by Debbie Coffey, V.P. & Dir. of Wild Horse Affairs, Wild Horse Freedom Federation

A Bureau of Land Management (BLM) “News” Release, claims there are about 3,500 wild horses and 600 wild burros in the Twin Peaks Herd Management Area (HMA). This HMA includes 656,173 acres of BLM administered lands in Lassen County, Calif., and Washoe County, Nev.

Wild Horse Freedom Federation believes these BLM estimates are wildly exaggerated and that BLM’s proposed 10 year removal plan will decimate the wild horses and burros on the Twin Peaks Herd Management Area (HMA).

The BLM has set the “Appropriate Management Level” (AML) in this HMA for wild horses as only 448-758 and for wild burros as only 72-116. The high AML of 116 is not even a high enough number for a viable herd of burros.

The BLM proposes to roundup to the LOW AML. This means the BLM will allow only 1 wild horse per 1,464 acres, and only 1 wild burro per 9,113 acres.

Public comments can be submitted by email to BLM_CA_twinpeaksgather@blm.gov. The BLM will also accept comments sent by mail to Attention: Twin Peaks EA, Bureau of Land Management, 2550 Riverside Dr., Susanville, CA 96130, or hand-delivered to the above address. The comments are due by Monday, July 1, 2019.

You can read the BLM’s Preliminary Environmental Assessment (PEA) HERE.

Wild Horse Freedom Federation’s comments are below. You can use our comments as suggestions for points you might like to make, but please write an email or a letter in your own words and add your own personal comments:

Attention: Twin Peaks EA Bureau of Land Management 2550 Riverside Dr. Susanville, CA 96130

BLM_CA_twinpeaksgather@blm.gov

VIA email and USPS Certified Mail

RE: Environmental Assessment DOI-BLM-CA-N050-2019-0011-EA Twin Peaks Herd Management Area Wild Horse and Burro Gather Plan

WILD HORSE FREEDOM FEDERATION (WHFF) COMMENTS ON THIS EA ARE IN BOLD ITALICS BELOW:

Wild Horse Freedom Federation supports ALTERNATIVE 4. No action. Defer gather and removal.

WHFF comment about an omission: Environmental Assessment DOI-BLM-CA-N050-2019-0011-EA fails to include considerations of the impacts of climate change on the wild horse & burro herds on Twin Peaks HMA.

1.2 Background

The population inventory conducted in May 2017 calculated an HMA population at 2,565 wild horses and 462 burros.

WHFF’s comment on this: An independent aerial survey was completed over northeastern California and northwestern Nevada for the Twin Peaks Wild Horse and Burro Herd Management Area on August 17, 2017.

Approximately 218 miles of transect strips were flown within the Twin Peaks Herd Management Area boundary. Using the aerial strip transect method, the survey estimated the populations of wild horses and wild burros in the Twin Peaks Wild Horse and Burro Herd Management Area as follows:

841 – 1,111 wild horses (including some mules)

97 – 128 wild burros

Over 400 photographs were taken during the flight; photos by Craig Downer, Jesica Johnston and Carrisa Johnston

Wild Horse Freedom Federation believes the BLM’s population estimates presented in this Environmental Assessment are greatly exaggerated. If the BLM has video from its population inventory conducted in May 2017, or any past population inventories, we would be happy to review them.

Also, in 2013, the National Academies of Science (NAS) completed a comprehensive review and report. This study concluded that the Bureau of Land Management’s Wild Horse and Burro Program had failed to use scientifically rigorous methods to estimate population sizes and growth or to assess the impacts of intensive management actions on genetic viability (NAS, 2013). The NAS report found no evidence of excess wild horses and burros. This raised questions about the basis for BLM management decisions concerning wild horses and burros and related range issues. Population and range information presented to justify decisions seemed to be scientifically underinformed or inaccurate.

