Urgent: Eagle Lake Field Office “Rush Fire Emergency Stabilization and Rehabilitation” EA DOI-BLM-CA-NO50-2012-45-EA
Open Letter from Wild Horse Freedom Federation to the BLM
To: BLM_CA_Eagle_Lake_FO_Email@blm.gov, kcollum@blm.gov and d65wilso@blm.gov
Wild Horse Freedom Federation submits the following comments:
Wild Horse Freedom Federation is urging no action (Alternative B) until a complete EA in compliance with NEPA or an EIS is submitted for public review.
The BLM has offered the public only 2 alternatives, either one plan (Alternative A) or no action (Alternative B). This EA is incomplete for offering only two alternatives, and for the reasons cited below, and contains incorrect, conflicting and skewed information.
Comment on 1.2 Purpose and Need
The “emergency” is moot. The fire is over. When the BLM decided to let the fire burn (actually telling local residents in advance the date when the fire would be put out) the fire stopped being an unexpected event, and then became a planned (and thus, controlled) fire. The backfires started by BLM were not always used to stop the fire, but to clear certain areas.
The BLM can bypass NEPA to control the immediate impacts of a real emergency that are “urgently needed to mitigate harm to life, property, or important natural, cultural, or historic resources,” but in the Rush Fire, the BLM violated many of the laws listed in this EA and it’s mandate to ensure a thriving natural ecological balance, with a “let it burn” policy that created this supposed “emergency.”
The multiple use mandate does not excuse the BLM from taking a hard look at the effects of its actions.
This EA is incomple because it does not include a map of the livestock grazing allotments.
This EA is incomplete because it does not include a map detailing where the highest concentrations of noxious weeds are.
This BLM EA doesn’t address the fact that a main cause of noxious weed infestations is, and will continue to be, livestock grazing, which disturbs the soil and gives noxious weeds a foothold, even though Table 3.5 on page 55 of the EA notes that casual factors for livestock grazing allotments not meeting the standard for upland soils and biodiversity ARE “livestock grazing” and “historic livestock grazing.”
This EA is incomplete because the maps only include every other township and range number on the maps.
This EA is incomplete because the maps don’t indicate all of the private property that is indicated on the BLM 30×60 minute series (topographic) maps for Eagle Lake and Gerlach.
The BLM’s incomplete data inhibits public comment.
Comment on 1.5 Authority, Laws, Regulations and Other Plans:
With the proposed action of this EA, the BLM will be in violation of the Wild Free-Roaming Horses and Burros Act of 1971. Wild Horse Freedom Federation has carefully reviewed the photographs of an independent aerial survey of the Twin Peaks HMA taken after the Rush Fire, which were also directed to the attention of Ken Collum, Field Manager of the Eagle Lake BLM office, which prove that less than 400 wild horses remain.
The BLM’s few photographs and maps using only dots in this EA are not proof positive, and we believe BLM’s inventory numbers and claims of 1,324 wild horses are grossly overestimated. Wild Horse Freedom Federation believes any attempt to remove wild horses from Twin Peaks will wipe out the last of the remaining wild horses on this HMA and be the total eradication of this one “use” in BLM’s multiple use mandate.
The BLM was in violation of the Wilderness Study Area Manual 6330, for not ensuring a thriving natural ecological balance. While this EA proposes to only reduce livestock grazing temporarily, the planned removal of wild horses will be FOREVER. The BLM will not ensure, but eradicate, an entire part of the thriving natural ecological balance.
Comment on 1.5.1 Environmental Assessments, other BLM Documents:
This EA is incomplete because it is tiered to EAs and documents that are outdated and obsolete. Some documents listed in this section are dated 1998 – almost 15 years ago! Since then, other uses have been approved in this area.
