Cross-posted from PPJ Gazette

May 20, 2012 by Debbie Coffey          Copyright 2012  All Rights Reserved.

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The Bureau of Land Management (BLM) continues at a breakneck pace to leave non-viable herds of wild horses on public lands and while it also considers cutting back on livestock grazing (watch out for drought management plans in your area).

Meanwhile, over and over again, extractive industries and new energy projects seem to go almost unchecked for use of massive amounts of water that adversely impact public lands and risk contamination of aquifers.

Just an aside on the letter below, Melani Mirati was the BLM’s COR (Contracting Officer’s Representative) at the 2012 Calico wild horse roundup and made the decision to allow the contractor (Sun J Livestock) to use a hot shot (electric prod) on a horse that had been stuck in a trailer and had just fallen on the ground.  (video link under SOURCES below).

Open Letter to the BLM:

May 18, 2012

RE: Public comment/Jackson Mountain wild horse gather

Dear Ms. Mirati and BLM Winnemucca Field Office:

In this document, BLM states:

“1.4 Purpose and Need for Action:

The purpose of the Proposed Action is to remove excess wild horses from within and outside the HMA, to manage wild horses at the established AML ranges for the HMA, to reduce the wild horse population growth rate in order to prevent undue or unnecessary degradation of the public lands by protecting rangeland resources from deterioration associated with excess population of wild horses within and outside the HMA boundaries, and to restore a thriving natural ecological balance and multiple use relationship on the public lands.”

My comment: The BLM has NOT proved an excess. It seems that not only are there no photos or videos shown to the public to verify the BLM’s estimation of the number of wild horses on the HMA, in order for Ms. Mirati’s population estimation to be correct, the mares would have to be giving birth to litters.

At the same time your office claims to need to remove wild horses to “prevent undue or unnecessary degradation of the public lands by protecting rangeland resources from deterioration associated with excess population of wild horses…,”on January 2012 your office issued an EA for the Hycroft Mine Expansion Project, which uses 900 million gallons of water a year (did you request 1′ and 5′ water drawdown maps for this EA?). A wild horse only drinks 15 gallons of water a day.

This Hycroft Expansion Project will use an additional 5,895 acres of PUBLIC LAND, with 2,172 acres of “new disturbance.” ON PUBLIC LAND, it seems this one project has 85 acres of roads, 176 acres including an open pit, 451 acres for heap leach pads, and 451 acres for waste rock facilities. Wild horses leave some hoofprints and eat some forage.

Please explain, exactly, how removing the wild horses will “restore a thriving ecological balance.”

Also, please explain how the Hycroft Mine Expansion’s many uses of water and disturbance of public lands, KEEP a “thriving ecological balance” and with 5 years needed for reclamation, how is this not years of “undue degradation” or “deterioration?”

Your district also has the Coeur Rochester Mine Expansion Project.  In August 2010,the EPA sent a letter to Bob Edwards of the BLM, stating that the EPA was concerned about this 7th Amendment to the Plan of Operation (POO) since 1986 and that no Environmental Impact Statements (EIS) were conducted regarding the Plan of Operation OR its amendments. The EPA stated it had concerns about the proposed project’s “potential direct and cumulative impacts on water and air quality.”

24 years and no EIS? It sure seems that “uses” of public lands that make more money get Findings of No Significant Impact (FONSI), which is in violation of FLPMA (Federal Land Policy and Management Act).

Your office also gave a FONSI to Newmont Mining’s Sandman Exploration Project, in the EA, it states this project will cause 500 acres of disturbance, and “none of the drilling products to be used under the Proposed Action contain hazardous substances and all are approved for well drilling and would therefore, not contaminate ground water aquifers or surface waters. Material Safety Data Sheets (MSDS) for common drill additives are included in the Plan.”

Then

“2.1.9 Solid and Hazardous Materials …Hazardous materials utilized within the Project Area would include diesel fuel, gasoline, and lubricating grease.”

Isn’t lubricating grease used on the drill? (If so, shouldn’t lubricating grease be considered a drilling product?). Hydraulic fracturing (fracking) is being used for this project, isn’t it?  It seems a Finding of No Significant Impact is often given to uses that have the potential for a LOT of impact.

In conclusion, without any photographs or videos of the wild horses, you cannot prove there is an excess and you only have the legal authority to remove the wild horses from their HMAs (Herd Management Areas) if there is an excess.

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SOURCES:

https://www.blm.gov/epl-front-office/projects/nepa/30004/36055/37911/Preliminary_EA.pdf

http://www.epa.gov/region9/nepa/letters/coeur-rochester-mine-preliminary-ea.pdf

http://www.blm.gov/nv/st/en/fo/wfo/blm_information/nepa0/minerals/hycroft.html

http://www.blm.gov/nv/st/en/fo/wfo/blm_information/nepa0/minerals/sandm