Riparian functional assessments completed between 2010 and 2018 document severe utilization of forage within riparian and wetland habitats and extensive trampling and trailing damage by wild horses and burros. Cultural resource surveys completed between 2008 and 2018 indicate that the wild horse and burro overpopulation is contributing to heavy trampling damage of cultural resource sites and artifacts from the animals. Land health evaluations and determinations completed between 2004 and 2018 indicate that the wild horse and burro overpopulation is contributing to the following standard(s) not being met: Riparian/Wetland.

WHFF’s comment on this: The BLM has not scientifically proven how much “damage” is caused by wild horses and burros versus how much “damage” is caused by privately owned cattle or sheep grazing on public lands. This EA does not include comparative reports of the utilization, trampling and trailing damage caused by privately owned cattle or sheep, to compare against the supposed utilization, trampling and trailing damage ALL being blamed on wild horses and burros. These BLM claims are unscientific and unfounded.

Ecologist George Wuerthner, Pres. Of the Board of Directors of Western Watersheds Project, has stated this:

“There is probably no activity that does more damage to our public lands, and in particular, degrades our wilderness areas, than livestock production. From the destruction of riparian areas, pollution of water, spread of weeds, killing of predators, social displacement of native ungulates, soil compaction, trampling of biocrusts, transmission of disease to wildlife, as well as forage competition with native herbivores, fencing that blocks wildlife migration, and so forth. Nothing has a greater negative ecological impact than livestock production.

The impacts of livestock production fit into a number of categories.

WATER POLLUTION: Numerous studies have shown that the presence of livestock in a drainage often leads to E coli counts that exceed state water quality standards. For instance, one cow will “deposit” between 75 and 100 pounds of manure per day. By comparison, a human may excrete 1 pound of fecal matter. So a herd of 500 cattle utilizing a drainage is the equivalent of allowing a community of 5000 people to spread their fecal matter across such a landscape.

DISEASE TRANSMISSION: Some of the diseases that native wildlife suffers from come directly from domestic animals. For instance, Chronic Wasting Disease (CWD) was originally transmitted to wild ungulates from a sheep research facility in Colorado. CWD is fatal and has spread to many western and mid-western states. Domestic sheep can also transmit pneumonia to wild bighorn sheep. The loss of many bighorn sheep herds is directly attributed to the transmission of the disease from domestic to wild sheep. Other diseases like Pink Eye, and brucellosis are also originally passed on to wildlife from domestic livestock sources.

PREDATOR AND PEST CONTROL: Much of the West is an arid with limited productivity compared to the mid-west and the eastern United States. As a result, livestock must spread across large areas to find sufficient forage. This places them at greater jeopardy from predation than animals grazing the back forty of a mid-west farm. For decades, ranchers have successfully lobbied the federal government to kill predators on public lands at taxpayer expense. … Indeed, predators can help to control the spread of diseases like CWD.

RIPARIAN DAMAGE: Riparian areas are the thin green lines of water influenced vegetation found along streams and lakeshores. In the arid West, 70-80 percent of all species depend on riparian areas for at least some of their food, shelter, and other habitat needs. Unfortunately, domestic livestock particularly cows evolved in moist forests in Eurasia and gravitate towards the habitat that most approximates their evolutionary habitat—the heavily vegetated riparian areas. Also, in much of the drier parts of the West, the majority of all forage is located in the thin green bands of vegetation along stream courses. Therefore, these critical habitats for many species from trout to songbirds to grizzly bears are typically degraded by the presence of grazing livestock. Livestock tramples and break down the streambanks, and also consume the vegetation, eliminating hiding cover, and removing forage that would otherwise support native species.

DAMAGE TO BIOCRUSTS

Most desert areas of the West have algae, lichens, and bacteria that reside on and just below the soil surface collectively known as biocrusts. Livestock hooves trample the biocrusts and compact soil making it difficult for biocrusts to colonized disturbed sites.

