Debbie Coffey         Copyright  2012    All Rights Reserved

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A current Bureau of Land Management (BLM) wild horse “eco-sanctuary” proposal by T. Boone Pickens’ wife, Madeleine Pickens (Saving America’s Mustangs) is for a NON-REPRODUCING herd, so HOW, exactly, is this supposed to save America’s mustangs?

It’s important to take a close look at what the BLM is doing with this plan (and with other eco-sanctuary plans), which also seems to be a new way to package the closing off of public lands to the publicKurt Golgart/wild horses

Where you could once get out of your car and walk on public land, will you now be fenced out of/off of any public lands?  Where you could once drive your car on public roads, will the “eco-tours” on the eco-sanctuary put you on buses or on wagons (like the BLM “tours” of the Indian Lakes Rd. short term holding facility in Fallon, NV)?

Will you now have to pay (either by fee or tax dollars) to see something you could see for free in the past?  Where you could once camp on public lands, will you now have to pay for accommodations at an eco-sanctuary?  Where you could once travel at any time of the day, will you now only be allowed to “visit” during certain hours?

Three Nevada wild horse Herd Management Areas (HMAs) are to be included as part of the “Northeast Nevada” (Saving America’s Mustangs) eco-sanctuary: the Spruce-Pequop HMA, the Goshute HMA and the Antelope Valley HMA. 

Saving America’s Mustangs will be using the Spruce Allotment, and grazing horses instead of cattle.  How will the wild horses on the HMA be kept separate from the horses on the eco-sanctuary?  It seems that there will need to be a lot of interior fences on public lands.

Removing protected wild horses

The BLM is removing wild horses from their federally protected wild horse Herd Management Areas while they over designate many other “uses.”  So much so, that it looks likes the wild horse Herd Management Areas are for everything BUT the wild horses.  For example, in a land use map of the Spruce-Pequop HMA, the HMA seems to contain Department of Defense and National Antelope Refuge (NAR) areas and many uses other than the wild horses.

It’s important to note these maps show land “use” designations like E-4 Use Area, C-1 Use Area, D-2 Use Area, etc.  These designations don’t seem to be listed in the BLM Land Use Planning Handbook (

H-1601-1).  So where can we find out what these designations mean?  More importantly, what inventory system is our public lands a part of

The Saving America’s Mustangs eco-sanctuary will use about 14,000 acres of private land, and 508,000 acres of public land.  The BLM has plans of “restructuring” the three HMA boundaries and “revising management objectives.”

The BLM hasn’t yet given the public any details of how it plans to “restructure” the three HMAs.  A crucial part of this eco-sanctuary plan has been glossed over.

The Wild Free Roaming Horses & Burros Act of 1971, even with revisions that watered it down, states under “Limitation of Authority,” Nothing in this Act shall be construed to authorize the Secretary to relocate wild free roaming horses or burros to areas of public lands where they do not presently exist.

Now look at the map of the proposed eco-sanctuary:  There seems to be public lands in this plan that aren’t part of the HMAs. 

Has Secretary of the Interior, Ken Salazar, exceeded his authority?

Wild horses, by law, are “to be considered in the area where presently found, as an integral part of the natural system of the public lands,” so how can the BLM possibly claim they’re “maintaining a natural thriving ecological balance” when they zero out HMAs (remove all of the wild horses and burros) or remove so many wild horses and burros that they risk the variability and viability of the herds?

And then there’s the very questionable issue of the BLM actually putting wild horses and burros on private property, knowing that the law states that wild free roaming horses and burros lose their status as wild free roaming horses and burros when they are transferred to private maintenance and are then no longer protected under the Wild Free Roaming Horses & Burros Act of 1971.

In the Saving America’s Mustang eco-sanctuary proposal, the BLM states “Those areas of the HMA that aren’t part of the eco-sanctuary will be evaluated to determine their ability to sustain a viable horse population with reduced acreage and water resources.”

Let’s cut to the chase.

There will only be about 7% left of the Spruce-Pequop HMA, for example, so the BLM will probably conclude that this newly reduced area of the HMA won’t sustain a viable, healthy herd, and will then use the excuse of not enough land/forage/water to roundup the remaining wild horses.  Will those wild horses then be sent to another eco-sanctuary or to long-term holding in another state?

While I commend Madeleine Pickens for saving hundreds of horses from going to slaughter and nothing in this article is meant to question what seems to be her good and generous intentions, the public needs to play the devil’s advocate with the BLM and consider all aspects of this plan.

Saving America’s Mustangs has 66 water rights in 5 Basins, many on the HMAs.  What if the eco-sanctuary isn’t approved?  Saving America’s Mustangs will still have all those water rights in and near the 3 HMAs.  Will Saving America’s Mustangs then apply for a change of use for all of the water permits?

Of course, the elephant in the room is that T. Boone Pickens (Mesa Water) is on the Advisory Board of Saving America’s Mustangs.  This could make you wonder if he’ll ever give advice about the water rights at any point in time.  Just last year in Texas, Mesa Water was in a legal

fight with the Texas Water Development Board over underground water goals.  Also, the executive director of the Texas Commission on Environmental Quality dismissed Mesa Water’s request for an inquiry and to possibly dissolve local water conservation districts, dismiss their boards or force them to change their goals.

