Debbie Coffey (c) copyright 2011 All Rights Reserved


December 27, 2011

To: Mr. Thomas Seley, Field Manager 

We're watching you!

Tonopah Field Office

1553 S. Main Street


 RE: Comment on the Bullfrog HMA wild burro gather 

Dear Mr. Seley:

I urge you to select the NO ACTION ALTERNATIVE to the Environmental Assessment (EA) for the Bullfrog HMA wild burro gather (DOI-BLM-NV-B020-2011-0102-EA). 

This EA states BLM is proposing to remove an “excess” 53-86 burros and leave only 70 burros on a 151,782 acre Herd Management Area (which is PRIMARILY for use by the wild horses and burros). 

On 1.3 PURPOSE AND NEED FOR ACTION of this EA, BLM states this action is “1) to protect rangeland resources from deterioration associated with an overpopulation of wild burros”

Where was all the concern with protecting rangeland resources when BLM mismanagement allowed the Barrick Bullfrog Mine to cause so much contamination that it needed reclamation? 

1.3 also states that this gather is needed “to restore and maintain a thriving ecological balance.” (page 5 of the EA) BLM’s interpretation of a “thriving ecological balance” seems broad at best, and by comparing these few burros and any damage they might cause to other projects/uses, and the damage to the environement those uses cause, it seems BLM is perpetrating fraud on the American public. It seems like a local residents have been more concerned about other projects, like Solar Millenium’s Amargosa Valley Project, just 30 miles south of Beatty, NV, which is in the Bullfrog HMA: 

Page 5 of the EA states “recurrent drought and sporadic precipitation patterns occur within the region often resulting from unfavorable conditions for healthy wild and burros. And on Page 6, “There are few available water sources, especially on the east side of the HMA.” and “Large portions of the Bullfrog HMA are ‘dry’…” 

In 3.1 GENERAL SETTING, (page 20) there is further information about drought in the area, which leads to the graph (Figure 2 on page 21) showing below average precipitation since about 2007. 

However, since about 2008, BLM has been mapping ROWs for solar power plants from Lathrop Wells to Beatty (which is within the Bullfrog HMA).

Are all these same concerns for drought and water featured prominently in EAs/RODs for ROWs and solar projects? Or was the water issue omitted or glossed over with a “finding of no significant impact” for that use? 

As you must know, solar energy uses huge amounts of water from aquifers, which will drop the water table in surrounding areas. The Solar Millenium project, which seems to be

only 20 miles south of the Bullfrog HMA and may share an aquifer, is only one solar project (out of many) and it was to use about 1.3 BILLION gallons of water per year from the aquifer. Here is an article from the New York Times, in case you didn’t know anything about this:

If the BLM is willing to drop 1.3 BILLION gallons per year for just one use, and then feigns concern that there isn’t enough water for 53-86 burros, it seems to indicate BLM mismanagement and to be a VIOLATION of FLPMA. It sure looks, to the average person, like the DOI is going after land uses that make the most money.  

By the way, is seems that Solar Millenium (owned by a German developer) which received a ROD, is being acquired by German owned company, Solarhybrid AG.  What is the Department of the Interior policy regarding foreign owned companies controlling our resources?

After reading this EA, it doesn’t seem that there are “NUISANCE BURROS” – it seems that there are only NUISANCE BLM POLICIES.  


Debbie Coffey