If a resource management plan puts some of the forage in an allotment off limits to grazing, can an allotment management plan move that resource into active status?
Western Horse Watchers believes the answer is No.
Table 2 and the discussion in Section 1.1 of the revised EA for permit renewal in Alvord Allotment suggest that the 1,892 AUMs in question are still in suspended status in the Andrews Management Unit and Steens Mountain Cooperative Management and Protection Area Resource Management Plans and Records of Decision.
You can’t write a Herd Management Area Plan that assigns 98% of the authorized forage to wild horses when the RMP allocates 84% to livestock, as previously noted.
The project must be preceeded by an RMP amendment.
Likewise, you can’t write an Allotment Management Plan that puts 1,892 suspended AUMs into play without changing the RMPs first?
Further, how do you justify the assignment of those AUMs to privately owned livestock when the pastures in question are in the lawful home of wild horses?