KBR Wild Horse and Burro News
  REPRODUCTION OF LETTER
FROM: WILD HORSE & BURRO FREEDOM ALLIANCE
     TO: BLM - WYOMING
 SUBJ: POSITION STATEMENT OF FUND FOR ANIMALS, ET AL,
            RE. PROPOSED WYOMING WILD HORSE GATHERS
 DATE: Februatry 17, 2000

Mr. Kurt Kotter, Field Manager
Rawlins Field Office 
Bureau of Land Management 
P.O. Box 2407
Rawlins, WY  82301-2407

Re: Environmental Assessments  WY-030-EA0-037 and WY-030-EA0-038

Dear Mr. Kotter:

On behalf of The Fund for Animals, the American Society for the Prevention
of Cruelty to Animals, the Animal Protection Institute, the Animal Welfare
Institute, the Colorado Wild Horse and Burro Coalition, the Doris Day Animal
League, Redwings Horse Sanctuary and Wild Horse Spirit, with a combined
membership totaling over one million members and supporters,  thank you for
the opportunity to submit comments on Environmental Assessment
WY-030-EA0-037, Maintaining Viable Populations of Wild Horses on Healthy
Rangelands in HMAs in the Rawlins Field Office Jurisdiction (EA -037) and
its accompanying Draft Decision Record (DR) and Finding of No Significant
Impact (FONSI).  From conversations between Bureau of Land Management (BLM)
officials and wild horse advocates at the BLM's Cheyenne office on February
10, 2000, it is our understanding that the final Decision Record
accompanying EA-037 will determine whether the January 10, 2000 Decision
Record and FONSI approved for EA Number WY-030-EA0-038 (EA-038), Wild Horse
Gathering Outside Wild Horse Herd Management Areas February 15 through April
1, 2000 will stand or will be vacated.  

As a threshold matter, we are very disappointed that the BLM did not prepare
an Environmental Assessment (EA) which analyzes alternatives to spring
round-ups in the state of Wyoming.  BLM officials had indicated to
representatives of several wild horse and burro advocacy organizations
attending a meeting at BLM headquarters in Cheyenne on November 8, 1999 that
such a draft EA would be available for public comments by the end of
December, 1999.  The Casper Star-Tribune also reported in a December 16,
1999 feature story that the EA would include an analysis of alternatives to
spring round-ups.  (Attachment 1)  Instead we are presented with an EA that
does not analyze any alternatives to spring round-ups, but rather includes
an appendix, the contents of which were provided to The Fund for Animals
approximately a year ago, stating that spring round-ups are necessary until
Appropriate Management Levels (AML) are achieved in Wyoming. (EA-037,  p.62)   

Not only is such failure on the part of the BLM unacceptable, but coupled
with the release of EA-038 and its accompanying final Decision Record,
inexplicably issued in "full force and effect," with no opportunity for
public comment, we question whether the BLM will give careful consideration
to comments from the public. Moreover, the issuance of the DR and FONSI with
EA-037, initially leaving only three days from the comment deadline to the
commencement of spring round-ups, adds to this crisis of confidence. The
release of a DR with the EA is clearly inconsistent with the intent of the
National Environmental Policy Act (NEPA) since it ostensibly predetermines
the outcome of the NEPA process. It is unrealistic to believe that the BLM
could read and seriously consider public comments, for example opposing
spring round-ups, while conceivably making arrangements to begin spring
round-ups.

There are certain management actions proposed in EA-037 which we
enthusiastically support and will discuss later in this comment letter, but
because of the urgency surrounding any decision regarding spring round-ups
in particular, let me begin by offering a list of topics specific to this
issue that warrant analysis.  This list is not new, only repeatedly ignored
by the BLM. 

