Open letter to the BLM

OPEN LETTER TO THE BLM:Regarding the “Desatoya Mountains Habitat Resiliency, Health, and Restoration Project”

April 7, 2012 by ppjg

Debbie Coffey Copyright 2012 All Rights Reserved.

(You might question the BLM’s project title after reading below. There’s nothing resilient or healthy about it. And not to malign BLM employees at local Field Offices – public lands planning comes from the President, Congress, Secretary of the Interior Ken Salazar and BLM Director Bob Abbey.)

__________________________________________________ ___

Department of Interior
Bureau of Land Management
Carson City District
Stillwater Field Office
5665 Morgan Mill Road
Carson City, Nevada 89701
desatoyaEA@blm.gov

BLM’s statements in the Environmental Assessment (EA) are italicized, and author’s comments are not italicized.

Introduction
“The project area encompasses approximately 230,000 acres, which includes …136,400 acres of the Desatoya Herd Management Area (HMA) (84% of the HMA).”

The Desatoya HMA is about 161,000 acres, and the BLM is only leaving 127-180 wild horses on the HMA that is primarily for their use. That is only one horse every
1,267.7 acres – one horse every 894.4 acres.

If there is not enough water or forage for the wild horses, this can only be from misappropriation of land uses allowed and facilitated by the BLM, which is mismanagement. When did the BLM last monitor the HMA for carrying capacity? Please send me documents related to any recent monitoring.

“Within the project area, up to approximately 32,705 acres of ground disturbing treatments are proposed over a ten year period including…herbicide treatment… Page 83 – In fact, 2,4-D has limited residual activity (2 weeks); therefore any incidental contamination risk to non-target plants would likely be negligible.”

When considering plants, animals, water and humans, note that:

The EPA says that 2,4-D is seventh largest source of dioxin in the U.S.
Dioxin DCDD that contaminates 2,4-D herbicide is not tested, measured or monitored by the EPA, or even regulated. A Canadian research paper states that dioxin DCDD may have large public health implications due to its prevalence in our food and environment.

DCDD is one of the hundreds of kinds of dioxin – (TCDD is the worst, but DCDD may be equi-potent):
NOTE: “2,4-D is contaminated with an unmonitored form of dioxin,
2,7-dichlorodibenzo-p-dioxin (2,7-DCDD)… There is very little research on this form of dioxin, but in 1986 2,7-DCDD was found to be “equipotent” to the very toxic 2,3,7,8-TCDD in a test of immunosuppression. Given the wide use of herbicides that are contaminated with 2,7-DCDD there may be large public health implications of this contamination of our food and environment.”

I am requesting that you read the information on the link above, since this has implications for human health, and that the BLM prepare an EIS.

The Interior Board of Land Appeals (IBLA) defined the goal for managing wild horse (or burro) populations in a thriving natural ecological balance as follows: ―As the court stated in Dahl v. Clark, supra at 594, the ‗benchmark test‘ for determining the suitable number of wild horses on the public range is ‗thriving ecological balance.‘ In the words of the conference committee which adopted this standard: ‗The goal of WH&B management ***should be to maintain a thriving ecological balance between WH&B populations, wildlife, livestock and vegetation, and to protect the range from the deterioration associated with overpopulation of wild horses and burros.‘ ‖ (Animal Protection Institute of America v. Nevada BLM, 109 IBLA 115, 1989).

The BLM is in violation of FLPMA because it is giving FONSIs to uses that do much damage to the range, use massive amounts of water, and carry risk, (but bring in money for royalties, etc.), while wildly exaggerating any “damage” done by wild horses.

The BLM will also be in violation of Dahl v. Clark (1.2) to determine the suitable number of wild horses on the public range, which is thriving ecological balance, and (1.3) the secondary purpose of the proposed action, which is to manage the HMA for a thriving natural ecological balance, because the BLM cannot justify a “thriving ecological balance” if BLM doesn’t prepare an EIS. As it is, with this EA, the BLM will be applying 2,4D to the land and has not done risk management considering combined sources of 2,4D in the area or cumulative effects to area water and drinking water.

