impacts in any manner. However, this was the basis for determining the initial wild horse and burro AMLs that are still being perpetuated today.<br /><br />> In 1994, in response to accusations that the BLM arbitrarily allocated forage to wild horses, burros and livestock, BLM did not dispute the initial forage allocations were only starting points and made no claim that these levels were actually appropriate until monitoring validated them.<br /><br />> The validity of continuing to support the current wild horse/burro AMLs as appropriate were contingent on proportional allocations between livestock and wild horses/burros and monitoring data to determine class use. In other words, they had to determine who was eating what.<br /><br />> The BLM implemented a new technique in 1992 that substituted a monitoring technique used to determine grazing distribution patterns to replace total carrying capacity evaluations. The exclusive incorporation of this new technique has never been re-evaluated for accuracy or appropriateness and may be especially relevant towards those rangeland users who exhibit wider distribution patterns such as wild horses, burros and other wildlife.<br /><br />> BLMs recent authorization of increases in livestock authorizations in the Soldier Meadows and Paiute Meadows Allotments, despite well known drought conditions, indicates available forage has been re-allocated for exclusive livestock use and failed to conform to requirements outlined in the 1982 Management Framework Plan that specified all future forage allocation adjustments must be done in a proportional ratio between wild horses/burros and livestock.<br /><br />> Based on BLMs reported wild horse populations from their March 2008 aerial census, wild horses exceeded the current established low AMLs for the Black Rock West, Warm Springs Canyon and Calico HMAs by at least 1,000 wild horses at the same time BLM was authorizing the increase of cattle use in the Soldier Meadows Allotment. Despite these "high" wild horse populations, BLMs monitoring information supported increased livestock use indicating impacts by wild horses were still marginal even at these high population levels - though BLM refused to publicly disclose or admit this fact in the 2009 Calico Complex Wild Horse Capture EA.<br /><br />> Current wild horse AMLs within these areas fail to accurately reflect “excess” populations. Many of the Calico Complex wild horses were removed merely to support an AML goal that has never been seriously reviewed since the initial agreement was made between BLM and the livestock operator in 1988.</div><div align="center"><br /><br />Calico Complex Wild Horse Captures - 2004<br /><a href="http://4.bp.blogspot.com/_rEtijg9Zriw/S8ZB7OEbIVI/AAAAAAAACEQ/_Yf-57sqFUI/s1600/Bl+Rock+Range+Wild+Horse+Capture_2-13-2004.jpg"><img style="WIDTH: 400px; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5460124083878043986" border="0" alt="" src="http://4.bp.blogspot.com/_rEtijg9Zriw/S8ZB7OEbIVI/AAAAAAAACEQ/_Yf-57sqFUI/s400/Bl+Rock+Range+Wild+Horse+Capture_2-13-2004.jpg" /></a><br /><span style="font-size:78%;">Photo from BLM Winnemucca Field Office photo files obtained via FOIA dated 2/13/2004.<br /></span><br />Associated Links<br /><a href="http://docs.google.com/viewer?a=v&pid=sites&srcid=ZGVmYXVsdGRvbWFpbnxhbWVyaWNhbmhlcmRzNHxneDo3NTM0YTBlNzBhYWRhMGYy&pli=1"><span style="color:#cc6600;">BLMs Response to 1994 Protests of SMA FMUD</span> </a></div>Unknownnoreply@blogger.com2tag:blogger.com,1999:blog-4562357749295999770.post-9175423669886324162010-03-27T17:56:00.001-07:002010-03-27T17:56:35.044-07:00Say Something!<div align="center"><object width="425" height="344"><param name="movie" value="http://www.youtube.com/v/A1cxxDe36uk&hl=en_US&fs=1&rel=0&color1=0x3a3a3a&color2=0x999999"><param name="allowFullScreen" value="true"><param name="allowscriptaccess" value="always"><embed src="http://www.youtube.com/v/A1cxxDe36uk&hl=en_US&fs=1&rel=0&color1=0x3a3a3a&color2=0x999999" type="application/x-shockwave-flash" allowscriptaccess="always" allowfullscreen="true" width="425" height="344"></embed></object><br /><br /><div align="justify">For months now, American citizens of all ages, political affiliations, and backgrounds across the nation have been calling on President Obama to step up to the plate and speak out to rein in the government’s management of the Wild Horse and Burro Program and America’s mustangs and burros.<br /><br />Despite campaign promises that he was squarely for protecting our wild herds, once elected, the President’s ongoing silence has become a deafening roar as concerns and pleas for intervention continue to be meet with nothing more than a Presidential cold shoulder.<br /></div><div align="center"><br /><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S66fJkn04fI/AAAAAAAACEA/-Ua4QH6ENck/s1600/CALICO%2520FALLON%2520OBAMA%2520JAN%2520FEB%25201197.jpg"><img style="WIDTH: 400px; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5453471185590608370" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S66fJkn04fI/AAAAAAAACEA/-Ua4QH6ENck/s400/CALICO%2520FALLON%2520OBAMA%2520JAN%2520FEB%25201197.jpg" /></a><br /><span style="font-size:78%;">Wild horse and burro advocates protesting Obama's silence<br />last month during the President visit to Las Vegas.<br />Photo courtesy of Arlene Gawne.</span></div><div align="justify"><br />Mr. Obama is obviously capable of taking swift and decisive action to speak out on issues of national importance, such as his immediate confession that “<em>he loves Las Vegas</em>” to appease the political fallout out and media backlash resulting from his targeting of Vegas as the national Icon of Excess.<br /><br />However, it appears the President’s compassion doesn’t extend as far for the ongoing plight of America’s mustangs and burros or their own national iconic status as it does for dinging the reputation of glitzy and glamorous fabulous Las Vegas.