The BLM has ramped up the removal of wild horses at a dizzying pace and it is hard trying to  keep up with them and comment on all of them (maybe that’s why the BLM waited to the last minute to send out all the press releases about roundups).  Below is an open letter to the BLM regarding the Challis Herd Management Area in Idaho.

Debbie Coffey  © Copyright 2012  All Rights Reserved

_____________________________________________________

September 9, 2012

Mr. Steve Ellis, BLM Idaho State Director
Mr. Joe Kraayenbrink, BLM Idaho Falls District manager
Mr. Todd Kuck, Challis Field Office Manager
Mr. Kevin Lloyd, BLM Rangeland Management Specialist

RE:  DOI-BLM-ID-1030-2012-0006-EA

Dear Mr. Lloyd, Mr. Kuck, Mr. Kraayenbrink and Mr. Ellis:

I urge you to select Alternative 5, NO ACTION.  Also, the proposed Challis Wild Horse gather may be in violation of laws, and the above proposed Preliminary EA gives misleading information to the American public.

On 1.3 Purpose and Need for Action, this EA states this action is needed “to be consistent with the established AML” (Appropriate Management Level) and that this action would “restore a thriving natural ecological balance.”

Actually, your proposed action wouldn’t restore a thriving natural ecological balance.  It would do just the opposite, and violate the law.  The Wild Free Roaming Horse and Burro Act of 1971, even with amendments, stressed that wild horses are “to be considered in the area where presently found, as an integral part of the natural system of the public lands.”

1) I believe your proposed action will be creating a non-viable herd. 
It seems that in the last genetic analysis of the Challis herd, the samples were received by Dr. Gus Cothran September 10, 2002 (about ten years ago), and the report was issued about a year later on September 15, 2003.  At that time, on page 3 of Dr. Cothran’s report, 25% had a frequency of less that 0.05, and he stated “This low frequency puts these variants at a high risk of loss.”  Will your proposed removal create an even higher risk of loss of not only frequency (putting variants at risk), but also risking variability and viability?

2) BLM has allowed that there could be only 1 wild horse per over 1,800 BLM acres within the Challis Herd Management Area (CHMA) (I’m not counting state and private acres in CHMA).  BLM was very active in the Resource Management Plan process, where it was decided what was “appropriate,” and the process of other land use plans, so BLM obviously did not negotiate to protect the wild horses on their own federally protected Herd Management Area.  BLM does not seem to have considered wild horses as “integral.”  Has the BLM so badly managed the rangeland within the CHMA that only 185 wild horses could be supported on 154,150 BLM acres of their federally protected Herd Management Area?

2.1.1 – Your proposed action
You would capture 274 horses out of the 322 you have on CHMA.  This leaves 48 wild horses.  Then you propose to give fertility treatment (PZP) to ALL of the mares you return to the range, and also plan to return some geldings (how many geldings will there be, exactly?).  How many fertile mares would be left out of that 48?  This proposal adds further concerns about the continuing variability and viability of the herd.

1.6 Relationship to Statutes, Regulations, Policy and other Environmental Analysis
This BLM EA has cherry picked only certain sentences out of certain laws.

Wild Free Roaming Horse and Burro Act of 1971 – this action will not be in conformance with this law, because not only does the need for action lack scientific evidence of the current variability and viability of the herd, you plan to leave only 48 or less mares that will be fertile.  Don’t any foals ever die in the wild there in Idaho?

On one page of the Idaho BLM website http://www.blm.gov/id/st/en/prog/wild_horses_.html, BLM claims wild horses have “few” natural predators.  Then on another page of the website, BLM states that the CHMA has a “full complement of large predators with mountain lions, bears, and wolves.”

http://www.blm.gov/id/st/en/prog/wild_horses_/hmas/challis_hma.html
Do mountain lions, bears and wolves ever prey on foals?  Remember, with PZP use, foals are born out of season.  And they sometimes run and play away from the adults.

