Wednesday, February 24, 2010

Gold In Them Thar Hills!

The BLM will be preparing a Draft Environmental Impact Statement (DEIS) for what they are calling, The Three Bar Ecosystem, a 750,000 acre project area that aims to restore the landscape from its current “degraded” conditions. The project is now in the scoping phase, where BLM asks the public what issues they want to see BLM address in the DEIS.

The main thrust of the proposal is about hazardous fuels reduction, meaning they are targeting the removal of pinion juniper trees and clearing hazardous fuels throughout the area, but that’s not the only action on the table.

Other areas they are looking into include improving habitat for mule deer, pronghorn antelope and sage grouse, a big push to protect streams currently occupied by the Threatened Lahontan Cutthroat Trout and adding two more new streams (big ones!) to stock them in, the Henderson and Vinini.

There’s also a lot of concern for protecting wildlife species, issues surrounding the preservation of the Pony Express Trail, a great deal of focus on riparian area protection (riparian areas are natural water sources such as streams and seeps), and a general, all across-the-board confession about the loss of plant health and diversity throughout the area.

The idea sounds good on paper and who knows, it might be, but there is a suspiciously high level of interest in the management of wild horses with lots of discussion about their contribution to the degraded resources with an equally suspicious LACK of discussion about livestock grazing in the area or what BLM intends to do, if anything, about that.

The proposal lists 12 livestock allotments affected by the Three Bar Ecosystem proposal, 4 wild horse Herd Management Areas, Roberts Mountain, Whistler Mountain, Rocky Hills and a portion of the Fish Creek HMA, and “numerous mining exploration activities and operations.”

The BLM doesn’t actually provide a list of the livestock allotments that comprise the “Twelve” but from the map provided, it appears the key players in the grazing department, in order of significance, are: Roberts Mountain, JD, Three Bars, Santa Fe Ferguson, Flynn/Praman, Grass Valley, Romano, Lucky C, Dry Creek, Shannon Station, North Diamond, and Underwood allotments.

Obviously, not all the allotments are entirely in the proposal area (some of them appear to have very little overlap), but it doesn’t take a rocket scientist to figure out, if the range is being cited as degraded inside the Three Bar Ecosystem boundaries, they are probably equally degraded on the other side of the imaginary line. All combined, BLM has authorized a total of 67,006 AUMs for livestock grazing just between eleven of these twelve allotments. Click Here for a complete breakdown of the grazing authorizations for these allotments.

For comparison value, the HMAs involved have an established AML range of 256-327 wild horses equating to a forage allocation low of 3,072 AUMs and a high of 3,924 AUMs.

In January 2008, BLM wild horse round ups were conducted in Roberts Mountain and Whistler Mountain HMAs, where 348 wild horses were removed while in January 2009, 80 were removed from the Rocky Hills HMA through the Callaghan Complex round up.

In the Callaghan Complex EA(1) , BLM stated that the JD and Grass Valley Allotments had issued new grazing rotation plans, “to reduce or eliminate hot season use of riparian and wetland areas in many of these allotments in order to make progress”.

Well, reading through the season of use BLM authorized in the Grass Valley and JD allotments, it doesn’t look like livestock was reduced or eliminated during hot season grazing after all.

In the Grass Valley Allotment, there is 1,047 head of cattle run between March 1 and November 30, 349 cattle run between April 1 and January 31, another 370 cattle run between May 1 and January 5, 146 cattle run between July 1 and January 31 and 244 cattle run between June 1 and August 15.

In the JD Allotment, which according to the Callaghan EA contains the majority of water for the Rocky Hills HMA, BLM allows 872 cattle to graze the area starting May 1 and continuing on through January 31 every year.

Other interesting facts surfaced by cross-referencing the wild horse round up proposals with the current plan. Some of these are:

**The Romano Allotment active preference received an increase of 825 AUMs in September 2008. This allotment overlaps the Whistler Mountain HMA, where the established AML is 14-24 wild horses. If that 825 AUMs had been given to wild horses instead, 68 horses could have been added to the AML and maybe they could have had a shot at being a remotely viable population.

**As of 2008, the Roberts Mountain and Three Bars Allotments had not been assessed for Rangeland Health conformance and these two allotments are sitting smack dab in the middle of the whole project.

