Clan Alpine public comment. DOI-BLM-NV-C010-2023-0004-EA

March 29 2023

We know that Clan Alpine HMA, HA, and Mountains are the traditional homeland of the Nuumu and Newe people and tribal members have a long history religious and spiritual connection with horses as they are considered a ‘powerful source of healing’ among all nations. The tribal members also use the clan alpine region as a source of culturally gathering traditional pine nuts.

The American people also consider the wild horse in the Clan Alpine HMA, the region, and in the entire country to be historically significant. From before the creation of the WFRHBA in 1971, wild horses and burros were a significant factor in the creation of this country. “Wild horses and burros are living symbols of the historic and pioneer spirit of the West; that they contribute to the diversity of life forms within the Nation and enrich the lives of the American people.”

According to ACHP. (2004). 36 CFR Part 800 — Protection Of Historic Properties, section (D) When Indian tribes and Native Hawaiian organizations attach religious and cultural significance to historic properties off tribal lands, section 101(d)(6)(B) of the act requires Federal agencies to consult with such Indian tribes and Native Hawaiian organizations in the section 106 process. Federal agencies should be aware that frequently historic properties of religious and cultural significance are located on ancestral, aboriginal, or ceded lands of Indian tribes and Native Hawaiian organizations and should consider that when complying with the procedures in this part.

This should be taken a step further to include the public citizens of this nation that also occupy the lands today and have rights of ownership of these public lands. I don’t know what could be more historic than the lands that once held millions of migrating native horses and burros who helped create the west, shape the west, build the west and helped pioneers to develop the land and the surrounding towns we occupy today. Without the horses and burros, there wouldn’t be an occupied west!

Documentation for centuries has shown the deep connection the public (foreign, domestic, and Native Indians) have to these wild animals and their historic and public natural lands. While some people have disrespected the animals for profiteering and greed, others will spend their entire lives as advocates with intention to protect them and their family bands from harm and death for the future of all generation to come. In a sense, that attempt by the citizens of this nation has become an American culture within itself as well.

The opportunity to visit these wild horses and burros that occupy our public lands; to learn of their history from books and online has brought people worldwide great enjoyment and connection to one another. Even in the horse and burro tragedies from roundups, death, and slaughter…  we are a connected people in sorrow and pain. Their existence has connected people from all cultures and created bonds that would not be possible if these creatures were not in existence and protected. The American people also recognize the healing qualities that wild horses create when being in their presence. Deep spiritual and religious connections occur when in the presence of such magnificent truly wild and free creatures.

My first experience amongst a wild herd was so emotionally overwhelming, and spiritual that I became an immediate advocate, and have spent the last two years consumed in mind, body, and spirit in my attempt to make their plight more known and bring awareness to others.

That encounter has brought me back in touch with my American history, and with the historical culture of our nation. It taught me to look deeper for the truth and what I found is that what has been stated in books that I was taught in my youth, is that the versions being told is one-sided and was written by men who attempted to eradicate the natives (genocide), and with it, their history. The white man’s version completely ignores the historic accounts of the Indigenous Natives that originally occupied the land, and had horse prior to the arrival of the Spanish.

Science, combined with historical Indigenous evidence and documentation, has shown that horses have been in North American prior to the Spanish settlers. “Good science requires diversity. It requires Native archeologists leading the charge because we’re now seeing that science and the Indigenous perspective often are converging on the same story.” One example is here… but more are being recognized worldwide.

History Colorado State Historical Fund. (2022, nov 17). Colorado Experience: Native Horses. Rocky Mountain PBS.  

There is cultural significance of wild horses for both the Native Indians, and Americans alike, and the horses, and their territories should be considered and included in National Historic Preservation Act (NHPA) and recognized as National Historic Landmarks.

In 1982, the National Research Council noted that public opinion was the “major motivation behind the wild horse and burro protection program and a primary criterion of management success,” suggesting that control strategies must be responsive to public attitudes and preferences and could not be based only on biological or cost considerations (NRC, 1982, p. 54).

As a citizen of this country, I want our public lands that are designated for wild horses to be ‘devoted principally for wild horses.’

I want it on record that as I attempted to research this Clan Alpine HMA prior to my comment, I was unable to locate very many documents from your BLM websites regarding this herd at all.

No documents in scoping notice. The link in your press release doesn’t work. Nor do the emails.

Are there documents relating to this herd and the National Historic Preservation Act?

