The announcement in the Federal Register on August 30 said that comments supported by quantitative information, studies, or those that include citations and analysis of applicable laws and regulations are most beneficial, more useful, and likely to assist the decision-making process for the management and protection of wild horses and burros.
Presumably, conclusions based on data would also be welcomed.
Consider this example from the Warm Springs HMA in Oregon.
The 204 horses allowed by plan receive 2,448 AUMs per year.
The HMA coincides roughly with the East and West Warm Springs Allotments.
The Western Watersheds map shows the arrangement.
Livestock receive 18,600 AUMs per year, according to the Allotment Master Report, 7.6 times more than the horses, in an area set aside for the horses.
The horses receive 11.6% of the authorized forage, neglecting wildlife.
The HMA is managed primarily for livestock.
The forage assigned to livestock would support an additional 1,550 wild horses, for a True AML of 1,754.
1. The BLM collects $25,110 per year in grazing fees from ranching activity inside the HMA.
2. The BLM spends $2,828,750 per year to care for the 1,550 horses displaced thereby.
3. The BLM could save up to $2,803,640 per year by placing horses in short-term holding back on the HMA.
Therefore, in keeping with the guidelines above, the recommendation would be to confine the ranchers to their base properties and manage the HMA principally for wild horses, as specified in the original statute, at huge savings to American taxpayers.
This is just one HMA.
The advocates, in their zeal for the Montana Solution, are ready and willing to help the agency achieve the 11.6% specification.
RELATED: WHBAB Meeting Announced.
Western Horse Watchers Association 
Sounds very quantitative and factual to me.
I didn’t realize the WHBAB was interested in facts or data.