DOGSKIN MOUNTAIN HERD MANAGEMENT AREA PLAN/CAPTURE PLAN UPDATE and ENVIRONMENTAL ASSESSMENT (EA) No. NV-030-03-036

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I. Introduction/Purpose and Need	5

Introduction	5

Land Use Plan Conformance Statement	6

Relationship to Other Environmental Documents, Statutes and Regulations	6

Other Activity Plans, Issues and Constraints	7

1. Multiple Use Decisions 1993:	7

2. Range Program Summary Update 1989 (now incorporated into the CRMP):	8

4. Allotment Management Plans:	8

5. Wildlife Habitat Management Plan:	8

II. PROPOSED ACTION	9

A. Animal Objectives	9

B. Habitat Objectives	13

ALTERNATIVES	13

Alternative 1	13

No Action Alternative	14

Alternatives considered but not analyzed	14

III AFFECTED ENVIRONMENT	14

PROPOSED ACTION	14

General Setting	14

Critical Elements of the Human Environment	14

Resources Present:	15

III A. Wildlife	15

III C. Water Quality (Surface/Ground)	15

III E. Migratory Birds	15

III F. Wild Horses and Burros	16

III G. Invasive, Nonnative Species	16

Other Resources Present:	16

III H. Livestock Use	16

III I. Recreation	16

III J. Soils and Vegetation	16

III K. Visual Resources	17

IV. ENVIRONMENTAL CONSEQUENCES	18

Proposed Action	18

IV A. Wildlife	18

IV B. Threatened or Endangered Animal Species	18

IV C. Water Quality (Surface/Ground)	18

IV D. Wetlands/Riparian	18

IV E. Migratory Birds	19

IV F. Wild Horses and Burros	19

Results from Dr. Jenkens’s model:	23

Table 1. Rate of Increase and Median number of horses removed under the different alternatives.	23

IV G. Invasive, Nonnative Species	23

Other Resources Present:	24

IV H. Livestock Use	24

IV I. Recreation	24

IV J. Soils	24

IV K. Visual Resources	24

ALTERNATIVES	24

Alternative 1	24

No Action Alternative	25

Mitigating Measures	26

Cumulative Impacts	26

Monitoring	27

A. Animal Studies	27

B. Habitat Studies	28

Table 2. Percent Ecological Condition	29

1. Utilization	29

2. Trend	29

3. Ecological Status	30

Evaluation	30

V. CONSULTATION AND COORDINATION	32

List of Prepares:	32

Persons, Groups or Agencies Consulted:	33

VI. APPENDICES	35

Literature Cited	35

Appendix 1, Minimum Viable Populations	38

Appendix 2, Population Data	39

Table 3. Population data.	39

Table 4. Initial age distribution post-gather	39

Table 5. Foaling Rates. Proportion of males is 0.58%	40

Table 6. Age specific survival rates.	41

Table 7. Average growth rate in 20 years, removals.	41

Table 8. Totals in 21 years, removals:	42

Table 10. Average growth rate in 20 years, removals. However, the population was only reduced to the upper AML.	42

Table 11. Totals in 21 years, removals only down to the upper AML.	42

Table 12. Population size in 21 years, removals only to the upper AML.	43

Table 22. Average growth rate in 20 years, no management, No Action Alternative.	43

Table 23. Population sizes in 21 years, no management, No Action Alternative.	43

II. Disposition of Removed Animals	50

III. Responsibility	50

I. Introduction/Purpose and Need

Introduction

With passage of the Wild Free-Roaming Horse and Burro Act of 1971 (Public Law 92-195), Congress found that: “Wild free-roaming horses and burros are living symbols of the historic and pioneer spirit of the West”. The Act states that wild free-roaming horses are to be considered in the area where presently found, as an integral part of the natural ecosystem of the public lands. The Secretary was ordered to “manage wild free- roaming horses and burros in a manner that is designed to achieve and maintain a thriving natural ecological balance on the public lands”.

The BLM National Wild Horse and Burro Strategy includes establishing and achieving Appropriate Management Levels (AML) on all Herd Management Areas (HMA’s) managed by the BLM, and to achieve and maintain AML on all HMA’s implementing a 4-year gather cycle. The numbers of animals projected to be removed were estimated using a wild horse population model developed by Dr. Stephen Jenkins of the University of Nevada Reno, based on a four-year gather cycle .

The Dogskin Mountain Herd Management Area (HMA) is situated within the administrative jurisdiction of Carson City Field Office (CCFO). In 1994, a Herd Management Area Plan/Capture Plan (HMAP) was prepared for the HMA. That plan presented management direction for managing the horse population. The AML range is 10 to 15, with an estimated current population of 100.

This plan update supercedes the previous plan and presents management direction for the Dogskin Mountain HMA. The terms horse and wild horse, both (Equus caballus) are used synonymously throughout this document.

The Dogskin Mountain HMA is located approximately 25 miles north of Reno, Nevada. The topography varies from moderately to very steep mountainous terrain. Portions of the HMA boundaries are formed by existing fence (map 1).

It is generally accepted that wild horses within the HMA originated from ranch stock that were released.

The HMA includes the entire herd area (6,895 acres), that area delineated as the wild horse habitat soon after passage of P.L. 92-195 (map 1).

Purpose and Need

The purpose and need of these actions are to achieve and maintain the HMA in a state of thriving natural ecological balance and multiple use relationship between the wild horse population, wildlife, livestock and the plant communities. In addition horse specific information would be collected to assess the overall health of the horse population. Specific objectives include managing the population to preserve and enhance the historic physical and biological characteristics of the herd and preserving and maintaining a healthy viable wild horse population within the HMA.

Land Use Plan Conformance Statement

The proposed actions and alternatives described below are tiered to and in conformance with the Carson City Field Office Consolidated Resource Management Plan of 2001 (CRMP), pages WHB –1-5. This analysis was conducted under an intensive monitoring program addressing the impacts of wild horses and livestock. This EA is a project specific refinement of the EIS focused on the management of wild horses in the Dogskin Mountain HMA. The Appropriate Management Level (AML for the Dogskin Mountain HMA was established through the allotment evaluation and FMUD process. The AML was set as a range.

The following decisions from the CRMP affect the Dogskin Mountain HMA:

1. Page WHB-2, decision 2- Maintain sound thriving populations of wild horses within HMAs.

2. WHB-3, decision 1 - Develop and implement an HMAP for the Dogskin Mountain HMA.

3. WDL-2, decision 4 – Maintain and improve wildlife habitat, including riparian/stream habitats, and reduce habitat conflicts while providing for other appropriate resource uses.

4. WDL-2, decision 5 – Maintain or improve the habitat condition of meadow and aquatic areas. Habitat condition for any wildlife species can be defined as the ability of a specific area to supply the forage, cover, water and space requirements of an animal. Habitat condition, therefore, is a measure of habitat quality, and is determined by assessments, surveys and studies.

5. WDL-2, decision 6 – Maintain or improve the condition of the public rangelands so as to enhance productivity for all rangeland values (including wildlife).

Relationship to Other Environmental Documents, Statutes and Regulations

The proposed action and alternatives are in conformance with the Wild Free-Roaming Horse and Burro Act of 1971 (PL 92-195 as amended); all applicable regulations at 43 CFR 4700 and policies; the Strategic Plan for the Management of Wild Horses and Burros on the Public Lands; and the Nevada BLM Revised Tactical Plan – Wild Free-Roaming Horses and Burros, Ensuring the Legend Lives Free. These documents are available for public review at the Carson City Field Office.

In June of 1992 the Director of the BLM signed the Strategic Plan for Management of Wild Horses and Burros on Public Lands. This document provides goals and objectives for the management of wild horses and burros including:

a.	Target specific age groups for removal.

b.	Target a specific sex for removal.

c.	Utilize fertility control techniques.

d. Nevada and Wyoming will use a selective removal strategy with fertility control that will assure that AML's are reached within a six-year time frame.

The authority for the proposed actions within this plan is contained in 43 CFR 4710.2, 4710.4, 4720.1, 4740.1, 4740.2 and the Wild Horse and Burro Act of 1971 (Public Law 92-195). In 43 CFR 4710.3-1 the authorized officer is directed to prepare Herd Management Area Plan (HMAP) for the management of HMA’s.

Because of the small size of the HMA necessitating a low AML fertility control will not be proposed for this HMA.

Other Activity Plans, Issues and Constraints

Existing Activity Plans have stated objectives and constraints relating to the HMA, and are summarized below.

1. Multiple Use Decisions 1993:

In 1993, a Multiple Use Decision (MUD) was issued for the Paiute grazing allotment, the HMA is situated completely within a pasture of Paiute grazing allotment. This decision divided the available forage between wildlife, wild horses and livestock. A specific Appropriate Management Level (AML) was set for the HMA, 10 –15 horses (180) AUM’s. Livestock were allocated 357 AUM’s for the pasture which includes the HMA. The pasture is larger than the HMA. This number was based on vegetation monitoring with the goal of achieving a thriving ecological balance between wildlife, wild horses, livestock and the vegetative community. Wildlife use within the allotment was adjudicated in accordance with the Lahontan RMP - 1984.

2. Range Program Summary Update 1989 (now incorporated into the CRMP):

a. Maintain utilization not to exceed 55% on key species on upland key areas (Range Program Summary Update 1989; RPS Update).

b. Improve ecological condition in 20 years by 1 condition class (RPS Update, 1989).

c. Maintain or improve willow and aspen stands to have at least 20% of all stems produce young over 5 feet (6 feet for aspen; RPS Update, 1989).

d. Limit utilization on meadows in identified sage grouse habitat to leave a minimum of 4" of growth by 15 September (RPS Update, 1989).

e. Limit utilization to 55% on current years growth on riparian areas (RPS Update, 1989).

f. Insure against adverse physiological stress to wild horses by monitoring water availability (RPS Update, 1989).

g. Maintain or improve wild horse habitat consistent with wildlife and livestock objectives (RPS Update, 1989).

h. Maintain or improve free roaming behavior of wild horses by protecting or enhancing wild horse home ranges (RPS Update, 1989).

i. Manage identified mule deer (Odocoileus hemionus) habitat to maintain a fair (26-50 rating) ro etter condition to support 181 deer 5/1 to 10/31 and 886 deer from 11/1 to 4/31, yearly, 1601 AUM’s reasonable numbers. Limit utilization to 455 on bitterbrush in habitat areas. Manage identified pronghorn (Antilocapra americana) habitat to maintain fair (31 points) or better condition. Limit utilization to 55% on key species in identified pronghorn habitat.