**As part of the Three Bar Ecosystem proposal, BLM states they are going to perform rangeland health monitoring for the Three Bars, JD, Flynn/Parman, Romano and Lucky C Allotments between October 2009 and July 2010.

There are two things that stick out right away about this:

1) Even though the Roberts Mt. allotment is sitting in the heart of the project area and it had not been evaluated for rangeland health, according to what BLM says they are planning here, they aren’t intending on collecting any monitoring data from Robert’s Mountain during the evaluation process and,

2) With all BLM’s talk about “hot season grazing” and “drought”, they aren’t going to collect any data during the two hottest, driest months of the year – August and September – in any of the allotments!

What makes this EXTRA suspect is, BLM also announces in the Three Bar Ecosystem proposal they intend to evaluate and potentially reset the wild horse AMLs for the Robert’s Mountain HMA!

There are some other serious problems I suspect the wild horses are about to face during the “planning process” besides BLMs conspicuous lack of data regarding the livestock grazing going on in the area.

The first major concern is the Three Bar Ecosystem’s prominent focus of the Lahontan Cutthroat Trout. Last time wild horses faced a planning process that involved protecting the LCT, an Amendment was created to the Elko land use plan that only involved wild horses and the restructuring of the Herd Areas into smaller Herd Management Areas.

In 2003, with only three months between start and finish of the bureaucratic process, the Little Humboldt Herd Area was slashed from 63,937 acres to 17,151 acres while the Rock Creek Herd Area went from 183,496 acres to a modest 126,753 acres. In case anyone was wondering who signed that decision, it was current BLM Director Bob Abbey.

The other highly contentious issue that is receiving little attention in this scoping document is mining exploration and operations are dominating the landscape, both inside and outside the project area.

In the 2008 Robert’s Mountain Complex wild horse gather plan, BLM admitted that:

The future development of the Mt. Hope Molybdenum Mine in the northern portion of the Whistler Mountain HMA and eastern portion of Roberts Mountain HMA could have large impacts to wild horses. The mine itself could consume up to 16,000 acres, which equates to nearly 20% of the Whistler Mountain HMA and 8% of the Roberts Mountain HMA. Potential pipelines in Kobeh Valley could cause disturbance to wild horses, and reduce water availability at remaining sources. In conjunction with road building, fencing, and other foreseeable actions, the overall affects could be reduced habitat for wild horses and fragmentation of that habitat.”

But that isn’t the only mining operations occurring smack dab in the middle of the Three Bar Ecosystem. While the Mt. Hope Mine is potentially going to gobble up land and water in Roberts and Whistler Mt., the Tonkins Springs Mine in the Rocky Hills HMA may be next.

The Tonkin Springs mine, which had not been operational since 1990, became the site of new, intensive exploration efforts thanks to US Gold’s aggressive acquisitions by CEO Rob McEwen.

Utilizing new techniques and new technology to explore the Tonkin Springs region, in May 20, 2008, a press release was issued titled, “Tonkin Resource Estimate Increases to 1.76 million ounces of Gold”, which is a 24% increase from their last projections in 2006. It also states, “There is great potential to increase this estimate further with immediate expansion opportunities at Tonkin…”

By the way, Mr. McEwen is a busy man. Not only is he the Chairman and CEO of US Gold, he holds the same title for Lexam Energy Explorations, currently involved in a nasty lawsuit regarding their Baca Oil and Gas Project located along the Rocky Mountains in Secretary Salazar’s home state of Colorado.

According to the Creston Eagle, US Fish & Wildlife Service (USFWS) didn’t feel seismic blasting, road construction, work crews, water testing and 14,000 ft. depth drilling in the Baca National Wildlife Refuge required an environmental impact statement. Instead, USFWS gave Lexam two thumbs up to carry forward with merely an EA. A federal judge didn’t agree and granted a preliminary injunction in September 2009, an injunction Lexam described as “disappointing” in this September 4, 2009 press release.

Lexam is also involved in a uranium mine project in northern Quebec (think nuclear “renewables”) as well as recently acquiring 27% of Canada’s VG Gold Corporation outstanding shares and 42% of their diluted shares.

For now, here is what the Three Bar Ecosystem Scoping Summary has to say about wild horse management being planned in this preliminary phase.

The following wild horse range conditions are desired by the BLM for the 3-Bars ecosystem:

*Production of the dominant and/or native perennial grass and forb components on all range sites achieves a minimum of 50% of the range site potential.

