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The 361 page EA is voluminous, not because it contains detailed information about the wild horses of Triple B, but because it simply creates an extremely large geographical area.
The document contains the agency standard for an EA of cut and paste Codes of Federal Regulations (CFRs) that recite authority for elements of removals and obligations to profit driven uses, local governments, tribal authority and other species.
The document regurgitates the "healthy herds, healthy rangelands" without ever defining how wild horses are quantified into the equation.
There are no existing Herd Management Area Plans (HMAPs) for any HMA included in the document. An HMAP is supposed to demonstrate all data about each HMA and outline a preservation strategy for the herd and habitat.
Instead the document gives an appearance of compliance by the number of pages. In truth it does not comply with the Wild Horse and Burro Handbook.
The document will tier to land use plans and multiple other documents to create the legal framework. The intention of the framework is supposed to include wild horses. Only a handful of current approved EAs in the nation include a tiered HMAP.
The National Academy of Sciences has failed the BLM on data for decision making program wide. Creating an HMAP, that outlines how the data gaps will be addressed, prior to any EA creation, would be a first step in dragging this program out of the cowboy myth and political corruption that has kept it broken, and an easy scapegoat for failures in addressing the larger grazing program, for over forty years.
The EA for this operation is an example of the effort the agency is giving to maintaining, not fixing, a broken program.
Photo: Laura Leigh, Wild Horse Education