Do you have any cultural resource documents relating to section 106 on this herd area for us to review?

I tried to locate this one you’ve mentioned in other documentation, but I wasn’t successful.

‘Bowen, K. (2015). Cultural Resources Class III Inventory for the Grazing Permit Renewal of the Clan Alpine, Cow Canyon, and Dixie Valley Allotments. BLM CRR 3-2570. On file at the Bureau of Land Management, Carson City District Office.’   I’ve sent an email request a few weeks ago for a copy of this, but it has still not been answered.

Are there any EIS relating to harm occurring to the horses, their genetics, the family bands, or the humans that are impacted by the gathers?  

Where can I locate all the genetic analysis’ from the Clan Alpine and surrounding herds if they intermingle going back to 1971, so we can see this historic DNA of this herd originally?

When was the last HMAP created for this herd? What other years where HMAPS created? Where may I review a copy of them? 

Links to any EA’s relating to this herd since 1971?

Where can I Iocate the Original HA maps from 1971 prior to Clan alpine, and surrounding HA’s prior to them becoming smaller HMA’s? How much of their territory has been Zeroed out?

No gathers are located, though we know they occurred from old news articles. Where can I locate information regarding this and population counts since 1971?  Where can I locate records relating to all gathers that have occurred in Clan Alpine since 1971?

You state: In July 2021 BLM conducted an aerial census flight and estimated the population of the HMA to be at 1,736 horses, which is well above AML. BLM expects to conduct another census flight in early 2023 to calculate a more current estimate.”

Has the second flight occurred as we are in the end of the third month in the 2023 calendar year?

Where can I locate all aerial censuses from 1971 to current, the July 2021 aerial census flight and particularly the December 2010 aerial census in Clan Alpine and surrounding HA’s?

We are aware that in 2011 you stated there were abundance or horses in that HMA, but had to cancel a roundup when an aerial showed not enough to gather after advocates notified you about this.

According to knowledgeable advocates who state: “Large numbers of wild horses consistently move from one HMA to the other and flyovers (for inventory) are not coordinated and concurrent. It should be pointed out that BLM has been aware of this “AML overlap” for a very long time.”

Is the BLM intentionally and knowingly using this to ‘deceptive counting approach’ to fraudulently increase the numbers of wild horses in the Clan Alpine HMA to warrant a gather (roundup)?

Are there overlaps with the surrounding herds? And if so, which herds overlap?

So how many horses ‘are really the average’ in the HMA, and not from adjoining HMA’s?

Can the horses move between the pastures within the allotments?

Can the horses move between the allotments within the HMA?

Can the horses move between specific allotments and other HMA’s? Which ones?

Until these answers have been fulfilled, you are knowingly deceiving not only the public, but also congress when you give them un-factual claims instead of stating facts.

Where can I see Maps that show how many horses are allowed in each of the three allotments, and their individual grazing pastures?

Where would I locate the percentage of HMA land the horses actually utilize?

Does the public own water rights within this Clan Alpine herd area?

Are there energy projects or mining taking place in the herd area?

The allotment master reports puts all 3 grazing allotments in the ‘improve category.’ Where can I locate the NEPAs, for the grazing allotments in clan alpine. Not sure I’m correct but are those called CX? 

Where can I locate the proposed or final documents for the (1992) Multiple Use Decision for this herd area?

Where can I locate all rangeland health assessments that are associated with this herd area covered in the going back to 1971?

Reports on how much forage is allocated to horse/burros compared to wildlife, and compared to cattle for this herd area.

Is there a Utilization study data reports for when the cattle were on the land, who consumes what forage?

I’ve spent many weeks attempting to locate answers and documents to my questions and was not very successful using your public websites. I wish these ‘publicly owned’ documents would be more easily accessible for me, and other members of the public who are concerned with the inner workings of our government.

I would like for my comment to be included in the ‘public’ scoping records in its entirety.

Thank you for the opportunity to comment on this. I look forward to the response.

Sincerely , Jennifer Robin.

To learn more of this Nevada herd and get documentation visit:

#clanalpineHMA #wildhorses

2 thoughts on “Clan Alpine public comment. DOI-BLM-NV-C010-2023-0004-EA

Add yours

  1. Stop rounding up or wild horses! We as taxpayers do not want our tax dollars spent on this cruel and inhumane roundup!

It's too quiet around here. Your words matter!

Up ↑

error: Alert: Content is protected !!
%d bloggers like this: