Bad Data in Cedar Mountain EA for Livestock Grazing?

The project targets wild horses in and around the HMA, referred to in Section 1.1 of the EA as the HA.  The HA covers 411,636 total acres, including 211,593 acres in the HMA.

The HA was marked with a blue border on Map 1, page 92 in the pdf.  It extends into the Dugway Proving Grounds.

Lands outside the HMA are not managed for wild horses and have no AML.

The AML for the HA would be identical to the AML for the HMA but the stocking rate allowed by plan would be lower.

The 390 horses allowed by plan in the HMA require 4,680 AUMs per year.  The forage assigned to wild horses in the HA would be identical.

The HA intersects four allotments, discussed previously.

Cedar Mountain Allotments 02-18-22

Data for livestock grazing were presented in Table 6 of the EA, page 26 in the pdf.

Cedar Mountain Livestock Data 07-10-22

The table indicates that four percent of Aragonite is inside the HA.

Map 2 in the EA, page 93, shows the allotment boundaries relative to the blue border.

Map 2 Aragonite Allotment in Cedar Mountain HA 07-10-22

Would you say that Aragonite, circled in red, is 4% inside the HA?  Looks more like 95%.

How about North Cedar Mountain?  Table 6 says 15%.  Looks more like 90%.

Map 2 North Cedar Mtn Allotment in Cedar Mountain HA 07-10-22

The allotments represent forage taken from the horses and sold on the cheap to the public-lands ranchers.  This is why AMLs are small relative to the available resources.

If you use the figures in Table 6, you will underestimate the forage assigned to livestock inside the HA.

If you use the eyeball estimates above for Aragonite and North Cedar Mountain, you come up with 17,068 AUMs per year assigned to livestock inside the HA.

Cedar Mountain HA Forage Calcs 07-11-22

That’s 3.6 times more forage than assigned to the horses.

The HA is managed primarily for livestock.

The forage assigned to livestock would support an additional 1,422 wild horses, for a True AML of 1,812.

The current population, thought to be 766 according to Section 1.1 of the EA, is well within this range.

The True AML could be achieved by confining the ranchers to their base properties and expecting them to pay the going rate to feed their animals.

But that’s not what’s going to happen.

The new resource enforcement plan, or livestock protection plan if you prefer, will get rid of as many horses as necessary to ensure the ranchers get their due.

The advocates would likely support the plan if it was limited to the Montana Solution and helicopters were only used for catch-treat-release.

RELATED: New Resource Enforcement Plan for Cedar Mountain Announced.

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