<br /><br />While President Obama’s limousine cruised down the streets to make amends and present apologies over champagne, wild horse and burro advocates tracked his brigade in efforts to be heard.</div><br /><p align="center"><a href="http://3.bp.blogspot.com/_rEtijg9Zriw/S66fP8m_8HI/AAAAAAAACEI/8UELmmKP-Bc/s1600/CALICO%2520FALLON%2520OBAMA%2520JAN%2520FEB%25201189.jpg"><img style="WIDTH: 400px; HEIGHT: 267px; CURSOR: hand" id="BLOGGER_PHOTO_ID_5453471295108804722" border="0" alt="" src="http://3.bp.blogspot.com/_rEtijg9Zriw/S66fP8m_8HI/AAAAAAAACEI/8UELmmKP-Bc/s400/CALICO%2520FALLON%2520OBAMA%2520JAN%2520FEB%25201189.jpg" /></a> <div align="center"><span style="font-size:78%;">Does the sign above the Presidential limousine accidentally capture the truth of President Obama's real agenda? Photo courtesy of Arlene Gawne.<br /></span></div><div align="justify"><br />Catapulted into office by a world hungry for change, Mr. Obama baited his audience with such promises as transparency, open government and giving the people a voice. Since his arrival at the White House, too often we have only seen more of the same!<br /><br />In late January, 2010, Public Employees for Environmental Responsibility (PEER), a long-standing organization developed and dedicated to protecting government whistle blowers who tell the truth about what is really happening behind the scenes, issued a news release detailing how the Obama administration planned to deal with the transparency issue and government workers.<br /><br />The new release was titled, “<a href="http://www.peer.org/news/news_id.php?row_id=1298"><span style="color:#cc6600;">Obama Gag Ordered On Federal Workers Like Those Under Bush</span></a>”, and it summarizes the issues by stating, “<em>Despite proclaiming new levels of transparency and accountability, the Obama team remains rooted in a ‘message control’ mentality that punishes workers for unscripted candor.”</em><br /><br />Highlighting key issues and tactics being used to shut down government transparency, PEER outlines how, after President Obama issued a “signing statement” in March 2009, he authorized extending his control for restricting information and public access to even include restricting federal employees’ ability to provide information to Congress, [which includes] “<em>his inherent authority to ‘supervise, control, and correct employees’ communication with the Congress</em>”.<br /><br />While I may not have the credibility or long-standing weight of PEER, since President Obama’s arrival on the American scene with his promises of transparency, open government and change, my own experiences mirrors PEER’s report as communications with government personnel have all but dried up. <br /><br />As public affairs specialists have taken center stage to orchestrate spin, myths and continued propaganda, the agencies themselves are echoing the same deafening Obama silence that continues to ring across the nation and abroad as the war on America’s mustangs and burros continues, unabated.<br /><br />On Thursday, citizens from across the nation went to Washington D.C. to "March for Mustangs", with support from simultaneous protests in Las Vegas, Los Angeles and London. It has been reported that the Washington protesters were met with mounted police, armed guards, had their photos snapped by some secret service type guy and were forbidden to set foot on the steps of the Department of the Interior.<br /><br />Across the sea, London protestors raised their voices in support and unison demanding real change and a halt to the destruction of these - our national treasures. <br /><br />Included in the protesters were <a href="http://www.maria-daines.com/music.html"><span style="color:#cc6600;">singer/songwriter Maria Daines and guitarist Paul Killington,</span></a> whose passionate words and praises for these fast-disappearing American icons show how these magnificent animals are loved throughout the world!<br /><br />Below is a video of Paul Killington leaning against a monument to former President Dwight D. Eisenhower in front of the American Embassy as he joins the call to President Obama to <strong><em>SAY SOMETHING</em></strong> about the war being waged against America’s mustangs and burro.<br /><br />I thought it would be appropriate to reminisce about what former President Eisenhower had to say before he departed from the American stage – since President Obama still has nothing to say….<br /><br />“<em>This conjunction of an immense military establishment and a large arms industry is new in the American experience. The total influence -- economic, political, even spiritual -- is felt in every city, every State house, every office of the Federal government. We recognize the imperative need for this development. Yet we must not fail to comprehend its grave implications. Our toil, resources and livelihood are all involved; so is the very structure of our society. In the councils of government, we must guard against the acquisition of unwarranted influence, whether sought or unsought, by the military industrial complex. The potential for the disastrous rise of misplaced power exists and will persist</em>.”</div><div align="right">Dwight D. Eisenhower, 1961 </div></div><div align="center"><br /><br /><object width="425" height="344"><param name="movie" value="http://www.youtube.com/v/7J9m_qkB_14&hl=en_US&fs=1&rel=0&color1=0x006699&color2=0x54abd6"><param name="allowFullScreen" value="true"><param name="allowscriptaccess" value="always"><embed src="http://www.youtube.com/v/7J9m_qkB_14&hl=en_US&fs=1&rel=0&color1=0x006699&color2=0x54abd6" type="application/x-shockwave-flash" allowscriptaccess="always" allowfullscreen="true" width="425" height="344"></embed></object></div>Unknownnoreply@blogger.com3