Consolidated RMP 2001 was an internal document that summarized land use plan decisions of the Reno EIS 1981, Lahontan RMP1986 and Walker RMP 1986. This document did not revise the existing land use plans, did not use any level of NEPA nor consulted the affected parties. As a result, simple wildlife data of the existing land use plans hold significant errors.

For Example, pronghorn antelope and desert bighorn sheep data are portrayed as Pronghorn Sheep and Desert Mountain Goat Habitats. This failure to portray wildlife habitat serves has the BLM’s lack of knowledge nor respect for state natural resources.

As far as procedures, these grossly outdated land use plans are further extended by BLM’s decision for an appropriate management level in 1993. The state held no opportunity to resolve resource conflicts in the land use plan over the past twenty one years nor the allotment specific decision over 14 years ago that established the AML. BLM continues to defend decisions fully ignoring or providing the state an opportunity to comment. BLM continues to defend a 14 year old decision without the benefit of rangeland monitoring data that was obligated to be collected in the RENO EIS 1981.

Decisions implementing the land use plan are outdated and fail the test of available or obligated data. BLM ignores science.

Failure to collect and assess rangeland monitoring data since the 1993 allotment specific decision discounts the adjustment in livestock management and appropriate management level of wild horses which fails any test of “restore a thriving natural ecological balance” as required by the Act. The proof of burden lies solely on the BLM as required by FLPMA and federal grazing regulations.

Genetic studies strongly support the conclusion the Dogskins Wild Horse Herd holds no genetic diversity. BLM defends its action on the failure of the Wild Horse and Burro Act to limit its authorities. In this situation, BLM ignores science to promote excessive management to sustain a herd for which it has no budget or abilities to accomplish in the short term or long term. The Carson Field Office continues to ignore its decisions, land use plan and science in other herds. For example, the Lahontan Wild Horse Herd has a similar AML of 10 head on a HMA without public land waters. In February 2006 the Carson Field Office gather over 230 wild horses and released 37 head back to the HMA. Specifically, BLM released 4 times the AML. This action cost the taxpayers over a quarter million dollars in horse gathers and sustaining them in feedlots. This example and the ongoing management of the Dogskins have inhibited other gathers in the state of Nevada and other states to a point of litigation in Wyoming to seek relief.

As BLM and IBLA defends it absolute discretion over science to support political agendas, the public resources remain in jeopardy.