Section 2.6.6 in the 2012 Final EA for resource enforcement actions says that reducing or removing livestock “would be inconsistent with the current land use plans and/or Final Multiple Use Decisions (FMUDs) for the Owyhee Complex and with multiple use management.”
In a subsequent paragraph, the writers note that “changes to livestock grazing cannot be made through a wild horse gather decision, and are only possible if BLM first revises the land-use plans to re-allocate livestock forage to wild horses and to eliminate or reduce livestock grazing.”
What’s at stake?
The five HMAs in the Complex overlap six grazing allotments, as shown in the map from Western Watersheds.
Table 5 in the EA provides HMA acres within the allotments. The forage available to livestock today is about 5% less than in 2012, so the current values were copied into the spreadsheet. Other values were taken from Table 5 or computed.
These figures can be used to estimate the forage assigned to livestock in each HMA, assuming the resource is evenly distributed across the allotments.
For example, Snowstorm Mountains intersects 69.3% of the Bullhead allotment, so the forage taken from the horses and sold to the ranchers is .693 × 12,050 = 8,351 AUMs per year.
The sum of these estimates is 66,897 AUMs per year. This resource would support an additional 5,575 wild horses, meaning that 5,575 wild horses have been displaced from their home range by privately owned livestock, about 11% of the 50,000 horses in off-range holding.
This is why those facilities are full, or nearly so, and why the bureaucrats are searching for more.
The advocates would solve the problem by getting rid of the horses, not the livestock.
Confine the ranchers to their base properties and let them pay market rates to feed their animals. What do you suppose happens during the off season?
The current AML of 999 (across five HMAs) could rise to 6,574. It’s that bad. The stocking rate would be 6.2 wild horses per thousand acres, or 160 acres per horse.
Grazing seasons can be found in the Authorization Use reports from RAS, one for allotments managed by the Humboldt River Field Office and another for allotments managed by the Tuscarora Field Office.
Western Horse Watchers Association 
The Court ordered the RETURN of wild burros to the range as Chief Justice Thurgood Marshall stated the importance of the government’s interest in preserving herds IN THEIR NATURAL HABITAT. https://tile.loc.gov/storage-services/service/ll/usrep/usrep426/usrep426529/usrep426529.pdf.
The federal property interest in wild horses, that was not settled in Kleppe was addressed in the 1980 wild horse case: United States v. Hughes. https://case-law.vlex.com/vid/626-f-2d-619-596454482 wherein the criminal CONVERSION of wild horses as government property is specifically defined.
Does the gov. extraction policy of capture, sale, adoption, and warehousing constitute criminal conversion of Wild horses and burros as well as an abuse of taxpayer funds?
One out of every 10 acres of US wildlife habitat ( approximately 245 million acres equal to 380,000 square miles) is managed by the BLM National System of Public Lands. How much of that is wild equid Natural Habitat and how many herds can it sustain?
In Mt. States v Hodel, the court determined that “In structure and purpose, the Wild Free-Roaming Horses and Burros Act is nothing more than a land-use regulation enacted by Congress to ENSURE the survival of a particular species of wildlife.
To correct government oversights the fatally flawed Resource Management plans must be amended by operation of law. “The herd areas will always be in existence. WH&B program has provision for developing an Herd Area Management Plan designed to implement management actions or areas designated as Herd Management Areas through the land use plan.
Management for a herd area is NEPA document which is subject to change should new, prevailing data become available. As such through NEPA.
The burden to demonstrate that BLM’s inventory of the 1971 WH&B areas of use was in error falls to the challenger. When the plan establishing areas of use was approved, it represented BLM’s decision based on best available data. If the public has quantifiable data which shows there may be an error, they need to provide those data to petition BLM to reconsider the decision.” notes Tom Pogacnik, Acting Deputy CA State Director, Natural Resources, Bureau of Land Management, 2008
Most succinctly on the issue of management in her MEMORANDUM OPINION ROSEMARY M. COLLYER, District Judge stated:
“BLM’s authority to “manage” wild free-roaming horses and burros is expressly made subject to “the provisions of this chapter[,]” 16 U.S.C. § 1333(a), including the provision that “[i]t is the policy of Congress that wild free-roaming horses and burros shall be protected from capture….” Id.§ 1331. It would be anomalous to infer that by authorizing the custodian of the wild free-roaming horses and burros to “manage” them, Congress intended to permit the animals’ custodian to SUBVERT the primary policy of the statute by capturing and removing from the wild the very animals that Congress sought to protect from being captured and removed from the wild. It is difficult to think of a “management activity” that is farther from a “minimal feasible level” than removal.”
Yet forty-five years following the Kleppe wildlife decision, et al, the Agencies continually neglect to implement Congressional mandates by amending Resource Management Plan (RMP)by NEPA ( Section 106) protocols for compliance to restore and re-wild heritage herd INVENTORIES. ( 43 CFR 4710.2 Inventory and monitoring. “The authorized officer shall maintain a record of the herd areas that exited in 1971, and a current inventory of the numbers of animals and their areas of use. When herd management areas are established, the authorized officer shall also
inventory and monitor herd and habitat characteristics.”)