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Wild Horses and Rangelands in Crisis: horses under-counted more likely




Wild Horses: Short-term Solutions -- Long-term Problems
by Rose Strickland


The Toiyabe Chapter Executive Committee passed a resolution to support Interior Secretary Ken Salazar's wild horse and burro initiative as a short-term measure for wild horses which cannot be adopted.  The federal initiative would set up a system of reserves for horses on grasslands in the mid-West and in other areas for horses now only corralled in Western facilities and also emphasizes increased contraception and herd management as well as continued roundups in order to reduce numbers to sustainable levels on public rangelands.

The Sierra Club letter also stated that long-term solutions to problems in the Bureau of Land Management's wild horse program are equally critical.  These include more transparent information by the BLM on wild horse numbers, Herd Management Areas, impacts on rangeland health, the effectiveness of contraception methods and other management techniques, what managing horses in a "thriving natural ecological balance" means, and the science underlying wild horse management.    This will be a difficult task in the face of the high level of polarization on the issue which is preventing effective discussions on how healthy herds can thrive on public lands in balance with other public resources and multiple uses.

The conclusion states our commitment to finding ecologically and financially sound solutions to the management of our nations's wild horses and burros and our public lands and resources: 

"Our members very strongly value our public lands, our wildlife, our wild lands and our wild horses.  We believe that wild horses and burros are an integral part of our national public lands heritage and their humane treatment is universally supported.  Sierra Club conservationists have worked for over 30 years on public lands issues in Nevada...We look forward to working with you on long-term solutions for sustainable uses of public lands and resources by wild horses and burros and all other multiple uses."

Equus Pacificus from 25,000 years BP found near Pyramid Lk, NV.

Horse Talk
by Rose Strickland

Range cons, wild horse enthusiasts, academics, tribal and animal rights representatives, scientists, hunters, ranchers, state and federal agency managers, politicians and conservationists gathered in early November to discuss management and public policy on wild and feral horses and burros in the US.x The conference, called by the Society for Range Management and co-sponsored by the Sierra Club, was held at the Sparks Nugget and included a tour of wild horse facilities north of Reno.

The purpose of the conference was a twofold search for practical solutions both to the current wild horse and burro dilemma on public rangelands and to the issue of domestic horse disposal and release upon public and private lands since the downturn in the economy and the lack of economic disposal methods due to closure of all horse slaughter facilities in the US. Panel presentations were designed to establish basic ecological, biological, and economic realities surrounding both feral and wild horse management, since practical solutions must be based upon these realities. In short, the wild horse dilemma was presented as increasing wild horse and burro populations and negative impacts on wildlife and other multiple uses of public lands, declining adoption demand, and increasing costs for BLM holding facilities and the feral horse disposition problem as destroying the domestic wild horse market.

Discussions were difficult due to the strongly held, yet polarized positions on both problems as well as potential solutions to these multi-faceted issues. Much support was expressed for keeping wild horses and burros on public rangelands in "thriving natural ecological balance" as mandated by the 1971 Wild Horse and Burro law, but there was little agreement on what constituted "thriving ecological balance." Little support was expressed for H.R. 1018, the Rahall bill. Some support was expressed for Interior Department Secretary Ken Salazar's Wild Horse and Burro Initiative as a good beginning if not a total solution and for legislation known as H.O.R.S.E.

Tribal representatives told the conference participants that over 20,000 wild horses on reservations were not counted in the Dept. of Interior population estimates nor addressed in Secretary Salazar's initiative, but were causing the same adverse impacts evident on public lands. Domestic horse breeders explained some of the unintended consequences of a recent ban on horse slaughter in the US, including abandoning pet horses and dumping horse carcasses since no "legal" and affordable disposal options are now available to horse owners.

All agreed that there is a need for credible information and education about wild horses, their management, impacts upon rangeland ecosystems, population numbers and dynamics, fertility control and alternative management options.

