To: Bureau of Land Management
The undersigned urge the Bureau of Land Management to halt the planned Saylor Creek gather and decline to finalize the current Determination of NEPA Adequacy.
There is an error in the legal review of existing NEPA and legal precedent.
The legal issue is not whether BLM now claims the Saylor Creek herd exceeds current Appropriate Management Level. The issue is that BLM already implemented the 2019 Saylor Creek Environmental Assessment, DOI-BLM-ID-T010-2019-0006-EA, to the point of reaching AML in 2020.
BLM’s own public statements show that, after the 2020 gather, the agency released 11 horses back to the range and brought the population to the Appropriate Management Level of 50. Once that happened, the 2019 EA had achieved its stated purpose. It could no longer serve as an open-ended NEPA authorization for future removals whenever the population later changed.
If BLM now believes the herd is again above AML, the agency must make a new excess determination and support any new gather decision with new or supplemental NEPA analysis. A DNA is not a substitute for that analysis where the prior EA has already been fully implemented and the original over-AML condition addressed.
The undersigned therefore request that BLM:
- Cancel or postpone the scheduled Saylor Creek gather.
- Decline to finalize the current DNA.
- Prepare a new or supplemental NEPA analysis for any new removal proposal.
- Clearly identify and analyze the proposed fertility control method before making a final decision.
Wild horse management must comply with NEPA, comply with existing court precedent, reflect current conditions, and allow meaningful public review.
BLM should not use a spent EA to justify a new round of removals at Saylor Creek.
Sincerely,