Biocrusts hold the soil together with micro-filaments, reducing erosion, as well as capturing atmospheric nitrogen and “fixing” it so it is available to plants. Biocrusts often colonize the surface between bunchgrasses and other plants and prevent the germination of weedy species like cheatgrass.

SPREAD OF WEEDS

Livestock is among the most important factor in the spread of weeds in the arid West. They accomplish this in three ways. First, their feces and hides will carry weed seeds to new sites. By destroying biocrusts, they facilitate the establishment and germination of weeds. Finally, by selectively grazing/browsing on native grasses and shrubs, they weaken these desirable plants, making it more difficult for them to compete against the weedy species.

FENCING AND OTHER INFRASTRUCTURE

(Fences)…can block wildlife migrations and of course represents the opposite of an “unconfined” kind of experience.

SOCIAL DISPLACEMENT

Many wildlife species like elk avoid areas actively being grazed by domestic livestock. These animals are displaced into other habitats, that is likely less suitable. If one assumes that elk or other animals are picking the habitat that is most suitable to their survival, if displaced, that creates an accounted impact on native wildlife. It may leave wildlife more vulnerable to hunters and/or predators. It may mean less productive forage. It may expose the animals to more severe weather.

FORAGE COMPETITION

On most public lands, the majority of forage is allotted to private domestic livestock, not wildlife. As a result, livestock are consuming food that would otherwise support native herbivores from ground squirrels to elk. Every pound of forage going into a domestic sheep or cattle is that much less food for native species.

Grazing of plants can also impact other wildlife. For instance, butterflies, hummingbirds, and bees all depend on flowering plants for food. If sheep or cattle mow down these plants, it indirectly reduces the food for these other species.

SOIL COMPACTION

Livestock is concentrated and often compact soil with numerous impacts on ecosystems. For one compacted soil decreases infiltration and thus increases water run-off, thus indirectly contributing to erosion and desertification. Livestock compaction also affects other native species. Many native bees, for instance, live in burrows in soil and can be negatively affected by soil compaction. Some desert tortoise, toads, and frogs seek out rodent burrow for shelter. Livestock can collapse burrows and thus limit habitat for these species.

OVERGRAZING

… livestock selectively graze plants, removing the better tasting and palatable plants and leaving behind the less desirable plants. As a result, they change the natural distribution of plants, typically reducing the native grasses and shrubs and contributing to the spread of the weedy species. Beyond that, the removal of significant amounts of vegetation can expose the soil to greater moisture evaporation, and thus contributing to desertification.

EFFECTS ON FIRE REGIMES

Livestock can have numerous impacts on fire regimes. Wildfire is critical to healthy ecosystems, however, the temporal and spatial scale of fire is important. For instance, in some ecosystems like sagebrush, as well as juniper/pinyon woodlands, typically support major wildfires that occur hundreds of years apart. When livestock promotes cheatgrass, an exotic annual that is highly flammable, it can result in far more frequent wildfire which is outside of the historic frequency. If fires are too frequent, native ecosystems of sagebrush can be converted to cheatgrass.

On the other hand, in other situations like in low elevation dry ponderosa pine forests which historically experienced low severity fire at frequent intervals, livestock grazing by removing the fine fuels of grasses, can give trees a competitive advantage leading to denser forest stands that may be more vulnerable to higher severity blazes.”

1.3 Purpose and Need for Action

… restore and maintain a thriving natural ecological balance within the Twin Peaks HMA.

This action is needed to protect rangeland resources from undue or unnecessary degradation and restore a thriving natural ecological balance and multiple-use relationship on BLM-administered public lands.

