January 12, 2011 – Fertility Control EA

The Billings Field Office has issued a Finding of No Significant Impact and Decision for the Pryor Mountain Wild Horse Range Fertility Control Environmental Assessment (DOI-BLM-MT-0010-2011-0004-EA Tiered to the Pryor Mountain Wild Horse Range Environmental Assessment MT-010-08-24 And Herd Management Area Plan May 2009). Copies of these documents can be downloaded by clicking on the images or links below.

Finding of No Significant Impact/Decision Record


Environmental Assessment


I would highly recommend that you read through these documents in their entirety. They aren’t too long; together the two documents are less than 50 pages in length. (It only took me about 50 minutes to read everything in both documents.) The EA has been formatted to be really user-friendly. As you go through the EA, you will notice that there are sections highlighted in grey. These are areas that were either added or changed from the preliminary EA. This makes it easy to see what changed since then. As you read through it, you will see that the EA basically has eight different sections and two appendices, each of which has important information. Below I have summarized some key points to learn about as you read through these sections.

1.0 Background Information: Section 1 acts as an introduction to the EA. The first part of this section is 1.1, the introduction. This section has information on the idea of tiering environmental assessments. It also has a general introduction to the proposed action. Section 1.2 (Location) goes over the location that the EA covers. It basically describes the geography of the Pryor Mountain Wild Horse Range. Section 1.3 (Purpose and Need for the Proposal) explains why there is need for action and how and why the impacts of a fertility control program will be analyzed. Section 1.4 (Relationship to Planning) elaborates on the different plans and laws that guided the decision making process for the EA. Section 1.5 (Scoping) explains how the BLM released its original scoping notice. Section 1.6 (Public Comment) explains how the BLM carried out a public comment period and what was done with those comments.

2.0 Proposed Action and Alternatives: Section 2 goes over the proposed action and other alternatives analyzed in the EA. Section 2.1 (Proposed Action) describes the proposed action. Section 2.2 (No Action Alternative) explains what the no action alternative would be as well as what its effects would be. Section 2.3 (Alternative Considered but Elminated from Further Analysis) discusses a different strategy involving gathers.

3.0 Affected Environment and Environmental Consequences: Section 3 goes over the different impacts that the plan may have. Section 3.1 (Critical Elements of the Human Environment) consists of a table showing the potential impacts to different resources. Section 3.2 (Wild Horses) provides very specific information on how the proposed fertility control program could possibly (both positively and negatively) impact the Pryor Mountain Wild Horses. It also has research-based information on potential impacts. I think that this is a very important section to carefully read.

4.0 Cumulative Impacts: This section discusses what may result in the future from the implementation of the EA.

5.0 Mitigation and Suggested Monitoring: This section explains how a fertility control program would be carried out as best as possible.

6.0 Consultation and Coordination: This section starts by discussing the history of the development of the EA with public comment. Section 6.1 (Response to Comments) is a large section where the BLM has addressed specific comments that they received. This is a pretty comprehensive section that has some more detailed information in it.

7.0 References: This section has information on all of the sources cited throughout the EA.

Appendix I: This appendix has a history of the past use of PZP on the Pryor Mountain Wild Horse Range.

Appendix II: This appendix has the standard operating procedures for the use of PZP.

Again, I would encourage everyone to read through the EA. If you have any questions, feel free to post them; and I will work to get them properly answered!

Published in: on January 12, 2011 at 3:37 pm  Comments (7)  

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  1. On pg 7 under 1.4, Relationship to Planning, the Preliminary Environmental Assessment says:

    The Wild Free-Roaming Horses and Burros Act of 1971 (Public Law 92-195) as amended, Section 1333 (b) (1), states that the Secretaries of the Interior and Agriculture shall “determine appropriate management levels of wild free-roaming horses and burros on areas of public lands; and determine whether appropriate management levels should be achieved by the removal or destruction of excess animals, or other options (such as sterilization or natural controls on population levels).” According to 43 CFR 4700.0-6, “Wild horses shall be managed as self-sustaining populations of healthy animals in balance with other uses and the productive capacity of their habitat.” In addition, 36 CFR 222.21 states that wild horses within USFS territories be administered to “maintain a thriving ecological balance considering them an integral component of the multiple use resources, and regulating their population and accompanying need for forage and habitat in correlation with uses recognized under the Multiple–Use Sustained Yield Act of 1960.”