4. Allotment Management Plans:

The Paiute Grazing Allotment Plan was approved in 1989.

5. Wildlife Habitat Management Plan:

Dogskin-Virginia Mountain Wildlife Habitat Management Plan, 1977:

a. Provide 1601 AUMs of forage for deer within the Paiute Allotment.

b. Limit utilization on bitterbrush to 45% of current years growth.

c. Most riparian sites appear degraded. Reasons are several: over utilization of riparian vegetation by domestic livestock, wild horses and wildlife; use for firewood and as camping areas.

Generally the objectives of the HMP and this plan do not conflict, as there are few conflicts between the animals if the total utilization on key grass species is limited to 55% or less. However successful sage grouse nests (Centrocercus urophasianus), are surrounded by residual grass cover that is 18 cm or higher, measured as drop height, therefore, horse and livestock numbers may need to be reduced in order to provide nesting habitat for sage grouse.

II. PROPOSED ACTION

The Proposed Action and two alternatives, one of which is the No Action Alternative, are analyzed within this document and impacts identified. The description of all the alternatives is given below.

The Proposed Action is to achieve and maintain the HMA in a state of thriving natural ecological balance and multiple use relationship between the wild horse population, wildlife, livestock and the plant communities. The following are specific objectives of the proposed action.

A. Animal Objectives

Objective 1

Maintain the wild horses in good or excellent physical condition.

Management Method

Provide an adequate amount of forage for the individual horses in the population by adjusting the population of wild horses to a level in balance with the forage productivity of the habitat within the HMA (Habitat Objective 1 and requirements of wildlife and livestock). Based on the analysis of monitoring data under Habitat Objective 1, providing a proper amount of forage per animal would allow the animals to maintain themselves in a healthy condition, better able to withstand environmental fluctuations.

Prior to future removals current monitoring data will be analyzed to determine if the AML's set in the multiple use decisions are still appropriate. Future gathers may be postponed if current data indicates that the HMA can support an increased horse population.

Objective 2

Maintain the free-roaming nature of the wild horses.

Management Method

All projects proposed on BLM administered land within the HMA will be carefully evaluated through an environmental assessment process as to their effect on free-roaming behavior and movement of wild horses.

Objective 3

Maintain the wild horses within the HMA.

Management Method

Improve the habitat within the HMA and identify key habitat areas within the HMA through monitoring efforts. Maintain the fences along allotment boundaries where they form part of the HMA boundary.

During periodic population reductions, horses gathered outside of the HMA will not be released back into the HMA (to the extent possible) because they would likely return to the area from which they were removed (Waring 1979, Tyler 1972 and observations of released horses within the CCFO). Any wild horses located outside of the HMA would receive priority for removal.

Objective 4

Minimize the adverse effects of gathers to both the individual wild horses and the population.

Management Method

Maintain an interval between removals of at least 3 to 4 years. Managing the horse population within the range set through the MUD process would increase the time interval between captures, thereby reducing stress, injuries and deaths associated with capture operations.

Wild horse populations have an average rate of increase of between 14% and 24% annually (Garrott, 1990). From monitoring data, an annual growth rate of at least 19% can be expected under reasonable population levels in this HMA. By reducing the population of wild horses within the HMA to a point below the maximum number of wild horses that the habitat can support and allowing the population to build back up to the maximum level the next removal could be delayed for 3 to 4 years. The number of wild horses would not exceed 15 and would help achieve Habitat Objective 1.

Various forms of contraceptives (Strategic Plan) may be used to slow the rate of increase. However, due to the low number of horses that this HMA is capable of supporting contraceptives were not considered.

If wild horses were reduced to 15 individuals (the high end of the AML), gathers would need to be conducted yearly which would lead to frequent band disturbances and other forms of stress. Furthermore, yearly gathers would not be physically or fiscally feasible. Removal procedures are contained in Appendix 1. Maintain the wild horses population within the range of 10-15 individuals.

Utilize a helicopter to herd horses into corrals constructed out of portable steel panels. Other motorized equipment would also be used in the transport of captured horses.

Nursing mares or foals, which have become separated from their nursing mares, may need to be roped. However, based on past removals it is anticipated that less than 1 percent of the animals would require roping.

The Bureau of Land Management may contract with a private party for the removal operation. If a contractor is used he/she would be supervised at all times by Bureau employee(s).

Objective 5: Place only adoptable horses into the adoption program.

Management Action: To the extent possible only animals less than 10 years of age would be placed into the adoption program, other excess unadoptable horses would either be released into another HMA, placed into a sanctuary or released back into the HMA. However, during the next gather and possible subsequent gathers horses 5 and under would be placed into the adoption program, horses 6 through 10 would be released back into the HMA and older animals placed into a sanctuary, although some of the animals 6 through 10 may be removed if needed to reach AML.

Once the Bureau attains AML on a national basis, and gathers occur on a 3 to 4 year cycle AML’s would be maintained by only removing younger more adoptable and adaptable animals.

Place horses removed from areas outside of the HMA into the adoption program, sanctuaries or other HMA's regardless of age.

Objective 6: Maintain and improve riparian areas.

Management Action: Maintain the horse population at a level compatible with riparian objectives, in certain cases constructing enclosures around springs, seeps and creeks may be necessary.

Objective 7: Identify individual animals for population studies and to facilitate identification of animals illegally removed from the HMA.

Management Action: Using freeze- marking techniques, a unique number may be placed on the left hip of the animals that are to be returned to the HMA. These horses are restrained in a squeeze chute for ageing and blood drawing, by applying a freeze mark the animals would be restrained for an additional 90 to 120 seconds.

Objective 8: Track loss of heterozygosity and alleles.

Management Action: During periodic removals blood samples would be drawn from some of the captured animals for analysis. As with applying a freeze mark this action would only add 90 to 120 seconds of additional squeeze chute time for the horses identified to be sampled, and would result in negligible additional increases of stress.

Objective 9: Identify prevalence of distemper.

Management Action: During periodic removals nasal swabs maybe collected from some animals. As with applying a freeze mark this action would only add 90 to 120 seconds additional of squeeze chute time for the horses identified to be sampled, and would result in negligible additional increases of stress.

Objective 10:

Maintain genetic diversity.

Management Method

Animals from other HMA’s within this Field Office may be released into the HMA to allow for gene flow, thereby avoiding any deleterious affects of inbreeding resulting from small population size.

B. Habitat Objectives

Objective 1

Allow no more than 55% utilization on key grass species (Indian ricegrass, Idaho fescue, needle grass) and 40% on interim grass species (bottlebrush squirreltail and bluegrass) yearlong on previous years growth by March and maintain >18 cm of residual herbaceous cover in sage grouse nesting habitats.

Management Method

As stated (vegetation section) the present stocking rate over the entire HMA needs to be adjusted downward. Based on current data an adjustment of the horse population within the HMA is required. Average use During the 2004 – 2005 monitoring period was 80%, even at 55% use sage grouse nesting habitat would not attain > 18cm residual herbaceous cover.

Based on vegetative monitoring a reduction in horse numbers down to the AML is needed over the entire HMA.

Objective 2

Maintain 10 cm of grass cover on wet meadows by 15 September. Avoid excessive use of springs and riparian vegetation.

Management Method

As stated (vegetation section) the present stocking rate over the entire riparian heavy use areas needs to be adjusted downward. Based on current data an adjustment of the horse population within the HMA is required. Herbivore numbers need to be maintained at levels, which do not adversely impact the hydrology, soils or vegetation in riparian zones. Maintaining the populations at proper levels would be an important action, however, some areas would require fencing to maintain vegetation and function.

ALTERNATIVES

Alternative 1

Alternative 1 is identical to the proposed action with the exception that the population would only be reduced to the upper end of the AML.

No Action Alternative

The no action alternative would not include any of the objectives and management actions.

Alternatives considered but not analyzed

Herding from horseback and water trapping were considered, however, they are not feasible for this HMA. The only possible exception would be if a small number of horses became a nuisance on private property, such as alfalfa fields where a small strategically placed trap may be practicable.

III AFFECTED ENVIRONMENT

PROPOSED ACTION

General Setting

The HMA is located within the Dogskin Mountains median elevation is approximately 1,700m. The dominant vegetation consists of Utah juniper (Juniperus ostosperma), bottlebrush squirreltail (Sitanion hystrix), big sagebrush (Artemisia tridentata), Nevada ephedra (Ephedra nevadensis), Indian ricegrass (Oryzopsis hymenoides), Sandberg bluegrass (Poa secunda), Needle-and-thread (Stipa comata), desert needlegrass (S. specieosa), bluebunch wheatgrass (Agropyron spicatum), bitter brush (Purshia tridentata), and mountain mahogany (Cercocarpus ledifolius),

Critical Elements of the Human Environment

The following critical elements of the human environment are not present or are not affected by the proposed action or alternatives in this EA:

Air Quality

Areas of Critical Environmental Concern

Cultural Resources (trap site locations would be surveyed prior to construction, trap sites will be placed in areas devoid of significant cultural resources)

Environmental Justice

Farm Lands

Flood Plains

Hazardous Materials

Native American Religious Concerns

Paleontology (trap sites would be cleared prior to construction)

Wild and Scenic Rivers

Threatened or Endangered Plant Species (none known to exist within the HMA)

Threatened or Endangered Animal Species (none known to exist with the HMA)

Wilderness

Resources Present:

III A. Wildlife

The HMA includes habitat for mule deer, mountain lion (Felis concolor), sage grouse, prairie falcons (Falco mexicanus), golden eagles (Aquila chrysaetos), chukar partridge (Alectoris chukar), and many other species.

Spring snails may exist within the HMA this plan incorporates the Spring snail Conservation National Memorandum of Understanding and IB 99-156 by reference. Most bird species found within the HMA are protected under the Migratory Bird Treaty Act, in addition golden eagles are protected under the Bald Eagle Protection Act.