WHFF’s comment on this: How can there be a “thriving natural ecological balance” or a fair “multiple-use” relationship on BLM-administered public lands in the Twin Peaks HMA when just one permittee, Espil Sheep Co., for 9 months out of the year, has more privately owned livestock grazing on Twin Peaks HMA than the LOW AML of wild horses and burros listed as the proposed action of this EA? WHFF prepared this graph using data from authorizations listed on BLM’s Rangeland Administration System (RAS):

Graph 1, prepared by WHFF, based on data from BLM Rangeland Administration System Data

This graph shows the numbers using COW/CALF pairs:

Graph 2, prepared by WHFF, based on data from BLM Rangeland Administration System Data

In June, Espil Sheep Co. grazes 8,896 privately owned sheep (cows/calves) and almost 2,050 cattle (cow/calves), but for that month (and every month), the BLM proposes to leave only 448 wild horses and 72 wild burros on Twin Peaks Herd Management Area. In other words, in June, it seems that just this one permittee’s 10,946 privately owned livestock will outnumber the 520 wild horses & burros by over over 20 to 1 on the Twin Peaks Wild Horse & Burro Herd Management Area.

The BLM has not produced scientifically defensible studies on how much “degradation” wild horses and burros may cause versus the degradation that is caused by the much higher numbers of privately owned livestock grazing on the Twin Peaks HMA.

2.2.1 Management Actions Common to Alternatives 1, 2, and 3

Data including sex and age distribution, condition class information (using the Henneke rating system), color, size, and other information may also be recorded, along with the disposition of that animal (removed or released). WHFF’s comment on this: The word MAY in the sentence above should be replaced with the word SHALL. It is absolutely neccessary to provide this information to the public for accountability of the BLM’s activities and actions in managing America’s wild horses and burros.

2.2.2 Management Actions Common to Alternatives 1 and 2 • Fertility control for mares and jennies would be applied in conformance with current wild horse and burro policy and guidelines.

2.2.3 Alternative 1 (Proposed Action): Phased-in Gather and Removal of Excess Wild Horses and Burros to Low-AML, Sex Ratio Adjustment, and Population Growth Suppression

The HMA would be gathered to low AML (448 horses, 72 burros). The core breeding population of the HMA would be comprised of 60 percent males (approximately 270 intact horses and 43 burros) and 40 percent females (approximately 240 horses and 29 burros)

Male Sterilization

Discussions about herds that are ‘non-reproducing’ in whole or in part are in the context of this ‘metapopulation’ structure, where self-sustaining herds are not necessarily at the scale of single HMAs. So long as the definition of what constitutes a self-sustaining population includes the larger set of HMAs that have past or ongoing demographic and genetic connections – as is recommended by the National Academies of Sciences 2013 report – it is clear that single HMAs can be managed as nonreproducing in whole or in part while still allowing for a self-sustaining population of wild horses or burros at the broader spatial scale.

Neutering (gelding)

By including some geldings in the population, and having a slightly skewed sex ratio with more males than females overall in the core breeding population, the anticipated result would be a reduction in population growth rates while allowing for management of a larger total wild horse population on the range.

WHFF’s comments about this: These alternatives are all violations of the Wild Free-Roaming Horses and Burros Act of 1971 (Public Law 92-195). This Act of Congress stipulates that “All management activities shall be at the minimal feasible

level.” All of these proposed methods manipulate the dynamics of wild family bands and the survival of the fittest.

Adoption or Sale with Limitations and Off-Range Pastures (ORP)

ORPs are designed to provide excess wild horses with humane, life-long care in a natural setting off the public rangelands. There wild horses are maintained in grassland pastures large enough to allow freeroaming behavior and with the forage, water, and shelter necessary to sustain them in good condition. About 33,000 wild horses that are in excess of the existing adoption or sale demand (because of age or other factors) are currently located on private land pastures in Iowa, Kansas, Oklahoma, Missouri, Montana, Nebraska, Wyoming, Utah, and South Dakota.

