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new-logo25Debbie Coffey    PPJ Investigative Reporter          Copyright 2013        

Director of Wild Horse Affairs, Wild Horse Freedom Federation    


The Nevada Bureau of Land Management (BLM) Drought Management Environmental Assessments have omitted any mention of the big water guzzling uses, like mining, oil and gas development and solar, but go into detail in an array of plans to get rid of more wild horses and livestock (which compared to these other uses, hardly use any water).

The BLM has gone all out to make the public believe that man-made causes of drought (less water and palomino-valley-captiveforage because of huge water use by extractive industries), don’t even exist. While the BLM feigns concern about severe drought in Environmental Assessments (EAs), the BLM doesn’t mention one peep about curtailing any usage of water or land by mining, oil and gas development, or solar (which can also use a lot of water) on public lands.

This is the Industrialization of the West, under the guise of “drought.”

On the BLM Nevada Drought Information webpage, the Nevada BLM Drought Handbook  mentions a few other issues, like closing roads and recreation permit stipulations.

But the BLM District Drought Management Environmental Assessments for the Ely, Elko, Winnemucca and Battle Mountain BLM Districts, all contain similar language and focus on removing and diminishing the wild horses and livestock, but NOT one word about mining, oils and gas development, or solar. The BLM has just buried this.

Below are my comments on the Ely District Drought Management Environmental Assessment.


Dear Mindy Seal, Amy Lueders and Rosemary Thomas,

I urge NO ACTION, with the exception of temporary water hauls to wild horses.

“1.2 Purpose and Need for Action:
The purpose of the action is to provide rapid response to drought conditions on the Ely District by adjusting management of wild horses, livestock and other authorized uses.”

This EA ONLY addresses management of wild horses and livestock, but NOT any other “authorized uses.” What does the Ely District Drought Management Plan do to adjust any other uses other than wild horses and livestock in your District? How can you have a District Drought Management Environmental Assessment when ONLY 2 uses out of the many multiple uses in your district are considered?

What about mining? What about oil and gas exploration and development? What about solar? What about geothermal? Aren’t these all “authorized uses” within the Ely District?

The BLM has promised transparency, so the public needs to be informed of the acre feet annually (afa) used by each other use in each hydrographic basin within the Ely District.  These are other factors that should have been included this EA, but were completely omitted.

Any EA for drought management should include ALL of the uses in your district that use water.  If this information is not included in a Drought Management EA, then your office is perpetrating fraud on the American public.

As you should know, mining, oil and gas development, and some types of solar use a lot of water and can drop the water table. In some instances, the BLM has minimized the impact of the use of water by mining operations by not requiring 1’ and 5’ water drawdown maps for the EAs of mines.

page 17 (Wild Horse Removal)
While drought is seasonal, the BLM plans to PERMANENTLY remove wild horses. The BLM plans to only temporarily remove livestock, but to permanently remove wild horses. BLM should do water hauls to avoid removing any wild horses. Rounding up wild horses is much more expensive.

Page 18 (Removal of animals to a point below the low AML)
This will endanger the viability and eliminate part of the thriving ecological balance. How about not having the upcoming Dec. 10, 2013 oil and gas lease sale in your District? How about having active mines or oil and gas leases cut back on production during severe droughts?

Page 20 (Supplemental Feeding of Wild Horses)
“Supplemental Feeding of wild horses on rangelands during times of drought would adversely affect areas on or near the location that feed is being supplied.”

What about adverse affects in many areas in the Ely District during times of drought by other uses? What about all the acres adversely affected by oil and gas development, especially within or near Herd management Areas? If the BLM is so concerned about the drought, shouldn’t you cancel the upcoming December 10, 2013 oil and gas lease sale?

The BLM, while getting rid of wild horses and livestock, is going full speed ahead with plans to expand the Pan Mine Project and Barrick’s Bald Mountain Mine.

Won’t there be any adversely affected areas during future droughts from the planned Pan Mine Project, which expands the original 2011 exploration plan disturbance area from 100 acres to approximately 3,140 acres? This one project will:
The expansion of the boundary is a result of constructing, operating, closing, and reclaiming the following:
• Two main open pits: the North Pan Pit and the South Pan Pit;
• Four satellite pits: the Black Stallion, North Syncline, Syncline, and South Syncline pits;
• Crushing facilities and associated stockpiles;
• Two waste rock disposal areas;
• Heap leach pad, conveyors, processing facilities, and ponds;
• Water supply wells and delivery/storage system;
• Haul and secondary roads;
• Additional exploration within the Plan area;
• Ancillary facilities including: power supply; stormwater controls; reagent, fuel, and
explosives storage; buildings including administration, laboratory, security, warehouse,
core shed, and parking; potable water supply and septic systems; maintenance shop;
ready line; light vehicle wash; communications facilities; helicopter pad; plant growth
medium and woody debris stockpiles; Class III – waivered landfill; area for petroleum
contaminated soils; monitoring wells; borrow areas; fencing; and yards.

