The original Tassi-Gold Butte Herd Management Area Plan (HMAP) (BLM 1982) was completed in 1982 and allowed a herd of approximately 90 – 100 wild burros to roam freely in what was the Tassi-Gold Butte HMA at that time. BLM states that the 1998 Decision Record for the Mojave Amendment of the Arizona Strip RMP (BLM 1998) modified the 1982 decision to implement the HMAP and set the wild burro herd management level at zero.

The 1998 Arizona Strip Amendment was simply not an analysis document that would be appropriate to change the 1982 HMAP. Only by open and transparent revelation of data and public participation through the HMAP revision process should any changes be made to ensure appropriate actions. 

BLM has shortchanged both the burros and the public. 

BLM has not done any landscape level analysis to demonstrate that zeroing out the burro population would achieve the goals stated in the proposed action: to zero out the burros. BLM is instead relying on outdated supposition that is not appropriate analysis for such and extreme action. 

Please engage in an open HMAP scoping and crafting a final HMAP revision before moving forward with drafting any gather plan. 

Burros speak loudly to the history and legacy of the area and should be managed to maintain that historic legacy for future generations to enjoy. Burros in this area are a public resource and should be protected as such. 

Thank you.