See the Sierra Club Feral Animal Policy for public lands here. (http://www.sierraclub.org/policy/conservation/feral.aspx) For more information on how a non-profit organization is facilitating wild horse adoptions, go to: www.mustangheritagefoundation.org. If you're interested in feral horse problems and domestic horse issues, you can find out more at: www.unitedorgsofthehorse.org.

See Washington Post article on Secretary Salazar's Plan: Salazar Presents Ambitious Plan to Manage Wild Horses Preserves in Midwest and East, Sterilizations Proposed as Population Grows Beyond Control in West.


WHAT YOU CAN DO

  1. WHAT ARE THE PROBLEMS?:  Do your homework and research the issues:  wild horse impacts on rangeland health and native species and their habitats, BLM management - what works and doesn't work, how does monitoring help determine range ecosystem health and "thriving natural ecological balance," how forage is divided among wildlife, livestock and wild horses, and wild horse management including adoptions, effectiveness of contraception, and where and when roundups are needed.  If you're very interested, check out the laws and regulations which govern BLM management of public lands, wild horses, and all the multiple uses and decide whether the laws work or not.
  2. ASSESS PROPOSED SOLUTIONS:  Study Department of Interior Secretary Ken Salazar's initiative on addressing current WH&B issues.  If you support the DOI proposals or if you have other ideas on how to address the multiple and complex issues of public  lands and wild horses and burros, write a letter to Secretary Salazar and copy the Nevada Congressional delegation - Senators Reid and Ensign and your Congressperson.
  3. BECOME A PUBLIC  LANDS ACTIVIST:  Public  lands and wild horses and burros belong to the American public.  Figure out how to take an active part in decisions being made every day on grazing, wild horses and burros, recreation, wilderness, wildlife habitat, mining, roads, ATVs, land disposals, and the myriad of other public resources being managed by the Bureau of Land Management, the US Forest Service, the US Fish & Wildlife Service, the National Park Service, and the Bureau of Indian Affairs.  If your interest is in native wildlife, get involved with the programs of the Nevada Department of Wildlife whose professional wildlife biologists are under attack and the USFWS which is making a decision soon on listing Sage Grouse under the Endangered Species Act.
  4. SIERRA CLUB VOLUNTEER:  Join the efforts of Sierra Club chapter activists to keep public lands public, improve public rangeland conditions, protect native wildlife and resilient habitat, and preserve wild horses and burros.  Write letters, lead field trips, testify at hearings, inform our members and the public on both problems and solutions - some of the many activities in our conservation campaigns.

Secretary Salazar's Letter to Harry Reid on Wild Horse and Burro Plan

Questions and Answers on the Secretary Salazar's Wild Horse and Burro Plan


Wild Horses: A Current Crisis

Chapter leaders recently discussed what policies and actions the Sierra Club should adopt and imple- ment on the current wild horses and burros (WH&B) crises. Consideration was given to members’ often passionate opinions as well as to input on possible policies and over 30 years of work by conservationists on public land issues in Nevada, the Eastern Sierra, and other parts of the West.Wild Horses

The Sierra Club has long been active on this issue. With WH&B overpopulations on public rangelands, proposed legislation in Congress, shortfalls in BLM budgets, falling adoption demands, and rumors of BLM using its authority to euthanize excess unadoptable animals, the chapter ExCom voted to reaffirm Sierra Club policies on WH&B and to take a strong role in pending WH&B legislation.

Chapter leaders have submitted comments on H.R. 1018, sponsored by Congressman Rahall.  The legislation does support needed changes to the BLM’s management and adoption program, but includes provisions that will undermine Congressional mandates for environmental protection, healthy rangeland ecosystems, and multiple use of public lands.



Editorial: Wild horse advocates aren't doing the animals any favors

DECEMBER 9, 2009 (Reno Gazette Journal)

If the Bureau of Land Management's numbers are correct, wild horse advocates are doing their charges no favors by delaying the BLM's plans to round up thousands of horses across the West in the coming months.

Left on the public range to fend for themselves, those horses quickly could run out of the forage they depend on for food, and, yes, many will die from starvation. So will other wildlife that can't compete with the horses for the already scarce resources.