III B. Threatened or Endangered Animal species

There are no known threatened or endangered species found within the HMA. However, the Nevada Department of Wildlife (NDOW) is concerned that the sage grouse (a BLM Special Status Species) habitat may be deteriorating. A category 2 candidate species, the loggerhead shrike may nest in the area.

III C. Water Quality (Surface/Ground)

There is one perennial stream which generally flows above ground for approximately 1.5 km. Additionally there are several springs and seeps. Some of the springs will require protection because of excessive trampling caused wild horses and livestock (livestock have not been placed in this pasture for several years).

III D. Wetlands/Riparian

There is over use of riparian vegetation and springs have been degraded and are no longer in a state of thriving ecological balance. Some springs have had all of their associated riparian vegetation removed (heavy and severe use) and hoof action is compacting the soil, which could decrease or stop the flow of water. On spring system is protected by an exclosures designed to allow water to flow out under the fence.

III E. Migratory Birds

Many species of migratory birds inhabit the HMA, including blue birds, shrikes, night hawks, swallows, swifts, fly catchers, kingbirds, raptors, owls, hummingbirds, warblers, finches, juncos, wrens, sparrows, requiring diverse habitat types.

III F. Wild Horses and Burros

The HMA contains approximately 6,895 acres of public and private land. The AML range for the HMA is 10 to 15. At the present time, the wild horses have unrestricted movement within the HMA and due to fence failure some horses have moved outside of the HMA and are now inhabiting adjoining allotments. Some of the wild horses now using areas outside of the HMA, as all or part of their home range. This is primarily due to an increase in the population beyond that which the HMA can support. The population is estimated to be over 100 animals. An estimated 6 wild horses (Appendix 4) occupied the HMA in 1971, after the passage of the Wild Horse and Burro Act. The AML range is 10 – 15.

III G. Invasive, Nonnative Species

No known noxious weeds occur within the HMA, however, Scotch Thistle (Onopordum acanthum), yellow star thistle (Centaurea solstitialis), hoary cress (whitetop; Cardaria draba), and perennial pepper weed (tall whitetop; Lepidium latifolium) are all found very near the HMA.

Other Resources Present:

III H. Livestock Use

The HMA lies within a pasture of the Paiute Grazing Allotment, however this pasture has not been grazed for several years due to the over use caused by excessive wild horses.

III I. Recreation

Traditional forms of recreation such as sightseeing, driving for pleasure on roads and ways, camping, hunting, hiking, photography and nature study are common activities within this HMA.

III J. Soils and Vegetation

Precipitation within the HMA is low, averaging 20 cm per year. The soils within the HMA exhibit wide ranges of depth, drainage class, percent surficial and subsurface rock fragments, pH, and other diagnostic soil properties. For detailed site specific soil descriptions see Washoe Co. Soil Survey, South Part, USDA-SCS.

Two major range sites (026XY 020NV & 026XY 018NV) dominate the HMA and are described below:

Sandy 20 – 25 cm precipitation zone. (026XY 020NV)

1. Associated species: needle – and – thread, Indian ricegrass, Thurber needlegrass, desert needlegrass, and Wyoming big sagebrush.

2. Occurs on alluvial fans, with slopes ranging from 2 – 30 percent at elevations from 1,372m to 1,829m.

3. Soils are deep, moderately deep, and excessively drained.

4. Annual production in average years is 182 kg to 364 kg / acre.

Shallow Granitic Upland 25 to 30 cm precipitation zone (026XY 018NV)

1. Associated species: desert needlegrass, Thurber needlegrass, bottlebrush squirreltail, antelope bitterbrush, Wyoming big sagebrush and green ephedra.

2. Occurs on foothills and mountain slopes in association with granitic rock outcrops. Slops are generally from 15 to 50 percent. Elevations range from 1,524 to 1,828 m.

3. Soils on this site are shallow to bedrock and excessively drained. The available water capacity is very low. The shallow rooting depth and excessive drainage are the most limiting factors in the development of this site.

4. Annual production in normal years is 182 to 364kg / acre.

III K. Visual Resources

The proposed plan would take place on lands managed under Class III Visual Resources management (VRM) objectives. In a Class III area the objective is to partially retain the existing character of the landscape. The level of change should be moderate. Management activities may attract attention but should not dominate the view of the casual observer. Changes should repeat the basic elements found in the predominant natural features of the characteristic landscape.

IV. ENVIRONMENTAL CONSEQUENCES

Proposed Action

IV A. Wildlife

Managing horses within a range of 10 to 15 (total utilization <= 55%) would have positive impacts on wildlife by insuring adequate forage and space for wildlife species. This horse level would help in providing habitat requirements for wildlife.

During capture operations, the helicopter will be operated in a manner to avoid any golden eagle aeries.

IV B. Threatened or Endangered Animal Species

There are no known threatened or endangered animal species within the HMA.

IV C. Water Quality (Surface/Ground)

By managing the horse population within the AML range water quality would be improved and the need to construct protective exclosures would be lessened but not eliminated.

IV D. Wetlands/Riparian

As horses obtain water the resultant mechanical action of their hoofs compacts the soil stressing and sometimes killing native vegetation, creating sites conducive for establishment by nonnative invasive species. Also, as the number of horses increases sites around water sources including riparian vegetation sustain greater use. The more palatable riparian species sustain greater use while the less and unpalatable species benefit from less competition and tend to dominate riparian areas, reducing the value to wildlife.

Managing horses between 10 to 15, a level which can be maintained by the vegetation (<= 55% total use) compatible with other uses (wildlife & livestock grazing) would result in the vegetative community being maintained or improved. By reducing and limiting the horse population some riparian areas would recover naturally, however, some riparian areas would require protection in the form of enclosures to recover and maintain the vegetative diversity associated with them and required by a plethora of animal species. During years of lower population levels the vegetation may incur benefits associated with less grazing pressure and disturbance to horses associated with removal operations would be minimized.

Riparian areas would be improved under the Proposed Action or all Alternatives other than the No Action Alternative. By maintaining the horse population at a level compatible with the ability of riparian vegetation to resist the deleterious effects of grazing riparian vegetation would improve, decreasing erosion. Establishment of noxious plant species will be inhibited by achieving and maintaining a healthy riparian plant community.

IV E. Migratory Birds

By managing the herbivores (horses and livestock) so that the vegetation is maintained at levels stated in the CRMP, Sierra Front Northwestern Great Basin Area Standards and Guidelines, habitat requirements for most species of migratory birds would be expected to be improved. Riparian areas, including wet meadows and other areas providing herbaceous vegetation, such as aspen groves, rose and willow thickets are crucial to many migratory birds because these areas provide nesting and foraging sites. Many species of migratory birds rely on the insects and other invertebrates associated with riparian vegetation.

Sagebrush, grasslands, mountain mahogany, pinyon pine and juniper communities also provide important nesting and foraging areas for migratory birds. Some migratory birds are sagebrush obligates including sage grouse, sage sparrow (Amphispiza belli) sage thrasher (Oreuscoptus montanus) and vesper sparrow (Pooecetes gramineus). These various species of birds (and others) require sagebrush for all or part of their life history. However, the specific sagebrush habitat requirements differ widely between species, for example sage grouse require nesting habitat with residual grass cover of 18 cm or more and pre-nesting and brood rearing habitat with a mix of forbs and grasses interspersed between sagebrush which generally equates to sagebrush canopy cover between 15 to 25 percent. However, sage thrasher, require thick relatively tall (1 m) sagebrush for nest concealment. Therefore, to manage for all sagebrush obligates (including reptiles and amphibians) various types of sagebrush communities need to be managed for throughout the landscape on large scales.

Maintaining and recreating some of these conditions would likely require further management of herbivores, and may require reductions in grazing use in sage grouse nesting habitat or riparian areas.

All actions as a result of this plan will be done in compliance with Executive Order 13186, Responsibilities of Federal Agencies to Protect migratory Birds.

IV F. Wild Horses and Burros

The main issue with this HMA involves the propensity of the horse population to increase at relatively high rates (15 - 20% annually). Few adult horses or foals within this HMA succumb to predation the only “natural” population regulating mechanism would be the availability of forage. However, before the horse population would be limited many native species of wildlife would have been eliminated from the HMA and surrounding area. Also, many native plants would have disappeared facilitating the establishment and expansion of non-native noxious weeds. When unchecked a population of horses can have devastating effects on native vegetation, wildlife and the livestock industry

By managing the population of horses within the AML range a healthy population would result, insuring the persistence for generations to come.

From analysis of monitoring data it was determined that 15 horses are the maximum that the HMA can support while maintaining thriving natural ecological balance between vegetation, horses, wildlife and livestock. In order to minimize the stresses and disruption of band structures the population of wild horses would be reduced below 15 and allowed to increase back to 15. Based on recent rates of increase (19% annually) the population would need to be reduced to 10 animals in order to maintain acceptable utilization levels during gather intervals.

Managing horses between 10 - 15 a level, which can be maintained by the vegetative community with other uses, would minimize the stresses to the individual horses associated with limited food and space resources. Minimizing the stresses would be especially important to the young animals. Managing the population in a way that maximizes the intervals between removals minimizes the stresses associated with removals. Managing horses in harmony with their habitat and maximizing intervals between removals would result in only positive benefits (i.e. reduced stresses to the animals and a healthy vegetative community). Furthermore, it is not physically or fiscally possible to capture horses in the same HMA every year. If horses were allowed to increase above the AML, resource damage would occur adversely affecting the vegetative community, wildlife community, horse population, livestock producers and recreationalists who would be disappointed in seeing degraded communities lacking species diversity.

Managing the wild horses within a range (i.e. 10 - 15) would require that the population be reduced below the maximum allowable population level (15). A healthy viable population would be maintained.

Reducing horses below the maximum number (AML) that the habitat can support in concert with the other uses (i.e. wildlife and livestock grazing) would reduce the stress of gathers by allowing an interval of approximately 3 to 4 years between gathers.

The release of unadoptable horses from other HMA’s would tend to increase allelic diversity and would be expected to compensate for alleles lost by stochastic events thus maintaining heterozygosity. Furthermore, introduction of new genetic material would aid in maintaining and increasing the natural variability of the population. All impacts would be positive.