WHFF’s comment about this: Wild Horse Freedom Federation investigations prove this statement in this EA is false: “ORPs are designed to provide excess wild horses with humane, life-long care in a natural setting off the public rangelands.” Wild Horse Freedom Federation’s White Paper states”WHFF has assembled extensive documentary and percipient witness evidence that the BLM’s reported numbers of horses and burros in many of the long-term holding facilities for America’s wild equids are wildly incorrect. In short, thousands of horses and burros that are supposedly in long-term holding are seemingly not actually in those locations, and not obviously in the control of the BLM or any other government agency or contractor. Somehow, these horses and burros have disappeared.”

Euthanasia and Sale without Limitation

Under the Wild Horse and Burro Act, healthy excess wild horses or burros can be humanely euthanized or sold without limitation if there is no adoption demand for the animals. However, while euthanasia and sale without limitation are allowed under the statute, for several decades Congress has prohibited the use of appropriated funds for this purpose. If Congress were to lift the current appropriations restrictions, then it is possible that excess horses removed from the HMA over the next 10 years could potentially be euthanized or sold without limitation consistent with the provisions of the Wild Horse and Burro Act.

WHFF’s comment about this: Wild horses and burros are given drugs that should never be given to animals used for food production.

2.3 Alternatives Considered but Dismissed from Detailed Analysis

Remove or Reduce Livestock within the HMA This alternative would remove or reduce authorized livestock grazing instead of gathering and removing wild horses and burros within the HMA…The BLM is required to manage wild horses and burros in a manner designed to achieve a thriving natural ecological balance between wild horse and burro populations, wildlife, livestock, and other uses. Thus reducing livestock AUMs to increase AMLs would not achieve a thriving natural ecological balance. Horses are present year-round and their impacts to rangeland resources differ from livestock, as livestock can be controlled through an established grazing system (confinement to specific pastures and limited period or season of use to minimize impacts to vegetation and riparian). This alternative would also be inconsistent with the Wild Horse and Burro Act, which directs the immediate removal of excess wild horses and burros. WHFF’s comment on this: Erik Molvar, Exec. Dir. of Western Watersheds Project, has stated “Cattle damage public lands, and as cattle grazing intensity increases, so does an invasive weed called cheatgrass. Native to Eurasia and spread by domestic livestock, this annual weed outcompetes native grasses for water and soil nutrients when lands are degraded, and is extremely flammable after it dies each year. When cheatgrass burns, the fires wipe out the sagebrush that sage-grouse, pronghorn and other sensitive wildlife need to survive.” “…These terms and conditions serve to minimize livestock grazing impacts to vegetation during the growing season and to riparian zones during the summer months. Wild horses and burros, however, are present year-round, and their impacts to rangeland resources cannot be controlled through establishment of a grazing system, such as for livestock. Thus impacts from wild horses and burros can only be addressed by limiting their numbers to a level that does not adversely impact rangeland resources and other multiple uses. WHFF’s comment on this: Using the BLM’s Rangeland Administration System (RAS) data for the allotments on the Twin Peaks HMA, Wild Horse Freedom Federation prepared this graph based on the authorized numbers of livestock for each allotment. It is obvious that while the BLM has characterized some grazing allotments as being “minimized,” this use is favored over wild horses and burros. Also, privately owned livestock are present and graze year-round on Twin Peaks HMA. Graph 3, prepared by WHFF, based on data from BLM Rangeland Administration System Data This graph shows the numbers using COW/CALF pairs: Graph 4, prepared by WHFF, based on data from BLM Rangeland Administration System Data If the BLM were truly striving for a “thriving natural ecological balance, the BLM would not have eliminated removal or reduction of livestock from further consideration. Livestock grazing on public lands is a privilege, not a right. This alternative should not have been dismissed.

3.2.2 Livestock

All livestock permits within the Twin Peaks HMA have undergone multiple changes to permit terms and conditions over the past 30 years.

The BLM has reduced active livestock use on the Twin Peaks HMA by 61 percent over the last 50 years (see Appendix I).

WHFF’s comment on this: According to Public Employees for Environmental Responsibility (PEER), Records of BLM’s Land Health Standards (LHS) assessments:

“have until now been scattered among BLM field offices, incomplete, inconsistent, error-prone, and poorly maintained.”

