1. The BLM announcement and website noted this as a Scoping period when it was not a Scoping, it was comments on a draft plan. Please rectify the error and extend the comment period accordingly.
2. This EA that purports itself to be both a gather plan and an HMAP is only 68 pages long for a 1.1 million acre gather area of 4 HMAs compared to the "gather only EA" for the single HMA Fish Creek, 230,675 acres created by the same field office that was 185 pages. BLM has clearly shortchanged the much larger and complex Callaghan Complex. This EA is woefully data and analysis poor.
3. Please provide direct data and links to rangeland health assessments, inventory, water availability and flow (not just a map that has no info).
4. Clearly, BLM has failed to address AML that was set through agreement in the 1980s. Please provide a valid methodology for affirming/evaluating AML in these 4 HMAs. AML is illogical and obviously wrong even to the layperson. If high AML is around 500 and BLM has not done a gather and the population has reached 5000, AML lies somewhere between these numbers. BLM must provide some analysis through the Herd Management Area Plan or risk perpetuating a deep injustice to both wild horses and the public interest.
5. The zeroed out portion of North Shoshone must be reevaluated. It was inappropriately zeroed out of wild horses in favor of domestic horses in contravention of the CFRs.
6. BLM must evaluate AML based on fire fuel reduction and analyze the impact of a removal of large numbers of wild horses on fire fuels. Leigh v. Raby (3:22-cv-00034)
7. A gather plan EA and an HMAP EA are not the same thing, Leigh v. Raby 3:22-cv-00034 and 2:22-cv-01200 BLM can create both concurrently but cannot ignore the specific difference between the two and must meet requirements of both. This EA falls short of even meeting the established standard for this district for a gather EA only.
8. BLM can satisfy HMAP requirements ONLY if they can clearly demonstrate that data and analysis were disclosed in other documents. The RMP that set boundary lines and AML was not a landscape level analysis and no analysis or methodology was disclosed. Please rectify.
9. BLM must establish safe gather times of year specifically for these HMAs. BLM is mandated to manage humanely. Terrain and foaling season are significant factors involved in humane management. BLM must include this analysis.
10. BLM has created a recreation area that encompasses the entire South Shone HMA causing stress and herd movement. The HMAP must include analysis of the impact and mitigation measures.
11. BLM must include range improvements. Waters in these HMAs have either been fenced off or are non functional. Cattle guards are in disrepair. Please provide a map and strategy for repairs.