The Tier 1 analysis in Appendix A of the draft EIS for the Rock Springs RMP amendment provides data for current conditions on the Divide Basin HMA.

Those numbers were copied into a spreadsheet to see how wild horses are managed relative to other mandated users of public lands.

The EIS did not provide allotment sizes, grazing seasons, and animal types within the HMA.  The grazing season on some of the allotments is three months and on others it’s four to six months, according to Section 3.10 of the EIS, so an average grazing season of four months was assumed.

Management indicators for the other mandated users were computed on the basis of cow/calf pairs, whose resource requirements are equivalent to those of wild horses, allowing a side-by-side comparison.

The results are presented in the following charts.

The indicators show that the HMA has not been managed principally for wild horses, as required by paragraph 1332(c) of the statute.

The horses have a smaller footprint and environmental impact compared to livestock, but the RMP amendment will eliminate them under the preferred alternative.

“Hey WHW, what about CFR 4710.3-2?  The government doesn’t have to manage HMAs principally for wild horses unless it chooses to do so.”

Good question.

Can a federal regulation trump a duly enacted statute?  That would be a substantive comment on the EIS, although it might pertain more to the Adobe Town HMA, which will be downsized in the revised RMP but not wiped out.

RELATED: Adobe Town Horses Get Short End of Stick.

Cumulative totals through 02-07-20, per the BLM roundup page for the Eagle Complex:

• 1,209 animals gathered
• 14 deaths (1.2%)
• 546 studs (45.3%)
• 658 mares (54.7%)
• 5 new foals (2019 foals counted as adults)

The proportion of mares, many of whom are now heavily pregnant, continues to be assignably higher than the proportion of studs, based on statistical limits where n = 1,204 and p-bar = .50.

The thriving ecological balance is now only 391 wild horses away (1,700 horses to be gathered − 100 to be returned − 1,209).

RELATED: Eagle Roundup Day 21, Eagle Wild Horses Get Short End of Stick.

The three-tier analysis in Appendix A of the draft EIS for the Rock Springs RMP amendment provides data for current conditions on the affected HMAs (listed as Alternative A, No Action).  For more information on the three-tier method, go to Appendix 3 in the WHB Management Handbook.

Tier 1 data for the Adobe Town HMA were copied into a spreadsheet so key indicators of wild horse management could be compared to those of livestock.  The HMA is to be managed principally for wild horses per paragraph 1332(c) of the statute, but do the numbers reflect that?

The EIS did not provide the allotment sizes, grazing seasons, and animal types within the HMA.  The absence of those figures would be a substantive comment on the EIS.

Indicators for livestock were computed on the basis of cow/calf pairs, as their resource requirements are equivalent to those of wild horses, allowing a direct comparison.

The grazing season on some of the Adobe Town allotments is three months and on others it’s four to six months, according to Section 3.10 of the EIS, so an average grazing season of four months was assumed.

The indicators for horses and livestock are compared in the following charts.

If the ranchers place their animals on pastures within the allotments, the day-to-day stocking rates would be higher than shown above.  If they didn’t rotate pastures the land would be ruined in a season.  More rape and pillage sold as environmental stewardship.

Most of the allotments in the planning area are operated under grazing strategies incorporating rest, seasonal rotations, deferment, and prescribed use levels that provide for adequate plant recovery time to enhance rangeland health.

The HMA is not managed principally for wild horses.  Horses have a smaller footprint and environmental impact than livestock, but the RMP amendment will reduce their numbers appreciably under the preferred alternative.

The RMP update is not about keeping the horses off private lands, it’s about giving the ranchers unfettered access to public lands that surround their private parcels.

Moreover, the BLM is not a hapless victim of a rogue court that’s trying to shove the rancher-friendly consent decree down their throats.  The ranchers could have been ordered off the public lands, making them bear the costs of keeping their property private, not the horses and not the taxpayers.

RELATED: Rock Springs EIS Posted, Is Wyoming a Fence-Out State?