*Plant species frequency, production, and composition indicate an upward trend at range sites where the dominant and/or co-dominant species are missing.

*Whistler Mountain HMA wild horse population maintained below the established AML range of 14 to 24 wild horses.

*Fish Creek HMA (north) wild horse population maintained below the established AML range of 6 to 10 wild horses.

*Rocky Hills HMA wild horse population maintained below the established AML range of 86 to143 wild horses.

*Roberts Mountain HMA wild horse population maintained below the current established AML of 150 horses. It is desirable for a range of AML to be established for this HMA to indicate a low population and high population. The estimated range based on existing knowledge/data is 90 to 150 wild horses.

*Wild horse populations maintain average body condition scores of 5 or higher on a year-round basis.

*No occurrence of the need to conduct emergency gathers or to haul water to HMAs.

*All unnecessary fences are completely removed within the 3-Bars ecosystem.

With respect to the "desired results" of keeping wild horse population BELOW the existing range of AML's, it is currently unclear if this was an editing error or if this is indeed what the BLM is shooting for. However, since written documents carry the bulk of the legal weight, I intend on responding as if they meant this to be a fact until I see it changed in writing.

BLM hasn’t posted a copy of this proposal on their Battle Mountain website but a blurry version is available HERE and I have also uploaded the copy I received via snail mail you can access HERE.

There also seems to be some confusion about the actual comment deadline.

On the Battle Mountain Homepage, under Federal Register Notices, BLM states the comment deadline is February 24, 2010. The first link provided above stated the comment deadline was February 25, 2010. The letter I received via snail mail states the comment deadline was March 1, 2010 4:30 p.m. pst while the “official” Federal Register Notice states that, “all comments must be received prior to the close of the scoping period or 15 days after the last public meeting, whichever is later”.

This leads to the question, so when is the last public meeting? According to BLM News Release 2010-03, the answer is February 23, 2010. The News Release goes on to add that, “Comments from the scoping meetings must be received by March 11, 2010, no later than 4:30 p.m.”

So which one is right? February 24th, February 25th, March 1st or March 11th? And if it’s March 11th, will BLM only accept comments from those who attended the meetings as stated in their News Release or will they accept all public comments as stated in the Federal Register?

While again leaving the public dazed and confused as to how and when they can participate, here is the contact information anyway. Also, if you choose to become involved, you must specifically state you would like to stay on their mailing list about this proposal.

Mount Lewis Field Office
50 Bastian Road
Battle Mountain, NV 89920
Phone: 775-635-4000
FAX: 775-635-4043
Contact people: Donavan Walker or Dave Davis.

Please be aware that submitting information for this proposal, including personally identifying information such as your name and contact information may become part of the public record. While you may request that BLM withhold this information, they may not be able to guarantee privacy in all instances.

Roberts Mountain Wild Horse
Downloaded from BLMs Internet Adoption Website on 12/09/08.

(1) Callaghan Complex Wild Horse Gather, EA# NV062-EA08-134.

Monday, February 15, 2010

BLM Protests Greet Obama

From the Desk of Equine Welfare Alliance....

BLM Protests to Greet President Obama in Las Vegas and Carson City, NV

CHICAGO, (EWA) – Wild horse and burro advocates from across the country plan on greeting President Obama on February 18 in Las Vegas with a protest of the Bureau of Land Management’s (BLM) mismanagement of the Wild Horse and Burro program and total disregard of the 1971 law protecting the wild horses and burros on their public lands.

The highly criticized Calico Complex round-up in Nevada that concluded on February 5 resulted in the death of 48 wild horses and the loss of 30 unborn foals. The death toll continues to climb from injuries resulting from the round-up as well as health issues from diets, such as Alfalfa hay that wreaks havoc on wild horses unaccustomed to a rich diet after feeding a lifetime on desert grasses.

The Calico round-up is being called one of the most deadly round-ups in history. Video footage shows foals being chased by a Cattoor helicopter as they tried to keep up with their mothers fleeing during the stampede. Two baby horses literally later had their hooves fall off, dying a dreadfully painful death at BLM's hands. The horses were run over miles of rough terrain in the dead of winter.