Also regarding a “thriving ecological balance,” it seems that there are many geothermal leases in the Edwards Valley, and geothermal extraction can use hydraulic fracturing (fracking) and the chemicals being injected into the ground aren’t publicly known and there is also risk of water contamination.

When your office prepares an EIS, please notify the public if genetically engineered (GE) seeds will be used in the “reseeding” project. If so, which seeds will be genetically engineered and what could the impact be to human health? (For example, cows that will eventually end up in the food chain, may be grazing on genetically engineered seeds.) What will the impact of genetically engineered seeds be on the wild horses ingesting GE grass on the range? In your EIS, please provide studies to prove the safety regarding this to animals and humans.

1.2 “Over the next ten years, the BLM intends to continually capture and treat mares as needed and remove excess wild horses, when necessary to maintain the wild horse population within the AML range .”

Will the BLM be doing an EA for each planned gather? If not, what is the precedent for removing wild horses from their HMA without an EA, when there is not an emergency? This EA seems to be just a “blank check” to remove wild horses continually over a 10 year period, without monitoring the range or doing an EA each year for this purpose.

2.1 The Proposed Action
General — The proposed action has been developed in collaboration and partnership with the Nevada Division of Wildlife (NDOW), the Carson City and Battle Mountain District Offices, the University of Nevada Reno, the US Department of Agriculture (ARS & NRCS), Great Basin Bird Observatory, U.S. Geological Survey, and Smith Creek Ranch LLC.

WHAT ABOUT input from the PUBLIC, whose tax dollars pay for this (and your salaries)? Is this EA the first input opportunity the public has had? Was any scoping done? Please send me an unredacted copy of all of the public scoping comments.

…ranch would close the gate on the corral/trap either remotely or a mechanical release method may be used such as a trip wire. If a mechanical release method which is activated by the horses is employed the trap would be inspected daily whenever there is a possibility of the gate being closed.

The trap will ONLY be inspected once a day? What if a horse is injured? Will it be left to suffer for 24 hours or so? Since the trap is a remote location, shouldn’t a camera be on the gate in case there is a problem or injury to a horse? The BLM should supply cameras and tv monitors, like the ones BLM uses at Palomino Valley or Litchfield.

“Personnel from Smith Creek Ranch would follow all of the procedures outlined in Appendix D, Standard Operating Procedures for Wild Horse (or Burro) Gathers.
Gathered horses that are identified for removal would be taken to the Indian Lakes holding facility in Fallon, NV”

Indian Lakes Road is no longer going to be an intake facility, per John Neill, Indian Lakes Road COR, stated during an April 2012 public tour at the Indian Lakes Road STH facility. (Apparently, this does not represent policy and could change.)

“…the Palomino Valley Corrals near Sparks NV. The animals would be transported either by BLM personnel, Smith Creak Ranch personnel or a private contractor and subject to all the stipulations in Appendix D. Horses that would be An Animal and Plant Inspection Service (APHIS) or other veterinarian may be on-site”

A Veterinarian “may” be on site? A VETERINARIAN SHOULD BE REQUIRED TO BE ON SITE, THE ENTIRE TIME, FOR ALL GATHER ACTIVITIES, including loading and unloading of horses. Also, what experience do Smith Creek Ranch personnel have handling wild horses? What are the requirements? If there are no requirements, I will request a detailed description of the training BLM will give Smith Creek Ranch personnel.

“during the gather activities, as needed, to examine animals and make recommendations to the BLM for care and treatment… a freeze mark applied by either BLM personnel, Smith Creek Ranch personnel or a private contractor…”

2.4 Designate the Desatoya HMA as a “Wild Horse and Burro Range
Designate the Desatoya HMA as a ―Wild Horse and Burro Ranges‖. This action under 43 CFR 4710.3-2 would require the amendment of the CRMP, which is outside the scope of this EA. Only the BLM Director or Assistant Director (as per BLM Manual 1203: Delegation of Authority), may establish a Wild Horse and Burro Range after a full assessment of the impact on other resources through the land-use planning process.

