You can sign onto the public comment letter for Stone Cabin and Saulsbury draft 2022 BLM Environmental Assessment (EA); a ten-year mashup of multiple forms of fertility control and roundups. Deadline is November 23.
I, the undersigned, submit the following comments:
This PEA represents a flawed Appropriate Management Level (AML) that was estimated more than 30 years ago. This PEA, and all noted underlying documents, do not provide any formula of how AML was set or when it (the formula or actual AML) would be revised. These are parameters an HMAP-EA would fully outline. The document does not reflect an HMAP revision or any equivalency. BLM must prepare an HMAP or amend this PEA to reveal data and equations used to set AML.
The 2022 monitoring BLM notes on this PEA are primarily to expand the use of livestock and are not adequate to demonstrate validity of AML or determine excess wild horses.
The Monitor USFS WHT is located in between the Saulsbury and Stone Cabin HMAs, no studies have been done to show which populations spend more time on BLM or USFS land denoting jurisdiction for removal or population growth suppression tools, determining if horses are in fact off-HMA or representative of transitory movement (that may have always existed and has increased due to human activity) and setting an accurate AML. This PEA was not presented as a joint EA (or EIS) with USFS. Therefore, this PEA is inaccurate, does not adequately represent appropriate jurisdiction of the resource that is the subject of this proposed activity and must be set aside.
The Gather-PEA includes multiple studies on the procedures, substances, devices, individually but not compounded or “cumulatively.” The combination of long-term mashups of fertility control, or if fertility control is even appropriate in each sub-unit, might be best addressed in an Environmental Impact Statement (EIS) (if BLM refuses to do that analysis appropriately in an HMAP-EA or within this PEA or RMP revision).
Thank you.