From: Shawna_Richardson@nv.blm.gov Sent: Friday, January 19, 2007 12:21 PM To: Cathy Barcomb Subject: Fw: stone cabin caballos Attachments: pic32046.jpg Shawna Richardson Wild Horse and Burro Specialist Battle Mountain Field Office Battle Mountain, Nevada 775-635-4181 ----- Forwarded by Shawna Richardson/BMFO/NV/BLM/DOI on 01/19/2007 12:19 PM ----- Andrea Felton/TFS/NV/BLM /DOI To Shawna 01/15/2007 05:55 Richardson/BMFO/NV/BLM/DOI@BLM PM cc Subject Fw: stone cabin caballos Andrea Felton Wild Horse and Burro Specialist Bureau of Land Management Tonopah, NV 89049 (775) 482-7847 ----- Forwarded by Andrea Felton/TFS/NV/BLM/DOI on 01/15/2007 05:54 PM ----- Katie Fite To andrea_felton@blm.gov, 01/15/2007 01:29 valerie_metscher@blm.gov, PM doug_furtado@blm.gov, douglas_furtado@blm.gov cc kfite@cableone.net Subject stone cabin caballos (Embedded image moved to file: pic32046.jpg)[] January 14, 2007 Andrea Felton and Valerie Metscher Battle Mountain BLM 50 Bastian Road Battle Mountain, NV 89820 Tonopah Field Station PO Box 911 Tonopah, NV 89049 RE: Stone Cabin Complex Wild Horse Gather EA NV065-EA07-028 Dear BLM, Western Watersheds Project is deeply concerned that BLM is sweeping the tremendous ecological problems caused by domestic livestock in this landscape completely under the rug. This action involves a huge land area, involves a wild horse herd that roams across agency boundaries, involves a highly controversial reduction in wild horses based on exceedingly limited information and analysis. It is being done WITHOUT ANY ACCOMPANYING REDUCTION IN LIVESTOCK or critical and “hard look” at the relative impacts of livestock use and numbers compared to horse use and numbers. It requires preparation of an EIS. NEPA requires that federal agencies base their decisions on sound ecological information and current science. This EA does neither. The EA fails to present critical information on the role of domestic livestock grazing in affecting the health of the lands and waters in the Stone cabin Complex. Where has BLM conducted current rangeland health assessments and carefully and systematically separate horse from livestock impacts? If BLM has conducted such assessments, what is the population of horses in the particular areas that may be failing to comply with the FRH? What is the population in the areas that are found to be in compliance with the FRH? What is the livestock use pattern and stocking rates in these same areas? Please provide detailed information on Actual Use by domestic livestock in each pasture or unit here during the past 20 years. Please provide detailed information, including maps on all domestic livestock facilities, water haul sites, mineral and salting sites, and assess their impacts on causing conflicts with wild horses and wildlife habitats (displacement, weed infestation and spread, depletion of native vegetation, etc.) as well as the current state of repair of all such facilities. Please provide parallel information for wild horses and explain how you have arrived at this information. Please provide a full history of any warning letters, trespass actions, or other non-compliance here. BLM provides no basis for its claims that claims that this action would be in compliance with the FRH. In fact, it may very well Please also provide a detailed analysis of the current effects of livestock grazing on important and sensitive species and their habitats and populations. Please provide detailed analyses that clearly differentiate – with on-the-ground monitoring – between livestock and wild horse use. How have classes of livestock, livestock use of areas, etc. changed since the days of the old LUP, or 1996 that is discussed here, or other benchmark dates? A full range of reasonable alternatives must be considered. These include: Analysis of a series of reductions in domestic livestock grazing to provide better forage and less disturbance to horses; establishing more conservative standards of livestock use to result in better conditions; leaving intact horse bands in regions of the Complex to examine the role of band stability ion population regulation; no issuance of TNR (isn’t this a Vacant allotment – due to sagebrush rebels in the past not paying grazing fees) coupled with termination of livestock use in the winter range area described on page 19 as being very important) , and a host of other actions and alternatives that BLM could readily consider here. For example, in Carico Lake where we just received a proposal to issue TNR use, we request that as part of this EA process, you consider temporary removal of any horses that you may believe are damaging specific resources to this allotment. Since there is an abundance of forage there, it seems an ideal place to