The three-tier analysis in Appendix A of the draft EIS for the Rock Springs RMP amendment provides data for current conditions on the affected HMAs (listed as Alternative A, No Action). For more information on the three-tier method, go to Appendix 3 in the WHB Management Handbook.
Tier 1 data for the Adobe Town HMA were copied into a spreadsheet so key indicators of wild horse management could be compared to those of livestock. The HMA is to be managed principally for wild horses per paragraph 1332(c) of the statute, but do the numbers reflect that?
The EIS did not provide the allotment sizes, grazing seasons, and animal types within the HMA. The absence of those figures would be a substantive comment on the EIS.
Indicators for livestock were computed on the basis of cow/calf pairs, as their resource requirements are equivalent to those of wild horses, allowing a direct comparison.
The grazing season on some of the Adobe Town allotments is three months and on others it’s four to six months, according to Section 3.10 of the EIS, so an average grazing season of four months was assumed.
The indicators for horses and livestock are compared in the following charts.
If the ranchers place their animals on pastures within the allotments, the day-to-day stocking rates would be higher than shown above. If they didn’t rotate pastures the land would be ruined in a season. More rape and pillage sold as environmental stewardship.
Most of the allotments in the planning area are operated under grazing strategies incorporating rest, seasonal rotations, deferment, and prescribed use levels that provide for adequate plant recovery time to enhance rangeland health.
The HMA is not managed principally for wild horses. Horses have a smaller footprint and environmental impact than livestock, but the RMP amendment will reduce their numbers appreciably under the preferred alternative.
The RMP update is not about keeping the horses off private lands, it’s about giving the ranchers unfettered access to public lands that surround their private parcels.
Moreover, the BLM is not a hapless victim of a rogue court that’s trying to shove the rancher-friendly consent decree down their throats. The ranchers could have been ordered off the public lands, making them bear the costs of keeping their property private, not the horses and not the taxpayers.