HEBER/OVERGAARD – Some horse advocacy groups want the Apache-Sitgreaves National Forests (ASNF) to extend the public comment period for the Heber Wild Horse Territory Management Plan and Environmental Assessment (EA) that accompanies it.

Heber Wild Horse

A Heber Wild Horse grazes on the Apache-Sitgreaves National Forests in the Black Mesa Ranger District. 

Thursday, April 22 is the last day that the public can submit their comments via the website at cara.ecosystem-management.org/Public/CommentInput?project=18916.

Apache-Sitgreaves National Forests Supervisor Anthony Madrid, in a phone interview with the Independent, says the Forest Service highly encourages the public to submit their comments.

USFS website to submit comments

Pictured is the landing page used to submit comments to the Heber Wild Horse Territory Management Plan proposed draft. 

However, Citizens Against Equine Slaughter (CAES) disagree with Madrid’s statement, alleging that the Apache-Sitgreaves National Forest is intentionally omitting their comments from the document.

CAES has been one of the most vocal opponents of the Apache-Sitgreaves National Forests’ Heber Wild Horse Territory Management Plan throughout the process. They say the current public comment period is "an unequal 'public' process."

Although CAES and many other horse advocates disagree with the proposed methods of how to “manage” the Heber Wild Horses, their current argument focuses on two things – the difficulty navigating the public comment website and what they say is the intentional disregard of their right to participate in the public comment process.

CAES has argued for a two month extension to the public comment period ending Apr. 22.

Theresa Barbour, Founder of Water for Western Wildlife/Emergency Needs Initiative (ENI) and a CAES consultant, spoke to the Independent about the matter.

Barbour, on behalf of CAES, alleges that ASNF has not created a reasonable, nor effective way for the public to submit comments to the Plan which is a vital part of the process.

Barbour describes the website is cumbersome, difficult to navigate and says it has changed or been reorganized throughout the 30 day comment period. She cites rearrangement of reference materials and attachments which creates confusion for the public trying to understand and weigh in on the matter.

Barbour, CAES founder and board member Patience O’Dowd and others have contacted Apache-Sitgreaves National Forests Supervisor Anthony Madrid to point out what they consider a flawed website and an unfair process.

“Commenting on the proposed draft is a huge task and an important part of the process,” says Barbour.  

Barbour, O’Dowd and some other equine advocates say that the Forest Service (ASNF) doesn’t want to include their comments because they don’t want the public to read them.

“CAES’ public comments from the scoping period or the Environmental Assessment (EA) are not included in the current document,” says Barbour.

“It’s a National Environmental Protection Agency (NEPA) violation if ASNF doesn’t include our documents and references,” says Barbour. “Part of the process is that we read the Forest Service plan, their references and their studies and we have the ability to refute them without our own sources.”

Barbour says that CAES has been told by the ASNF that their comments simply won’t be added to the public document (Heber Wild Horse Territory Management Plan draft and Environmental Assessment), until after the comment period. This renders them inaccessible to the public, she says.

“Adding public comments or documents to the record during the comment period is illegal,” says Barbour. “What about the people that already commented on the plan but didn’t have our documents available to read?”

Barbour says that she wonders if ASNF will consider the organizations comments at all.

“We think it was intentional – leaving our comments off,” says Barbour.

In addition to not including their comments in the Heber Wild Horse Territory Management Plan draft, CAES says there are other issues including times when the website is down.  

“At the first part of the 30 day period, there was a list of all the reports,” adds Barbour to their list of website problems. “At some point the reports were moved to the Environmental Assessment Draft Specialist Reports area.”

"We just found out today that the USFS has also added an important report on the [horse] Census called: "2019HorseBandObservations" under the Draft EA Specialist Reports Section," writes O'Dowd in an email to ASNF. "This is again, no public notice."  

Document list

Project document list under the Scoping tab. 

Barbour and O'Dowd, in the same email, allege that the following documents and references were added to the public record after the 30 day comment period opened: Draft EA Specialist Reports, Wild Horse Population Modeling, Range Report, Recreation Report, Botany Biological Evaluation, Cultural Resources Report, Watershed Report, Wild Horse Report, Vegetation Report, Terrestrial Wildlife Report, Aquatics Biological Evaluation and Specialist Report and 2019HorseBandObservations.

In a responding email, Madrid states that they have received CAES' comments on the Heber Wild Horse Territory Management Plan and will upload the cited reference and reports. 

"Again, I apologize for the oversight and commit to incorporate your comments in the final environmental assessment as appropriate," writes Madrid. 

CAES cites more website problems

Scoping and Analysis

Scoping and Analysis tabs on the  HWHT Management Plan proposed draft website.

Barbour also says that a “Scoping” tab and an “Analysis” tab was added to the website which is one of several ways the website materials were reorganized.

Then she explained how the “Socio- Economic” tab on the website was either moved or renamed. And, at one point the forage utilization and allocation appeared five times in different documents or areas of the website.

Barbour emphasized what CAES says is another significant problem with the “References Cited” list on the website.

