KBR Wild Horse and Burro News
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. 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