“the agency considers allotments that are not meeting standards but “making significant progress” in the same category along with allotments that are meeting standards–so allotments in the former category, even if significant ecological damage remains, are said to warrant no changes in management.”

“In addition, the agency has no formal method of accounting for past or historic livestock damage, so only those allotments where impacts can be attributed to current grazing are considered to be not meeting standards due to grazing and in need of changes in stocking rates or grazing management.”

There are a total of nine livestock operators who are currently authorized to graze livestock in these allotments annually. The cattle and sheep operators are authorized to use a total of 26,644 AUMs of forage each year. An AUM is the amount of forage needed to sustain one cow, five sheep, or five goats for a month.

The BLM allocated forage for livestock use, and the management of cattle and sheep in the Twin Peaks HMA involves careful adherence to permit stipulations, particularly regarding livestock numbers and season-of-use restrictions.

WHFF’s comment on this: Public Employees for Environmental Responsibility has stated “Despite two critical Government Accountability Office reports, BLM does little to detect or deter unauthorized grazing…. A 2018 PEER lawsuit confirmed that the agency still does not even monitor grazing trespass from year-to-year.”

The Destruction to Twin Peaks’ Pyramid Lake Riparian Area Caused by Hundreds of Private/Corporate Non-Native Domestic Livestock “Camped Out” and Defecating and Trampling this Fragile Lake Bed on Public Land (June 2012)

In fact, BLM’s Eagle Lake Field Office management has not adhered to permit stipulations and has often turned a blind eye to livestock grazing trespass.

Kathleen Gregg emailed Ken Collum (BLM Eagle Lake Field Office Manager) to inform him of many instances of livestock tresspass (including those listed below), but to our knowledge, there was little, if any, action taken.

June 15, 2013 @ Buckhorn Byway about 4 miles east of Pilgrim Lake at intersection of road to Hole In

The Ground

June 16, 2013 @ Middle of Painter’s Flat

June 23, 2013 @ Reservoir Painter’s Flat @ Harrison Spring Road intersection

June 29/30, 2013

Buckhorn Byway at intersection to Round Corral Lake

Buckhorn Byway about one mile east of Pilgrim Lake

Buckhorn Byway North of (back of) Pilgrim Lake

Buckhorn Byway south of Sob Lake

Round Corral

July 18, 2013 @ Buckhorn Byway @ Rodeo Flat

August 9, 2013 @ Horne Ranch Road about 1 mile east of Horne Ranch

September 6, 2013 @ Horne Road about 1 mile east of the Sheep Shed

June 8, 2014

Buckhorn Byway east of Pilgrim Lake on Surprise FO, ~ 30 cattle + calves

Buckhorn Byway west of Pilgrim Lake, ~1500 sheep

October 10, 2014 @ Smoke Creek Road @ about 15 miles east of Hwy 395, ~600 sheep w/herder

June 2, 2013 satellite photos showing trespass

Mixie Flat cattle trespass

Accommodation Spring sheep trespass

April 4, 2013 livestock trespass (about 500 sheep) witnessed and reported by BLM employees during

an aerial flight – see BLM data report for location.

In BLM FOIA records obtained by Kathleen Gregg regarding the livestock trespass by Kurt Stodtmeister in 2013, the Eagle Lake Field Office response indicates that Mr. Stodtmeister had trespass cattle grazing for 3 months.

Tables 3-2 and 3-3 below include the number of animals and AUMs that are permitted in each grazing allotment for cattle and sheep, the permitted season of use, and the type of grazing system used.

WHFF comment on this: THERE ARE DISCREPANCIES WITH THE DATA PROVIDED IN BOTH OF THESE TABLES and the authorized permit use on BLM’s Rangeland Administration System, so one or the other of these BLM records is incorrect.