Bob Abbey should do this, and I am asking Teresa Knutson to request that he do this.

p. 37 “While impacts to water from horses are different than cattle due to behavior (horses tend to not linger at a source and drink in the morning and at night), decreased cover and diversity of grasses and shrubs as well as decreased mammal burrow density have been documented from wild horses at water sources (Beever and Brussard 2000, Ganskopp and Vavra 1986).”

What about all of the other “uses” taking water from the aquifer, since the BLM doesn’t require 1’ and 5’ water drawdown maps, and a stream can dry up with a 1’ water drawdown? I doubt if the studies cited above considered this important aspect in their report or determination. What about the water used by all the geothermal leases in the area, which may use water from the same aquifer?

P. 38 “The herbicide proposed to be used in the Cold Springs fuel break is imazapic, and 2,4-D would be used for rabbitbrush and decadent sagebrush control. The environmental risks of these herbicides were analyzed in the Vegetation Treatments Using Herbicides on BLM lands in 17 Western States Programmatic EIS (2007). The application scenarios for the risk categories for terrestrial animals were direct spray, off-site drift (wind erosion), indirect contact with foliage after direct spray, ingestion of contaminated vegetation or prey, and runoff, which includes percolation to the root zone, at typical and maximum application rates. The Proposed Action would not exceed the maximum application rates.”

The BLM is only considering the “proposed action” alone, and is not considering or factoring in cumulative use in the area. The BLM needs to do an aggregate risk assessment considering exposures to humans, animals, water, drinking water, plants from COMBINED SOURCES in the area. BLM should do Drinking Water Level of Concern (DWLOC) testing and use the Forward Calculation Approach to include in an EIS (which I am now formally requesting, in writing, in this public comment).

According to the Environmental Protection Agency (EPA) 2,4D,

Exposure to 2,4-D has been reported to result in blood, liver, and kidney toxicity (1, 2, 4). Chronic oral exposure in experimental animals have resulted in adverse effects on the eye, thyroid, kidney, adrenals, and ovaries/testes (1). Experimental animal studies have demonstrated delayed neurobehavioral development and changes in neurotransmitter concentrations in offspring exposed during pregnancy or lactation (5-9).

Low concentrations of 2,4-D have been found in groundwater in some states. Agricultural run-off containing 2,4-D may contaminate groundwater in some areas.

Experimental animal studies of chronic oral exposure have reported adverse effects on the eye, thyroid, kidney, adrenals, adrenals, and ovaries/testes (1). In addition, some experimental animal studies have reported teratogenic effects (birth defects) at high doses, including increased fetal death, urinary tract malformation, and extra ribs (15, 16). When adult female experimental animals were exposed to 2,4-D during their pregnancy and lactation periods, their exposed offspring exhibited neurological effects, including delayed neurobehavioral development (5) and changes in several neurotransmitter levels or binding activities (6-9, 17) and ganglioside levels (18, 19) in the brain. Delayed neurobehavioral development was manifested as delays in acquisition of certain motor skills such as the righting reflex (5).
If the EPA reports this, how can this BLM EA, without considering cumulative uses in the area, state that risks will be “negligible?” (see below)

“The risk assessment concluded that in general, imazapic, even at high doses, does not adversely affect terrestrial animals, including invertebrates, as it is rapidly metabolized in urine and feces and does not bioaccumulate in animal tissue. The document did state that during pregnancy mammals may be more at risk and long-term exposure had negative effects on birds. However, application of imazapic would occur in the fall/winter, which is outside of the gestation period for most animals that may use the project area; therefore these risks would likely be negligible (BLM 2007b, BLM 2007c).”

“2,4-D can present risk to some wildlife species due to direct spray, consumption of the recently sprayed vegetation, and consumption of contaminated insects.”

Please prepare an EIS.

