Who Should Americans Blame For Incinerating Flames And Deadly Smoke From Wildfire?
It now seems clear that the current wildland and wildlife management policies that affect wildfires is flawed (maybe negligent?) in light of the changing climate combined with a significant decline in America's native species large herbivores.
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Decline In Deer And Wild Horses Kindling Catastrophic Wildfires
Large herbivores, such as deer and wild horses have over evolutionary time evolved to control and maintain the grass and brush that is ubiquitous across the landscape. The now prodigious grass and brush that has resulted from a significant decline in our native herbivores is fueling and kindling catastrophic wildfires, makes them abnormally hot, resulting in the incineration of everything in their path.
And as these devastating wildfires burn for weeks and months at a time, the air quality in many areas reaches a 'hazardous' level due to extreme particulate concentrations combined with gaseous toxins that are deadly.
During this 2020 wildfire season, the air quality in many areas of California and Oregon (and elsewhere in America) reached levels where people are made seriously ill, while others who are exposed to this deadly air are then preconditioned and made more susceptible to a myriad of health issues down the road, and that is especially true for our children.
As a result of the ongoing mismanagement of large herbivores, this letter was penned to the Bureau of Land Management managers in the Medford, Oregon District offices by William E. Simpson II, a naturalist-researcher who studies the effects of herbivores (specifically wild horses) on wilderness landscape and wildfire.
TO: Elizabeth Burghard - BLM District Manager Medford, OR
Lauren P. Brown -
Manager - Cascade-Siskiyou National Monument
CC: Et. Al.
RE: Who Should Americans Blame For Incinerating Flames And Deadly Smoke From Wildfire?
Dear Ms. Burghard and Ms. Brown:
Enjoying our "hazardous air"? It stems from obtuse management policies that fail to observe the reality of science instead of politics, egos and money.
At a time when we need all the fuels (grass and brush) reduction and maintenance we can muster, here we discover that the Bureau of Land Management ('BLM') is removing large herbivores (nature's grass and brush mowers) from our landscape locally and nationally, which is already deficient in large herbivores according to the best science.
The following statement is relevant in regard to the removal of wild horses from the Cascade-Siskiyou National Monument and areas surrounding the Monument, like the Soda Mountain Wilderness Area and the Pokegama Herd Management Area, where the BLM is idiotically rounding up wild horses (aka: large herbivores) this coming week.
"The removal of large herbivores has adverse effects on landscape structure and ecosystem functioning. In wetter ecosystems, the loss of large herbivores is associated with an increased abundance of woody plants and the development of a closed-canopy vegetation. In drier ecosystems, reductions of large grazers can lead to a high grass biomass, and thus, to an increase in the frequency and intensity of wildfires. Together, with the loss of a prey base for large carnivores, these changes in vegetation structures and fire regimes may trigger cascades of extinctions (Bakker et al., 2016; Estes et al., 2011; Hopcraft, Olff, & Sinclair, 2009; Malhi et al., 2016)." http://oxfordre.com/environmentalscience/view/10.1093/acrefore/9780199389414.001.0001/acrefore-9780199389414-e-545
Additionally, you should be taking more of a leadership role in controlling your subordinate, Mr. Joel Brumm of your Bureau of Land Management ('BLM') office and his obtuse rantings (in public) that are both scientifically and legally incorrect, when he says: "wild horses are trespass animals in the Cascade-Siskiyou National Monument ('Monument')". Mr. Brumm's blathering in this regard is just nonsense in the face of real science and arguably incorrect in the face of the law.
We all need to keep in mind that 'administrative policy' does not supersede established law or Acts of Congress, which represent the will of the American people as a whole, as opposed to the whims of some administrative fiefdom and it's ruler (dictatorship), as has been the case at the BLM.
The corruption and malfeasance at the BLM now seems to arguably top any other government agency... here are just three of many examples, one concerns a BLM employee from the Medford District Office:
1) Former BLM Official (Medford, OR) Pleads Guilty to Public Corruption Charges Sophisticated Contract Manipulation Scheme Defrauds BLM of Over $400,000 https://archives.fbi.gov/archives/portland/press-releases/2010/pd041610
2) Inspector General Report Confirms Mass Slaughter of Wild Horses During Reign of Then-Interior Secretary Ken Salazar: https://www.huffpost.com/entry/inspector-general-report_b_8393670
3) The BLM make a material misrepresentation to the Congress of the Unites States of America in their 2018 Report To Congress 'Management Options For A Sustainable Wild Horse And Burro Program', where on page-1, paragraph 5 of the Executive Summary they wrote: "Wild horses and burro have no natural predators...". That statement is false in the face of wildlife ecology and evolution. Mountain lions, bears, wolves, and coyotes kill and eat the foals and adults as their natural prey.