This use has much more potential for adverse areas and covers much more area than the small areas where you might temporarily feed some wild horses.

The BLM said of the Pan Mine Project: “The BLM’s Purpose for the Proposed Action is to authorize a legitimate use of public lands, which would allow Midway to construct and operate a gold mine.”
Does the BLM Ely District office consider mining a “legitimate use” of public lands, but wild horses and burros an “illegitimate use” of public lands?
The BLM has stated about Oil and gas leases “Water Resources and Water Rights are not
issues for lease sales, since no ground disturbing activities are associated with the sales per se.”

PER SE? (So, the BLM only looks at the actual lease sales, but can’t imagine the next step, which is development? Is the BLM incapable of foresight in its management of public lands?)

“Any concerns that arise during development of parcels subsequent to lease sales would be handled through design features, mitigation measures, and/or project stipulations.”

OR NOT. Has anyone in the Ely District office read about fracking? If not, here are a few links:

How Rural America Got Fracked

Fracking Our Food Supply

Fracking Damage Cases and Industry Secrecy
Pages 50-52
Since this EA addresses Socio-Economic Values, please consider this:
Resource Curse: Why the Economic Boom That Fracking Promises Will Be a Bust For Most People (Hard Times, USA)
Page 67
There are no GPS coordinates or dates the photos were taken for the photos. This is unscientific.

Page 70
There are no GPS coordinates for these photos. This is unscientific.

Pages 70-71
“Wild horses also cause damage through excessive trailing and hoof action, which causes destruction of vegetation and increases erosion and trampling of riparian areas; thereby causing bank shear, contaminating water quality and affecting riparian function.”

I’m glad the Ely District office brought up contaminating water quality as a concern, since your office is forging ahead with plans to expand Bald Mountain Mine. What about all the arsenic and mercury contamination of surface water that has already been caused by that mine?
BLM stated “In general, established background water quality levels are good with the exception of arsenic, which exceeds the 0.05 mg/l Nevada water quality standard.”

Are you just going to allow this mine to cause more contamination to water? I wrote an article about this mine and the water contamination. Here is a link:

Also, since your office is concerned about water contamination, please read these articles:
New Study Predicts Frack Fluids Can Migrate to Aquifers Within Years

Fracking Wastewater Can Be Highly Radioactive

Finally, since the BLM brings up destruction of vegetation, increased erosion and the trampling of riparian areas, have you ever looked at satellite photos of the areas of the mines? You should go to google earth and type in Ruth, Nevada. Just south of the town, it looks like there is a mining project that seems to be about 30 miles wide! Bet that kicked up a little dust.

Also, you can look here (you can even type Bald Mountain Mine in the search box and look at it):
Has your office seen any photos of oil fields? Look at this:

Talk about the trampling of riparian areas! This destruction to rangelands is no comparison to some trailing and hoof action caused by some wild horses. Don’t you feel kind of silly for even mentioning “trailing and hoof action” now? (If not, you should.)

And, last but by no means least, don’t forget about the water grabs that are going on!

Page 78 Fertility Control
BLM should not be considering fertility control on non-viable herds.

Map 1.2 Ecoregions on the Ely District
Please cite the U.S. LAW that authorizes “Ecoregions” (not just DOI policy or regulations).

In conclusion, you might want to google the name of your state + BLM to see if your state BLM is making similar “drought” plans. Look at your state’s BLM page and the BLM district office maps to see which district includes your city (even big cities like Los Angeles are part of a BLM District), and keep an eye out for what is being planned in your state and in your district, because public lands are being robbed blind.



How Rural America Got Fracked

Fracking Our Food Supply

Fracking Damage Cases and Industry Secrecy

New Study Predicts Frack Fluids Can Migrate to Aquifers Within Years

Fracking Wastewater Can Be Highly Radioactive

Resource Curse: Why the Economic Boom That Fracking Promises Will Be a Bust For Most People (Hard Times, USA)