According to Section 4.4.6.3 of the WHB Management Handbook, a minimum herd size of 50 breeding animals (total population size of 150 – 200 animals) is recommended to maintain an acceptable level of genetic diversity within reproducing wild horse herds.

Given an aimed-at stocking rate of one wild horse per thousand acres (27,000 animals on 27 million acres), every HMA should contain at least 150,000 acres.

How many of them fall short of that guideline?  Have at it.

Don’t forget the WHTs.

A minimum recommended herd size for wild burros has not been established.

Cumulative totals through 02-05-20, per the BLM roundup page for the Eagle Complex:

• 1,156 animals gathered
• 14 deaths (1.2%)
• 520 studs (45.1%)
• 632 mares (54.9%)
• 4 new foals (2019 foals counted as adults)

Helicopters were grounded for several days due to high winds.  One mare was put down today due to colic.  The hirelings probably referred to it as ‘capture shock.’

The proportion of mares continues to be assignably higher than the proportion of studs, based on statistical limits where n = 1,152 and p-bar = .50.  The number of new foals does not correspond to a 20% growth rate, not even close.

The thriving ecological balance is now only 444 wild horses away (1,700 horses to be gathered − 100 to be returned − 1,156).

RELATED: Eagle Roundup Day 16, Eagle Wild Horses Get Short End of Stick.

Some advocates have been told on socialist media to keep their mouths shut and others have been confronted in public places for their stance on the horses, according to a story posted this evening by ABC15 News of Phoenix.

RELATED: Heber Ranchers Push Back.

The Board of County Commissioners decided yesterday not to render a decision on the reduction of setbacks from Concentrated Animal Feeding Operations requested by Equine Elite, according to a report posted this morning by the Wyoming Tribune Eagle.

Commissioners will consider the proposal in more detail at their March 3 meeting.

RELATED: Laramie County BOC Meeting Agenda Posted.

UPDATE: Public hearing begins at 4:12 in this video.

The $100,000 reward has produced no actionable information.  Report posted yesterday by KTNV News of Las Vegas.

RELATED: BLM Acknowledges New Clark Mountain Reward.

BLM announced today a request for proposals to warehouse excess horses in Oklahoma, Kansas or Nebraska.  Facilities must accommodate 1,000 to 10,000 head, with four-year and nine-year renewal options.

Bids will be accepted through March 2.

A story posted this morning by The News & Observer of Raleigh, NC shows a photo of a marsh area and asks how many horses are hiding there.  They are hard to spot but there are six, according to the report.

The story goes on to say that the greatest threat to the horses nowadays is—wait for it—climate change.

Yeah, right.

The greatest danger to these animals is the local ‘advocacy’ group, whose members refer to them as ‘highly threatened,’ yet they’re darting them with contraceptives.

On the Onaqui Mountain HMA with Willie and Candee Proctor.

The draft RMP Amendment and EIS for the four HMAs affected by the Rock Springs Consent Decree did not provide parcel sizes and grazing seasons for the 28 allotments involved, so the question will have to be answered by bootstrap.

Data for livestock on public lands in Wyoming yield 18.6 cow/calf pairs per thousand acres, assuming a six month grazing season.

Section 3.10 in the draft EIS indicates an average grazing season of about four months, so the estimated stocking rate would be 27.9 cow/calf pairs per thousand acres.

One square mile contains 640 acres, so the estimated number of cow/calf pairs that could be placed on a private checkerboard parcel is 27.9 ÷ 1,000 × 640 = 17.9.

Each parcel would require 4 × 5,280 = 21,120 linear feet of fencing plus a water source, a sizeable expenditure for just 18 ‘free ranging’ cow/calf pairs.

Of course, the rancher could import feed to allow the number of animals to increase into a profitable range, as it should be: Concentrated animal feeding operations (CAFOs) are for domestic livestock, not wild horses.

RELATED: Is Wyoming a Fence-Out State?