Wild horse advocates have requested on more than one occasion that the BLM
explore and analyze alternatives to spring round-ups, including but not
limited to, utilizing contract gathering crews so more than one crew could
be conducting round-ups simultaneously later in the year, using nearby
alternative holding facilities owned by the BLM, constructing temporary
facilities, and/or leasing facilities from private individuals, arranging
schedules to accommodate the adoption pipeline both in terms of the timing
of round-ups and temporarily holding animals until they could be placed
therein, and forming partnerships with wild horse advocacy organizations to
work cooperatively on these and other related matters.   

Apparently, these suggestions have fallen on deaf ears.  EA-037 states on
page 62: "It is not desirable nor feasible to utilize contract gathering
services for a portion of the activity.  The capacity of existing facilities
will not support multiple gathering and it would not be cost effective to
construct additional facilities for use for only a few years."   This
statement is the extent of the analysis.  No cost/benefit analysis is
provided.  There is no discussion of the availability of nearby BLM holding
facilities such as Salt Lake City in Utah and Sandwash Corrals and
Yellowstone Creek Corrals in Colorado. Interestingly, both facilities in
Colorado will be unused this year because no round-ups have been scheduled
in the state.  BLM could opt for installing temporary holding corrals to
accommodate additional horses or for looking into leasing private facilities
as has Nevada due to the emergency situation caused by fires this past year.
Given BLM's reliance on the Wyoming crew, it would make sense to have a
contingency plan in place in the event the crew became incapacitated.
Another crew used by BLM is available in Vernal, Utah that in all likelihood
could be scheduled for additional round-ups in Wyoming. 

Granted, there would be some additional costs associated with round-ups
later in the year. However, the EA does not disclose pertinent information
so the public has no idea how much such costs would be.  In addition, these
costs would only apply for the next few years until AMLs are achieved.
Chuck Reed in the BLM's Rawlins office indicated that additional costs were
not the primary obstacle during the February 10, 2000 meeting.  He stated
that coordination within the BLM across state jurisdictional boundaries was
the greatest problem.  However,  it defies reason to believe that the BLM
could not coordinate its activities in such a way as to accommodate the
relatively few horses that would be removed during the spring season in
Wyoming.   
 
Given the unpredictability of the weather in Wyoming from year to year and
given the mitigative measure that "no gathering will be done during periods
of extremely cold or wet weather," (outlined in EA WY-037-EA1-039, Wild
Horse Gathering Outside WHHMAs 1991-1992), there is always the possibility,
and in many years the probability, that scheduled spring removals will be
canceled, and thus the goal of moving toward AMLs is thwarted.  According to
data obtained from the University of Wyoming, for the last ten years in
Rawlins, monthly average temperatures have ranged from 13 to 32 degrees
Fahrenheit in February with the temperature dipping as low as minus 36
degrees and from 32 to 38 degrees in March with minus 18 degrees as a low.
Given that Rawlins is a very windy region, when one factors in the wind
speeds for which there is relatively little archival data, the wind chill
factor for those months would be considerably lower than the average
temperatures.  Not only would scheduling removals later in the year
guarantee that a certain number of horses would be removed, but more
importantly, later removals will also ensure that wild horses, especially
pregnant mares, will not experience the stress of being chased by
helicopters, handled, transported and confined in unfamiliar surroundings
during a critical time of the year.  

While stress is associated with any round-up, regardless of its timing,
stress is particularly problematic during winter months when the
physiological condition of both horses and wildlife are already taxed due to
the cold weather and lack of nutritional forage.  These special conditions
(viz., cold, calorie budget, wildlife wintering) are appropriately noted in
a chart in EA-037 as conditions that preclude round-ups during the months of
December, January and early February. (EA-037, p.36)  However, they are
conveniently omitted as conditions to be considered for late February and
the entire month of March, precisely the times that the BLM proposes to
round-up horses.  If anything, the condition of horses and wintering
wildlife becomes more critical as winter progresses.  >From an energetics
perspective, horses and wildlife would have greater energy reserves in
January compared to February or March.  Dr. Joel Berger in his work Wild
Horses of the Great Basin: Social Competition and Population Size confirms
that wild horses were in the worst physical condition at the end of winter
and in the best condition during summer.   The National Research Council
reached the same conclusion in 1978.  This information was provided to BLM
officials at the February 10, 2000 meeting in Cheyenne.  If BLM officials
are concerned about cold and calorie budget in the aforementioned months,
they should be equally, if not more, concerned about the same in late
February and March before spring green up occurs in Wyoming.

