******* ENVIRONMENTAL ASSESSMENT*****

Jarita Mesa (El Rito)

Here is a list of problems with the EA and DN:

1) The Forest Service did not accurately count the number of wild horses in the Area.

The EA states that there are 20-70 horses, with an average of 25-30. However, the EA says that the Forest Service has never counted more than 60 in the last 30 years. As such, they do not really know exactly how many horses are actually out there. This is further illustrated by the contract, which states that there were two counts within 2 and 1/2 weeks that concluded 33 horses on one count and 63 on another. There were no photos taken and questionable methodology, so the second count could have double counted horses. Overall, if there is no accurate count of how many wild horses are in the area, how can the Forest Service ensure that there will be at least 20 (at least 20-70 is the goal of the DN) horses to protect the "viability" of the herd? Further, if the original count of 33 was accurate, and the contract allows for 30 horses to be captured, the population will be wiped out.

2) The Forest Service is allowing improper methodology for capture.

The Forest Service states in the DN that one of the methods to be used for capture is pushing the horses into traps with helicopters, snowmobiles, and horses. This method, according to the DN, is to be used in winter with sufficiant snow conditions. The EA itself says that "injury to wild horses during gathers will be minimized by using approporiate methods and seasons . . . ." (EA p. 8). The EA is inconsistent with the DN and the contract in this respect, because the Forest Service plans on using these methods in the spring. However, the Forest Service managed to give themselves an outlet on this whole issue because the EA states that the season of capture is not part of this decision. They further claim that there are no long term effects from helicopter herding (EA p. 31). I find both of these contentions very problematic, considering that the method of helicopter corraling can have very serious reprocusions if conducted during the breeding season. There must be a reason why both the EA and DN list appropriate conditions for methods.

3) The criteria for capturing are based on arbitrary assumptions.

The EA states that the criteria for capturing the horses is 1) poor health of the horses, and 2) sex/age ratio adjustments. However, the EA states that the FS has no age or sex ratios for the herds, but that they will judge them during capture. Such ratios should be predetermined before this roundup begins.

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Last modified: 04/25/08