Such depredation of wild horses is very well documented in my recent published Study: https://docs.wixstatic.com/ugd/6a30c6_98642a78546849f0a94e2687cdf35654.pdf
In addition to all the local cultural archaeology that soundly documents the presence of wild horses in and around the Cascade-Siskiyou National Monument and Soda Mountain Wilderness Area over the last 300-years, the local newspaper records from the late 1800's and early 1900's documented 'hundreds' of wild horses as living in the area of the present-day Monument as symbionts, keeping it safe from catastrophic wildfire. Furthermore, there is paleontological (fossil) evidence of wild horses in the same area; meaning a presence of thousands of years in the area.
Then as documented history shows; the Bureau of Land Management (mismanagement?) shows up in the year 2000 and without any compliance with public notice and other regulations, starts quietly removing wild horses in violation of The Federal Land Policy and Management Act ('FLPMA') regulations and the 1971 Wild Burro and Horse Protection Act, pursuant to:
1) The Federal Land Policy and Management Act, or FLPMA required(s) that: “… wild horses and burros shall be considered comparably with other resource values in the formulations of land use plans” 43 CFR Sec. 4700.0-6
2) THE WILD FREE-ROAMING HORSES AND BURROS ACT OF 1971 (PUBLIC LAW 92-195) §1331.
Congressional findings and declaration of policy Congress finds and declares that wild free-roaming 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; and that these horses and burros are fast disappearing from the American scene. It is the policy of 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.
This Act (§1331) was enacted in December 1971, at which time a significant herd of wild horses was present on and around the Monument and Soda Mountain Wilderness Area, both of which are in your current jurisdiction.
In addition to the failure by the BLM when the Cascade-Siskiyou National Monument was established in June 2000, those existing local wild horses, heritage wildlife, were a ‘natural resource’ and arguably became a resource also protected under the Antiquities Act, as has been consistent with recent interpretations of the Antiquities Act in regard to preserving bio-diversity of the associated flora and fauna, and are also therefore to be included.
Today, we find that the local BLM office(s) has arguably omitted and failed in providing full and complete disclosure and reporting requirements in land planning under FLPMA, obfuscated facts and has arguably violated their fiduciary duty to the public to protect the local wild horses on the Monument, where there are also wild horse fossils reported; of course that is another inconvenient truth.
It's important to note that the statute of limitation on fraud begins when a fraud is discovered; let this be notice of that fraud being discovered.
We also know that:
The U.S. Ninth Circuit Court of Appeals in California recognized wild horses as native species, explaining that BLM “establishes Appropriate Management Levels (“AMLs”) for populations of native species – including wild horses, burros, and other wildlife – and introduced animals, such as livestock.” In Defense of Animals, et al. v. U.S. Dept. Interior, et al., No. 12-17804, *6 (9th Cir. May 12, 2014). On Sep 28, 2011 (See Craters AR at 16698. Memorandum Decision & Order) the court addressed “sensitive” species pursuant to BLM’s 2001 Special Status Species Policy. This Policy requires that “sensitive” species be afforded, at a minimum, the same protections as candidate species for listing under the ESA. It called on BLM managers to “obtain and use the best available information deemed necessary to evaluate the status of special status species in areas affected by land use plans …” See Policy at § 6840.22A. Under the Policy, those land use plans “shall be sufficiently detailed to identify and resolve significant land use conflicts with special status species without deferring conflict resolution to implementation-level planning.”
Native species wild horses have been in the Monument for more than 200 years according to cultural archaeology, thousands of years based on the local fossil record (in the Monument), and for 55-million years in North America. While homosapiens as a species are barely 250,000 years on the planet... If anything, Joel Brumm may be the 'trespass animal' in the Monument and on the planet?
If we keep ignoring the genuine facts, and sidestepping truth and our duty to do what is truly correct just to get that retirement check (if we can make it past the deadly flames and toxic smoke), there may not be much left to retire into! Think on that for a minute....
Regards, William E. Simpson II - Naturalist
Capt. William E. Simpson II - USMM Ret.
Naturalist - Author - Conservationist
Wild Horse Ranch
P.O. Bx. 202 - Yreka, CA 96097
Author @ HorseTalk