Furthermore, while BLM officials acknowledge an obligation to ensure the
health of the herd (EA-037,  p.61), they must also acknowledge that they
have both a statutory and regulatory obligation to ensure the humane
treatment of wild horses.  "Humane treatment" is defined as "handling
compatible with animal husbandry practices accepted in the veterinary
community, without causing unnecessary stress or suffering to a wild horse
or burro." (CFR 4700.05 (e))  Thus, herd health deals with populations of
animals; humane treatment deals with individual animals.  

From the analysis, it appears that the BLM is relying on the opinion of two
veterinarians. (EA-037 pp. 62-63)   Former Wyoming State Veterinarian, Dr.
Don Bosman, states that any assessment of the affects of running a late term
pregnant mare for 7-10 miles depends on many factors including  the mare's
weight, condition, type of soil, terrain, air temperature, etc.  However,
despite the conditions outlined by Dr. Bosman, the BLM continues to ignore
the fact that these animals are undeniably stressed at this time of year and
the trauma associated with a round-up is very different from the condition
of Dr. Bosman's well-cared for mares who romp in the field "just for fun."  

Dr. Werner McFarland, a private practitioner in Rawlins with a growing area
of concentration in equine reproduction, attempts to compare and contrast
physiological responses between domestic horses and wild horses, although it
is unclear whether his inferences are based upon scientific study.  No
studies are cited.  He claims that wild horses are better equipped to handle
stress than are domestic horses because they are more physically active and
are tested routinely through flight and fear responses.  However, it is
questionable whether wild horses physiologically weakened in the last throes
of winter compared to properly cared for domestic horses would necessarily
be better equipped to handle stress.  Domestic horses are accustomed to
being handled and transported; wild horses are not.  Furthermore, given the
fact that the BLM states in the EA that there is currently little threat
from predators in the vicinity, it is also unclear whether these horses
experience the flight and fear response to the degree that is implied.
(EA-037, p. 7)  

The BLM  fails to reveal that there is a division within the veterinary
community about the humaneness and the risks associated with rounding up
wild horses, especially late term mares, during February and March.   In the
past, we have submitted letters from veterinarians discussing such risks,
including Dr. Donald Moore, an equine practitioner, who was a contract
veterinarian with the BLM in Colorado in the late 70s.  He assisted BLM in
the Douglas Mountain area and in the Sand Wash Basin, areas similar in
landscape and climate to that found in the Rawlins wild horse herd
management areas (HMAs). (Attachment 2)  Dr. John Harris who serves on the
animal welfare committee of the American Association of Equine Practitioners
has expressed similar concerns.  Dr. Brenda Sappington, Ph.D. (Oakhurst, CA)
and Dr. Karen Mueller (Bellingham, WA), both equine practitioners, and both
of whom have examined the spring round-up analysis provided by the BLM
concur that multiple unnecessary risks are associated with spring round-ups.
Stress-induced abortions to colic to foal limb injuries are among the host
of potential risks that are present during spring round-ups.  I doubt
seriously that many veterinarians would recommend to their clients that they
subject their own domestic mares in the late stages of pregnancy  (who, I
might add, are not winter-stressed) to the round-up ordeal.  Dr. Michael G.
McDole, resident veterinarian at Sunwood Farm in Veradale, Washington, sums
up the issue succinctly when he says "It is  just common sense not to over
stress a pregnant mare."

