Closure of the HMA to livestock grazing was not brought forward for detailed analysis because the action would not conform to the multiple-use mandate of FLPMA and the existing land-use plan, which authorizes AUMs for wild horse and livestock grazing in the allotments within the HMA.
Further, as stated in Appendix E of the NEPA analysis, management of livestock grazing is designed to achieve standards for rangeland health and conform to guidelines for grazing management.
Unfortunately, that remark is not supported by the data. If it was true, the acreage in the Improve category would be lower. The land-use plan has been in effect since 1999.
The Western Watersheds map shows the allotments that overlap the HMA. Section 3.8 in the Final EA says there are seven allotments within the HMA but only calls out six.
The map shows a small portion of the Willow Creek allotment at the eastern side of the HMA, which may correspond to #7. Click on map to open in new tab.
Table 2 in Appendix G shows the percentages inside the HMA. Willow Creek is not in the list. The Allotment Master report provides the acreage and active AUMs.

The forage taken from the horses and sold to the Warm Springs permittees, assuming the resource is evenly distributed across the allotment, is .79 × 4,478 = 3,538 AUMs per year. The total estimated forage assigned to livestock inside the HMA is 9,756 AUMs per year.
That resource would support an additional 813 wild horses, meaning that 813 horses have been displaced from the HMA by privately owned livestock. That’s 1.6% of the 50,000 horses in off-range holding.
The 253 horses allowed by plan require 3,036 AUMs per year. Livestock receive 3.2 times as much forage as the horses, in an area set aside for wild horses. The HMA is managed primarily for livestock.
The True AML would be 253 + 813 = 1,066 and the stocking rate at the new AML would be 6.3 wild horses per thousand acres, or 158 acres per horse.
The pre-gather population of 244 is well within this range. It hasn’t even exceeded the current AML!
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