relocate some of the horses to – temporarily –until you make necessary adjustments to get the livestock in Stone Cabin lands under some semblance of control. This EA is so extremely biased against horses and TOWARDS the livestock industry that it doesn’t even pass the laugh test. There are many fewer horses than domestic livestock here, yet BLM makes a big deal about horses getting out on the road – well, if there are no fences, then there is a MUCH GREATER CHANCE that cows will be hit and endanger motorists than horses – given the great disparity in AUMs here. Why are cows standing in the road not a concern here? Why are human lives endangered by cows not of as much concern as the much smaller number of horse encounters? While BLM describes events in 1996 on winter range in Saulsbury - it blames horses. What was the domestic livestock grazing situation there for the preceding decades – and also since that time. How much has livestock grazing been reduced? How much rest has occurred? Etc. While it is nice that BLM mentions the importance of riparian-wetland areas, the EA provides not a single shred of information and data about the condition of these areas, and that examines the different and separate, as well as cumulative impacts of livestock grazing and trampling vs. wild horse impacts, to these sites. Plus, nowhere is there any data on flow rates, changes in flows over time, location and effects of all livestock facilities or other water flow alterations including water diversions, de-watering spring gutting/development projects, and all manner of other alteration that may affect wild horse and wildlife use of these areas, as well as rare aquatic biota. BLM claims (EA at 19) that there would be a “reduction of utilization levels”. There is no evidence that this would occur, as BLM in Battle Mountain, in a recent EA for issuance of TNR use in a Battle Mountain allotment to the north – Carico Lake – claims that whatever the use it sets out there is an Objective to be MET – i.e. very blade of grass that is available. Ranchers will just compensate by stocking to the max – and likely exceedances will occur Were, specifically in all pastures and use areas, and in relation to EVERY Key Area –and where is EVERY Key Area located (please provide maps) is there evidence documenting utilization rates across the allotments. Were livestock prevented from grazing the Stone Cabin and Saulsbury areas in 1995, 1996, 1997, 1998? Or any other areas in the HMA? Were numbers reduced? BLM has not provided data and information critical to support its assertion that key forage plants would increase in vigor. We need to know what key forage plants still remain where, if larger-statured native grasses have been replaced by small increaser species, or worse – annual weeds – and other critical information. It has not examined the current rangeland health – at each and every key area, riparian area, etc. here – and the location of surface waters including any playas, spring and seeps, streams, water pipelines, wells, stock ponds, water haul and other sites, in relation to stocking rates and actual use by domestic livestock that has occurred – or that is foreseeable - here. Where is the monitoring information that indicates watering areas used by this herd of horses are in good or excellent condition? That is very important data, and we would like to see it portrayed and analyzed in detail in the NEPA document. Are those areas currently grazed by domestic livestock, and at what actual levels? What is the information NDOW bases it concerns on? How is military training activity – including low level flights, rangeland flare-caused fires or other activities affecting these lands and ecological conditions, or the causing stress or disturbance or displacement? Where (including on Forest or other lands used by this horse herd) are there mining claims, oil and gas leases, geothermal, rights-of-way, or other exploration and disturbance existing, ongoing or planned? Where have all recent healthy forests or vegetation manipulation projects occurred in BLM and Forest lands here? Where are they proposed? How will these activities affect wildlife habitats and populations, and use of the landscape? How will they affect horses? How will they affect livestock grazing use, stocking rates, or cumulative disturbance impacts? There is deep suspicion that BLM is now, on several fronts, moving to alter conditions to promote livestock grazing through prescribed burns and other pinyon-juniper and sagebrush thinning or killing projects. What were the effects of the Minnesota fertility study? BLM claims to be studying this fertility drug in each and every Nevada EA, yet little has ever resulted that we have seen. At some