Prior to the extirpation or near extirpation of the ancestral horses (Asia) from which the domestic breeds were derived and consequential feral horse populations, the progenitor wild horses were likely distributed in large out breeding populations. However, for a variety of reasons present day feral horses cannot be managed in large populations due to land use practices, and vegetative constraints on population size. In addition, the Wild Horse and Burro Act, limited management of “wild” (feral) horses to the geographic area which they inhabited in 1971. However by moving animals between HMA’s we can in a genetic sense link the HMA’s creating a large outbreed population of horses.

During periodic removals, animals captured from areas outside of the HMA would either be placed into the adoption program, released into other HMA's or released back into the HMA as far from the point of capture as possible. However, horses are likely to return to their home ranges after release (Tyler 1972, Waring 1979 and post release census flights). Therefore, releasing animals back into the HMA would only be done when other alternatives are not practical or available.

Discussion has occurred regarding the appropriate sex ratio for free ranging populations of horses. It is intuitively obvious that fewer excess animals would result from biasing a population to favor male animals, however, some individuals have asserted (without any data to substantiate their claims) that if the percent of males surpasses some threshold civil unrest would occur resulting in increased aggression between males as they now must divide up fewer females between them. Based on 70 years of collective experience managing free roaming horses in this field office we doubt the before mentioned scenario, once horses have established a hierarchy few subsequent bouts of aggression occur. In any “natural” population of feral horses the majority of males will not control harem bands, they will be found either singularly or in small loosely knit bands. We believe that biasing a population to favor males would result in smaller harem bands and more and or larger bachelor bands, which would not adversely impact the social structure of the population with the only effects being positive, fewer animals would need to be removed and placed into the adoption program and the duration between gathers may be increased. Unfortunately we do not have any data to substantiate our assertion therefore, we did not consider this option for an alternative.

Within the Carson City Field Office 3,665 (49.5%) female wild horses have been removed and 3,732 (50.5%) male horses have been removed (wild horse and burro data base). Thus, the gather data suggests a slight bias, favoring males; in addition, during gathers a disproportionate percentage of females are collected due to the inherent biases of the gather techniques. Male horses are found in smaller bands or singularly, decreasing their rate of delectability also bachelor bands do not herd as effectively as harem bands. Because pilots contracted to gather horses are paid per horses captured they focus on harem bands thus, to a certain extant ignoring bachelor bands, resulting in a biased sex ratio at the trap site.

Unfortunately we do not have any data on the magnitude of the trap site bias. However, intuitively one would suspect a greater percentage of male horses than female horses in a “natural” setting. This bias would result from greater number of females dieing after birth due to the increased stresses of reproduction and lactation including parturitions gone terribly bad, resulting in the death of the mare. A mare must divert a substantial amount of energy to produce a foal and ensuing lactation for the next year or more, increasing her susceptibility to adverse environmental conditions and predation by mountain lions.

Male horses while they control a band also undergo increased stresses compared to their bachelor cohorts. However, due to the keen competition for females, harem-controlling males will generally loose control of harems long before their physical condition is compromised to a dangerous level. Thus, the sex ratio is not at parity and males tend to accumulate in the population. Therefore, we contend that biasing the sex ratio to favor males would not be “unnatural” and have only positive effects for the population and the taxpayer.

Removing young animals would result in removing only readily adoptable animals (young animals) and slow the rate of increase. However, for the next 1 or 2 removals it is expected that some older animals would need to be removed in order to attain AML, these horses would be placed in sanctuaries. Once AML is reached and removals occur approximately every 4 years a minimal number of animals would need to be placed into the adoption program and the interval between gathers could be maximized. Leaving the older horses (10 years and older) in the population would preserve the genotypes that have proved most adapted to the free roaming existence.

A program developed by Stephen Jenkins (WinEquus, version 1.40, April 2002) was used to compare possible outcomes of various management scenarios designed to provide individuals interested in population dynamics an understanding of possible population responses to various management strategies was run for the targeted population levels of this HMA using several scenarios, namely: removals only, and no management. Dr. Jenkens does make the disclaimer that this model should not be used to make management decisions, the intended use is to convey a range of possible population responses to certain perturbations. These different scenarios provide a forecast regarding the number of expected excess horses in the future, which would be considered when selecting the preferred alternative and described in appendix 3.

Under the removal only scenario the median population size over 21 years was 16 and the median number of animals removed was 45 exclusive of the number required during the first removal. Under the no management scenario the median population size was 100 with an ending median population of 226 and a highest trial population of 913. Obviously the HMA could not sustain a population of 100 horses much less a population of 913. Before the population reached these levels the HMA would have been converted to a veritable desert with noxious weeds and juniper trees the only remaining vegetation, most species of native wildlife would have disappeared and the allotments involved would no longer be capable of supporting livestock.

Additionally a scenario of only reducing the population to the upper AML level was examined. Obviously under this scenario with the birth of the first foal post removal the HMA would be over AML, thus over stocked. The AML range was designed to prevent over stocking and the problems associated with over stocking. Under the removal only scenario where the population was only reduced to the upper AML the median population size over 21 years was 20 and the median number of animals removed was 60 exclusive of the number required during the first removal.

Clearly maintaining the population within the AML range results in fewer total animals removed over the 20 year time frame.

Results from Dr. Jenkens’s model:

Table 1. Rate of Increase and Median number of horses removed under the different alternatives.

Alternative	Median Pop. Size	Rate of Increase	Median # Removed 20 yr.
Proposed Action, Removals	16	18.3%	45
Alternative 1. Removal Only to Upper AML.	20	18.8%	60
No Action1	100	19.0%

1At the end of 20 years the median population was 100, however, the median maximum was 226 and the highest trial was 913 animals.

See appendix 3 for population parameters and more detailed results.

IV G. Invasive, Nonnative Species

The establishment and spread of invasive nonnative species would be discouraged by maintaining a healthy native vegetative community which would only be possible by maintaining the horse population within the AML range, and responsibly manage livestock numbers and season of use.

Other Resources Present:

IV H. Livestock Use

By managing horses at the identified levels forage would be available for grazing by livestock which would help meet RMP objectives and would allow a thriving ecological balance to be obtained and maintained between the vegetative community, wildlife, horses and livestock. This would result in positive impacts. The vegetative community, horse populations and wildlife populations would be stabilized. It is anticipated that after the reduction the utilization would decrease to 55% on key species. Horses that are removed would be placed into private maintenance through the Bureau's Adopt a Horse Program, sanctuaries or other HMAs.

IV I. Recreation

As the habitat improves, the esthetics would improve as would most wildlife populations, increasing the overall recreational experience.

IV J. Soils

By maintaining a healthy plant community soil infiltration, runoff, and erosion would remain within site parameters.

IV K. Visual Resources

As the habitat improves as a result of plan implementation there may be minor improvement to the visual resources of the HMA. In general however, there would be no significant impacts to visual resources. The proposed action would not substantially alter the existing visual character of the landscape and would meet Class III VRM objectives.

ALTERNATIVES

Alternative 1

Alternative 1 is identical to the proposed action with the exception that the population would only be reduced to the upper end of the ALM, however, with the birth of the first post gather foal the population would be over AML and the horse population would not be in a state of thriving natural ecological balance. However, due to budgetary constraints this alternative may need to be selected. The horse population would be over AML, however, the numbers would be substantially less than the current numbers and there would be improvements within the vegetative community, though not as great as would be expected under the proposed action. It is expected that alternative 1 would only be selected for the first gather implemented under this plan and that the horse population would be reduced to the lower AML during subsequent gathers/removals implemented under this plan.

All resources would be substantially improved over the current situation, although some long-term effects may return as the population increases.

No Action Alternative

The No Action Alternative would not include any of the objectives and management actions. The wild horses would not be maintained at a level compatible with their environment, and would continue to increase. Eventually all or most riparian areas would be destroyed resulting in the loss of many native species of animals and plants, the upland grasses would also be removed resulting in the loss of many other species of animals including sage grouse. As the grasses become over grazed sagebrush and other woody plants become dominant, also as the native vegetation, both riparian and upland grasses become stressed by over grazing invasion by non-native weeds is facilitated, both the encroachment of woody plant species and establishment of invasive weeds may be irreparable, potentially changing the range site for many decades, certainly longer than any of our planning horizons.

The vegetation (quantity, quality and species evenness) would eventually decrease to a point, which could no longer support the horse population. At this point a large proportion of the horse population would die along with wildlife and livestock. However, prior to the population crash the habitat would have deteriorated, and undesirable exotic invader species such as halogeton (Halogeton glomeratus), cheatgrass (Bromus tectorum) and Russian thistle (Salsola kali) would have established themselves over large areas. Thus, the HMA's capacity to support horses would now be only a small fraction of its current potential capacity and it would take many decades of low or no grazing pressure and tremendous vegetative manipulation at a huge cost for the HMA to recover to its former potential carrying capacity. The no action alternative would also preclude attainment of wildlife, soil, water and livestock objectives in the RMP and advance the need to list the sage grouse as a threatened or endangered species under the Endangered Species Act.

Habitat improvement would not be realized with this alternative. The frequency of key species would decline. The animals would continue to search for food and further degrade their habitat, thereby reducing the carrying capacity of the area, which would eventually lead to unacceptable adverse physiological stress to the horses and degraded vegetation condition.

Over utilization within and outside of the HMA would continue to occur and as the range becomes further deteriorated the carrying capacity of the HMA and allotments would be reduced. The objective of limiting utilization to 55 percent or less would never be met. Downward trend would occur, and ecological condition would decline. In the long-term, the excessive utilization would eliminate nearly all the forage plant species. Attainment of RMP objectives would not be met.

Further deterioration of the range would occur and the area would not be in a state of thriving ecological balance between wild horses, wildlife, vegetation and livestock. Also, potential watershed impacts could have adverse effects on Lahontan cutthroat trout.

Resources would be adversely affected compared to the Proposed Action or Alternatives 1 as the vegetative community would sustain substantial over use.

Mitigating Measures

Under the Proposed Action or the Alternative1, no mitigation is necessary. Under the No Action Alternative, no mitigating measures are practical.

