I really do not have the time to do yet one more blog...

I am still working on the blog specific to why Arapaho Creek should be an HMA, we are short on time to submit comments - and yet here I am.

Typing away my afternoon with a lot of anxiety and frustration at the entire thing, and at this moment especially over the proposed HMAP for the Red Desert Complex.

This thing is.... well, it reads mostly like a long-term roundup and removal plan rather than a long-term plan for management of wild horses on wild lands!

Herd Management Area Plan - that sounds like something that should be focusing on how best to manage wild horses on their wild lands.... right???

I don't have a lot of experience in reading these things and knowing what they should look like and what they should discuss, so I went to compare the new proposed HMAP to the previous one done in 1994 - and then I realized that the document provided to us the public to review in preparation to comment on the new HMAP - it is not even the final HMAP for 1994, nope, it is the preliminary document offered for comment - we do not know what was in the actual final HMAP last done for the desert.

Even as a preliminary document I found it wonderfully full of information... an over-whelming amount of information!! Good thoughtful well written information.....

It is a lot to go through, and I cannot pretend to have read it all as I find myself limited in time to read multiple documents and write this, and this HMAP has extra as at that time it included HMAs that were not in the Red Desert Complex but were managed by the Rawlins office - but I absolutely love that there is so much information freely provided and find myself jealous of the public that in the 1990s were given so much actual information without fighting every single step!

I then went to the most recent HMAP that I am aware of, the 2019 Fifteenmile HMAP, which was well written with 23 pages of discussion on how wild horses and their land would be managed, with the interest of the horses and the land in the document.

In comparison to other HMAPs the one we have been offered to review and comment on for the Red Desert Complex is flimsy.... all of 11 pages almost all of which are tables, several of which barely have a sentence, rather than actual substantive information.

Seriously?

This is what is going to be allowed to pass as a management plan that is to stand for how many years? HMAPs are not updated very often.... so when it is done there should be quality information and time planning and writing invested in it!

Things that could and should be included in the Red Desert Complex HMAP:

** Discussion of recent forage utilization and when measurements were last done and when and how often they will be done in the future.

** Discussion of previous HMAP objectives and a comparison to current conditions.

** Annual wild horse populations for every year since last completed HMAP - for many years annual census flights were completed to observe population growth of wild horse herds, more recently yearly flights may not have been completed, but there should still exist an estimate as is required annually for each HMA.

** Discussion specific to maintaining the New World Iberian characteristics as part of the management, there is some discussion of specific desired genotypes, but there is no specific language describing the retaining of New World Iberian influence in the complex - something that has historically been an expected part of this complex.

** How many geldings will be released, this can be provided as either an actual number per roundup or as a % of herd, also where will the identifying freeze brand be placed on the geldings and what will it look like.

** Will AML be adjusted for the HMAs that have geldings released in them? Geldings are obviously not able to reproduce and so should not be included in the AML number in which there are a set number of adult breeding pairs.

In this Red Desert Complex action the HMAP is treated as a secondary document listed as an appendix in the EA, which is fine, to attach it to the EA, but to treat it as a part of the EA (or as an after thought to the EA) is misleading.

An HMAP is a document that provides additional long-term guidance on wild horse management and their wild lands, it is an outline of sorts, showing us long-term plans on how the herd will be managed and what will be done to help manage the health of the herd and the health of the lands.

This document barely references any of these things, instead repeatedly referring to AML assessment 'about' every three years and completing immediate removal of wild horses any time it is determined there are 'excess' horses in order to achieve low AML.

That is hardly a healthy discussion or plan for managing wild horses on wild lands.

I cannot stress to you how necessary it is for us the public submit comments challenging this HMAP - it needs to be re-written and re-submitted for public comment.

Additionally the most recent final HMAP completed in 1994 needs to be provided to the public to review in comparison to the new proposed HMAP.

The encouragement of public participation is sadly lacking in this thing and cannot be ignored, there are many things in the past that have escaped attention and now it is incredibly difficult to push back on that precedent - but we must push back!!

Please - read as much as you are able of the preliminary EA and HMAP for the Red Desert Complex, and then prepare and submit your individual and unique comments through the NEPA website, the link to the documents and participation are below:

Home page link:

https://eplanning.blm.gov/Project-Home/?id=6c9a6ab7-c027-f111-8341-001dd804183b

From the home page you can click on documents and/or participate now - good luck, any questions please let me know, and thank you!!!

P.s.... I am indeed still working on the blog specific to Arapaho Creek and will have that out in a few days!