This map doesn’t indicate how many horses each dot represents, as other BLM aerial survey maps have done (for instance, 1-10 horses would be one color dot, 10-25 horses would be a different color dot, and 25-50 horses would be another different color dot).The photographs on pages 70-72 of this EA do not specify GPS coordinates or the exact date the photo was taken. Most notably, Photograph 1 at the top of page 70 looks like it has been “photoshopped” or altered in some way – if you look at the bottom, right side of this photo, you will see a rectangle like a photo was placed on top of another photo, and the bottom edge of this area is straight (it looks like the green grass cuts off in a straight line).If this photo was altered without notifying the public, this EA is fraudulent. Also, Wild Horse Freedom Federation notes that there are no more than 10 horses in any of the photos in this EA, and that the BLM did not indicate if any of these photos contained the same horses.BLM could have just “cherry-picked” these particular photos to make it seem like there is “not enough forage.”Comment on 2.1.3 Invasive Plant Inventory and Treatment
The BLM does not specify (or disclose to the public) in this EA, what chemicals will be used. The BLM has not fully explored the effects of herbicide use on endangered animals, including sage grouse.
The BLM has not informed the public if it will distribute the herbicides using aerial spraying (in which BLM essentially carpet-bombs the land and water with toxic chemicals), or if BLM employees will find the weeds out in the field and spray them directly using tanks carried on all-terrain vehicles or backpacks. This EA also doesn’t include any requirements that the BLM explore other options for removing noxious weeds first, before aerial spraying. BLM should hand-pull, mechanically remove or burn weeds where possible.
Comment on 2.1.5 Protective Fence
Permanent Fence (page 18) and Map 3 (page 19) indicate that out of the 315,577 acres burned in the Rush Fire, the BLM plans to use American taxpayer’s money to build at least one permanent fence on PRIVATE PROPERTY. For instance, it looks as if the bottom permanent fence on Map 3 is right on private property in the Smoke Creek Ranch area, and not on public lands.
At least one other part of the permanent fence seems to be in areas that would benefit grazing areas for privately owned companies (for instance, John Espil’s Sheep Company and Clark’s Valley Land & Sheep Co.)
On page 13, MAP 2, the 2012 Rush Fire Seeding Sites, out of the entire 315,577 acres that were burned in the Rush Fire, the BLM has selected to have American taxpayers pay to reseed areas including PRIVATE PROPERTY and areas around a powerline.
Comment on 3.10 Wild Horses & Burros
BLM plans to PERMANENTLY remove wild horses & burros, while only temporarily reducing livestock grazing “until vegetative establishment objectives are met.” This may be less than 2 years.
The BLM claims a reason to remove wild horses & burros is there is not enough forage for to sustain them. However, the Rush Fire ONLY burned 9% (7,860 acres) of prime habitat for wild horses & wildlife within the HMA.
BLM did not address ANY NATURAL regrowth of vegetation in this EA.
The BLM also claims a reason to remove wild horses & burros because there is not enough water for them. This is contradictory to BLM’s other assertions within this same EA, in section 2.1.11, which indicates there is increased watershed flow and water catchments.
Wild Horse Freedom Federation, after examining independent scientific research, believes the BLM has overestimated the population inventory of wild horses & burros, and that any attempt to remove them will permanently eradicate this “use” from their federally protected Herd Management Area.
On page 77, what data does BLM have/use to substantiate its claim that there is a “low frequency” of wild horse observation? What comparison studies have been done regarding/differentiating wild horse observation from, for example, wildlife observation?
Has every single member of the public who has gone on public roads or onto public lands been obeserved by the BLM or reported to the BLM why they went where they went or what they went to observe? Does the BLM not consider wild horses & burros to be part of the thriving natural ecological balance?<
Again, and lastly, only 9% of prime habitat for wild horses & burros was burned within the Herd Management Area in the Rush Fire, and there will soon be, if not already, natural regrowth, so the BLM should not remove any of the wild horses & burros, or adjust their current AMLs.
Wild Horse Freedom Federation
more wild horse info at www.windwildhorse.com