Cumulative Impacts

Cumulative impacts are impacts on the environment, which result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively major or problematic actions taking place over a period of time.

Past, proposed and reasonably foreseeable actions that may have similar effects to the Dogskin Mountain HMA horse population would include past removals and future removals. Two removals have been completed in the past, and future gathers and removals would be scheduled according to a 3-4 year gather cycle. Should the Proposed Action be implemented the horse population would be maintained at a level compatible with the vegetative community and other uses, a thriving natural ecological balance would be achieved. Should Alternative 1 be selected the horse population would be over AML with the birth of the first post removal foal, however, the adverse impacts to the vegetative community would be substantially less than the no action alternative. Due to budget constraints Alternative 1 may be selected for the first removal action of this plan. Cumulative effects of both the Proposed Action and Alternative 1 would include continued improvement of the range condition, and riparian-wetland condition. Additional cumulative beneficial effects from implementation of the Proposed Actions or Alternatives 1 to wildlife, the horse population and domestic livestock would occur as forage availability and quality is maintained and improved. Water quality and riparian habitat would also continually improve. .

Adverse cumulative impacts, would occur if the No Action Alternative is implemented, these effects would include continual over utilization of vegetative resources, which would result in decreased vegetative density, plant vigour, seed production, seedling establishment, and forage production. This would ultimately result in decreases of the ecological status of plant communities.

With continued over use on upland sage grouse habitat a negative adverse cumulative impact to this species would occur. Wildlife, migratory birds, and horses would all be negatively affected by these adverse cumulative impacts to natural resources.

Wild horses would continue to expand onto private lands and other areas outside of the HMA negatively impacting private property.

Based upon these considerations, the effects of other existing and reasonably foreseeable future activities including the Proposed Action and Alternative one, would not cause a major affect to the environment. The No Action Alternative would continue8 to cause impact to the environment.

There would be no known adverse cumulative impacts to any of the resources analysed in this document as a result of the Proposed Action or Alternative 1.

Monitoring

A. Animal Studies

The studies described below are designed to monitor the attainment of the specific management objectives developed for this HMA.

1. Actual Use

Need: It is necessary to continue collecting data on the number and kinds (wild horses, wildlife and livestock) of animals, which are utilizing the forage within the HMA in order to make quantifiable decisions with regard to wild horse, cattle and wildlife numbers by season of use.

Method: Helicopter censuses would be the method used to estimate the wild horse population in conjunction with on the ground identification of individual animals. These censuses would occur at 3-year intervals or less. Actual use by wild horses would be derived from population estimates.

2. Demography

Need: Data are needed on the foaling rate of mares and the survival rate of foals and adults

in order to determine the rate of increase. Also data on the sex and age structure of the herd is needed.

Method: Capture data, ground and aerial observations will provide baseline data. This will aid in determining the efficacy of different management strategies. Data will be analyzed using baseline parameters specific to this HMA where applicable. Age structure and annual rates of increase have been obtained from past gathers and aerial census. Also, age specific mortality and fecundity rates may be obtained from published data (Feist 1975; Wolfe 1980, 1989; Eberhardt 1982; Seal 1983; Siniff 1986; Garrott 1990a, 1990b, 1991a, 1991b, 1991c, 1991d; Eagle 1992).

3. Genetic Diversity

Need: Data are needed to monitor the genetic diversity of the herd.

Method: As the animals are aged blood samples will be drawn and later analyzed by a private contractor in order to monitor changes in allelic frequencies in accordance with the Gather Policy and Selective Removal Criteria for Wild Horses, Washington Office IM 2002-095. Minimum sample size is 25% of the upper end of the management range or a minimum of 25 samples, though no more than 100 samples will be needed from any one HMA. A veterinarian or other trained personnel would collect the blood samples.

4. Characteristics

Need: Data are needed regarding the historical physical characteristics of the herd.

Method: During the sorting of captured animals color and size would be recorded. The general characteristics would also be noted. Also, incidence of undesirable genetically determined traits, such as albinism, and club feed etc., will be documented.

5. Condition Class

Need: The physical condition of the animals is needed to assess overall herd health.

Method: The condition class would be recorded using the Henneke System for those animals that are exceptions to the average, such as noticeably thin, or fat.

B. Habitat Studies

The Lahontan Resource Area Vegetation Inventory of 1980-1982 collected the following data on ecological condition classes for sites in the Paiute Grazing Allotment other than woodland and seedings.

Table 2. Percent Ecological Condition

Allotment	Early Seral	Mid Seral	Late Seral	PNC*
Paiute	24%	71%	5%	0

*Potential Natural Community (PNC)

The selection of studies methodology and key area/key species to which these studies are correlated was made in accordance with procedures established in the Nevada Rangeland Monitoring Handbook (NRMH) and the District's Monitoring Plan.

1. Utilization

Implementation of Habitat Objective 1 would require maintaining utilization levels at or below 55% on key grass species (Indian rice grass, needlegrass and Idaho fescue; level recommended in the Nevada Rangeland Monitoring Handbook), and to 40% on bottlebrush squirreltail and Poa. Ten centimeters or more on wet meadows, to meet riparian objectives in riparian areas and18 cm or more in sage grouse nesting habitat. 18 cm or more in sage grouse nesting habitat and

Need: To determine the amount of use (degree of utilization) attributable to wild horses,

livestock and wildlife.

Method: Utilization studies would be conducted prior to cattle turnout in dual use portions of the HMA. In addition to this, utilization data would be collected on the entire HMA at the end of each livestock- grazing season. All utilization studies would be done using the Key Forage Plant Method. Each point where a utilization transect is run would be considered a study area and the location would be shown on the appropriate topographic map. (Outlined in BLM Handbook TR4/ 400-3 p. 11). Use pattern maps would then be constructed from these studies, showing relative areas and intensity of utilization.

2. Trend

Need: Trend refers to the direction of ecological change or forage condition. It indicates whether the rangeland is moving toward or away from its potential or specific management objectives.

Method: Frequency transects at key areas are read every 5 years.

3. Ecological Status

Need: Ecological status is determined by the present state of the vegetation and soil

production of an ecological site in relation to the potential natural community for that site.

Ecological range condition would be measured for each key area following MH 4400-1

guidelines (Natural Resource Conservation Service Range Handbook) to assure progress towards desired seral stages.

Method: Once key species are identified a key area condition transect would be done. Key area condition transects would be re-evaluated upon measurement of a statistically significant change in frequency data. These results would be evaluated to determine change in frequency data (trend). Furthermore, results would also be evaluated to determine if the appropriate objectives have been realized. (Refer to Nevada Rangeland Monitoring Handbook p. 13).

Evaluation

All adjustments in livestock and wild horse use in the Dogskin HMA would be based on rangeland monitoring. Monitoring information would be collected and evaluated on a yearly basis in accordance with the Nevada Rangeland and Monitoring Task Force recommendations.

Utilization results and use pattern maps would be analyzed to determine if Habitat Objective 1 is being achieved. Actual use would be used in conjunction with utilization data in revision of the numbers in the plan. Horse and cattle numbers may be adjusted either + as utilization results indicate. Cattle adjustments would be based upon monitoring as described in the AMP's specific for each allotment. Future Multiple Use Decisions may amend the numbers specified in this plan.

Riparian areas provide critical habitat to many species of wildlife and wet meadows for young sage grouse. Riparian areas comprise less than 5 percent of the habitat in Nevada though these areas are critical for over 90 percent of the species during some part of their life history.

The ultimate aim for horse management is the attainment and maintenance of a thriving “natural” ecological balance between the vegetative community (uplands and riparian) and the herbivorous including wildlife and livestock. To these ends herbivore management is constrained by the ability of the vegetative communities to resist the adverse effects of grazing.

Depending on specific situations the limiting components could be upland vegetation or riparian vegetation. Livestock and to a lesser degree horses tend to seek out riparian areas in the hot months, often compacting the soil and removing excessive amounts of vegetation.

Residual grass cover of 18cm or more is an essential component for good nesting success of sage grouse. While the grass community likely could be maintained at utilization levels which remove more then 18cm of residual growth, in sage grouse nesting habitat 18 cm of residual growth would be the limiting factor in herbivore management. Likewise in many situations the upland vegetation may be able to cope with herbivory levels that are detrimental to the riparian communities, therefore the utilization on riparian vegetation would be the driving factor in determining herbivore numbers.

Adjustments in wild horse numbers would be based on the results of utilization studies (III. B. 1.) with the objective of limiting total vegetation use within the HMA to 55 percent or less on key species and 40 percent on interim species in upland areas and leaving 18cm or more of residual grass cover in sage grouse nesting areas.

The Range Program Summary Update of 1989, provided specific objectives for riparian management which are still valid and include managing riparian areas to achieve and maintain late-seral ecological condition and limit utilization to 55% of current years growth and limit utilization on meadows in identified sage grouse habitat to leave a minimum of 10cm of growth by 15 September. Maintain or improve willow and aspen stands to have at least 20% of all stems producing young over 1.52m (1.83m for aspen in height), and stream bank vegetation utilization not to exceed 30%.

By maintaining the vegetative communities in a healthy state availability of ample forage resources would be assured for all of the herbivores thus the horse population would be maintained in a healthy state in balance with the vegetative, wildlife (including migratory birds) and livestock communities.

The formula for calculating proper use:

Actual use (AUMs) = Potential Actual Use (AUMs)

Average/Weighted Desired Average Utilization

Average Utilization

When total utilization increases above 55 percent on key species and 40 percent on interim species, or when sage grouse habitat objectives or riparian objectives are not attained a gather would be conducted to bring the wild horse population to a level consistent with management objectives (see also II., A., objective 4.).

Horses that have established home ranges outside of the HMA would be removed as soon as is practical.

Results of the soil monitoring studies would also be used as an indication of attainment of Habitat Objective 1 and 2.

Helicopter censuses would be the method used in identifying the need for removals in accordance with Animal Objective 1.

Young/adult ratios may indicate that removals need not be as frequent as estimated or they may indicate that more animals need to be removed or contraceptives employed.

Animal distribution and use pattern mapping would be used to reevaluate important water sources.