If the eco-sanctuary is approved, what happens in 20-30 years when all of the horses in the non-reproducing herd have died?  Will we even have any wild horses left on public lands in another 20-30 years to put on this eco-sanctuary?  Where will those horses be removed from?  Will the BLM put another non-reproducing herd on this eco-sanctuary?  Where is all of this heading?  The BLM plans more eco-sanctuaries, so the Saving America’s Mustangs plan seems to be setting the stage for more to come.

The BLM had several “open houses” about this eco-sanctuary plan, to offer brochures and show maps to the public, but the BLM has not had a formal public meeting to listen to public comments.  In a formal public meeting, statements are on the record, and there are minutes for the public to read (even if it takes the BLM many months to type up and post them).  It seems as if this eco-sanctuary is already a done deal, and that the BLM is only feigning interest in public comment.

Did any of the maps the BLM showed at the open houses show the two new mining projects that are just 10-15 miles north of the eastern part of the Spruce-Pequop HMA: the West Pequop Exploration Project and the Long Canyon Mine?  These will likely use millions of gallons of water from the aquifer in coming years.

What about the money?  On the Saving America’s Mustangs website, it states: “the foundation still needs money to manage the ranch, the farm, repair the fences, install new irrigation, rebuild homes for the help, and care for the horses.”  It also states “The Foundation provides the government with: (1) abundant long term capacity for horses at about the same cost, $500 per year per horse, as its current long term holding facilities…”

BLM’s non-reproducing herds idea is a plan for extinction.

At the National Wild Horse & Burro Advisory Board meeting, it seems that Dean Bolstad, Deputy Division Chief of the Wild Horse & Burro Program, announced that both the Saving America’s Mustangs and the Wyoming eco-sanctuaries would contain non-reproducing herds.  Zachary Reichold (BLM) told a wild horse advocate that the idea for non-reproducing herds originated with himself and Dean Bolstad.  Do these two BLM employees who arbitrarily made this decision have more power than you, the American public?

You can, and should, send your written comments regarding the eco-sanctuary plan, by September 19, 2012, to the project e-mail address:

EcoSanctuaryComments@blm.gov or to the

BLM Elko District Office,

Wells Field Office,

3900 E. Idaho Street,

Elko, NV 89801,

Attn: Wild Horse Eco-Sanctuary, or fax at (775) 753-0385. 

You also pay the salaries of and can send comments to Dean Bolstad at

dbolstad@blm.gov, to Amy Lueders, BLM Nevada State Director at alueders@blm.gov, and to Ken Miller, the BLM Elko District Manager, at kmiller@blm.gov.  You can read all of the information about the eco-sanctuary here:
http://www.blm.gov/nv/st/en/fo/elko_field_office/blm_information/nepa/nenvwh_ecosanctuary.html

This eco-sanctuary plan is not only about the wild horses, it’s about our public lands.  The BLM wild horse eco-sanctuary plan is a “public – private partnership” that seems like it will ultimately close off public lands to the public and one way or another, make you pay for what you once had for free.

SOURCES:

The Wild Free Roaming Horses & Burros Act of 1971:

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/sale_authority.Par.69801.File.dat/whbact_1971.pdf

BLM info for the eco-sanctuary:

http://www.blm.gov/nv/st/en/fo/elko_field_office/blm_information/nepa/nenvwh_ecosanctuary.html

http://www.blm.gov/nv/st/en/fo/elko_field_office/blm_information/nepa/pequop_exploration.html

http://www.blm.gov/nv/st/en/fo/elko_field_office/blm_information/nepa/long_canyon_eis__7.html

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/elko_field_office/information/nepa/eas/archives/final_antelope_complex.Par.77939.File.dat/map_2_spruce_pequop_allot_useareas.pdf

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/elko_field_office/information/nepa/eas/archives/final_antelope_complex.Par.9724.File.dat/map_3_goshute_allot_useareas.pdf

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/elko_field_office/information/nepa/eas/archives/final_antelope_complex.Par.50227.File.dat/map_4_antelopevalley_allot_useareas.pdf

http://www.blm.gov/pgdata/etc/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/sale_authority.Par.69801.File.dat/whbact_1971.pdf

https://www.savingamericasmustangs.org/index.php/info/horse_sanctuary/

http://amarillo.com/news/local-news/2011-01-06/mesa-requests-new-trial

http://www.savingamericasmustangs.org/

http://www.blm.gov/pgdata/etc/medialib/blm/nv/field_offices/elko_field_office/information/nepa/eiss/archives/nenvwh_ecosanctuary.Par.23699.File.dat/spruce_2%20%282%29.pdf

http://www.blm.gov/nv/st/en/info/newsroom/2012/august/elko__blm_begins_process.html

BLM Land Use Planning handbook:

http://www.blm.gov/pgdata/etc/medialib/blm/ak/aktest/planning/planning_general.Par.65225.File.dat/blm_lup_handbook.pdf

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