And the BLM, accused of wildly overestimating the number of wild horses on the ranges and mistreating those it rounds up, will be blamed for that, too.

This battle, which has been going on for decades, is one that the BLM needs to win but cannot.

It's not a fair fight, of course.

The opponents of the roundups have the power of mythology on their side -- the romanticism of the free spirits racing across the West, a throwback to the days before man put up fences (although supporters of reducing the numbers of wild horses insist that most are simply horses that were once tame but either escaped their owners or were set free by those who didn't want them any more).

The BLM has ranchers (vilified for ruining the public lands with their cattle) on its side. It has hunters. It has rural residents.

But the opponents have Hollywood stars on their side. They have folks who love the idea of wild horses, even if they know little about the reality. They have children on their side. They have the Nevada quarter.

Also on the advocates' side is many years of the federal government's own ineffective and absurdly expensive efforts to control the wild horse population in Nevada and throughout the West.

The BLM's current estimate is that there are 37,000 wild horses and burros on public lands in the West, about half of them in Nevada. (Opponents of the roundup believe it's more like 15,000.) However, nearly that many, 34,000, are kept in government-run corrals and pastures. Already this year, the BLM has spent $50 million to manage the wild horses in the West; last year, it was $36 million. As the numbers increase, so do the costs.

Finally, the advocates have pictures on their side -- pictures of horses desperate to escape the terror of helicopters chasing them into pens and pictures of cowboys roping them and leading them into captivity.

Given all of that ammunition on the advocates' side, it's surprising that anyone spoke in favor of the roundups at the hearing held by the BLM's National Horse and Burro Advisory Board in Reno this week. Who wants to dash the dreams of children, after all? Who wants to destroy the "symbol of Nevada"?

Yet, it does no good to pretend there are no problems with giving the horses free rein throughout the West. Nor does it do any good to demonize anyone who argues that the horses need to be controlled, for their own good if for no other reason.

It's long past time to put an end to these disputes, which accomplish little beyond making the plight of the horses worse -- whether they're on the range or in government corrals. It's time to temper the romanticism with a little reality. It's time for a policy that may not make everyone happy (that's probably impossible under the circumstances) but will protect the horses from their own fecundity.

Leaving them to starve to death on the range is not the way to honor them.

Sierra Club Comments on H.R. 1018

June 1, 2009

The Honorable John Ensign
400 So. Virginia #738
Reno, NV  89501

Re:  H.R. 1018

Dear Senator Ensign,

Although there is no companion legislation yet introduced into the Senate, we wanted you to have our comments on this bill which would disastrously affect both Nevada's wild horses and public lands and add considerable costs to the wild horse and burro management and adoption program.

On behalf of the 5,500+ members of the Toiyabe Chapter of the Sierra Club in Nevada and the Eastern Sierra, I am submitting these comments about our concerns with H.R. 1018.  Unfortunately, we must oppose this legislation as written because it does not resolve many problems facing the Bureau of Land Management's (BLM) wild horse and burro program and also causes new problems. 

Our members very strongly value our public lands, our wildlife, our wilderness areas, and also our wild horses.  Sierra Club conservationists have worked for over 30 years on public land issues, providing comments on Environmental Impact Statements and Environmental Assessments and on public land management and grazing plans, taking range tours, participating on BLM advisory committees, developing standards and guidelines for healthy rangelands, participating on the Nevada Governor's Sage Grouse Conservation Planning team, and serving on many "consensus" groups addressing livestock, wildlife, and wild horse and burro issues, on-the-ground. 

As you know, Nevada has the largest number of wild horses and burros in the West.  Yet Nevada's rangelands have been devastated lately by extended droughts and wildfires burning millions of acres of public and private lands, are threatened by proposed massive groundwater withdrawal projects and increasing risks to Sage Grouse and other native endemic species, all in the face of budgets which are inadequate to monitor and manage our public lands and resources.

