To: Bureau of Land Management
Re: Jackson Mountains Wild Horse Herd Management Area Plan
Please accept this public comment on the proposed Jackson Mountains Wild Horse Herd Management Area Plan.
The current draft does not provide enough clear, science-based information to support the major decisions it proposes. The plan should be revised before it moves forward because it fails to fully explain how key decisions were made and does not adequately protect the long-term survival of these wild horses.
1. Jackson should not be treated as one single herd
BLM’s own information shows that the North (Bottle Creek) and South areas are different subpopulations. Those groups face different conditions and different threats, and they should not be managed as if they are one single, interchangeable herd.
The plan should analyze the North and South areas separately, set separate management levels, and explain how each group will remain genetically healthy over time.
2. BLM must clearly explain how AML was set
Appropriate Management Level, or AML, is the number that drives removals, fertility control, and the future of the herd. Yet the draft does not clearly show the public how that number was calculated or whether the old assumptions still make sense today.
BLM should provide the actual data and analysis behind AML, including forage, water, habitat conditions, and current environmental realities such as drought, fire, and range degradation.
3. The plan should not hide invasive sterilization behind misleading language and should not even include such an invasive measure with so little analysis of management alternatives
Jackson’s draft HMAP and related NEPA documents open the door to extremely invasive management tools, including the surgical sterilization of mares. That is especially alarming because the plan is already dealing with a population divided into distinct subunits and already at risk from low genetic numbers even before any fertility control is imposed.
BLM appears to frame sterilizing mares already counted within AML as though it is being generous by allowing more horses to stay on the range. But these are not extra horses above AML being spared removal. They are horses that would already remain on the range under the agency’s own AML framework, now being permanently altered instead.
The public should not accept this rebranding. Surgical sterilization is not a gift to wild horses. It is a permanent and invasive intervention imposed on animals that BLM already planned to leave on the range. Sterilization must be omitted from the final plan.
4. The plan ignores major outside pressures on the herd
The draft does not fully analyze major outside impacts, especially mining and related development that could affect habitat, water, movement, and long-term survival in the northern part of the HMA.
A real management plan must look honestly at all major pressures on the herd, including industrial development and other habitat disturbances, before approving actions that permanently reduce the horse population.
5. BLM must address livestock impacts before reducing horses further
The plan does not seriously evaluate how livestock grazing affects the range, especially in the southern area, and it dismisses livestock reduction as outside the scope. That is not acceptable when BLM is proposing more removals and invasive interventions on wild horses.
Before reducing wild horses further, BLM should fully analyze livestock impacts and consider whether changes in grazing management could reduce conflicts and protect habitat.
Request
BLM said they would actually disclose data, methodology and analysis on these and other issues at Jackson Mountain both during and after litigation in 2012. BLM cannot roll back that language.
BLM should withdraw this draft and issue a revised plan that includes separate analysis for the North and South subpopulations, a transparent explanation of AML, full disclosure of mining and other habitat impacts, a full and honest analysis of sterilization impacts, and a serious analysis of livestock use and alternatives.
Until that work is done, BLM should not move forward with actions that could permanently reduce, surgically alter, or biologically weaken the Jackson Mountains wild horse population.