“Instructions for the public had to be added because the zip files were too large to download,” said Barbour. “The viewer has to know to right click on the file, then they are instructed to ‘save the link as’. Right after that, Google warns the viewer that ‘this file cannot be downloaded secured’. Next there is an up arrow that the viewer must click on in order to keep the document that Google warns ‘cannot be downloaded securely.’”

Downloading large files

Pictured is a section of the website explaining how to download large files. 

This is one of several issues with the Apache-Sitgreaves National Forests public website that creates hurdles and lessens the confidence of the public says Barbour.

“It’s hard for the public to stay on top of the information and be able to comment because it’s so confusing,” said Barbour.

"In any case, our fellow public are not seeing any substantive comments from CAES, are not benefitting from our comments at this point in the NEPA process, and this damages our abilities for involvement," writes CAES Founder Patience O'Dowd in an email to ASNF. 

Forest Service response

The Independent contacted Madrid about CAES’ allegations and he responded promptly via phone.

He said that the Heber Wild Horse Territory Management Plan was created by an interdisciplinary team of about 12 experts within the US Forest Service and Apache-Sitgreaves National Forests staff.

“Initially we posted the draft Environmental Assessment (EA) and the Draft Territory Management Plan,” said Madrid “Those are requirements that we have to be able to provide as part of the proposed action so the public can make an informed decision.”

Heber Wild Horses

A buckskin mare is one of a small herd of Heber Wild Horses. 

With regard to the Specialist Reports and their location, Madrid said that the public requested those. As the public requested, the ASNF added the corresponding documents to the website for public viewing.

“From time to time during the comment period we received other requests for materials or references,” said Madrid. “As we have gotten requests, we have added them in an effort to be responsive and transparent. We posted all the documents so the public has access to all of the same information.”

In answer to the difficulty CAES cited in navigating large files, Madrid acknowledged they did have reports from public that they were having difficulty.

“In response, we posted to ‘How To’ document,” said Madrid. “If there are problems downloading anything on the website we encourage the public to contact us. We’ve tried to follow up with people quickly as possible so they can download the materials.”

Madrid said that ASNF staff met via phone with CAES board members, an area resident and equine advocate and several others the same day as the call with the Independent.

“We held a call with Patience and her team to talk about some of their concerns,” said Madrid. We walked through the process how we would review and consider comments moving forward. We hear their voice and explained how we would include their comments.”

“Madrid said our comments “would be ‘discussed’ but that doesn’t mean they will be included in the document for public review,” said Barbour.

To further clarify the different comment periods, Madrid said that “We had a scoping period last year from February to March. That was the initial scoping period where we solicited information from the public on the Heber Wild Horse Territory Proposed Action Plan Draft to help us get more information.”

“Now, the official comment period is underway,” says Madrid. “CAES submitted hard copies of comments – they didn’t submit to the website. But as we finalize the Environmental Assessment, we will be reviewing and considering all public comments from both last year’s scoping period the scoping period and the official comment period.”

Madrid stated that the comments submitted by CAES would be provided in the final Environmental Assessment and will be shared with the public. He did not indicate that there would be an extension of the current public comment period.

Final words from CAES

“Madrid told us in his email from April 6 that he handed our comments to his NEPA staff to be uploaded on the CARA website,” said Barbour. “On our USFS virtual meeting with Madrid and others, USFS employee Marshall Moy, (who Madrid referred to as his Forest NEPA Planner), told us that our comments were left off the public database of public comments from the scoping period because they were never uploaded to the CARA website.”

Heber Wild Horses

A Heber Wild Horse colt and other yearlings in the forest.

“This makes me question if they ever read comments because the tables of issues brought up in public comments are created using keyword searches on that CARA database,” said Barbour.

Management Plan timeline

“Hopefully, by fall 2021, we will share the final EA with the public and will have an objection period,” said Madrid. “There will be another opportunity for folks to engage.”

Madrid assured the Independent that the Apache-Sitgreaves National Forests will consider all comments and ideas. He also said that if there are comments they feel apply to the scope of the EA, they will incorporate them as the EA is finalized.

“There are lots of interested stakeholders in the Heber Wild Horses Territory Management Plan,” said Madrid. “We try to find a balance between their needs.”

Madrid said that, as of Monday, Apr. 19, they had received just under 500 public comments.

“The meeting we had with CAES was positive,” said Madrid. “They offered to work proactively with the ASNF on the Heber Wild Horses and we very much appreciate that opportunity to work collaboratively with all stakeholders. Again, we encourage folks to complete their submit their comments during the official comment period.”

How to submit comments:

The Apache-Sitgreaves National Forests administration highly encourages the public to submit comments now, before the April 22, 2021 deadline. If you have any difficulty with the website, please call the Springerville office at 928-333-6280.

Comments including attachments may be submitted electronically to: cara.ecosystem-management.org/Public/CommentInput?project=18916. The following formats are acceptable: .doc, .rtf., txt., .html or .pdf.

If access to the electronic database is not available, specific written comments may be mailed to Heber Wild Horse Territory Management Plan, P.O. Box 640, Springerville, AZ 85938; or faxed to 928-333-5966.

Due to limited office access and other precautions during the COVID-19 pandemic, the agency is unable accept hand-delivered comments.

Reach the reporter at


Laura Singleton is a reporter for the White Mountain Independent, covering Show Low city government, business and education.

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