The BLM claims that helicopter operations will be stopped or suspended if a
significant number of foals are encountered.  However, there is no
definition of what constitutes a "significant" number.  Is it two or five or
ten or twenty or fifty?  Moreover, according to veterinarian Dr. Elizabeth
Colleran, excessive running as would occur when being chased by helicopters
can potentially result in compression injuries to the limbs of young foals
less than two months old.  Such injuries account for a high percentage of
fractures in foals and are closely related to angular limb deformities which
may ultimately render the young horses undesirable for adoption.   Dr.
Brenda Sappington and Dr. Holly Cheever (Voorheesville, NY) concur with her
assessment.  (Dr. Colleran's assessment will be provided by Chris Papouchis
with the Animal Protection Institute in supplementary comments.)  

Given there appears to be no universal agreement within the veterinary
community about the appropriateness of spring roundups in an environment
such as that found in Wyoming, such practice cannot be deemed "an animal
husbandry practice accepted in the veterinary community."    Unless and
until such time as it is recognized as such, the BLM should err on the side
of caution to ensure that wild horses are receiving the humane treatment to
which they are legally entitled.  

Moreover, BLM is violating its own guideline outlined in EA-037 which
prescribes avoiding unaccustomed stress after the onset of the 38th week of
pregnancy to appropriately safeguard against stress-induced abortion during
removal and processing wild horses. (EA-037, p. 59)  Although the EA
continues to state that shutting down gathers between April 1 and July 4 was
effective in avoiding subjecting pregnant mares to unaccustomed stress after
their 38th week of pregnancy at least 85% of the time, it appears that BLM's
math needs to rechecked.  A mare's gestation period is on the average 340
days (Attachment 3) or approximately 48 1/2 weeks.  If, as the BLM claims
85% of the foaling occurs between May 15 and June 15, then mares should not
be stressed after March 1. However, this does not account for the 15% of
mares who foaled before April 1 just last year, nor the percentage of those
who foal between April 1 and May 15.  If BLM officials are concerned about
the humane treatment of these animals, as well they should be, then no
removals should take place after mid-January.  

It is difficult to ascertain the basis for the BLM's proposal to conduct
spring round-ups.  So much of the information provided is conflicting.  One
of the studies being relied upon by the BLM was conducted by Lee Boyd in
1978 and 1979.  Boyd concluded in 1980, "The main foaling season (in the Red
Desert) is from late March through July with a peak in May and June, however
a few foals are born at other times of the year." (EA-037, p.60)   In its
own documents, the BLM states "The peak foaling period usually runs from
April 1 through June 15.  (Decision Record for EA WY-037-EA4-121 and 122, p.
3)  Another document states "The peak foaling period for wild horses is a
critical time to consider when planning round-ups.  Mares and colts should
not be subjected to any unnecessary stress during this time.  It extends
from early May to mid-June, though the period ranges from March to
September." (EA WY-037-EA1-039, p.7) [Emphases Added]  If it is inadvisable
to stress mares after their 38th week of pregnancy, as the BLM states in its
own analysis, and winter-stressed mares can begin to foal as early as March
in any given year, then round-ups in late February and March are
indefensible and the BLM must abandon its ill-conceived strategy of spring
round-ups and develop other strategies for achieving AMLs.   

The BLM also relies on pen studies conducted in 1997, 1998 and 1999 and a
review of data from 1986-1998 to determine the constancy of foaling
patterns.  Of 804 mares held at the facilities in Rock Springs and Riverton
during this period, 302 foaled --  96% between April 15 and June 30 with
85% born after May 14.  However, drawing conclusions from these data is
difficult at best.  The trauma associated with round-up, handling, transport
and captivity, change in diet, change in activity levels etc. may influence
foaling patterns.   Moreover, additional information about the pregnancy
status of the 804 mares needs to be obtained for analysis.  If, for example,
500 of the 804 mares were pregnant prior to round-ups, but only 302 gave
birth, this would mean that almost 200 animals may have suffered abortions
or given birth to premature, nonviable foals.      
 