The multiple crises of overpopulations of WH&Bs, inadequate adoption demand and skyrocketing costs of BLM holding facilities prompted us to conduct an informal poll of the opinions on various wild horse and burro issues of our members and leaders, knowledgeable resource managers and other conservationists.  The full (and passionate) range of positions on these issues were reflected in the poll results.  Yet the underlying beliefs in environmental protection, humane treatment of all animals, healthy ecosystems and our native wildlife were very strong.  Subsequently, our Executive Committee recently voted to reaffirm our national Sierra Club policies on resource protection and to convey our concerns about H.R. 1018 to our elected officials and the Department of Interior.

While HR 1018 includes provisions which we believe are needed, if adequately funded, to improve the wild horse and burro management and adoption program on public lands, the Toiyabe Chapter of the Sierra Club must oppose this bill because of provisions which we believe would undermine public land and environmental protection laws and not improve WH&B management nor the adoption program. Our detailed comments follow:

1.  Weakens the Wild Horse and Burro Act's mandate for "thriving natural ecological balance" on public rangelands and environmental protection laws:  While mandating BLM's wild horse and burro management to meet this standard (Sec.4(a)(3) and (5), the bill also proposes provisions which would prohibit the Secretary of Interior and the BLM from actually meeting this requirement:    

    a.  Sec. 4(d) apparently prohibits removal of any wild horses and burros, even those exceeding Appropriate Management Levels (AMLs) and even when current populations of wild horses and burros are destroying or harming rangeland ecosystem health and and native wildlife habitat unless the Secretary determines that an adoption demand exists.  If adoption demand does not exist, then the bill language implies that BLM cannot capture and remove animals which are damaging public rangelands.  We doubt whether the Secretary can make this determination given declining adoption rates in recent years and increases in releases of domestic horses by private owners onto public lands due to the economic downturn.  Therefore, this provision cannot meet the mandate for "thriving natural ecological conditions."

    b.  Sec. 4 (d)(4) restricts holding wild horses and burros actually removed from public lands to 6 months.  If not adopted, the bill implies that these excess unadoptable animals will be returned to degraded rangelands.  This action also cannot meet the "thriving natural ecological balance" mandate.

    c.  Sec. 4(h) provides for "temporary" removal to protect the health and safety of wild horses and burros, citing the example of a drought.  However, droughts are rarely over in 6 months nor can most rangelands recover in 6 months from extended droughts.  Nor are areas devastated by wildfires rehabilitated in 6 months.  How long is "temporary" removal?  If it's longer than 6 months, does this provision require the BLM to return wild horses and burros to public rangelands in poor ecosystem health?  If so and the animals die of thirst and starvation, we do not believe that this proposed legal mandate is either humane or meets the legal mandate for "thriving natural ecological balance."

    d.  Sec. 4 (g) reverses the existing Congressional mandate for BLM to euthanize excess, unadoptable wild horses and burros.  Instead, neither of the bill's two alternatives  - maintain environmentally destructive levels on public rangelands and/or put free roaming animals into a holding facility for 6 months and, if not adopted, release them back to degraded rangelands - will achieve a "thriving natural ecological balance."  Since BLM has never used its existing authority to destroy wild horses and burros, there is no logical basis for claiming that BLM has abused this authority.  To ensure that this necessary authority is not abused, we suggest that a provision be added to the bill to require public notice and a public hearing before BLM euthanizes any wild horses and burros.

    e.  Sec. 4 (c)(9) mandates research, development, and implementation of "enhanced" fertility control of wild horses and burros. 
        o  We know of no evidence that past fertility control programs  have been cost-effective. 
        o  Since BLM does not conduct "research,"  would this be contracted to other governmental agencies or universities?   
        o  Frequent capture and handling of wild horses and burros is incompatible both with achieving a "natural thriving ecological balance" and the preserving the free-roaming nature of these animals.

    f.  Sec. 4 (a)(5) mandates "minimal management" of wild horses and burros to protect the natural ecological balance of all wildlife species, especially endangered species.  This provision ignores the fact that it is lack of management which properly addresses overpopulation of WH&Bs which is destroying or damaging wildlife habitat, including the habitats of threatened, endangered, and sensitive species.  In reality, the BLM is already able to provide only "minimal management" of WH&Bs on public rangelands since over 73% of its budget is consumed by the holding and adoption program.  Also, in reality, it will take tremendous improvements (including large increases in annual budgets) in the BLM's wild horse and burro program to "protect the natural ecological balance of all wildlife species," even minimally. 

