Table 1 in the Comment Report shows ten allotments that intersect the HMA, along with size, available AUMs and grazing seasons.
Unfortunately, the percentage of grazing land (or forage) falling inside the HMA was not provided, so a ‘Short End of Stick’ report is not possible.
The AUM figures in Table 1 for West Lookout Pass appear to be for the number of animals on the permit, not the amount of forage, per the Authorization Use report for the allotment. The grazing seasons may also be incorrect, so the 2018 allocation was assumed to be the same as 2021 and that’s why the value is marked in red.
The HMA contains about 205,000 public acres according to the EA. The allotments contain about 267,000 public acres, so some of them must extend beyond the HMA boundaries. The map provided with the EA does not show their boundaries.
Six of the ten allotments do not meet standards for rangeland health.
Eighty six percent of the public acres in the allotments do not meet standards for rangeland health.
For every public acre in the Maintain category, there are six acres in the Improve category.
There is no category for blaming substandard conditions on wild horses.
Suppose that 80% of the permitted forage falls within the HMA, about 15,700 AUMs per year.
The horses allowed by plan receive about 2,500 AUMs per year, so livestock would be receiving six times more forage than the horses—on land set aside for the horses.
The HMA would be managed primarily for livestock.
The forage assigned to livestock would support an additional 1,300 wild horses, for a True AML of 1,510.
The pre-gather population was about 500, so there were no excess horses in the HMA and no justification for a roundup or fertility control program.
The 1,300 wild horses cheated out of a spot on their home range account for 2.6% of the 50,000 horses in off-range holding. How many more HMAs would you have to look at to account for all of them?