Furthermore,  EA-037 fails to discuss potentially adverse impacts on
wintering wildlife in the vicinity of round-up operations. Helicopter
disturbance of wintering wildlife including wild horses should not be
discounted.  I have discovered three compilations prepared by the U.S. Fish
and Wildlife Service, the U.S. Air Force and independent consultants
consisting of bibliographic abstracts, a literature synthesis and an
annotated bibliography that cite studies conducted on the effects of
aircraft noise and sonic booms on domestic animals and wildlife.  Several
studies indicate helicopters can cause greater impacts to wildlife than
fixed wing aircraft or military jets. This is especially true when
helicopters are flying at low altitudes as is the case during round-up
operations.  Wildlife reactions to helicopter disturbance are similar to
that of sonic booms   

Research conducted on ungulate species, specifically pronghorn and caribou,
show panic reactions to helicopter disturbance.  Animals appeared to be more
sensitive to disturbances during gestation and calving seasons.  And while
the researchers readily admit that little is known about the long term
effects of noise on the physiology of wild ungulates, behavioral changes in
wildlife resulting from exposure to sudden or loud noise, such as sustained
running or avoidance behavior, cause increased expenditures of energy, which
reduce the rate of survival and reproduction.   More importantly, the
researchers concluded that this is particularly harmful during periods of
stress such as late winter or during drought conditions. (Attachment 3)
Thus, helicopter round-ups during February and March may be having far
greater adverse impacts on wildlife and wild horses than the Bureau of Land
Management (BLM) implies in its various environmental analyses.  

The BLM also revealed that although the agency has received requests from
private landowners to have the wild horses removed from private lands
outside of HMAs, no one has insisted on removals during the spring.   It is
simply irresponsible and inconsistent with the definition of  "humane
treatment" in the BLM's regulations to force wild horses to expend energy
reserves and to risk potential injuries and possibly life threatening
conditions when there is no immediate need to do so.  The objective of BLM
capture operations should be to maximize safety and humaneness for the
horses.  While any round-up of wild animals may result in some level of
loss, if the loss can be prevented, it should be. 

Other issues within EA-037 and its DR and FONSI also warrant discussion.  As
has been conveyed on numerous occasions, NEPA requires an analysis of a
range of reasonable alternatives. While EA-037 offers four alternatives,
only three can be considered bona fide alternatives.  BLM admits that
alternative three which relies on natural decimating factors as described in
the EA would  be illegal because it would not respond to landowner requests
to have wild horses removed from private lands, as required by the Wild
Free-Roaming Horse and Burro Act (WFHBA) and BLM regulations. Thus,
alternative three is nonviable and its analysis pointless.   

An adequate discussion of alternatives should have included a combination of
some of the management strategies provided -- e.g., a reliance on natural
decimating factors coupled with fertility control, restoration of wild
horses into areas where they have been zeroed out, or a reconfiguration of
HMAs to ensure that the biotic needs of wild horses are met.  For example,
it is unclear how the BLM originally defined Herd Area (HA) boundaries in
Wyoming in the early 70s after the enactment of the 1971 WFHBA and how those
boundaries have since been redefined through the designation of HMAs. We now
understand that in many instances HAs were defined by a one time census that
failed to account for seasonal migrations of wild horses.  Whether this
occurred in Wyoming is unclear.  Regardless, it appears that the
free-roaming nature of wild horses has been considerably curtailed in the
process of designating HMAs. Although BLM data can be incredibly confusing
to interpret because it is often inconsistent and contradictory, it appears
that the original 4,309,991 acres of BLM land alone where horses were found
in the 70s  have been reduced to 2,867,616 acres today with AMLs set at
3,153 wild horses. In the Rawlins district the AMLs of only 920 wild horses
have been established on 1,529,000 acres of BLM land and 607,000 acres of
other lands.   It is impossible to determine from the information provided
in EA-037 whether the biotic needs of horses have been adequately considered
in the process of designating HMAs.   For example, if most of the water
sources on the Lost Creek and Stewart Creek HMAs are on privately owned or
controlled lands (EA-037, p.8), then perhaps a reasonable course of action
for the BLM would be the development of water sources for wild horses in the
HMAs to discourage their straying on to private lands or negotiations with
landowners for greater tolerance of wild horses on these lands, land swaps,
conservation easements, etc.  The BLM should explore land exchanges in
checkerboard areas to consolidate public and private lands.  Larger parcels
of land could work to the advantage of  the horses and the public alike by
enhancing management options, reducing the amount of fencing and potentially
enhancing property values for private lands.      