2.  Attack on federal mandates to manage public lands for multiple uses:   While not specifically stating that the bill would amend the Federal Land Planning and Management Act (FLPMA),  H.R.1018 apparently proposes to elevate wild horses and burros over all other uses and users of public lands.

    a.  Sections 3(a)(2) and 4 (c)(8) require the designation and maintenance of sanctuaries or exclusive use areas for wild horses and burros on public lands.  Not only would exclusive wild horse and burro use areas violate FLPMA multiple use requirements, we question whether these provisions could be carried out.  How would the BLM eliminate all native wildlife from these "exclusive" areas?  Why would the public and public land users support eliminating grazing, recreation, wilderness, mining, and the other multiple uses from our public lands for the exclusive use of wild horses and burros? 

    b.  The  mandate for exclusive use areas should be changed to a mandate for BLM to consider sanctuaries as part of the land use planning process on public lands, subject to requirements of FLPMA, National Environmental Policy Act (NEPA), and other legal requirements.

    c.  Sec. 4 (a)(6) apparently re-defines wild horses and burros as "wildlife" since it requires "any adjustments in forage allocations are made after taking into consideration the needs of other wildlife species."  WH&Bs are neither "wildlife" nor are they "domestic livestock."  This language should be clarified and corrected.

    d.  These provisions apparently exempt wild horses and burros from meeting standards and guidelines set by the BLM to achieve healthy rangeland ecosystems.

3.  Undermining other environmental protection laws:  Bill provisions which require the BLM to maintain levels of wild horses and burros which are destroying or damaging wildlife habitat, habitat for threatened, endangered, and sensitive species, especially Sage Grouse in Nevada, and the health of rangeland ecosystems and other environmental resources, and to establish or expand WH&B use areas on public lands and use "enhanced" fertility control measures on WH&Bs without any consideration of environmental impacts or the impacts on a thriving natural ecological balance would violate  environmental protection mandates of the NEPA and other laws..

4.  Prohibition of BLM's WH&B management tools:  Sec. 4 (d)(3) prohibits BLM from using helicopters to capture wild horses and burros, even in cases where it is the most humane roundup method. 
    a.  In parts of Nevada which are characterized by rough, rocky country, chasing wild horses and burros with domestic horses is dangerous to horses and riders.  Herding WH&Bs using vehicles or ATVs is also dangerous, if not impossible.  We believe that proper use of helicopters for roundups results in fewer injuries to wild horses and burros and federal managers and their horses. 
    b.  We note that H.R.1018 does not prohibit the use of helicopters or other aircraft by BLM in conducting inventories of wild horses and burros.  In fact, there is no other way to achieve accurate counts of wild horses and burros, or of deer, antelope, elk and other animals which cannot be counted from the ground.  We question why helicopters are appropriate tools for wild hors and burro  inventories, but not for roundups.

5.  Provisions which we could support:  Provisions requiring improvements in BLM's wild horse and burro program could address some of the existing problems, but are very expensive and, if not properly funded, would result in taking yet a greater percentage of the limited BLM's WH&B budget away from its management responsibilities.

    a.  Sec. 4 (b) requires the BLM to maintain an inventory of wild horses and burros, update it annually, and publicize inventories by Herd Management Areas (HMA). 

