PUBLISHED WITH PERMISSION OF MR. CRAIG C DOWNER
February 27, 2012
Battle Mountain District Office
Bureau of Land Management
50 Bastion Road
Battle Mountain, Nevada 89820
Fax 775-635-4000. Tel.. 775-635-4034
Attention: Angelica Rose
I have just reviewed your DEIS on the Eureka Moly company’s Mount Hope mining project particularly as it affects wild horses in their legal herd management areas of Robert, Whistler, Fish Creek, etc. I find this mining project to be entirely unacceptable and contrary to the chief mandates of the Wild Free-Roaming Horses and Burros Act of 1971. As spelled out in the DEIS, the Mount Hope open-pit mining project would directly remove tens of thousands of acres of wild horse and other wildlife habitat and have a pervasive negative impact on adjoining areas over a broad circumference. The negative impact would continue for several decades, more probably even centuries into the future. The projected negative impacts to the water sources and to the existing vegetative communities (to which the wild horses have adapted over the generations here) would devastate these populations and the wild-horse-containing habitat that has adjusted to and in many ways benefited from their presence. The proposed mitigating measures are unrealistic and a mere whitewash for the unacceptable damage that would be caused. I strongly urge adoption of the NO ACTION alternative. To do otherwise would violate the WFHBA on many points in addition to NEPA, since the proposed action would constitute a significant negative impact on the formerly healthy and vital Roberts Mountain Complex wild horse herd. I have visited this herd and would be personally and professionally impacted by the enactment of this project.
In reading the DEIS, I have noted the following points:
(1) When stating that there are “no natural predators” of wild horses found in the area you are misleading the public. The puma (Felis concolor) occurs here and is a significant natural predator of these animals. Coyotes may also take foals and other disadvantaged wild horses. These species should not be overlooked nor should our own species, members of which do frequently and illegally kill wild horses, either directly or indirectly.
(2) Your analysis lacks consideration of the negative ecological effects of the more shallow water table drainages, as would be caused by the huge open pit, trenches, as well as the short- and long-term toxic effects of chemicals used in crushed ore leaching and natural leaching of discarded crushed ores that involves sulfur and nitric acids. These ill-effects can last for centuries into the future. You should do an analysis of both one-foot and five-foot drainages, including maps, for these affect many species, and it would prove very difficult to adequately mitigate for their pervasive ecological damages.
(3) You need to examine the mandate of the WFHBA to maintain a “Thriving Natural Ecological Balance” as per Section 3a. This unanimously passed Act represents the General Public’s keen interest in our public lands and its, in fact, returned North American native wild horses and burros. The Mount Hope project would clearly upset this balance and, for this reason, needs to be cancelled. In it there would be no hope at all for the beautiful natural life community and its wild horses. Your treatment of the long-term viability of the affected wild horse population and the meta-population to which it contributes is entirely lacking.
(4) In my opinion, this mining project jeopardizes the long-term health and viability of the herd and herds surviving here and in no way accords with Section 2c of the WFHBA. This section defines a legal herd area as “the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros … and which is devoted principally but not necessarily exclusively to their welfare in keeping with the multiple use management concept for the public lands.”
Finally: if we take “multiple use” to mean a balanced representation of all the values and presences on the public lands taken as a whole, then the proposed action through its undermining of the relatively minor presence of wild horses in their small fraction of the public lands where they have a legal to live – clearly does not accord with true multiple use. This violates the WFHBA as well as the Federal Land Policy and Management Act, the Public Lands Improvement Act, the Multiple Use and Sustainability Act and others.
Craig C. Downer
Wildlife Ecologist & Author
P.O. Box 456
Minden, NV 89423
PLEASE PUT AN END TO THE BLOOD SOAKED HANDS OF CANADA. PLEASE RAISE YOUR VOICES AND SAVE THESE MAGNIFICENT EQUINES.
Please support NDP, MP Alex Atamanenko’s call to close all Canadian Horse Slaughter plants.
“It is criminal to sell this meat to humans and the government must shut this industry down immediately”…
Contact Alex and give him your support.
Ottawa Office: email@example.com
525 Confederation Building
House of Commons
Ottawa, Ontario K1A 0A6
To protest against the inhumane slaughter of horses in Canada and the fact that many of these animals are unfit for human consumption due to the many drugs administered to domestic horses also slaughtered for their meat.
Contact: Minister of Agriculture: Gerry Ritz: 781 Confederation Bldg., House of Commons, Ottawa, Ontario K1A 0A6
Dr. Brian Evans, Chief Veterinary Officer of Canada, Canadian Food Inspection Agency and Geoge Da Pont, President, Canadian Food Inspection Agency
1400 Merivale Rd, Tower 1, Floor 6, Ottawa, Ontario K1A 0Y9
Speech for Wild Horse Summit, Las Vegas, NV, Oct. 12, 2008, organized by ISPMB
In 2008 Mr. Craig C. Downer a renowned Wild Horse Expert delivered his speech:
Paul’s message to President Obama, March 2010, outside the American Embassy, London
From: defendhorsescanada.org/do-it-now.html : The CHDC has documents evidence of horse neglect and abuse…the Federal Health of Animals Act is not enforced, the Recommended Code of Practice for Care and Handling of Farm Animals: Transportation of Horses in not enforced.
Canadian Horse Defence Coalition (website post) : Chambers of Carnage: A Sweeping Undercover Investigation of Canada’s Leading Equine Slaughterhouses.
Animal Defense League of Canada Newsletter: Bulletin #179 – Spring/Summer 2012 :
ADLC Website: www.ncf.ca/animal-defence
“The CFIA has reviewed the report and initiated an immediate investigation of the facilities in question to ensure that proper procedures are being followed and that mandated standards for duty of care are being consistently met…”
“Ask the Ministers for the results of that investigation of the videoed horrific abuse of horses – use of whips and electric prods, repeated botched attempts to stun horses at Canada’s equine slaughterhouses –and what legal action is being taken”.
American Wild Horse Preservation Campaign
Thursday: National Call-In Day to Protest Interior Secretary Salazar’s Pro-Horse Slaughter Appointment
Reminder: Speak Up for Idaho’s Wild Horses in Challis
FOREVER WILD AND FREE
IS IT BAD ENOUGH FOR YOU
CANADA BLOODIES HER HANDS AS USUAL!!! END THIS NOW!!
See Stats Canada chart showing number of American horses imported into this country for slaughter, the US banned this yrs ago and shut down their own slaughterhouses
Dirty little secret: Canada’s slaughter industry under fire
4 Slaughter Houses in Quebec, 1 slaughter house in Alberta