Table 3-2: Cattle Grazing Summary in the Twin Peaks HMA

WHFF’s comment on this: The numbers of cattle, with the exception of Deep Cut grazing allotment, all differ from the number the BLM has authorized for the permits on these allotments that are listed on the BLM’s Rangeland Administration System (RAS). And, according to the RAS, the 2 permits for the Spanish Springs AMP are for 178 cattle, not the 300 that are listed on this table.

Table 3-3: Domestic Sheep Grazing Summary in the Twin Peaks HMA

WHFF’s comment on this: The BLM has stated in this EA that “An AUM is the amount of forage needed to sustain one cow, five sheep, or five goats for a month.” Many of the AUMs are incorrect in Table 3-3, and as such, the BLM has minimized the Active Sheep AUMs:

The Twin Peaks allotment has 4,000 sheep (If 5 sheep use 1 AUM, then 1,000 sheep use 200 AUMs, so 4,000 sheep would use 800 AUMS per month). The period of grazing is 4/1-10/25 (almost 7 months) so AUMs should be closer to 5,600 AUMs, but this EA has only listed 2,850 AUMS in this table.

The Observation allotment has 4,000 sheep grazing for 2 1/2 months. The AUMs should be 2,000, but this EA only lists 958 AUMs in this table.

Shinn Peak allotment lists 1,000 sheep grazing, but the BLM grazing authorization #0404065 (Effective 1/16/2015) is only for 448 sheep.

Deep Cut allotment was not listed in this table, but is authorized (#0403898) (Effective 4/1/2019) to graze 800 sheep (on 100% public lands, year round). (1,920 AUMS)

Spanish Springs AMP allotment is not listed in this table, but is authorized (#0403898) (Effective 4/1/2019) to graze 1,000 sheep 4/1-3/31 (on 100% public lands, year round). (2,400 AUMs)

Since this is a 10 year EA, the pasture deferred rotations listed under Grazing System on Table 3-2 and Table 3-3, or other temporary adjustments, will likely not be in effect for the next 10 years. These tables should be based on the recently renewed grazing authorizations by BLM on the BLM’s Rangeland Administration System, and not on short term, temporary adjustments.

3.3.4 Riparian-Wetland Sites

This often leads to riparian systems becoming degraded from heavy use and soil loss occurs from a concentrated number of animals using limited perennial water sources.

Grazing by wildlife, livestock, and wild horses and burros can impact riparian/wetland areas through trampling and/or grazing of riparian vegetation. When forage plants are overgrazed and trampled, desirable native species can be replaced by less desirable species that produce little or no forage value. Since wild horses and burros graze year-round (unlike livestock where areas can be rested or deferred from grazing), wild horses and burros can damage riparian areas and spring sites in late summer and fall when little green forage is available in the uplands. A decline in soil condition, plant cover, and plant species composition from trampling and overgrazing can result in bare soil and/or encourage the invasion and growth of noxious weeds or other invasive plants in riparian sites. Early spring grazing can also adversely affect vegetation resources as a result of trampling of wet soils, uprooting of seedlings, and damaging mature plants. These damaging effects are all occurring as a result of the overpopulation of wild horses and burros in the Twin Peaks HMA.

WHFF’s comment on this: Wild horses and burros have been fenced out of many water sources and grazing areas in the Twin Peaks HMA. So, they are forced to only drink or graze on more limited areas within the Twin Peaks HMA.

Privately owned livestock graze year round on the Twin Peaks HMA. Yet, the BLM states “These damaging effects are all occurring as a result of the overpopulation of wild horses and burros in the Twin Peaks HMA.” Please see WHFF’s Graph 4 above, comparing the overwhelmingly higher numbers of cattle and sheep, compared to the fewer numbers of wild horses and burros. Also, given the errors and omissions WHFF has noted on BLM’s other tables and Appendix J in this EA, we question the accuracy of these claims and BLM’s calculations.