Unfortunately, from the tone of the DR and FONSI, there appears to be little
desire to explore such options.  Instead the BLM appears fixed on
maintaining the status quo.  The first paragraph of the DR and the Handbook
referred to throughout EA-037 emphasize preserving the multiple-use
relationship that presently exists in the area.  The DR also states
"Management will be based on the current configurations of HMAs and the AMLs
that have been determined for those areas as identified in the Great Divide
RMP." (DR and FONSI, p.1)  As the BLM is aware, managing for a number of
horses arrived at through the land use planning process violates an Interior
Board of Land Appeals' order which "required that AMLs be established
through the analysis and evaluation of monitoring data to determine the
'thriving natural ecological balance' for wild horses and burros with other
resource uses as specified in the Act."   

Furthermore, the definition of 'multiple use' is defined in the Federal Land
Policy and Management Act of 1976 as follows: "The management of the public
lands and their various resource values so that they are utilized in the
combination that will best meet the present and future needs of the American
people; making the most judicious use of the land for some or all of these
resource or related services over areas large enough to provide sufficient
latitude for periodic adjustments in use to conform with changing needs and
conditions; the use of some land for less than all of the resources; a
combination of balanced and diverse resource uses that take into account the
long-term needs of future generations for renewable and non-renewable
resources, including, but not limited to, recreation, range, timber,
minerals, watershed, wildlife and fish, and natural scenic, scientific and
historic values; and harmonious and coordinated management of the various
resources without permanent impairment of the productivity of the land and
the quality of the environment with consideration being given to the
relative values of the resources and not necessarily to the combination of
the uses that will give the greatest economic return or the greatest
output." (Emphases added)   It is clear from this definition and from
language in the WFHBA that while multiple use must be considered, it is not
necessary to have all uses on all lands nor is it necessary to preserve the
existing use or the existing level of use.  Therefore, a programmatic EA, as
EA-037 has been described by the BLM, should have included an analysis of
closure of HMAs to livestock grazing and reduction of livestock grazing in
HMAs as alternatives in themselves or in conjunction with other management
alternatives. 

While the BLM implies that Alternative 1 will allow for consideration of
such options, given the stipulation in the Handbook that will be guiding
management decisions in Alternative 1 that "actions pursuant to that Act be
taken in such a way as to preserve and maintain the multiple use
relationship that presently exists in the area,"  (Handbook, p.7 of 77)
[Emphasis added], it is doubtful whether alternatives such as closure or
reduction of livestock grazing in HMAs will be seriously considered.  To
raise further concern, the discussion of socioeconomic impacts implies that
there would be significant adverse impacts  to the regional economy if
livestock use were eliminated or reduced in HMAs.  (EA-037, pp. 43-46) The
total authorized domestic livestock use within the HMAs is 14% of the
livestock use authorized within the Rawlins Field Office.  Only 18 of the
588 grazing allotments in the Rawlins Field Office jurisdiction occur within
HMAs (EA-037, p.19)  It is impossible to determine how significant any
adverse impacts resulting from the elimination or reduction of these 18
grazing allotments would be when no cost/benefit analysis is provided.  If
as the EA states, "Some operators would be affected less than others, but
many would  be forced to seek additional sources of income,"  we might ask
on what is this statement based.  No financial information whatsoever was
provided in the EA.   

