The area in question is “checkerboard” land (alternating public and private land parcels) in four federally designated Herd Management Areas (HMAs): Great Divide Basin, Salt Wells Creek, White Mountain, and Adobe Town. The public land blocks are owned by the federal government and managed by the BLM. About half of the private land is owned by the Rock Springs Grazing Association, also known as RSGA, and half is owned by Occidental Petroleum.
Despite owning less than a fifth of the land within the four HMAs, the RSGA is demanding that all wild horses be removed from all private and public lands in the area, based on the RSGA's declaration that it will no longer tolerate wild horses on "its" private lands. The BLM has released an Environmental Impact Statement (EIS) and has set an April 30th deadline for public comments.
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Dear Rock Springs Field Office Manager:
Please accept the following comments on the Rock Springs Resource Management Plan Revision (DOI-BLM-WY-D040-2011-0001-RMP-EIS). This latest action is part of BLM Wyoming's years-long effort to wipe out wild horses from the Wyoming Checkerboard for the benefit of commercial livestock interests.
I strongly oppose the proposal to make land use amendments to the Green River and Rawlins Resource Management Plans that would authorize the elimination of 2.5 million acres of federally designated wild horse habitat and result in the removal of 40 percent of Wyoming's wild horse population (based on 2019 population estimates). As a citizen and a taxpayer, I remind the BLM that the public lands in this area belong to all Americans, and all Americans have a stake in their management. Like the bald eagle, mustangs are federally-protected American icons, and 80 percent of Americans want to preserve them on our public lands.
The BLM cannot use a settlement agreement with the Rock Springs Grazing Association (RSGA) as an excuse to eradicate wild horses from this area. The settlement requires only that BLM analyze the impacts of such action; it does not require implementation of this destructive plan. Further, the RSGA does not even own the majority of checkerboard land and should not be allowed to dictate the management of public lands in this area, including whether or not wild horses are allowed to live in this critical habitat area.
Instead of “zeroing out” the Great Divide Basin, Salt Wells Creek and White Mountain Herd Management Areas -- including removing every single horse from the popular Pilot Butte Wild Horse Viewing Loop -- and slashing the size of the Adobe Town HMA, the BLM must look at alternatives and mitigation measures to maintain a healthy wild horse population in this area, including:
The EIS fails to adequately analyze the impacts of this mass removal plan to the wild horses themselves (genetic effects of mass removal and habitat loss) and the behavioral, social and health impacts of proposed surgical sterilization and sex ratio skewing of remaining herds. In addition, the impacts to American taxpayers -- who will pay the price for the costly roundup and warehousing of wild horses in holding pens and subsidize commercial livestock grazing -- have not been disclosed or analyzed.
As troubling is the EIS's failure to analyze the full impacts of the decision to destroy three popular wild horse habitat areas -- including the popular and conveniently located wild horse viewing loop -- on recreational users of the public lands and the local ecotourism industry.
The Tenth Circuit Court of Appeals has ruled definitively that the BLM cannot use a landowner request for removal of wild horses from private lands as an excuse to eradicate them from public land as well. The plan to wipe out the wild horses of the Wyoming Checkerboard illegally elevates commercial livestock interests over the public interest. It must be scrapped in favor of alternatives that preserve these mustangs in this critical habitat area for present and future generations of Americans to enjoy.
Thank you for your consideration.