According to the BLM, the round-ups are for the welfare of the horses. They claim the horses are starving but the photos and footage tell a different story. They claim the few thousand horses remaining free roaming are ruining the ranges but the GAO reports reflect the millions of privately owned livestock being subsidized by tax payers are the cause of the range degradation.

Although the wild horses and burros belong to the American public and the BLM speaks of transparency by the bureau, humane observers had very limited access at the round-up and are being kept away from the Fallon Facility where the horses are being held.

George Knapp from KLAS TV I Team recently aired two reports, BLM Wraps Up Huge Wild Horse Roundup and Wild Horses Forced into a Stampede of Death, which are an eye-opener to those unfamiliar with the BLM round-ups.

The Equine Welfare Alliance, The Cloud Foundation and In Defense of Animals (IDA) encourages concerned Americans to join the protest on February 18 at 1:30 at the Lloyd D. George Federal Courthouse, 333 S. Las Vegas Building, Las Vegas, NV. Expected speakers at the protest are Craig Downer, wildlife ecologist and humane observer at the Calico round-up, Neda DeMayo, founder and CEO of Return to Freedom, Gina Greisen, president of Nevada Voters for Animals and Arlene Gawne, wildlife artist. Additional information can be obtained from Arlene Gawne at 702.277.1313 or

As second protest, Truth Rally, will be held on February 20 in front of the Legislative Building on North Carson Street, U.S. Highway 395 in the state capitol of Carson City, NV and is sponsored by The Alliance of Wild Horse Advocates. Information is available from Bonnie Matton, Wild Horse Preservation League at 775.220.6806 or

"Valentine Gift to BLM"
Protestors outside of the BLM entrance to Red Rock Canyon near Las Vegas, NV , 2/14/10.
Courtesy of Arlene Gawne

The Equine Welfare Alliance is a dues free, umbrella organization with over 95 member organizations. The organization focuses its efforts on the welfare of all equines and the preservation of wild equids.

Thursday, February 4, 2010

The Irony Of Ivanpah

Photo of Industrial Solar Plant ~ Courtesy of Basin and Range Watch

The Obama Administration recently released their proposed Budget for the BLM, which includes a whopping $75.7 million dollars for the BLMs Wild Horse and Burro Program with an additional request of $42.5 million to purchase land for ONE wild horse preserve related to Secretary Salazar’s new vision for the future of America’s herds - despite having approximately 680,000,000 acres of land currently under federal control.

On July 9, 2008, Congressional Representative’s Nick Rahall, Chairman of the Committee on Natural Resources and Raul Grijalva, Chairman of the Subcommittee on National Parks, Forests and Public Lands, sent a Letter to BLM regarding their management of the Wild Horse and Burro Program. In it, they stated, “You may be aware that the BLM’s inability to administer the budget of the Wild Horse and Burro Program with any trace of fiscal accountability is a long standing concern…”

In that letter, Representatives Rahall and Grijalva also asked,

“It has been reported that over 19 million acres of land, on which wild horses and burros existed at the time of the passage of the Wild Free-Roaming Horse and Burro Act in 1971, is no longer available for wild horses. Is this figure accurate? If so, what is the justification for terminating wild horse and burro use of these lands?”

“Why has the BLM not reintroduced wildhorses/burros to lands that previously were available to the animals in 1971, which have subsequently been closed to their use?”

Yes, what about the land that has “disappeared”….

The Government Accountability Office (GAO) was suppose to include an answer to where all the land went in their report released in November 2008 but apparently, the question of acreage was too daunting for the GAO to try to sort out, so they deferred it to BLM to answer.

BLM was suppose to release a report in March of 2009 but that deadline came and went. In June of 2009, the BLM presented a “draft” report to the National Wild Horse and Burro Advisory Board that included “lump sum” explanations of where all the acreage disappeared too under such headings as, “Resource conflicts” or “Unsuitable Habitat” or “Other Reasons” but nobody has seen, nor is anybody asking BLM to actually provide a full accounting of what this really means.

Real answers to the question of “lost acreage” seems to have melted into the background while Salazar is busy sticking his tin cup out to the American taxpayer to compensate for land and herds stolen from the public.

The Clark Mountain Burros
The Clark Mountain burros were one of the oldest and most unique wild burro herds in America. Living in relative isolation for four centuries, their genetic tests revealed the herd had a “high proportion of rare variants” based on genetic tests performed by leading geneticts Dr. Gus Cothrane at the behest of the National Wild Horse & Burro Program on wild herds across the West.

