The present-value analysis following Table 3-3 in the Draft EA, as noted yesterday, shows there is no economic justification for wild horse roundups.  That would be a substantive comment.

If the present value of the costs exceeds the present value of the benefits, the proposal should be rejected.  In this case, the proposal is to remove and warehouse wild horses.

Another comment involves the rationale for the benefit calculation: Money spent on removing and warehousing wild horses is offset by grazing fees, not the price of hay the ranchers would have to pay if (OMG) their livestock were confined to private property with imported feed.

• Spend $954 to remove a wild horse from his home range
• Spend $568 per year to keep him in long-term holding
• Collect 12 × $1.35 = $16 per year from the rancher to whom his food is sold

There’s no way you could get that past your boss in the private sector.

Concerns about resource allocations and management priorities, although valid, should not be submitted as they are outside the scope of the project.

Comments on the EA can be submitted through January 9.

RELATED: New Desatoya Gather Plan Available for Review.

The $10 million payment is acknowledged on page 14 of the Division G Explanatory Statement for the FY 2021 appropriations bill.

Those funds, derived from grazing fees, are plowed back into the program every year to make life better for the public-lands ranchers.  Refer to paragraph (b)(1) in Section 1751 of the Federal Land Policy and Management Act (the ‘No Rancher Left Behind Act’).

Money to remove animals that rob forage from the ranchers, such as wild horses and burros, is discussed on page 13 of the statement.  Taxpayers provide those funds.

The current fee is $1.35 per AUM, determined by a formula in Section 1905 of the Public Rangelands Improvement Act.  Note that the base fee, $1.23 per AUM, was set in 1966.

Section 3.2.8 in the Draft EA for resource enforcement actions in the Desatoya HMA notes that the value of grass hay in Nevada is $68 per AUM.

That means the ranchers are paying two cents on the dollar to feed their livestock, even on lands set aside for wild horses and burros.

Paragraph (a)(9) in Section 1701 of FLPMA says the United States shall receive fair market value for the use of the public lands and their resources, unless otherwise provided by statute, which in the case of livestock grazing is PRIA.

Now you know why there is so much interest in achieving and maintaining AMLs, the goal of the rancher-friendly ‘Path Forward.’

What would happen if grazing fees reflected market conditions?

Table 3-3 in the EA provides costs associated with roundups and off-range holding.

In the discussion that follows, the present value of gathering and holding an animal over a 25 year period was estimated to be $15,950.  The present value of the benefits arising therefrom—forage available to privately owned livestock over the same period—was estimated to be $14,209.

The present value of the costs exceeds the present value of the benefits, meaning it’s a bad investment.  Nobody in the private sector would do it.

But insulating the ranchers and their overlords from the realities of a free market is what the grazing program is all about.

If grazing receipts were used in the benefit calculation ($1.35 per AUM), instead of avoided costs ($68 per AUM), the present value would be nil and the proposal would never even see the light of day.

RELATED: Grazing Program Ancillaries.

The Division G Explanatory Statement in the FY 2021 appropriations bill does not direct the BLM to spend $11 million on wild horse contraceptives, although it does include an expectation that wild horse management actions will “include a robust expansion of fertility control utilizing methods that are proven, safe, effective, and humane.”

That may signify the end of the story, at least for now.  Roundups and off-range holding will likely consume most of the budget, as adoptions go down and surrenders go up.

It’s sad, really.  An idea so good that even the Rolling Stones would support it.

RELATED: PZP Amendment Omitted from Senate Spending Bill?

Well, maybe 400 years.  Before anybody was talking about immunocontraception and humane management practices.

Refer to this report by The Virginian-Pilot, posted this morning.

RELATED: Helicopter Finds Winter Hideout of Corolla Wild Horses.

You should never approach wild horses unless you’re a trained volunteer with CO2 pistol, CO2 rifle or blowgun in hand.

A report published yesterday by WAVY News shows several people getting too close to the horses, which is illegal.  The photo initially appeared on socialist media.

Cruelty, enticing, harboring, luring, seizing and failure to report injury are also unlawful, according to the story.

RELATED: Currituck Horses at Great Risk?

The $2.3 trillion measure includes $900 billion in Covid relief, according to a report published today by AP News, and, presumably, a $14 million increase in the WHB program to pursue an “aggressive, non-lethal population control strategy” for wild horses and burros on America’s public lands.

RELATED: House Spending Bill Increases WHB Funding.

Many in the horse world know it as a dewormer.  But if you search for Ivermectin Covid-19, you’ll find reports on its use in treating the virus.

The local feed store had it in paste form on December 24.  But it also had several other types of dewormers.  There were no special warning signs in that area—Ivermectin not fit for human consumption—and there were no indications that it was being taken off the market or going out of stock.

My guys get Panacur on an as-needed basis.  It’s expensive but works well.

RELATED: Colt’s First Worm Treatment.

This article by The Daily Pitchfork, dated December 12, is an example of what doesn’t come up when you’re searching for information about wild horses.

It’s almost as if the companies running the search engines have an agenda or something.

RELATED: ‘Wild Horse Wars’ Refuted.

If we have three co-equal branches of government, why is there so much interest in the presidency?

The political party trying to force its way into the White House hates Christmas as much as it hates the Constitution.

What exactly did they do yesterday?  Spend some time in front of their holiday trees, listening to holiday music, wishing each other happy holidays?

Most of its members already subscribe to the movement discussed in this video, they just haven’t come out of the closet yet.

Some want no-horse ponies, mares that have become sterile through extended use of contraceptives.

Do they agree with the idea of managing HMAs primarily for livestock and HAs almost exclusively for livestock?  Sure looks like it.

How do they differ from the public-lands ranchers?  The ranchers want AMLs achieved as quickly as possible, while the ‘advocates’ want herd sizes reduced gradually.

Unfortunately, darted mares consume resources assigned to ‘other mandated uses of public lands,’ and that’s at the center of the debate.

RELATED: What Is a One-Horse Pony?

He came into the world that you might be saved from eternal damnation.  Thanks to Megan Smith for the video.