level, there has to be an assessment, and accountability of such actions. Is this drug hormone, and if so are it or its breakdown products in urine or other wastes polluting desert waters? What is the role of horses here in promoting a healthy mountain lion and other native carnivore population? Where have all fires occurred? What was the result of these fires? What areas and plant communities – how many acres? Where? When were surveys done? contain cheatgrass, bromes, or other invasive grasses as a component of understories? Where are these species dominant? What lands are at risk to further infestation, and what is the relative role of horses vs. domestic livestock in this? It is impossible to understand what the EA (as at 22) is claiming about age structure. No old horses should be removed. Is BLM still bound by that 1987 settlement? It is 20 years old now, and conditions on the ground have changed. Plus, the public has even greater concern about the impacts of domestic livestock (compared to wild horses) on the landscape. Please provide detailed economic analyses of the livestock grazing cost to the public (administrative as well as mitigation) as well as alternative uses foregone. We note that there are LLCs and a Manager indicating an absentee - perhaps hobby owner? Is sub-leasing going on? If so, whose livestock actually graze here, and what has been their record of compliance on any public lands grazing allotment? Are there loans or bank liens on the grazing permits or base properties? Who owns the base properties? Does APHIS conduct subsidized predator killing here? If so, where, and what does that cost taxpayers? Does aerial gunning or other disturbance affect or displace wild horses or wildlife? Please provide a detailed analysis of the relative impacts of horses vs. domestic livestock vs. wildlife, vs. combined wildlife and horse use – on the lands of Wilderness Study Areas here. This action will have a major effect in increasing the likelihood of TNR issuance or increased grazing use (far above levels of actual use) on these lands. There may not be a bit of on-the-ground difference in environmental effects if ranchers increase use, or stock up to permitted levels. BLM must tell the truth here, and not claim that somehow rounding up horses will result in improvement on the ground unless it acts to control domestic livestock grazing to a much greater extent than it has in the past here. It seems like a blatant falsehood to claim that BLM’s actions will have “minimal impact” on herd population or dynamics. It will have a tremendous impact on the dynamics of band groups, and potential learned use of areas. What role does learning play in wild horse of land areas? The outcome of the proposed action is highly uncertain. You claim that you will follow selective removal criteria, “to the closest extent possible” – yet you do not explain how you will deviate, nor do you analyze a range of alternatives related to such criteria – like leaving bands all intact in areas where horse numbers are not as great, and other actions that could be taken to ensure minimizing disturbance to horses and the lands as part of your actions here. This reminds me so much of the senseless predator killing that occurs on public lands, and mesopredator release that causes even greater problems. Stable coyote pairs are killed. Then, younger or more animals move in, and predation on sage grouse or other species increases. Here, are you ultimately creating more problems just a few years down the road by breaking up horse bands? You describe “compensatory wild horse fluctuations” occurring – so why don’t you do something for once that does not completely upset the structure of the horse population everywhere here - especially in areas where there may be well established bands - and NOT remove those? What would be the results if you set aside one area or two areas to do this in? Please make sure a detailed analysis of all impacts to all values of WSAs is provided. Additionally, we have a real concern with BLM relying on Key Areas for monitoring horse impacts – horses typically range much further from water than cattle, so to accurately gauge their use, BLM should establish monitoring areas. BLM must also related horse numbers to actual land area, and not just fly the whole thing, and lump numbers across this vast region. There needs to be precision in determining effects, which horses to remove or keep, and other such effects. We may submit additional comments. Also, pasted below is my letter commenting on helicopter concerns, and a letter written to the State Director concerning your EA’s ignorant casting aside of legitimate input and concern. We are also providing a list of scientific literature