I submit the following scoping comments for DOI-BLM-WY-D040-2024-0101_EA, "Gather Plan to Remove Excess Wild Horses from Herd Areas Previously Designated as Herd Management Areas"

 

1. The legality of the underlying EIS that sets the AML at zero (DOI-BLM-WY-D040-2013-0001-RMP-EIS) is a question currently before the court. No action should be taken before adjudication including moving forward with a draft Gather-EA.
2. The scoping notice indicates removals of nearly 5,000 wild horses will begin in fiscal 2025 (October 2024) signifies BLM will move swiftly in crafting a Gather-EA to complete the "zero out." Again, we urge caution until the courts determine the legality of EIS and underlying factors. 
3. BLM identifies only 2 alternatives in the scoping notice: remove with helicopters and bait trapping or not remove at all. BLM should add a 3rd alternative that uses small removals, data collection to evaluate an AML that would be manageable and a resetting of AML in the HMAs instead of "zeroing out."
4. BLM did not complete/update the Herd Management Area Plan (HMAP) process for the herds it proposes to zero out. The HMAP should have evaluated mitigation measures such as land swap to address conflicts with livestock and the pipeline. BLM must complete an HMAP before taking action to complete the objectives in the EIS to determine if there are alternatives (such as mitigation through tiered small removals to set a new AML, land swap, etc.)
5. Please address how removal of all of the wild horses in the areas BLM proposes to revert to Herd Area status (zero out) impact fire fuels as this was never addressed in any HMAP in the Gather-EA analysis.
6. Please include the HMAP process in DOI-BLM-WY-D040-2024-0101-EA.

 

Thank you for the opportunity to comment.