    OK. I’m wondering about the meaning of the part of this that says “maintain a thriving ecological balance CONSIDERING THEM AN INTEGRAL COMPONENT OF THE MULTIPLE USE RESOURCES…” referring to the wild horses on USFS territories. To me, that shouldn’t mean totally eliminating them from USFS land, which is what happened in the last gather, and is still being worked on, is it not?

    I’ll continue to read, and maybe will answer my own question by doing so, but maybe you can help me understand this part if you have time.


    • Any answer yet?

      • There are a couple things I’ve heard in regard to the FS horses.

        First, from the introduction of the 1971 Act: “Congress that wild free-roaming horses and burros shall be protected from capture, branding, harassment, or death; and to accomplish this they are to be considered in the area where presently found, as an integral part of the natural system of the public lands.” “Considered in the area where presently found” is the key part of that sentence. I have seen and heard this interpreted to mean that managers are supposed to consider these areas for horses, but that doesn’t mean that they are required to use the entire area for horses. Many wild horse areas have herd areas that are much larger than the herd management areas that horses actually live in (the Pryors has a little bit of HMA out of HA, the Peaks a fair a mount, and the Fifteenmile quite a bit up here.)

        Also, the Forest Service’s planning documents for the Pryors only allow for the management of the horses in Area Q up there; this is what a lot of us call the Forest Service Triangle, the northwestern part of the Range that is actually a FS Territory.

        Another good resource for this is 43 CFR Part 4700, this is the section about wild horses. It can be read here: http://law.justia.com/us/cfr/title43/43-

        Hope this kind of helps!

  2. Thank you for the outline above. It is very helpful.

  3. PS Is there a simple way to explain the below by defining some of the practical implications of this statement – (found in EA)

    “Pryor Mountain Wild Horse Range (PMWHR). The combination of agency and private rangelands authorized for use by wild horses. Not to be confused with Wild Horse Range (see definition below) which is a special designation which only the BLM portion of the PMWHR has this status. ”

    If you explained this elsewhere please indicate where.


  4. Also have fires changed anything in past few years that would affect the food sources on the lower to mid elevations of the horse range?

    Is there a problem with bromus tectorem on the horse range? If so, how might this affect the range in the aftermath of a fire? I understand the bromus tectorem is an agent in spreading fires, thus engulfing more of the food plants the horses would normally use in the winter time.

  5. “…and to accomplish this, they are to be considered in the area where they are presently found,as an INTEGRAL part of the natural system of the public lands”. Since the definition of “integral” is “necessary for completeness: essential” or “making something complete”, and since there is a comma following “found”, not a period, I interpret that to mean that the horses should be a part of the use of the area,(if they were there in 1971), not exclusively, but not to be excluded either. Both of the phrases in that sentence refer equally to the word “they” [wild horses and burros]. In other words, “they” are to be considered in the area where presently found AND “they” are to be considered an integral part of the use of the area[of public lands].USFS land IS “Public Land”, as I understand it.

    I’m going to refresh my memory a bit on the functions of grammar and sentence construction, whether or not the horses were considered to be “there” when the Act was written, and I will visit and read the link you provided about 43CFR Part 4700, above. I hope it will clear things up a bit more for me. I’ll also take a look back and the maps you’ve posted for us identifying the areas.

    I guess it all boils down to what angle the interpreter of the law prefers; and maybe how well they understand and use the English language.

    Thanks for taking time to try to help me understand all this.

    I was wondering if you might get time to indicate as closely as possible,on a map of the Range, where the water sources are located sometime, too. I have a pretty good idea about a few, but don’t have a clue about the rest.

    Thanks again for all you do.

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