you should address related to arid lands ecology. Sincerely, Katie Fite Biodiversity Director Western Watersheds Project PO Box 2863 Boise, ID 83701 Katie@westernwatersheds.org January 14, 2007 Mr. Ron Wenker Nevada State Director Bureau of Land Management Dear Director Wenker, I am outraged at the simplistic distortions of Nevada BLM staff in a recent Tonopah/Battle Mountain BLM horse round-up EA for the Stone Cabin Complex. In 2006, BLM sent a scoping letter asking for comments on use of helicopters in its wild horse program. So I commented. Now, those comments PASTED BELOW are being characterized in the Stone Cabin EA in a single sentence statement portraying me/WWP as some kind of Flat Earther. BLM’s Stone Cabin EA, in seeking to marginalize and minimize ANY alternative world view, states on page 46 “Katie Fite … wrote a letter objecting to the use of helicopters for use in wild horse and burro management”. This is exactly the kind of distortion – and telling only PART of the story, and attempting to cast legitimate public input that differs from a livestock industry perspective in the worst possible and biased light - that we have come to expect as routine from Elko BLM. Now, the poisonous Elko attitude appears to be pervading the work of the Tonopah/Battle Mountain Office as well – or perhaps your State-level horse staff? In seeking to simplify and minimize concerns about potential costs and impacts of helicopter use on wild horses, wildlife and public wild lands, BLM does a grievous disservice to the public. I ask that this draft EA be rescinded, and a new and greatly revised EIS be prepared that does not make simplistic distortions and that more accurately represents the concerns raised about helicopter use, as well as the role of livestock in impairment of the public lands in the HMAs. AND it is necessary to prepare an EIS for this helicopter use across Nevada. You see, I’ve flown in helicopters. I know firsthand that they spook and may stress wildlife and wild horses. I have also had discussions with responsible and caring BLM wild horse staff here in Idaho who also have expressed concerns about helicopter use – especially in areas where APHIS has been aerial gunning, or horses are harassed for other reasons – as in your case, some areas of Nevada where ranchers/the livestock industry may potentially be engaging in aerial or other horse harassment – like portions of allotments in the Owyhee country. Thank you for your attention to these concerns. Katie Fite Biodiversity Director Western Watersheds Project PO Box 2863 Boise, ID 83701 May 26, 2006 Maxine Shane Debra Kolkman Susie Stokke BLM PO Box 12000 Reno, NV 89520-0006 Dear BLM, Here are comments of Western Watersheds Project on BLM’s use of helicopters in wild horse removal and survey work and other aspects of the deeply flawed wild horse management that we are seeing occur across Nevada. How much do all aspects of the Nevada wild horse program cost taxpayers? How much of this is helicopter costs? Are there alternative methods to survey horses – such as developing a science-based systematic sampling survey method on-the-ground. That certainly seems feasible and realistic and safer, instead of cowboying in helicopters at the cost of $600 and hour or more. That would much reduce the disturbance to wildlife and recreational users from BLM horse ‘censuses”. Plus, it would reduce stress on the horses and disturbance of wildlife and recreationalists. Please describe how horses (all age classes) and wildlife react to helicopters, if they are driven into fences, suffer injuries, or otherwise suffer stress or harm from this any BLM helicopter activity. How can this be minimized? Is BLM using helicopters to census or pursue horses in Wilderness or WSAs? If so, why is this being done, and what are the impacts? Are helicopters landing in WSAs or Wilderness as part of horse census/pursuit/round-ups? We are very concerned about this activity, if it occurring. Please provide analysis and data on where and how such activity occurs in all HMAs. What bighorn sheep or other big game populations are being disturbed by this activity? Please provide maps overlaying bighorn sheep populations with horse helicopter use. BLM must re-assess the “need” to round up wild horses in the Buck and Bald, Pilot Mountain, Silver Peak, Paymaster, South Shoshone/Bald Mountain Complex, Tobin/North Stillwater/Augustas, Stone cabin/Saulsbury/Reveille Complex, Dry Lake Complex, Roberts Mountain, Whistler Mountain, Jackson Mountains, Wilson/Deer Creek Complex and Buffalo Hills. This is because: BLM is authorizing TNR use (extra cow and sheep AUMs) across Nevada right now – demonstrating that forage exists for horses and that BLM must believe that