One of the last remaining Clark Mountain Burros
Courtesy of Basin and Range Watch ~ May 2009

In 1994, with the passage of the California Desert Protection Act (CDPA), the burros only perennial water source was transferred to National Park Service (NPS), also now managed under Secretary Salazar, through the creation of the Mojave National Preserve. NPS then issued a General Management Plan declaring a zero burro management policy for the Clark Mountain wild burros.

On September 20, 2005, California Senator Feinstein, author of the California Desert Protection Act, issued a Letter to then Secretary of the Interior Gale Norton, which stated, “…a population of wild burros should be maintained within the Mojave National Preserve’s boundaries” and “I want to be on record as expressing my support for maintaining a viable and self-sustaining population of these wild burros in the Mojave National Preserve and I oppose any efforts to remove such a population.

No records can be found to determine if BLM and NPS tried to work it out by developing a Memorandum of Understanding (MOU), a common management tool used so that both agencies may fulfill their respective mission - but we can see the seeds being laid for the future of the burros in the Desert Managers Group California Desert Interagency Burro Strategy signed in 1999.

So far, no evidence can be found indicating NPS ever considered Senator Feinstein’s request to preserve and protect the Clark Mountain burros found within the Mojave National Preserve but we can see their stance here in this NPS E-mail Response in 2006 addressing public concerns about removals and rumored shootings of wild burros in the Preserve, where 3,022 burros had already been removed just between 1997 and 2003. Click Here to learn more.

In 2002, then BLM California State Director Mike Pool (now Deputy Director of the entire BLM) signed the Record of Decision for the Northern and Eastern Mojave Desert Management Plan (NEMO) that zeroed the Clark Mountain burros out.

During the planning process of NEMO, BLM presented five Alternative management options, four of which proposed to continue to manage the Clark Mountain burros. These Alternatives included such options as adjusting the AMLs upwards, supplying alternative water sources, modifying existing HMA boundaries to preserve and protect both wild burros and desert tortoise and initiating a five year carrying capacity range analysis.

Despite having many alternatives available to continue “managing” the burros, Director Pool signed off on the decision to zero them out. The only question that seems to remain is which heading BLM's "Lost Land Explanation Team" now includes the Clark Mountain “unsuitable” Herd Area acreage under.

Desert Tortoise
In the Environmental Assessment (CA-690-EA04-27) issued by the Needles Field Office in December 2006, authorizing the final removals for the Clark Mountain burros through 2012, BLM attempted to imply that the total elimination of all wild burros within the Clark Mountain Herd Area was required to protect Desert Tortoise within the Ivanpah area.

With respect to noted impacts by wild burros to desert tortoise, no data, viable information or studies were done within the Clark Mountain area regarding either their impacts to rangeland health or their affects on desert tortoise whatsoever.

In 2005, U.S Geological Survey (USGS) issued a report titled, “Threats to Desert Tortoise Populations: A Critical Review of the Literature”. Only one paragraph was included regarding wild horses and/or burros impacts on the threatened desert tortoise found on page 57. Here is the exact conclusion presented by USGS within that analysis; “Wild burro and tortoise ranges overlap in some places, but the overlap is quite low in the West Mojave. No published studies were found that investigated the impact burros or horses (neither of which are native to North America) have on tortoise populations. The primary effect is likely to be habitat alteration through soil compaction and vegetation change. Burro populations are probably not extensive enough in most areas to pose a major threat to tortoise populations, but this is speculative.”

On June 1, 2009, California State Wild Horse and Burro Lead Amy Dumas reported a remaining population of approximately 60 wild burros within the Clark Mountain area (per.communication via email) but numerous reports from the public state there are less than 20 wild burros actually left after the BLM removed over 100 in January 2007.

The Ivanpah Solar Plant
As the Obama Administration, Secretary Salazar and such heavy hitters such as T.Boone Pickens are pushing a Fast Track and selling the American public on their “green, renewable energy” agenda while turning a blind eye to all the former wild horse and burro habitat these projects need in order to come to fruition, it's beoming more and more apparent it's not just land these guys are after anymore.

With a megalithic public resource grab swinging into full gear, the last of our Nation’s vast resources are headed to the chopping block for international consumption by the corporate interests funding these resource grabs and partnering with our “public officials”.