    b.  Sec. 4 (c) requires the BLM to take actions to improve wild horse and burro management but sets an unrealistic one year deadline.  Many of the proposed actions may have significant impacts on the environment and the management of other public lands uses.  We strongly urge that the bill include a requirement for the impacts of these actions to be assessed in a full and open Environmental Impact Statement process and incorporated into the existing land use plans through amendments. 
        1.  Sec. 4 (c) (1):  improve the process for estimating numbers of wild horses and burros.  While improving count methodology is supportable, it is not clear that any methodology will solve the problems of wild horses and burros moving across HMA boundaries or across BLM district and state boundaries.  Nor will it provide a way to track the increasing numbers of domestic horses being turned out on public lands by their owners who can no longer afford their care.
        2.  Sec. 4 (c) (2):  develop a policy for setting consistent AMLs.  We suggest that a BLM handbook would be more effective in setting standards to achieve "consistent" AMLs, rather than a study on a new "policy."
        3.  Sec. 4 (c) (3):  provide a public process for final AML standards.  This process should occur as part of an overall EIS on significant changes in the wild horse and burro and other public lands programs.
        4.  Sec. 4 (c) (4) and (5):  provide training to each BLM field office in the use of standard techniques and methodology in estimating wild horse and burro populations and determining appropriate management levels.
        5.  Sec. 4 (c) (6):  consult with federal and state agencies and others.  We request that the criteria for individuals with "scientific knowledge and special knowledge" be expanded to include biodiversity, ecosystem health, and global warming impacts on public lands.
        6.  See our comments above in #s 1, 2, and 3 which explain our opposition to provisions in Sec. 4 (c) 7), (8), and (9) which weaken or exempt wild horses and burros from compliance with existing federal land management and environmental protection laws and which also require unnecessary frequent capture and handling of these free-roaming animals.
        7.  Additions:  we would recommend that the WH&B program EIS also examine existing the environmental impacts on "thriving natural ecological balance" of existing BLM management practices, such as manipulating herd sex ratios, capturing an entire herd and then selectively releasing "desired" animals back on public rangelands, and neutering of both males and/or females.

    c.  Sec. 4 (f) requires the Secretary to take actions within one year to improve the wild horse and burro adoption program.  We don't know if all of the actions can reasonably be implemented in one year.  In any event, many are very expensive and will require significant increases in BLM's wild horse and burro adoption program budget by Congress.  We support, if properly funded, provisions in Sec. 4 (f)(1), (2), (3), (4), and (5).

6.  Other: 
    a.  Sec. 11 requires a number of reports from the secretary with a one year deadline. 
        1.  Sec. 11 (C) requires a description of the methods used to determine the AMLs and the degree of consistency in how these methods were used.  Sierra Club members participated over 20 years in many BLM "consensus" processes in which AMLs were "negotiated."  We do not recall any environmental assessments nor suitability studies to justify or provide any scientific rationale for the #'s on which the groups achieved consensus.  Many of the participants have retired or are deceased, so reconstructing the history of how AMLs were set will be a real challenge to the BLM.  In any event, we believe that the entire process of setting AMLs as well as HMA boundaries should be reopened and examined in a full Environmental Impact Statement process, as suggested above..
        2.  We request that other reports be required on the wild horse and burro program, including:
            a.  What is the current ecological condition of all HMAs?  On what data is this condition assessment based?
            b.  How often does the BLM monitor livestock and wild horse and burro use as well as the condition of public rangelands - annually, every 2-5 years, or over 5 years? 
            c.  Has BLM ever determined the suitability of HMAs for wild horses and burros?  Through what process?  Was this a public process?  Is there sufficient forage and available water in each HMA for the AML #s or the actual populations?
            d.  Are current populations of wild horses and burros meeting standards and guidelines for healthy rangelands in each HMA?  On what data is this report based?
            e.  What impacts on native wildlife, including threatened, endangered, and sensitive species are actual #s of wild horses and burros having, both within HMAs and outside HMAs?
            f.  What percent of the BLM budget is spent on actual management (including monitoring) of wild horses on public rangelands?

Thank you for considering our comments.  Please contact Rose Strickland at 775 329-6118 if you have any questions about these comments.