Of additional concern is the fact that livestock actual use has averaged
considerably lower than livestock grazing preference for several years.  As
noted in the EA,  "The overall decline in the range sheep industry has
resulted in a low and variable rate of actual use by sheep operators.
(EA-037, p.19)   Perhaps the time has come to revisit forage allocation in
the HMAs.  As is reported in the 1996 Report of the Review Team on Forage
Allocations for Wild Horses and Livestock, "... the ultimate decision on the
balance between wild horses and livestock is a social and political one
based upon public perceptions and values."   Horses should not be scapegoats
of the forces of economic downturns.  More importantly, the interests of a
national public, not just a local public, should be duly considered.  The
Great Divide Resource Management Plan (GDRMP) was completed in 1990.  The
Handbook indicates that Resource Management Plans are periodically revised.
I would submit that the time has come to review forage allocations in the
HMAs, especially given the fact that horses have been excluded from so much
habitat through the designation of HMAs.  If this can be accomplished
through a maintenance action as was done when the boundaries of the HMAs
were redefined several weeks ago, fine.  If it requires a Land Use Plan
amendment or another mechanism for revisiting forage allocation, then let
the process begin.

While the EA claims that many wild horse populations are double the current
AMLs, it also concedes in the discussion on selective removal strategies
that "beginning populations  of twice AML did not appear to pose special
concerns either to habitat or animal health."  (EA-037, p.54)  It is not
clear from this statement whether horse populations at twice AML were
adversely impacting domestic livestock or wildlife.  Assuming that livestock
and wildlife are included in this equation and that wild horse populations
at twice AML did not pose special concerns either to the habitat or to
animal health, this would suggest that the current AMLs are too low and
should be adjusted upward, again supporting the position that the time is
appropriate for reviewing the GDRMP.   

Whether this is or isn't the case depends upon the sufficiency of the
modeling process.  The description of the modeling and the modeling process
in Appendix A is deficient.   An EA should not be a document that asks more
questions than it answers, rather it should provide the layperson with
adequate information about a particular topic so that he or she can prepare
informed and substantive comments.  Additional information about the
specific model developed by Dr. Stephen Jenkins should have been disclosed.
The parameters of the model and the source of all the data used in each
parameter should have been identified.  As  EA-037 concedes, a model is only
as good as the data used.  In this case, since the EA fails to disclose the
data that were used  in the model, the public cannot assess the validity of
the data, and therefore the model. 

EA-037 indicates that the model evaluated a number of management scenarios
using a typical population which was described as consisting of 100 adults
plus the young of the year.  However, the EA provides no information about
the sex ratio or age structure of this supposed typical population.  Was the
sex ratio split 50:50?  Were there more females than males or more males
than females?  Was the population bottom heavy with an abundance of younger
animals or top heavy with older horses?  This information at a minimum must
be provided to even begin to understand some of the conclusions referenced
in other sections of the EA. 

It is also clear that the BLM is concentrating too much on overall numbers
of horses in an HMA and not carefully considering the viability, genetic
health and social dynamics of wild horse populations.  While I am heartened
to see for the first time in a BLM document the use of 150 as the minimum
number to ensure genetic viability (EA-037, p.18) , it is unclear to what
extent, if any, genetic exchange is taking place in two of the three HMAs --
Stewart Creek and Lost Creek. The chart on page 19 indicates potential
points of contact, but there is nothing in the EA to confirm that exchange
has occurred or will occur.  Is there documentation to that effect?  If so,
it should be included in the EA; if not, the public should know.
Information from the 1994 Evaluation indicates that many areas within HMAs
contained  fencing that prevented free movement of horses.  Does the same
hold true today?  In order to be able to assess whether the metapopulation
section of the EA adequately addresses concerns about genetic exchange, the
EA should have included maps detailing locations of fences,  horse
distributions,  movement patterns,  etc.   In fact, the inclusion of a
variety of  maps would have helped in better understanding many of the
references in the EA.  The EA also does not describe the methodology used to
arrive at population estimates for the HMAs.  At the November meeting in
Cheyenne, Chris Papouchis with the Animal Protection Institute specifically
asked that this information be included.   