Prior to future removals current monitoring data will be analyzed to determine if the AML’s set through the multiple use decision process are still appropriate. Future gathers may be postponed if current data indicates that the HMA can support an increased horse population. Also, future gathers may decrease the horse population below the minimum AML if current monitoring data indicate that the AML is too high for current range conditions.

Modification

This plan may be modified if data from studies and experience indicate that changes are desirable. Also, animal numbers and ranges may be modified through Multiple Use Decisions, which would result from ongoing monitoring.

V. CONSULTATION AND COORDINATION

List of Prepares:

John Axtell, Project Lead/Wild Horses

James M. Gianola, WH&B Program Lead

Peggy Waski, Cultural Resources

Terry Knight, Recreation, Visual Resources

Walt DeVaurs, T&E Species, Wildlife

Pete Raffetto, Range Resources

James DeLaureal, Soils/Invasive Non-Native Species

Jim Schroeder, Water Resources

Terri Knutson, Environmental Coordinator

Persons, Groups or Agencies Consulted:

This draft HMAP update / Capture Plan and EA update has been sent to the following persons, groups and government agencies in order to solicit comments.

American Horse Protection Assoc.

American Humane Association

American Mustang and Burro Assoc.

Andrea Lococo

Animal Protection Institute

Barbara Flores

Bob Marshal

Craig C. Downer

Elaine Letcher

Fund for Animals

Gary McCuin, Agriculturist

Joanne Hardesty

Joe Dahl

Mace Bergmann

Marge Sill

National Wildlife Federation

Nevada Cattlemen's Association

Nevada Commission for the Preservation of Wild Horses

Nevada Department of Wildlife, Region I.

Nevada Humane Society

Nevada State Clearinghouse

Nevada State Division of Agriculture

Nevada State Grazing Board

NORA

Office of Cong. Gibbons

Office of Sen. Ensign

Office of Sen. Reid

Paul Clifford

Rebecca Kunow

Resource Concepts Inc.

Roberta Royle

Sharon Crook

Sierra Club, Toiyabe Chapter

The Mule Deer Foundation

The Sierra Club

U.S. Fish and Wildlife Service

U.S. Humane Society

Wild Horse Organized Assistance

VI. APPENDICES

Literature Cited

Allendorf, F.W. and N. Ryman. 2002. The Role of Genetics in PVA. Pages 50-85 in S.R.

Beissinger and D.R. McCullough, editors, Population Viability Analysis. The University of Chicago Press, Chicago and London.

Bowling, A.T. Wild horse parentage and population genetics, Final Research Report to USDI, BLM.

Bowling, A.T. and R.W. Touchberry 1990. Parentage of Great Basin feral horses. J. Wildl. Manage. 54(3):424-429.

Caughley, G. 1977. Analysis of vertebrate populations. John Wiley and Sons, New York, N.Y. 234pp.

Eberhardt, L.L., A.K. Majorowicz and J.A. Wilcox 1982 Apparent rates of increase for two feral horse herds. J. Wildl. Manage 46(2):367-374.

Eagle, T.C., E.D. Plotka, R.A. Garrott, D.B. Siniff and J.R. Tester 1992. Efficacy of chemical contraception in feral mares. Wildl. Soc. Bull. 20:211-216.

Falconer, D. S., and T.F C. Mackay 1996. Introduction to quantitiative genetics. 4th editioh. Lhngman, London, United Kingdom.

Feist, J.D. and D.R. McCullough 1975. Reproduction in Feral Horses. J. Reprod. Fert,. Suppl. 23:13-18.

Garrott, R.A. 1990a. Demography of feral horse population in the western United States, PhD. Thesis Univ. Minn. 130pp

Garrott, R.A. and L. Taylor 1990b. Dynamics of a feral horse population in Montana. J. Wildl. Manage. 54(4):603-612.

Garrott, R.A., D.B. Siniff and L.L. Eberhardt 1991a. Growth rate of feral horse populations. J. Wildl. Manage. 55(4):641-648.

Garrott, R.A., T.C. Eagle and E.D. Plotka 1991b. Age-specific reproduction in feral horses. Can. J. Zool. Vol. 69.

Garrott, R.A. 1991c. Feral horse fertility control: potential and limitations. Wildl. Soc. Bull. 19(1).

Garrott, R.A. 1991d. Bias in aging feral horses. J. Range Manage. 44(6):611-613.

Garrott, R.A. and D.B. Siniff 1992. Limitations of male-oriented contraception for controlling feral horse populations. J. Wildl. Manage. 56(3):456-464.

Hansen, Michael C., 1982. Diets of mule deer, pronghorn antelope, California bighorn sheep, domestic cattle, and feral horses in northwestern Nevada. Unpublished report to cooperators 45pp.

Lande R. 2002, Incorporating Stochasticity in PVA. Pages 18-40 in S.R. Beissinger and D.R. McCullough, editors, Population Viability Analysis. The University of Chicago Press, Chicago and London.

Natural Resources Council, 1991. Wild horse populations: field studies in genetics and fertility, National Academy Press, Washington, D.C. 41pp.

Ralls, K., and J.D. Ballou. 1983. Extinction: lessons from zoos. Pages 164-184 in C.M. Schonewald-Cox, S.M. Chambers, B. MacBrysde and W.L. Thomas, editors, Genetics and conservation: a reference for managing wild animals and plant populations. Benjamin/Cummings, Menlo Park, California.

Seal, U.S. and E.D. Plotka 1983. Age-specific pregnancy rates in feral horses. J. Wildl. Manage. 47(2):422-429.

Siniff, D.B., J.R. Tester and G.L. McMahon 1986. Foaling rate and survival of feral horses in western Nevada. J. Range Manage. 39(4):296-297.

Tyler, S.J. 1972. The behaviour and social organization of the New Forest ponies, In Animal Behaviour Monographs Eds., Cullen, J.M. and Beer C.G., Oxford England pp 87-196.

Wolfe, M.L. 1980. Feral horse demography: a preliminary report. J. Range Manage. 33(5):354-360.

Wolfe, M.L., L.C. Ellis and R. MaCmullen 1989. Reproductive rates of feral horses and burros. J. Wildl. Manage. 53(4):916-924.

Waring, G.H. 1979. Behavioral adaptation as a factor in the management of feral equids in symposium on the ecology and behavior of wild and feral equids, Univ. of Wyoming Laramie pp. 85-92.

Appendix 1, Minimum Viable Populations

Many species of vertebrates suffer from the deleterious effects of inbreeding depression if the population size is small and isolated. Inbreeding depression is manifested as decreased individual fitness and population growth rate (Ralls and Ballou 1983; Falconer and Mackay 1996). “Based on estimates of mutability in quantitative characters (Lande 1976; Lynch 1988), Franklin (1980) and Soule (1980) recommended a minimum Ne of 500 to maintain typical levels of heritable variance. Recent experiments indicate that a large fraction of the mutational variance in quantitative characters is associated with recessive lethal and semi-lethal side effects such that the quasi-neutral, potentially adaptive fraction of mutational variance is about one-tenth as large as previously thought (Mackay et al. 1992; Lopez and lopez-Fanjul 1993a,b). Lande (1995) suggested that the Franklin-Soule number should be increased by a factor of ten.” (Lande 2002).

“Recent considerations of this problem have led to the recommendation that an effective population size (Ne) of approximately 1,000 individuals is needed to allow continued adaptive evolution and to avoid the accumulation of new harmful mutations. This recommendation would correspond to more than 5,000 individuals in many species. Such large populations will not be possible in many species except by increasing the connectivity among geographically separated populations over a wide area.” (Allendorf and Ryman, 2002).

In harem breeding animals such as horses, an effective population will be much smaller than the census population, since matings are not random, a relatively few dominant males are responsible for the majority of matings. However, free roaming horses generally exhibit greater genetic diversity than most domestic breeds. Through the domestication process many deleterious alleles may have been purged thus allowing for greater inbreeding without the resulting deleterious effects of inbreeding depression. However, Allendorf and Ryman, (2002) assert that inbreeding depression is caused by many recessive alleles with minor deleterious effects therefore purging these numerous alleles is unlikely. Thus, a prudent manager would attempt to maintain as much genetic diversity as is practical.

“Inbreeding depression due to fixation of deleterious partially recessive mutations can be reversed, at least temporarily, by introduction of genes from unrelated individuals into an inbred population, which allows natural selection to eliminate the deleterious mutations. It can be permanently prevented by continued immigration every one or two generations of a single unrelated individual into each local breeding population regardless of its size (Lande and Barrowclough 1987). Such a plan was recently implemented for the endangered Florida panther, motivated by strong circumstantial evidence of inbreeding depression and its low genetic divergence from other conspecific populations. Such genetic augmentation may be sufficient to reverse inbreeding effects and not too high to swamp possible local adoptions (Hedrick 1995).” (Lande, 2002)

Appendix 2, Population Data

Table 3. Population data.

Census Date	Number of Horses Counted Inside the HMA	No. Removed
1973	6
1975	9
1983	13
1986	46
1987	39
1988	66
1989	64
1991	101
1991	62
1993	59
1994	14
1995	46
1998	77
2002	39

All censuses were conducted after 1975 with rotary wing aircraft.

The following parameters were used:

Table 4. Initial age distribution post-gather

Age Class	Females	Males
5	1	1
5	1	1
7	1	1
8	1	1
9	1	1

Based on past gathers at least 10% of the horses are likely to remain undetected, thus evading capture attempts.

We do not have any specific data on foaling rates for the Dogskin Mountains, however, it is felt that the Garfield Flat HMA, also with in this Field Office would reasonably reflect the Dogskin Mountain rates.

Table 5. Foaling Rates. Proportion of males is 0.58%

Age Class	Foaling Rate
Foal	0
1	0
2	0.52
3	0.67
4	0.76
5	0.89
6	0.76
7	0.90
8	0.88
9	0.91
10-14	0.81
15-19	0.82
20+	0.75

These data were collected by M. Ashley and S. Jenkins at Garfield Flat, Nevada between 1993 and 1999. Marked females were followed for a total of 351 animal-years to generate these data on foaling rates.