Let’s look at the math:
322 horses currently on CHMA now
-274 you plan to gather
leaves only 48 on the range  How many of those will be fertile mares?  Only 20?  Or only 2?  Are any of the 48 considered to be wild horses only foals?
Then, you’ll return 137 horses (but 55 will be PZPed mares, and HOW MANY GELDINGS???)  For all we know, you plan to geld all of the stallions you return, so please be specific about the number of geldings and the number of intact stallions that will be returned.

Let’s look at how you could be in violation of some laws (BLM has cited these very laws to support the need for this proposed wild horse gather, so this is within the purvue of the above Preliminary EA):

Federal Land Policy and Management Act of 1976 (FLPMA) – The BLM seems to turn a blind eye to the need for a “thriving natural ecological balance” for other uses, like the Thompson Creek Mine, which seems to be less than 15 miles east of the CHMA, and has many risks to the environment.  http://www.wildwhiteclouds.org/news_mining_ThompsonCreek.html
It seems that BLM hasn’t cared, and still doesn’t care, about habitat or resource degradation when it comes to the uses that make the most money.  This would be in violation of FLPMA, which directs that BLM give consideration to the values of resources, and “not necessarily to the combination of uses that will give the greatest economic return or the greatest unit output.”

Mr. Kraayenbrink, In August of 2010, you signed this letter urging the EXPANSION of the Thompson Creek Mine.
http://www.blm.gov/pgdata/etc/medialib/blm/id/nepa/challis_fo/thompson_creek_mine.Par.23564.File.dat/TCM_Scoping_Letter_Final_08032010.pdf
Not only will this expansion include disturbances to wetlands from the proposed mine dumps and tailings pond, but in the Thompson Creek Mine Technical Report, it states” Long term closure risks remain primarily around water quality and the plan to treat water in perpetuity.” 
http://www.thompsoncreekmetals.com/i/pdf/Thompson_Creek_TechRpt_9Feb2011_FINAL.pdf
The water may need to be treated FOREVER.  How does this contribute to a “thriving natural ecological balance?”  Don’t you think horses are more “NATURAL” than a tailing pond?  The BLM is actually promoting a thriving UNNATURAL ecological IMBALANCE.
http://www.jbrenv.com/projects/view/126

And, since FLPMA is a central to this Preliminary EA, what ever happened with the proposed land exchange, where Thompson Creek Mine wanted to swap 900 acres (of probably useless land) for 5,000 acres of public land.  Remember, FLPMA directs that the BLM is to manage public lands so they they will “best meet the present and future needs of the American People.”  Will we be able to enjoy or use the proposed 900 acres if they are given to us by Thompson Creek Mine in this land swap?  http://www.gpo.gov/fdsys/pkg/FR-2010-08-03/html/2010-19054.htm

Public Rangelands Improvement Act of 1978 – by BLM’s own acknowledgement, directs BLM to continue the policy “of protecting wild free-roaming horses and burros…”  How are you “protecting” wild horses when you’re facilitating the demise of the variablity and viability of the herds?

Challis Resource Management Plan (RMP)
– 185 is the LOW AML and 253 is the HIGH AML for wild horses and the BLM may “adjust horse numbers to a lower level if causing unacceptable levels of resource degradation.”  The amount of “unacceptable levels” and “resource degradation” that wild horses might cause are MINISCULE compared to the degradation caused by other uses (again, the nearby Thompson Creek Mine, which I assume is also within the Challis RMP area).  Why is the risk of water contamination by the Thompson Creek Mine “acceptable?”  Why, when the RMP was being prepared, did the BLM, who participated in the process, not demand a higher AML for the wild horses?

BLM POLICY – is just that, it’s POLICY, and not law.  Is it BLM policy to waste  hundreds of thousands of taxpayer dollars rounding up only an “excess” of only 69 wild horses (calculated from the high AML)?