Egan and Johnson Basin Restoration Project Preliminary Environmental Assessment
Craig Downer’s Comments:
August 27, 2017
2. I am very concerned that under the guise of Greater Sage Grouse rescue, BLM would be in fact through this project perpetrate the continuing near monopoly of resources by the public lands livestock ranchers, including both cattle and sheep. I have spent weeks in and around the project area and have also overflown it and have given reports to BLM and to conservation organization in this regard. It seems just too convenient that the various grasses that are chosen as priority species are those that help the ranchers the most, while the exact needs of the other wildlife species, other than big game hunted species, are not adequately treated. It seems to me that there is a sort of “green-wash” going on here that is not really all that “green”.
3. In my capacity as an ecologist, I have made observations throughout the project area in connection with the legal wild horse presence as part of the Triple B HMA. I have given input in the defense of this national heritage species to your office and made declarations in court proceedings for their fairer treatment, e.g. higher AMLs, better resource allocations, etc. This stated, I particularly protest your dismissal of wild horses as an impacted legitimate interest by the project. The Pinyon Pines and the Utah Junipers in question are very important shelter species for the wild horses, and the great reduction that your project proposes would have a major negative impact on their survival during both very hot seasons (lack of shade) and very cold seasons (lack of shelter from storms, wind, etc.). I also resent the exclusion of the wild horses in your discussions of cheat grass reduction, for the wild horses are perfect reducers of cheat grass when allowed to eat such before they mature and set seed. Again I see that livestock such as cattle, sheep, and goats are favored here, but the wild horses are ignored in this regard. As I have observed in the field in the project area, the problem stems from their not being given their rightful legal access to their entire HMA because of a series of fences that interfere with their natural migratory patterns during the course of the day, month, and year. You also very much overlook the major beneficial role wild horses have in preventing catastrophic wildfires. As you are undoubtedly aware, these fires are alarmingly on the increase, along with temperatures, due to humanity’s pollution of the atmosphere with all his machines, livestock, etc., i.e. Global Warming. But the wild horses, if allowed to fill their niche here in their legal Triple B HMA would become perfect “fire-prevention brigades”. They would not only reduce the fuel load but convert it through their droppings into more nutrient-rich and moisture-retaining soils than would be the case with the current status quo that promotes a major monopoly by ruminant herbivores, i.e. cattle, sheep, mule deer, etc. The horse’s post gastric digestive system does not as thoroughly digest what the horse ingests, and in this and many other ways thus lends a much needed balance to the ecological community. And this goes hand-in-hand with their wide-ranging movements and their not camping on the riparian habitats, as domestic cattle set out on the rangelands tend to do. I urge your team to seriously consider these positive points about the wild horses and to integrate these into your further analysis.
4. I favor the No Action alternative, because the alternatives presented are too extreme and give me no other choice. Because of the major impacts that would ensue should you carry out this proposal, I assert that under NEPA you should perform an EIS.
Please keep me informed of further opportunities to participate in this EA/EIS process and of any decisions you are making. I am providing my address, email, and telephone number, should you wish to discuss any of the points I have risen. I would appreciate a response to the points I have raised. Again I greatly appreciate this opportunity to give my input and trust that you will give it due consideration.
Craig C. Downer