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.
