BLM Again Targeting Herd Filmed by Ginger Kathrens of The Cloud Foundation

Debbie Coffey   Copyright 2011 All Rights Reserved.

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Mr. James M. Sparks, Field Manager

BLM Billings Field Office

5501 Southgate Drive

Billings, MT  59101 

Dear Mr. Sparks:

            My comments regarding your scoping notice for capturing and removal of wild horses in the Pryor Mountains are: 

1)       In your “DESCRIPTION OF THE PROJECT” you base your reasoning for the need to remove the wild horses on “preventing deterioration of the range” while “maintaining a  thriving ecological balance.”  I will now notify you of reasons why I believe this “justification” is perpetrating fraud on the American public. 

In reviewing the 40 pages of APDs (Applications for Permits to Drill) for oil and gas since 2003, I see that many of them were approved.  Although this document is from the Miles Field Office in Montana, it included APDs within boundaries of the Billings, MT, BLM Field Office.

These permits were probably given a Finding Of No Significant Impact by BLM Field Office Managers, even though each well probably uses a couple of thousand gallons of water per day for exploratory drilling (much more than the horses drink, and much more terrain is disturbed by construction of the oil well pads and additional roads, etc., than could ever be attributed to some horse hooves).

It seems that when these APDs are granted, the BLM’s scope is myopic in that the BLM doesn’t seem to foresee, or care to mention, that if these any of these wells start to really produce, there will be a huge INCREASE in public land disturbance and INCREASED USE of water.

There are also many more APDs pending. Will I be reading any BLM Environmental Assessments about preventing or removing oil and gas production with reasoning that there’s a need for “preventing deterioration of the range” or “maintaining a thriving ecological balance” or any concern about the “watershed condition?” In looking at the oil and gas lease sales for Billings, MT Field Office, I see that thousands of acres of public lands are going to oil and gas lease sales each quarter.  I’m not going to take the time to add up the total amount of acreage now, but I will when I make a public comment on any upcoming EA by your field office.  If anything, this is OUT OF ECOLOGICAL BALANCE, and giving an unfair amount of “multiple use” to one use (oil and gas) over another use (wild horses)

2)       In your “RELATIONSHIP TO EXISTING PLANS and DOCUMENTS” you mention that your objective is “to manage for a balance,” and you also mention the “watershed condition.”  

Since you brought up water, in looking at some other projects in your district, I see that you gave a Finding of No Significant Impact” to the Bull Mountains Mine #1, a coal lease, saying this “will not significantly affect the quality of the human environment, individually or cumulatively with other actions in the general area. No environmental effects meet the definition of significance in context or intensity as defined in 40 CFR 1508.27…”   

Really?  How did you come to this conclusion after it was noted that Madison Formation wells provide water used for the underground mine equipment and the coal

preparation plant and use is approximately 500 gallons per minute?  That’s about 720,000 gallons of water PER DAY.   This is a LOT of water taken from the aquifer.

Have you added all of the additional water used by all the oil and gas leases?  If a reasonable person compared the above usage to the 15-20 gallons of water a day a wild horse drinks, they would come to the conclusion that I have:  If there is not enough water (or forage because of the lack of water) for our wild horses, it is ONLY because the BLM has mismanaged land and water use.   

Aquifers are not confined by Field Office or county boundaries.  The USGA has said of aquifers in your region “Most of the aquifers in Montana, North Dakota, South Dakota, and Wyoming are parts of five large regional aquifer systems. An aquifer system consists of two or more aquifers that function similarly. The aquifers can be hydraulically connected so that a change in hydrologic conditions in one of the aquifers will affect the other aquifers or separated but with common geologic and hydrologic characteristics. Much of the freshwater that is withdrawn in Segment 8 is obtained from the regional aquifer systems, some of which extend far beyond the boundaries of the segment.”  The BLM might as well just be honest and say “We’re getting rid of the wild horses come hell or high water to replace them with other ‘multiple uses’ that make more money.”  It’s obvious to the public that this is what the BLM is doing.

 http://pubs.usgs.gov/ha/ha730/ch_i/I-text2.html

http://www.blm.gov/mt/st/en/prog/energy/oil_and_gas/leasing/historic_sale_results.html

http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/energy/oil_and_gas/apds.Par.78213.File.dat/MCFOpending.pdf 

About those wild horses: Another “Bored” Meeting?

Debbie Coffey    Copyright 2011   All Rights Reserved.

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After reading the Federal Register notice (Sept. 6, 2011) announcing the next Wild Horse and Burro Advisory Board Meeting in Arlington, VA, Oct. 13-14, 2011, it seems that the “Public Comment Procedures” as written here may be in violation of your First Amendment right to free speech.

The notice states that “Speakers must submit a written copy of their statement to the address listed in the ADDRESSES section above, or bring a written copy to the meeting.” 

Why “must” you do this?  It’s a public meeting and you don’t have to submit anything to have the right to speak at a public meeting.  You can just tell them your name and tell them you want to speak.  Period.  The meeting will probably be recorded and the BLM could use the recording for transcription purposes, and any requested written comments should be voluntary.  That is not what is stated in the Federal Register.  Also, requiring that speakers submit a written copy of their statements could discourage some people (who don’t like to write) from speaking.  

You also don’t have to “address the specific wild horse and burro related topics on the agenda.”  This is a violation of your First Amendment right to free speech.  You can talk about anything you want to talk about.  If you want to get up and read “Little Bo Peep” for 3 minutes (or whatever time limit they set), you have the First Amendment right to do that.  If the BLM only wants you to talk about topics on the agenda, and then controls the agenda, they could then possibly control the content of public comments, which might then be against your right to free speech.

The notice also states “The BLM considers comments that are either supported by quantitative information or studies or those that include citations to and analysis of applicable laws and regulations to be most useful and likely to influence BLM’s decisions on the management and protection of wild horses and burros.” 

Why do we have to include “quantitative information or studies” with a comment or opinion for it to be “most likely to influence” the BLM?