Sincerely,

Toiyabe Chapter Public Lands Committee



Chapter Support's Interior Secretary Ken Salazar's Wild Horse and Burro Initiative


February 24, 2010

Mr. Ken Salazar, Secretary Department of Interior
1849 C. St. N.W.
Washington D. C. 20240

Dear Secretary Salazar:

On behalf of the 5,000+ members of the Toiyabe Chapter of the Sierra Club in Nevada and the Eastern Sierra, I am pleased to advise you of the Toiyabe Chapter's support for your October 7, 2009 initiative to create a sustainable national wild horse and burro (WH&B) program where healthy herds can thrive on public rangelands in balance with other public resources and multiple uses. We believe that the Department of Interior initiative is critically needed to address short-term problems in the Bureau of Land Management's WH&B program (BLM). For equally critical long-term problems, we recommend that the BLM address the public criticism of the WH&B management on public lands by conducting a comprehensive Environmental Impact Statement (EIS) on its program.

On January 30, 2010, our Executive Committee passed a resolution which supports your WH&B proposal as a positive step in addressing unacceptable wild horse and burro impacts on rangeland health, curtailing non-sustainable budget requirements for current holding costs, and showcasing the nation's wild horses and burros on public rangelands and reserves all across the country. While we support increased use of humane contraceptive programs, we do not believe that research has shown existing methods are cost-effective. Other contraceptive approaches are needed.

As you know, Nevada has the largest number of wild horses and burros in the West. Your proposal estimates 37,000 horses on BLM lands and 32,000 in short and long term care. We would like to point out to you that these estimates do not reflect horses on US Forest Service land, US Fish and Wildlife Service land, tribal lands or state lands. Your initiative needs to include solutions for all excess wild horses, not just those on BLM-managed lands.

Removing wild horses and burros from public lands remains controversial, not just for the BLM and the Department of Interior, but also for the Sierra Club and other conservation groups. The Sierra Club receives harsh criticism from some of our members and from wild horse enthusiasts when we support BLM wild horse roundups on Nevada's public lands. Critics question the need for removing any horses and appear not to understand WHY there can be too many horses at all or why reserves or population controls are needed.

Unfortunately, there is little credible information available to the public on the many burning
issues. These include the number of wild horses and whether they are in danger of extinction, how much ecological damage is being caused by excess wild horses and how much land is needed for wild horses. Many remain polarized on policy issues such as whether contraception is needed or humane, whether and how excess wild horses should be rounded up, what should happen to captured horses for which there is no adoption demand, even whether WH&Bs should be left to die of thirst or starvation on degraded public rangelands.

Therefore, we urge you to direct the BLM to initiate a comprehensive Environmental Impact Statement to address these issues and the environmental impacts of the WH&B program. All topics should be on the table, including how wild horse numbers are estimated and estimate's reliability, examining the scientific basis for setting and changing Herd Management Areas and Appropriate Management Levels, assessing WH&B impacts on ecosystem health and other multiple uses, the scientific basis for horse management approaches (contraceptive procedures, roundups, manipulating herd ratios, selective management - only males, only females, only neutered herds), and better define the criteria for determining "thriving natural ecological balance" of WH&Bs. Other issues should be studied: the ecological conditions of HMAs and their suitability (and how these are determined), whether standards and guidelines for healthy rangelands are being met (and how this is determined), and how much monitoring is required.

The Toiyabe Chapter of the Sierra Club is strongly committed to finding ecologically and financially sound solutions to the management of our nations's wild horse and burros and our public lands and resources. Our members very strongly value our public lands, our wildlife, our wildlands, and also our wild horses. We believe that wild horses and burros are an integral part of our national public lands heritage and their humane treatment is universally supported. Sierra Club conservationists have worked for over 30 years on public land issues in Nevada, providing comments on Environmental Impact Statements and Environmental Assessments and on public land management and grazing plans, taking range tours, participating on Bureau of Land Management (BLM) advisory committees, developing standards and guidelines for healthy rangelands, participating on the Nevada Governor's Sage Grouse Conservation planning team, and serving on many collaborative groups addressing livestock, wildlife, and wild horse and burro issues, on-the-ground.

We thank you for your leadership in tackling short-term problems of the WH&B program with this iniative. We look forward to working with you on long-term solutions for sustainable uses of public lands and resources by wild horses and burros, and all other multiple uses.

Sincerely,

Public Lands Chair

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