SOURCES:

https://www.blm.gov/epl-front-office...appendices.pdf

http://group.bmj.com/docs/pdf/8_3_s10.pdf

Hydraulic Fracturing Background Information | Hydraulic Fracturing | US EPA

Millions of Pounds of Toxic Dioxin to Flood US Farmland | Natural Society

Carcinogenic Dioxins Set Free: EPA Kneels to Monsanto | Natural Society

Federal Horse Rustlers & the Agenda 21 Hustle

April 30, 2012 by onephoenix

Debbie Coffey Copyright 2012 All Rights Reserved.

__________________________________________________ ___

To begin with, the National Association of Conservation Districts (the “mother” of all Conservation Districts) is partnering in a way that promotes IUCN and ICLEI USA, thus pushing Agenda 21, the UN’s action plan that will do away with your private property rights and Constitutional rights.

The Bureau of Land Management’s Wild Horse & Burro Advisory Board meeting (April 2012), was the first meeting including Sec. of Interior Ken Salazar’s new appointee, Callie Hendrickson. Hendrickson has served as an Executive Board member of the National Association of Conservation Districts, and works for the White River and Douglas Creek Conservation District in Colorado.

Several other representatives from state Associations of Conservation Districts were also at this meeting.
They looked like real Americans in their cowboy hats, but the influence they peddled was Agenda 21. Agenda 21 was disguised behind their words about rangeland health and pushing for the removal of, and for the unlimited sale (slaughter) of wild horses.
They were in Reno gambling with your Constitutional rights.

The National Association of Conservation Districts (NACD)
Mr. Chris Freeman was at this meeting representing the National Association of Conservation Districts (NACD). NACD is actively partnering with the Forest Service, which is a member of the International Union for the Conservation of Nature (IUCN). On the IUCN website, it states: “IUCN links its Mission to the paramount goals of the international community on environment and sustainable development, in particular Agenda 21…”
The objective of Agenda 21 is “communally and collectively owned and managed land.”

Neil Brennan and Gary Moyer, who work with Callie Hendrickson, were at the meeting representing the White River Conservation District in Colorado and pushing for the removal of wild horses. Gary Moyer is also listed as the Colorado Association of Conservation Districts’ representative to the NACD.

NACD publishes a newsletter “Forestry Notes,” funded by the Forest Service that contains stories supporting things like the Sustainable Urban Forestry Coalition, whose membership includes The Nature Conservancy and the International City/County Management Association. I’m all for more trees in cities, but let’s take a closer look at this.
The Nature Conservancy

The Nature Conservancy (TNC), is also a member of IUCN and participates in and promotes many UN programs, which ALL promote Agenda 21. TNC is a “non-profit” that pulled in over $925 million in just one year (2010 tax form). Their contractors include Tetra Tech, the huge environmental company that prepares Resource Management Plans and Environmental Assessments for the Bureau of Land Management (BLM). The public is led to believe that The Nature Conservancy buys land with private money and sets up nature reserves to help the environment.

But Tom DeWeese describes the reality: “The Nature Conservancy buys private land from owners (usually at drastically reduced, land-grab prices) who think it will remain in private hands and then sells it to the government! In fact, TNC has sold more than 9 million acres to the government at a nice profit.”
“The Nature Conservancy frequently uses phony front companies to get land” and it purchased “most of the islands off the coast of Virginia, containing 40,000 acres and sixty miles of coastline. In doing so, The Nature Conservancy was able to stop all private development and control the use of the land, damaging the tax base, killing thousands of jobs, and severely curbing the locals from hunting, fishing, camping and joy riding on the islands.
Don’t think the purpose was to preserve these beautiful, pristine islands for nature. The Nature Conservancy did bar others from developing the land, but not itself. Far from it, at a huge profit, the Conservancy developed upscale homes for the rich.”
Lee Pitts wrote in Agri-News: “TNC is involved in oil production and receives oil royalties.” “It hides behind phony corporations; serves as a shill for government agencies; and works behind the scenes with more visible environmental groups to intimidate property owners into selling. Its power, wealth, and control is almost beyond comprehension.”
Range Magazine published an article about The Nature Conservancy in 2003, and pointed out that TNC was “capable of manipulating governments, including that of the United States, endowed with assets amounting to nearly $3 billon…It would be directly in control of some 90 million acres worldwide, with more than 12 million acres…in the United States.”