We do not have any specific data on survival rates for the Dogskin Mountains, however, it is felt that the Garfield Flat HMA, also in this Field Office would reasonably reflect the Dogskin Mountain rates.

Table 6. Age specific survival rates.

Age Class	Females	Males
Foal	0.919	0.877
1	0.996	0.950
2	0.994	0.949
3	0.993	0.947
4	0.990	0.945
5	0.988	0.942
6	0.985	0.939
7	0.981	0.936
8	0.976	0.931
9	0.971	0.926
10-14	0.947	0.903
15-19	0.870	0.830
20+	0.591	0.564

These data were collected by M. Ashley and S. Jenkins at Garfield Flat, Nevada between 1993 and 1999. Marked individuals were followed for a total of 708 animal-years to generate these survival probabilities. All scenarios were run 100 times.

Proposed Action, would utilize removals median growth rate of 18.3 percent and a median average size at the end of 16 with the highest trail having an ending population of 37 horses. Over the 20 year period only 45 horses were removed.

Table 7. Average growth rate in 20 years, removals.

Lowest Trial	5.4%
10th Percentile	12.2%
25th Percentile	15.1%
Median Trial	18.3%
75th Percentile	21.7%
90th Percentile	23.9%
Highest Trial	28.8%

Table 8. Totals in 21 years, removals:

Gathered	Removed
Lowest Trial	14	12
10th Percentile	44	30
25th Percentile	53	37
Median Trial	62	45
75th Percentile	68	52
90th Percentile	78	59
Highest Trial	94	75

Alternative 1 would utilize removals techniques to control the population, with the population only being reduced to the upper end of the AML. This resulted in a median growth rate of 18.8% percent and a median average size at the end of 20 with the highest trail having an ending population of 44 horses. Over the 20 year period 60 horses were removed (median trial).

Table 10. Average growth rate in 20 years, removals. However, the population was only reduced to the upper AML.

Lowest Trial	4.8%
10th Percentile	12.2%
25th Percentile	15.5%
Median Trial	18.8%
75th Percentile	20.8%
90th Percentile	23.2%
Highest Trial	30.5%

Table 11. Totals in 21 years, removals only down to the upper AML.

Gathered	Removed
Lowest Trial	27	21
10th Percentile	49	37
25th Percentile	64	49
Median Trial	76	60
75th Percentile	88	70
90th Percentile	105	78
Highest Trial	148	117

Table 12. Population size in 21 years, removals only to the upper AML.

Minimum	Average	Minimum
Lowest Trial	8	15	21
10th Percentile	10	18	27
25th Percentile	10	19	29
Median Trial	11	20	31
75th Percentile	11	21	34
90th Percentile	13	22	36
Highest Trial	15	26	44

The No Action Alternative would leave the population to its own device (no management) and resulted in a median growth rate of 19.0 percent and a median size at the end of 21 years of 100 with the highest trail having an ending population of 913 horses. Of course well before the population reaches these magnitudes the habitat would be destroyed, most wildlife and native plats would have been extirpated, noxious non-native weeds would dominate, livestock could no longer be produced and the horses themselves would likely also be extirpated. However, we have provided the results below for academic interest.

Table 22. Average growth rate in 20 years, no management, No Action Alternative.

Lowest Trial	8.6%
10th Percentile	15.3%
25th Percentile	17.3%
Median Trial	19.0%
75th Percentile	20.7%
90th Percentile	22.3%
Highest Trial	25.3%

Table 23. Population sizes in 21 years, no management, No Action Alternative.

Minimum	Average	Minimum
Lowest Trial	4	26	63
10th Percentile	10	58	194
25th Percentile	10	83	266
Median Trial	11	100	355
75th Percentile	12	134	478
90th Percentile	13	177	679
Highest Trial	18	226	913

Unavoidable impacts in the form of injuries to the horses may occur during the removal process. Based on past gathers death loss is not expected to exceed 1% of the horses captured at the trap site. Potential injuries and fatalities can be limited through strict enforcement of contract specifications (Appendix 4) for safety and humane treatment of animals. BLM representatives would be monitoring the contractor's activities at all times during removal to ensure compliance with specifications and humane treatment of animals.

Some stress to the horses would be associated with the helicopter herding operations. However, after adoption the horses become accustomed to captivity.

Appendix 4, Removal Procedures

I. Methods for Removal and Safety

The methods employed during this capture operation would be either herding horses with a helicopter to a trap built with portable panels or capturing the horses using portable panels around water troughs. The Bureau of Land Management may contract with a private party for part or all of this operation. If a private party is used for this operation Bureau employee(s) would be supervising the contractor at all times during the gathering operation. The following stipulations and procedures would be followed during the contract to ensure the welfare, safety and humane treatment of wild horses and that wild horses are removed from proper areas. If capture operations are performed by Bureau personnel, the Bureau would follow the same stipulations that we require of a private contractor.

A. Roundup Procedures within Contract Area:

The Contracting Officer's Representative (COR) or Project Inspectors (PI) would determine specific roundup areas and numbers of animals within general contract areas as animal concentration, terrain, physical barriers and weather conditions dictate. Upon determination of the specific roundup areas, the COR/PI would select the general location of trap sites in which to herd the animals. Animal concentration, terrain, physical barriers and weather conditions would all be considered when selecting trap sites.

B. Motorized Equipment

l. All motorized equipment employed in the transportation of captured animals shall be in compliance with appropriate State and Federal laws and regulations applicable to the humane transportation of animals.

2. Vehicles shall be in good repair, of adequate rated capacity, and operated so as to insure that captured animals are transported without undue risk of injury.

3. Only stock trailers shall be allowed for transporting animals from traps to temporary holding facilities. Only Bobtail trucks, stock trailers, or single deck trucks shall be used to transport animals from temporary holding facilities to final destination. Sides of stock racks of transporting vehicles shall be a minimum height of 6 feet 6 inches from vehicle floor. Single deck trucks with trailers 40 feet or longer shall have 2 partition gates to separate animals. Trailers less than 40 feet shall have at least 1 partition gate to separate the animals. Each partition shall be a minimum of 6 feet high and shall have a minimum 5 foot wide swinging gate. The use of double deck trailers is unacceptable and shall not be allowed.

4. All vehicles used to transport animals to final destination shall be equipped with at least 1 door at the rear end of the vehicle which is capable of sliding either horizontally or vertically.

5. Floors of vehicles and loading chute shall be covered and maintained with a non-skid surface such as sand, mineral soil or wood shavings, to prevent the animals from slipping. This would be confirmed by a BLM employee prior to loading (every load).

6. Animals to be loaded and transported in any vehicle shall be as directed by the COR/PI and may include limitations on numbers according to age, size, sex, temperament and animal condition. A minimum of 1.4 linear foot per adult animal and .75 linear foot per foal shall be allowed per standard 8 foot wide stock trailer/truck.

The BLM employee supervising the loading of the wild horses to be transported from the trap to the temporary holding corral would require separation of small foals and weak horses from the rest, if they could be injured during the trip. Distance and condition of the road and animals would be considered in making this determination. Horses shipped from the temporary holding corral to the BLM facility would normally be separated by studs, mares and foals (including small yearlings). However, if the numbers of these classes of animals are too few in one compartment and too many in another, animals may be shifted between compartments to properly distribute the animals in the trailer. This may include placing a younger, lighter stud with the mares or a weak mare with the foals. Further separation may be required should condition of the animals warrant.

The BLM employee supervising the loading would exercise authority to off-load animals should there be too many horses on the trailer or truck.

7. The COR/PI shall consider the condition of the animals, weather conditions, type of vehicles, distance to be transported, and other factors when planning for the movement of captured animals. The COR/PI shall provide for any brand inspection or other inspection services required for the captured animals.

It is currently planned to ship all horses to the Palomino Valley facility. Communication lines have been established with the Palomino Valley personnel involved in off-loading the horses, to receive feedback on the condition of shipped horses. Should problems arise, shipping methods or separation of the horses would be changed in an attempt to alleviate the problems.

8. If the COR/PI determines that dust conditions are such that the animals could be endangered during transportation, the contractor would be instructed to adjust speed. The maximum distance over which animals may have to be transported on dirt road is approximately 5 miles.

Periodic checks by BLM employees would be made as the horses are transported along dirt roads. If speed restrictions are placed in effect, then BLM employees would, at times, follow or time trips to ensure compliance.

C. Trapping and Care

1. The helicopter shall be used in such a manner that bands of horses would remain together. Foals shall not be left behind.

To avoid adverse impacts to golden eagles the helicopter will be operated in a manner to avoid flying near aeries.

To avoid adverse impacts to water quality and riparian areas trap sites will be located in upland situations, along exiting roads. Since trap sites are located along existing roads threatened, endangered, sensitive or special states plant species are not likely to be impacted, however, these sites will be surveyed and if threatened, endangered, sensitive or special status plant species are present another location will be selected for a trap site.

The CCFO may use an observation helicopter to supervise the use of the project helicopter. In the absence of an observation helicopter a saddle horses may be used to place a BLM observer on a point overlooking the area of the helicopter herding operations. Mares would be checked soon after capture to determine if they are nursing. If nursing mares are captured without foals intensive monitoring would be conducted to identify the reason(s) foals are being abandoned and a solution would be developed. The health and well being of the captured animals are paramount and foals would not be left behind.

2. The rate of movement and distance the animals travel shall not exceed limitations set by the COR/PI who would consider terrain, physical barriers, weather, condition of the animals and other factors.

BLM would not allow horses to be herded more than 12 miles. The COR/PI may decrease the distance moved should the route to the trap site be steep or rocky enough to pose a danger or cause avoidable stress. Animal condition would also be considered in making distance and speed restrictions.

Special attention would be given to avoiding physical hazards such as fences. Map 1 shows locations of fences and any other potential hazards.

3. It is estimated that 2 trap locations would be required to accomplish the work. All trap locations and holding facilities must be approved by the COR/PI prior to construction. Proposed trap sites and holding facilities would be inventoried prior to construction in order to avoid those areas where cultural resources exist. The contractor may also be required to change or move trap locations as determined by the COR/PI. All traps and holding facilities not located on public land must have prior written approval of the landowner.