Table 3-4: Repeat assessment ratings for Twin Peaks HMA selected springs

Seven riparian areas within the HMA were selected in 2018 to represent a range of use.

WHFF’s comment on this: This study is scientifically indefensible. The BLM did not disclose the criteria for selecting each of the seven riparian areas and did not provide a map of the locations of these seven areas to the public.

4.2 Past and Present Actions

Livestock

Livestock have used allotments within the Twin Peaks HMA for grazing for at least 70 years. Prior to 1979, willful trespass livestock grazing occurred in the HMA and contributed to degradation of upland and riparian plant communities. Over the past 40 years, the BLM has reduced the amount of livestock grazing in the HMA by approximately 60 percent (including the numbers reduced from the stop of willful trespass) (see Appendix I). Livestock grazing management has been modified to reduce or eliminate impacts to vegetation and cultural sites though coordination with the grazing permittees. Through previous decisions, the BLM has allocated the available forage to livestock. Other decisions have resulted in adjustments to livestock numbers and seasons of use and for implementation of grazing systems and the associated range improvements to promote rangeland health.

WHFF’s comment on this: The fact that the high numbers we see today were reduced by approximately 60 percent over the past 40 years truly indicates the history of the egregious BLM mismanagement of America’s public lands.

Vegetation and Riparian

While the current livestock grazing system and efforts to manage the wild horse and burro population within the AML has reduced the potential of past historic impacts, the current overpopulation of wild horses and burros is continuing to contribute to areas of heavy vegetation use, trailing and trampling damage and is preventing the BLM from managing for rangeland health and a thriving natural ecological balance and multiple use relationship on BLM-administered lands in the area.

WHFF’s comment on this: The BLM has no credible, scientific proof for this. Please review WHFF’s Graph 3 and Graph 4 above. The exceedingly high numbers of privately owned livestock are obviously the biggest “use” preventing the BLM from managing for rangeland health and a thriving natural ecological balance on BLM administered lands.

4.3 Reasonably Foreseeable Future Actions

Livestock

Livestock grazing is expected to continue at similar stocking rates as those currently authorized.

WHFF’s comment on this: If livestock stocking rates continue at similar stocking rates as those currently authorized, the BLM will never achieve rangeland health or a thriving natural ecological balance. Even if every last wild horse and burro were removed from the range.

Appendix J. Livestock and Wild Horse and Burro Actual Use Tables 2010-2018

WHFF’s comment on this: Many of the livestock numbers in Appendix J do not match the numbers that were authorized on the grazing authorizations per the BLM’s Rangeland Administration System. There are many unexplained discrepancies. For example:

Appendix J claimss 2,000 sheep graze on Shinn Peak. But the BLM grazing authorization #0404065 (Effective 1/16/2015) is only for 448 sheep. (Also, in Table 3-3 of this EA, it claims 1,000 sheep graze on Shinn Peak, so the numbers between this Appendix and Table 3-3 don’t even match.)

Appendix J indicates that 221 cattle graze on Spanish Springs AMP. But this appendix did not include sheep. On 4/1/2019, the BLM authorized 1,000 sheep to graze on this allotment (authorization #0403898). These sheep are authorized to graze 4/1-3/31 (year round, on 100% public lands). The BLM lists 221 cattle, but the 2 authorizations (#0403386 and #0403487) for cattle grazing on RAS indicate only 178 cattle are authorized to graze.

On this appendix it indicates that 2,000-4,000 sheep graze on the Twin Peaks grazing allotment, however, per the RAS, the Twin Peaks grazing allotment is authorized to have 5,000 sheep from 4/1-5/30 per authorization #0402017 and #0403898.

There are many other discrepancies, so the livestock use numbers, including total livestock use numbers, are incorrect on Appendix J.

Below is the data provided to the public on BLM’s Rangeland Administration System (RAS) on the 9 grazing allotments in the Twin Peaks Herd Management Area: