May 18, 2005

RE:  Scoping for the Proposed Lucky Allotment Fencing and Seeding Proposal within the Legally Defined HMA

Dear Sirs,

Thank you for providing WHOA the opportunity to comment on the proposed range improvement project, billed as multiple use.  Please provide WHOA with a copy of the draft Environmental Assessment (EA) and decision.

WHOA opposes any permanent obstruction to the horses within a herd area, with the possible exception being riparian habitat protection.  This project did not indicate that the proposal was riparian related.  But more a big sage removal, a seeding, and fencing, to protect it for at least two years. 

The definintion of range as provided in Section 2 of the "Act", "C", is:  range; means the amount of land necessary to sustain an existing herd or herds of wild free-roaming horse or burro, which does not exceed their known territorial limits and which is devoted principally, but not necessarily exclusively to their welfare, in keeping with multiple use management concepts for public lands".  There is NOTHING vague about this definition!  What is "implied" is that wildlife have the right, and cows can use it to graze. NOWHERE does it infer that the only legal area the horses have where they can roam should be cut up to facilitate livestock management. 

We are not re-assured that this proposal, dressed up to look like multiple use, will benefit the horses in any way!  We can give you many examples, recent ones, where horses starved to death because of forgotten gates, another where they died of thirst, again, because of forgotten gates.  But the most severe was the discovery that wild horses were exclued from nearly 50% of their legal herd area beacuese of illegal add ons or ties ins to the original fences.  How did BLM not know this and who is supposed to be watching. 

WHOA will continue to vigorously defend the prohibitions of the wild free roaming horse and burro act.   

Most Sincerely,