It’s not just the land, it’s everything the land contains and for those of us who live in the Southwest, what really sticks out is, the water these industrial tycoons are going to suck dry and lock up from the people – forever!

"We are humbled by America’s bounty. We are humbled because the richness of our lands has enabled our Nation-time and again-to renew itself….repower itself…and reinvent itself for new challenges and opportunities.”
Interior Secretary, Ken Salazar
February 1, 2010

Water drop at Lake Mead, Nevada ~ Courtesy of National Park Service

To illustrate this point, here is what is going to happen with just ONE solar plant out of hundreds currently being “fast tracked” by BLM in the former home of the Clark Mountain burros.

Basin and Range Watch (BRW) has provided extensive research and coverage of what the Ivanpah Solar Plant really means. Rather than work first to set up solar panels and plates on homes and business in already developed places like Las Vegas located just 35 miles away, this so called “green” technology will set up shop directly adjacent to the Ivanpah Desert Tortoise Critical Area of Environmental Concern (ACEC) that the Clark Mountain burros were supposedly zeroed out to protect.

According to BRW, here is what the public ~ and the tortoises ~ can expect.

First, it will take five months to scrape the desert floor to clear all existing plants and animals from the initial 4,000 acres to get it started. Initially, 214,000 helistat mirrors will be set up in three rings that will aim sunlight at boilers located at centralized 459-foot towers. This will later blossom to a projected total of 318,000 mirrors and 5 rings. Herbicides would then be regularly sprayed across the landscape to “keep weeds down” (or anything else that tries to grow!)

During construction, the Ivanpah Solar Project will require an estimated 99,333 gallons per day of water for Ivanpah Plants 1 and 2 and 194,000 gallons per day for Ivanpah 3, with up to an additional 47,000 gallons used during pipeline hydrotesting. This would be about 76 to 149 acre-feet per year.

Additional water needs are projected for washing the mirrors that could result in an additional 50 acre-feet of ground water per year during grading of the soil and after that, a routine operation of washing the mirrors every two weeks will need about 100 acre-feet per year. The preliminary proposal also states, “over the next 50 years, the use of the….groundwater is expected to increase and, along with that increased use, the overdraft in the basin is expected to become greater. The project’s pumping of groundwater alone would contribute to this overdraft…”

Administrative and maintenance buildings, a warehouse, detention ponds, and a small sewage system will be built on site as well as “small amounts of hazardous wastes produced that contain mercury, lead, cadmium, copper, and other substances…”

The company in charge of this monstrocity, Bright Source, wants a total of 10,500 acres of public land and raised more than $160 million dollars from investors such as - but will need millions more to complete the project.

The Ivanpah site sits right across the valley from the Bighorn Generating Station, a 598-megawatt natural gas-fired plant, because the Ivanpah Solar Plant will also need natural gas in order to keep the start-up boilers warm during cloudy days. This will require a new 5.3-mile long pipeline connecting to the Kern River Gas Transport line.

Part of the proposal demands that ALL tortoises will have to be “re-located” from approximately 4,000 acres of the project. The projected “normal” mortality rate of 15% for “translocated tortoises” is being used but a recent Fort Irwin translocation operation suggests even higher mortality rates are probable; BRW projects mortality rates may be closer to 50%.

Right now, the BLM Needles Field Office has prepared a Draft Environmental Impact Statement and is still accepting public comments on the proposed Ivanpah Industrial Solar Plant.

As part of this process, a joint analysis between BLM and the Energy Commission released in 2008, regarding the impacts of the proposed Ivanpah Electric Generating System to the handful of remaining Clark Mountain burros was prepared titled, "Wild Horses and Burros". Click Here to view.

Digital image of what the Ivanpah Solar Plant will look like upon completion.

To view a copy of the Draft EIS, Click Here

Public Comments on the Ivanpah proposal are due by:

February 11, 2010

~Contact Information~

George Mackfessel
Planning and Environmental Coordinator
Bureau of Land Management
Needles Field Office
1303 South U.S. Highway 95
Needles, CA 92363
Phone: (760) 326-7000
Fax: (760) 326-7099 Att: George Mackfessel

Also, please be aware that submitting information for this proposal including personally identifying information such as your name and contact information may become part of the public record. While you may request that BLM withhold this information, they may not be able to guarantee privacy in all instances.