The International City/County Management Association

The International City/County Management Association (ICMA) partners with and works “in concert” with ICLEI. It is also called Local Governments for Sustainability and was established at the U.N. It’s an international association of local governments pushing U.N.’s Agenda 21 (also called Local 21) into many U.S. local governments. ICLEI will put more power and control in the hands of regional, non-elected boards. (Not city, county or state government, where you have a voice and a vote.) This is based on Regionalism.

ICMA is partnering with ICLEI and the Dept. of Energy to promote solar technologies. (You’d think that if the BLM were concerned with rangeland health, that they’d be concerned with the billions of gallons of water solar energy will use.)

The Dept. of Energy, along with the EPA and State Department, actually FUND ICLEI USA with your tax dollars.

The Forest Service also seems to be marching in lockstep to support ICLEI USA.
Was the deck stacked in Reno?

At the Reno meeting, Hugh Sanburg of the Colorado Farm Bureau commended Sec. Salazar for his appointment of Callie Hendrickson, and stated that Colorado Farm Bureau supported her. Is the Colorado Farm Bureau going to support IUCN, ICLEI and Agenda 21?

John Falen of the Public Lands Council was also at the Reno meeting. This Council claims to “promote the great American tradition of freedom,” but yet John Falen (along with Callie Hendrickson) participates in pro horse slaughter Summit of the Horse events, organized by United Horsemen and International Equine Business Association, which are “partnering” with RFID companies that are “partnering” with international RFID companies that comply with international law.

Everell Hayes, a longtime BLM employee, was representing the Public Lands Foundation at the Reno meeting. The Public Land Foundation’s members include past and present employees of the Bureau of Land Management, and its President is Henri Bisson, who was the BLM’s Deputy Director of Operations.

NACD (National Association of Conservation Districts) encourages their state associations to sign Memorandums of Understanding (MOUs) with the BLM, and even has a sample on their website. They agree to promote mutual interests. It seemed like a stacked deck at this meeting for not only an agenda to remove and slaughter wild horses, but to deal in Agenda 21.

At NACD’s national meeting in Las Vegas a couple of months ago, members of state Conservation Districts took a wild horse tour with Southern Nevada Conservation District. (Clark County, along with the cities of Las Vegas and Henderson, are members of ICLEI.)

Callie Hendrickson gave a presentation on wild horses before the tour, using BLM’s “fuzzy math” estimates (“guess-timates”) about the number of wild horses on the range.

Hendrickson’s presentation also included a photo marked Wild Horse Roundups by Cattoor Livestock (the website for Cattoor Livestock Roundup, Inc.), a photo with S. Cattoor on it, as well as old photos from 1996, 1997, and 2002. It doesn’t seem like Hendrickson’s presentation informed people about other “uses” in the areas of the photos (either on those old dates or presently) that use a lot of water from aquifers and drop the water table. Her presentation didn’t seem to include the water drawdown maps from any projects (other “uses”) near the places where those photos were taken. The other uses of water effect water (and forage) not only for wild horses, but for livestock and wildlife.

Prior to her BLM Wild Horse & Burro Advisory Board appointment, Hendrickson pushed for “sale without limitation” of older wild horses and wild horses not adopted after 3 attempts (most go to slaughter).

At the Wild Horse & Burro Advisory Board meeting, there was talk of the merging of plans between the BLM & USDA’s Forest Service with “paired decision records and implementation” and cooperating agency agreements. There was the irony that while the BLM claims concern about rangeland health and drought, it would suddenly change procedure, “extending the shelf life” of Environmental Assessments (EAs), to only prepare one every 10 years instead of the usual 1-4 years. This not only gives the BLM a blank check to roundup as many wild horses as they want in that 10 year period, it also gives the BLM even less accountability to the public.

Some things at the Reno meeting almost went unnoticed. Like a brief mention of Vortex. The Vortex Population Viability Analysis Package is software that BLM plans to use for the wild horses in our country. Vortex is only distributed by the IUCN/SSC Conservation Breeding Specialist Group or the Chicago Zoological Society, and has “participation at several IUCN components… Dr. Bob Lacy is a world-renown researcher who leads numerous international conservation initiatives, including the chairmanship of the CBSG (Conservation Breeding Specialists’ Group) of IUCN.”
The wild horses are the canary in the coal mine.

