Friends of Animals submitted comments to the Bureau of Land Management’s Salt Lake Field Office this week since the agency is once again on the brink of harassing and assaulting Utah’s Cedar Mountain Wild Horse Herd.
The BLM is proposing to rip an estimated 600 wild horses away from their families and homes in February 2017. A total of 200 horses would be removed and placed in the already oversaturated adoption program, and 400 horses would be returned back to the herd management area (HMA). Of the mares released back onto the HMA, roughly 200 would be treated with the fertility control vaccine Porcine Zona Pellucida – 22, commonly known as PZP-22.
We are sick and tired of wild horses being removed from herd management areas when cattle and sheep are allowed to graze without restrictions. In the north Cedar Mountain allotment in Utah, for instance 1,265 cattle are allowed to graze and 1,984 sheep are allowed to graze. But the appropriate management level for wild horses is 190 to 390.
Here are the reasons the Cedar Mountain Wild Horse HMA Capture, Treat and Release Plan and Determination of NEPA Adequacy (DNA) fails to comply with National Environmental Protection Act (NEPA):
1. BLM proposes to authorize this roundup based only on a Determination of NEPA Adequacy, which is not appropriate for a “new” action such as that authorized here. The 2016 Roundup Decision is not an “ongoing” action analyzed under the 2012, 2008, or 2003 environmental assessment. The 2016 Roundup Decision is a “new” action and therefore requires new or supplemental NEPA analysis.
2. The 2016 DNA relies on the analysis of the impacts of PZP on wild mares contained in the 2012 environmental assessment, which itself does not include any references to PZP research more recent than 2010. Since 2010, additional research regarding the significant impacts of PZP on wild mares and their foals has become available; BLM must provide that information to the public before subjecting the 200 Cedar Mountain wild mares to PZP.
3. In addition, transferring yet another 200 wild horses to BLM holding facilities will cost federal taxpayers 10 million dollars; under NEPA, BLM must analyze and disclose to the public the socioeconomic impacts of the proposed action.
4. Finally, the proposed action involves helicopter trapping in an area where federally protected Golden Eagles nest and during a time of year when Golden Eagles return to their nesting sites. While the 2012 EA stated that there was an “alarming declining trend in productivity and nest starts” for Golden Eagles, neither the 2016 DNA nor any of the NEPA documents upon which BLM relies provides any information regarding the location of Golden Eagle nests in relationship to the proposed trapping sites, the impact of helicopter trapping of wild horses on Golden Eagles or how BLM proposes to mitigate potentially significant impacts to nesting Golden Eagles.