The HMA intersects the Elephant Butte, Rats Nest, Reynolds Creek, Shares Basin and Hardtrigger allotments, as stated in Section 1.1 of the Draft EA for pest control actions in the Owyhee Front.
The National Data Viewer shows the arrangement. Click on image to open in new tab.
The allotments represent another layer of forage demand in the HMA, probably the largest, in addition to that of wildlife and wild horses.
- The carrying capacity of the HMA, referred to on these pages as the True AML, depends on the wild horse and livestock layers
- The True AML represents the number of horses the HMA could support if it was managed principally for them, as Velma and the 92nd Congress intended
- Overpopulation means more horses than allowed by plan, not necessarily more horses than the land can support
- The livestock layer represents horses displaced from their lawful home, now stockpiled in off-range holding
- The allotments mean the HMA is subject to animal agriculture, a purpose for which the fertility control pesticides were not registered
- Those who apply the products in this manner should be investigated, along with those who authorize them
Tables 5 and 6 in the EA refer to the Wildcat allotment, not Rats Nest, and include two other allotments that overlap the HMA in negligible amounts.
The HMA covers 69,910 total acres in western Idaho, including 62,149 public acres, according to the 2023 HA/HMA Report.
The 130 horses allowed by plan require 1,560 AUMs per year.
The stocking rate allowed by plan is 2.1 wild horses per thousand public acres.
The Allotment Master Report provides acreage, management status and active AUMs.
All five allotments are in the Improve category.
The allotments offer a weighted-average 96.5 AUMs per year per thousand public acres, equivalent to eight wild horses per thousand public acres.
This is on top of the 2.1 wild horses allowed by plan!
Therefore, the True AML should be around (8.0 + 2.1) × 62,149 ÷ 1,000 = 628, 4.8 times higher than the current AML.
The current population is thought to be 101, plus this year’s foal crop, according to Table 1 in the EA.
The number of horses displaced from the HMA by permitted grazing is 628 – 130 = 498, about 0.8% of those in off-range holding.
The HMA is managed primarily for animal agriculture, with livestock receiving 79% of the authorized forage, neglecting wildlife.
In a nutshell, the land-use plan allows 130 wild horses and livestock equivalent to 498 cow/calf pairs in the HMA, seven days a week, twelve months per year.
The True AML can be achieved by confining the ranchers to their base properties in a year-round off season.
The Wild Horse Fire Brigade would move the horses to a remote wilderness area, not particularly suited to livestock grazing, giving the ranchers access to all of their food.
The HMA does not have an HMAP. If it did, the document would comply with the forage allocations above.
RELATED: Owyhee Resource Enforcement Plan Out for Review.
Western Horse Watchers Association 
Thank you for providing HMA range resource analysis and information. It’s always very helpful when writing up Public Comments on the specific BLM EAs.
And mine are anti-PZP Public Comments which are far far outnumbered by the pro-PZP Comments.