miraculously the impacts of drought have waned. Thus, BLM claims in any environmental documents that horses must be rounded up due to drought are now false. New environmental analysis must be conducted. In many places, ranchers are stocking cattle in numbers above the average actual use that has occurred - and thus in reality are consuming proportionally more AUMs – and eating into horse food, cover and space. Plus, any increased management activities associated with more cows and sheep will further disturb and displace horses. BLM must provide a detailed account of how many cattle or sheep AUMs it has authorized to graze in 2006, compared to wild horse numbers in these same areas. BLM must also provide detailed information on how it is determining “excess” horse numbers, and why - for instance in the case of a recent letter from Elko BLM concerning the Buck and Bald Complex - it is re-rounding up areas where horses have already been rounded up. How much was spent in the Buck and Bald round-up last year? How much will be spent this year? What percentage is helicopter round-up costs compared to all other costs associated with horse round-ups? How much staff time does this take? BLM must also assess how aerial pursuit of horses and round-ups may break up horse family groups or band structure of horses, and the effects this may have on populations and use of lands. In addition, environmental circumstances have changed, with BLM undertaking many vegetation treatments, authorizing Oil and Gas exploration and leasing, a great deal of mining exploration and development, new livestock facilities, and many other intrusive activities on public lands so that horses are being displaced into suboptimal areas. In order to ensure that horses have sufficient food, cover and space, BLM must assess reductions or changes in livestock stocking rates and use levels. Plus, the BLM now has adopted and is vigorously promoting a new policy to allow ranchers to adopt horses with few strings attached. This has serious implications – including the very real possibility that ranchers will then be able to fairly readily mix wild horses rounded up with helicopters in with other stock, and surreptitiously sell the horses for meat. A tremendous backlog of captured horses exists, and scouring the public lands rounding up horses with helicopters - at the same time that BLM issuing extra AUM permits to public lands ranchers in Nevada – especially politically connected ranchers like Tomera (Elko BLM) – makes no sense. It is a likely death sentence for horses, yet ranchers get to rake in more near-free AUMs from the public lands. BLM must assess alternatives that provide horses with any TNR AUMs currently being considered for ranchers. What alternatives to helicopter round-ups exist? Where can they be used? How selective are helicopter round-ups? Please provide horse mortality or injury records for all helicopter activity and any other part of horse round-ups for the past decade. How many wild horses – and where – have been rounded up using helicopters in the past decade? Please provide a year-by-year tally. How many of these have been adopted? Injured? What are the current wild horse numbers in all of the above HMAs where round-ups are contemplated? We are extremely concerned about the likely road improvements and upgrades and disturbance associated with the use of semi trucks. Are roads bladed in association with round-ups? If so, where has this occurred? Where are all corral sites located? What impacts does road upgrading have on soils, vegetation (native and weeds), important and special status species, cultural sites, extending motorized use by crating new easy-access jumping off sites, etc.? BLM must provide detailed information on all corral sites or staging areas used in wild horse round ups, and the road access to them, and the full range of environmental impacts these facilities and impacts may be having.. Please keep us fully informed in all aspects of this proposal and apply this letter to development of an EIS here. Please also apply this letter as a comment on the wild horse removal activity in the Buck and Bald, Pilot Mountain, Silver Peak, Paymaster, South Shoshone/Bald Mountain Complex, Tobin/North Stillwater/Augustas, Stone cabin/Saulsbury/Reveille Complex, Dry Lake Complex, Roberts Mountain, Whistler Mountain, Jackson Mountains, Wilson/Deer Creek Complex and Buffalo Hills HMAS and all other HMAs. We have observed that BLM routinely inflates horse numbers and impacts in order to justify round ups. We have observed how much BLM staff seem to like these round-ups, as it provides a prolonged escape from the office, and opportunities to “cowboy”. 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