In fact, much of the information provided is confusing or deficient.  For
example, the population growth rates cited in the EA have huge fluctuations
without any explanation. The issue of how population management actions such
as removals impact wild horse social dynamics is ignored. The fertility
control section of Appendix A does not identify the immunocontraceptive
agents being used for experimentation and there is no discussion of how such
agents may impact the social dynamics of a wild horse population, a critical
issue for the public to understand.   For example, the impact of PZP on
recycling in mares could definitely impact wild horse population social
dynamics.  To understand this, the public needs more information about the
breeding behavior of wild horses.  Based on information in the EA, it seems
that some wild mares (although it is unclear the percentage) may naturally
recycle a few times before conception is achieved. (EA-037, p.60)   If this
natural rate of recycling does not differ from the PZP induced rate, then
the impact may be minimal at least for those mares.  If, however, PZP
produces recycling at a rate that is unnatural, thereby jeopardizing the
physical and psychological well-being of the horses, then its use becomes
problematic.  Are other agents available for experimentation?  And if so,
what impacts do they have?  

Of equal concern is that the actual fertility control alternative analyzed
in the EA was crafted in such a manner as to ensure that that it would not
be deemed acceptable.  Alternative four calls for the use of fertility
control alone to achieve AMLs in wild horse populations, many of which are
nearly double AML to begin with.  According to alternative four, assuming
that AMLs are accurate (an assumption with which I don't agree), achieving a
reduction in the populations to AMLs is achievable but will take a long
time, cost a lot of money, and in the interim, the horse populations will
grow beyond the size that certain segments of society will tolerate.   While
the EA mentions the possibility of employing round-ups to achieve AML and
then to use fertility control, this alternative is not scrutinized
(assuming the fertility control agent does not result in adverse impacts to
the social structure of the herd or to the physical and psychological well
being of individuals horses)  despite the fact that evidence suggests that
it would be a successful and less costly alternative.  This is another
example of an alternative that should have been thoroughly analyzed, but was
not. 

Perhaps there is a desire to remove animals to achieve the objective stated
in EA-037 on page 5: "A predictable supply of healthy, adoptable horses is
needed to maintain interest in the Adopt-a-Horse Program while it continues
to be the only available means for disposition of excess horses that must be
removed from the range."  While offering assistance to the public in their
efforts to view wild horses in a natural setting may be an appropriate
service for the BLM to offer, it should not be in the business of ensuring
that the public has an adoption opportunity.  The BLM is charged with the
protection and management of wild horses on the range, not with customer
satisfaction.  Adoption is not an end in itself; it is merely a means to
deal with "excess" wild horses.  Further, what does the BLM intend to convey
by placing wild horse adoptions in the category of economic values on page
24 of EA-037?

Finally, if the BLM ever intends to reduce the controversy surrounding its
management of wild horses in Wyoming, it must produce a comprehensive EIS or
EA which includes all relevant information about wild horse management.
Only by preparing a more complete analysis of all of the elements of wild
horse management can the BLM ever provide the public with a sufficient look
at the entire Wyoming program versus a glimpse at one piece of the puzzle.
For these reasons, we believe that the BLM must withdraw EA WY-030-EA0-037
and prepare a far more substantive analysis, preferably an EIS.  Thank you
for the opportunity to submit these comments. 


Sincerely,

Andrea Lococo
Rocky Mountain Coordinator 

Enclosures

cc:  Tom Fry (by U.S. Mail)
       Henri Bisson (by U.S. Mail)
       Al Pierson (by U.S. Mail)
       Tom Pogacnik (by U.S. Mail) 
       Chuck Reed (by U.S. Mail) 
       Howard Crystal, Meyer & Glitzenstein  (by U.S. Mail) 
Andrea Lococo
Rocky Mountain Coordinator 
The Fund for Animals
P.O. Box 11294
Jackson, WY  83002
(307)859-8840
Fax:(307)859-8846



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