As the wild horses are being removed from your sight, it is also the end of the trail for your private property rights, Constitutional rights, your voice in government, and real cowboys – what you are seeing in their stead is the implementation of Agenda 21 and international law.

__________________________________________________ ___________
TO LEARN MORE:
About ICLEI:
ICLEI
ICLEI: When they say local they mean it - DEMOCRATS* AGAINST* U. N.* AGENDA* 21
Is your city a member of ICLEI?

ICLEI - Local Governments for Sustainability : Global Members

What a horse slaughter plant could do to your town:
Texas Mayor Paula Bacon Kicks Some Horse Slaughter Tail - Forbes
What is behind the push for horse slaughter?
Horse Meat
More about the Forest Service and Agenda 21:
The Quiet Coup: The Implementation of Agenda 21″
THE QUIET COUP: The implementation of Agenda 21 « The PPJ Gazette

“Agenda 21 on Steroids”
Agenda 21 on Steroids « The PPJ Gazette

“The USDA’s Incestuous Relationship with the Rural Council and the United Nations”
The USDA

“Is the United Nations Stealing Control of our Water (and Republic) Right Out From Under Us?
Is the U.N. stealing control of our water (and Republic) right out from under us? « The PPJ Gazette
“The USDA Closing Roads to Public Lands While Opening Doors to the United Nations”
USDA Closing Roads to Public Lands While Opening Doors for the United Nations « The PPJ Gazette
“UN, Monsanto, Mining, Oil & Gas Companies Directing BLM Plans for our Public Lands”
UN, Monsanto, mining, oil & gas companies directing BLM plans for our public land « The PPJ Gazette
The Nature Conservancy:
Tom DeWeese -- Senate Poised to Vote on Huge Land Grab
http://www.rangemagazine.com/pdf/spr03_landlord.pdf
SOURCES:
http://www.whiterivercd.com/?page_id=6
BLM Announces Three Selections for National Wild Horse and Burro Advisory Board
Forestry - National Association of Conservation Districts
http://www.nacdnet.org/news/publicat...es_April12.pdf
ICLEI - Local Governments for Sustainability : Themes
http://www.nytimes.com/2009/09/30/bu...pagewanted=all
http://www.icleiusa.org/library/docu...eport_2010.pdf
US Forest Service - Urban Forestry
United Horseman News » AGTV – Blog
Public Lands Foundation
Climate Change - National Association of Conservation Districts
Member List — ICLEI Local Governments for Sustainability USA
Delegates Deadlocked in Durban: United Nations Climate Talks Head into Overtime - Planet Change | Inspiring people to learn about climate change and take action
ICMA: Leaders at the Core of Better Communities | icma.org
SunShot Solar Outreach Partnership | icma.org
May 2011 Forestry Notes - National Association of Conservation Districts
Callie Hendrickson, Executive Director, E-Z Communications | ZoomInfo.com
Partners | NRCS
http://nacdnet.org/policy/naturalres...y_platform.pdf
http://nacdnet.org/education/contest...stry_2011.html
Page Unavailable

http://www.beefusa.org/newsre

IUCN - SSC Leadership
http://www.blm.gov/pgdata/etc/medial...11_Phoenix.pdf
VORTEX PVA Software Chicago Zoological Society - Center for Conservation Leadership
Public Lands Foundation
Conservation District of Southern Nevada
Henri Bisson named new President of the Public Lands Foundation
http://www.whiterivercd.com/?page_id=6
ICMA International | icma.org
Conservation District of Southern Nevada
http://nacdnet.org/events/annualmeet...d%20Horses.pdf
http://www.cityofhenderson.com/susta...011_Report.pdf
The Nature Conservancy
Agriculture-Colorado:


Federal Horse Rustlers & the Agenda 21 Hustle « The PPJ Gazette