If tentative trap sites (Map 1) are not located near enough to the concentrations of horses, then the trap site would not be approved. The COR/PI would move the general location of the trap closer to the horses. Trap sites would be located outside of the WSA. Trap sites would not be approved where barbed wire fences are used as wings, wing extensions, or to turn the horses, during herding, toward the trap.

4. All traps, wings and holding facilities shall be constructed, maintained and operated to handle the animals in a safe and humane manner and be in accordance with the following:

a. Traps and holding facilities shall be constructed of portable panels, the top of which shall not be less than 72 inches high, the bottom rail of which shall not be more than 12 inches from the ground level. All traps and holding facilities shall be oval or round in design.

b. The loading chute shall also be a minimum of 6 feet high.

c. All runways shall be a minimum of 20 feet long and a minimum of 6 feet high.

d. Wings shall not be constructed out of barbed-wire or other materials injurious to animals and must be approved by the COR/PI.

e. All crowding pens including the gates leading to the runways shall be covered with material which prevents the animals from seeing out (plywood, burlap, etc.) and shall be covered a minimum of 1 foot to 5 feet above ground level. Eight linear feet of this material shall be capable of being removed or let down to provide a viewing window.

5. No fence modification would be made without authorization from the COR/PI. The contractor shall be responsible for restoration of any fence modification which he has made.

If the route the contractor wishes to herd horses passes through a fence, the contractor would be required to roll up the fencing material and pull up the posts to provide at least one-eighth mile gap. The standing fence on each side of the gap would be well-flagged for a distance of 300 yards from the gap on each side.

6. When dust conditions occur within or adjacent to the trap or holding facility, the contractor shall be required to wet down the ground with water.

7. Alternate pens, within the holding facility shall be furnished by the contractor to separate mares with small foals, sick and injured animals, and estray animals from the other horses. Animals shall be sorted as to age, number, size, temperament, sex, and condition when in the holding facility so as to minimize injury due to fighting and trampling.

As a minimum, studs would be separated from the mares and foals when the animals are held overnight.

8. Animals shall be transported to final destination from temporary holding facilities within 24 hours after capture unless prior approval is granted by the COR/PI for unusual circumstances. Animals shall not be held in traps or temporary holding facilities on days when there is no work being conducted except as specified by the COR/PI. The contractor shall schedule shipments of animals to arrive at final destination between 6:00 a.m. and 4:00 p.m.

9. The contractor shall provide animals held for 5 hours or more in the traps or holding facilities with a continuous supply of fresh clean water at a minimum of 10 gallons per animal per day. Animals held for 10 hours or more in the traps or holding facilities shall be provided good quality hay at the rate of not less than 2 pounds of hay per 100 pounds of estimated body weight per day.

10. It is the responsibility of the contractor to provide security to prevent loss, injury or death of captured animals until delivery to final destination.

11. The contractor shall restrain sick or injured animals if treatment by the government is necessary. The COR/PI would determine if injured animals must be destroyed and provide for destruction of such animals. The contractor may be required to dispose of the carcasses as directed by the COR/PI.

12. When refueling, the helicopter shall remain a distance of at least l,000 feet or more from animals, vehicles (other than fuel truck), and personnel not involved in refueling.

13. Mares and foals would be paired up soon after capture and separated from other adult horses. Mares that are within the target age group for removal would be shipped to PVC with their foal. Foals of older mares (mares older than the ones selected for removal) that are old enough to wean, would be weaned and shipped to PVC. While holding animals at temporary corrals every effort would be made to pair up mares with foals. Any foals that do not pair up with a mare would be shipped to PVC.

14. Foals of older mares which are too young to wean would be released back into the HMA with their mare. In order to minimize stress to the foals, older mares and their foals would be released separately from other mares and stallions. Depending upon the situation they may be released prior to the other animals or after the other animals have been released. Also, we may transport the mares with very young foals in a stock trailer to areas close to their core areas when feasible. The objective would be to maximize the period of time between releasing small foals and other animals. Also, mares with foals would be released in small groups to minimize the likelihood of the adult horses running off too quickly for the foals to keep up.

15. Following the release of animals from corrals or trailers, the area surrounding the release site would be monitored to determine the success of the release prior to the contractor moving to another area or the termination of the task order.

II. Disposition of Removed Animals

The wild horses and burros would be sent to Palomino Valley Wild Horse and Burro Placement Center to be processed for adoption.

Impounded, privately owned animals would be processed as outlined in the Bureau of Land Management, Nevada State Office Instruction Memoranda NV-84-116 and NV-85-416.

III. Responsibility

The Field Office Managers are responsible for maintaining and protecting the health and welfare of the wild horses. To ensure the contractor's compliance with the contract stipulations, the COR and PIs all from the CCFO and/or BMFO , would be on site. Also, the Assistant Field Managers and Field Managers are very involved with guidance and input into this removal plan and with contract monitoring. The health and welfare of the animals is the overriding concern of the Field Office Managers, Assistant Field Office Managers, COR and PIs.

The COR and/or PI would constantly, through observation, evaluate the contractor's ability to perform the required work in accordance with the contract stipulations. Compliance with the contract stipulations would be through issuance of written instructions to the contractor, stop work orders and default procedures should the contractor not perform work according to the stipulations.

Prior to issuance of the "Notice to Proceed" to the contractor, the COR and PIs would inspect the equipment to be used during the contract, to insure the equipment meets or exceeds the standards contained in the contract stipulations. Prior (less than 20 days) to the start of the contract and constantly during the course of the contract the COR and/or PIs would evaluate the conditions which may cause undue stress to the animals. The factors considered would include animal condition, prevailing temperatures, drought conditions, soil conditions, topography, animal distribution, distance animals travel to water, quantity of available water and condition of roads that animals are to be transported over. These factors would be evaluated to determine if additional constraints other than those already discussed above, need be initiated in order to safely capture and transport the animals (i.e. veterinarian present, or delay of capture operations). This is of special concern during this year of drought which may intensify the impact of removal operations on the animals and the roads.

VII. Finding of No Significant Impact and Decision Record

Decision: Implement the Dogskin Mountain HMAP and Capture Plan Update as identified in the Proposed Action and using the Procedures detailed in Appendix 4. The subject plan directs management actions for the Dogskin Mountain HMA. The major actions in the subject plan include limiting vegetation utilization to 55%, providing habitat for wild horses and wildlife, outlining studies to assure that Land Use Plan objectives are being met, removing excess wild horses and maintaining and improving riparian areas. The selected alternative is the proposed action, which contains the above mentioned features.

Finding of No Significant Impacts: Based on the analysis of potential environmental impacts contained in the environmental assessment, impacts are not expected to be significant and an environmental impact statement is not required.

Rational for decision: The Carson City Consolidated Resource Management Plan stated that Herd Management Area Plans would guide the management of wild horses through the determination of proper horse use levels. By maintaining the population of wild horses between 10 and 15 individuals the vegetation utilization levels would be maintained at sustainable levels (< 55% use). This action is not significant because a population of wild horses would be maintained within the HMA and the vegetation, wildlife and livestock would not be adversely impacted.

Unavoidable impacts in the form of injuries to the horses may occur during the removal process. Death loss is not expected to exceed 1% of the horses captured at the trap site. Some stress to the horses would be associated with the capture operations, however, after adoption the horses become accustomed to captivity. Because the loss of animals due to accidents is low the impacts involved in the capture operation are not significant.

The decision to implement the Dogskin Mountain HMAP and Capture Plan Update is in conformance with the Carson City Field Office Consolidated Resource Management Plan, and would restore the range to a thriving ecological balance and prevent a deterioration of the range, as analyzed in the subject EA, in accordance with Sec. 3(b) of the Wild Free-Roaming Horses and Burros Act, as amended, 16 U.S.C. 1333(b) (1989). This would result in reduced soil erosion and improve the physical condition of wild horses.

The proposed actions would not adversely impact air quality, ACECs, cultural resources, farmlands, floodplains, Native American religious concerns, T&E species, wastes, water quality, wetlands and riparian zones, wild and scenic rivers, migratory birds or wildernesses.

The capture portion of this plan is issued Full Force and Effect to allow for the immediate removal of excess wild horses from the Dogskin HMA to reach the established Appropriate Management Level (AML). Immediate removal of wild horses in excess of the AML is necessary to restore the range to a thriving natural ecological balance and to avert the imminent overgrazing caused by excess wild horses within the HMA. The Full Force and Effect determination is in accordance with the regulation at 43 CFR 4770.3(c).

Within 30 days of receipt of this decision, you have the right of appeal to the Board of Land Appeals, Office of the Secretary, in accordance with the regulations at 43 CFR, Part 4, Subpart E. If an appeal is taken, you must follow the procedures outlined in the enclosed form 1842-1, Information of Taking Appeals to the Board of Land Appeals. Within 30 days after you appeal, you are required to provide a Statement of Reasons to the Board of Land Appeals and a copy to the Regional Solicitor’s Office listed in Item 3 on Form 1842-1. Please provide this office with a copy of your Statement of Reasons. Copies of your Appeal and the Statement of Reasons must also be served upon any parties adversely affected by this decision the Appellant has the burden of showing that the decision appealed from is in error.

If the appellant wishes to file a petition (request) (pursuant to 43 CFR 4.21) for a Stay (suspension) of the effectiveness of this Decision during the time that the appeal is being reviewed by the Interior Board of Land Appeals, the Petition for Stay must accompany the Notice of Appeal. A petition for a Stay is required to show sufficient justification based on the standards for obtaining a Stay. Copies of the Notice of Appeal and Petition for a Stay must also be submitted to the appropriate Office of the Solicitor (see 43 CFR 4.413). If the appellant requests a Stay, the appellant has the burden of proof to demonstrate that a Stay should be granted.

Standards for Obtaining a Stay

Except as otherwise provided by law or by other pertinent regulation, a Petition for a Stay of a Decision pending appeal shall show sufficient justification based on the following standards:

1. The relative harm to the parties if the stay is granted or denied,

2. The likelihood of the appellant’s success on the merits,

3. The likelihood of immediate and irreparable harm if the stay is not granted, and

4. Whether the public interest favors granting the stay.

Approved by:

Daniel Jacquet	Date

Assistant Manager, Renewable Resources

Carson City Field Office