Table 15 in the Draft EA for resource enforcement actions in the Roberts Mountain Complex indicates that 11% of the Lucky C Allotment overlaps the HMA along with 32% of the Romano Allotment.
The HMA covers about 43,250 acres and is 100% subject to permitted grazing.
The 24 wild horses allowed by plan require 288 AUMs per year.
The Western Watersheds map shows the arrangement.
The Allotment Master Report shows 3,054 active AUMs on Lucky C and 2,887 active AUMs on Romano. These figures may differ slightly from those in the EA.
The forage in Lucky C assigned to livestock inside the HMA would be 3,054 × .11 = 336 AUMs per year, assuming the resource is evenly distributed across the parcel.
The forage in Romano assigned to livestock inside the HMA would be 2,887 × .32 = 924 AUMs per year.
The total estimated forage assigned to livestock inside the HMA is 336 + 924 = 1,260 AUMs per year, enough to support an additional 105 wild horses.
The True AML would be 24 + 105 = 129, over five times higher than the current AML, to be achieved by confining the permittees to their base properties and expecting them to pay the going rate to feed their animals.
What do you think happens during the off season?
The stocking rate at the new AML would be three wild horses per thousand acres, compared to a target rate across all HMAs of one wild horse per thousand acres.
Livestock in Whistler Mountain receive 4.4 times more forage than the horses, yet the area was set aside for the horses.
The HMA is managed primarily for livestock.
The BLM will collect 1,260 × 1.35 = $1,701 per year in grazing fees from ranching activity inside the HMA while it spends 105 × 5 × 365 = $191,625 per year to care for the horses displaced thereby.
Would you say that permitted grazing is a wise use of the public lands?