I submit the following substantive comments that require analysis in the Scoping report for DOI-BLM-NV-L060-2024-0013-EA:
Create a data-based foaling season for the complex. BLM is prohibited from doing helicopter drive-trapping during foaling season and must provide a site-specific analysis.
BLM must create an Environmental Impact Statement (EIS) and not the lesser Environmental Assessment for this HMAP. There has never been a landscape level assessment of wild horses in. the Pancake Complex in 50 years. In-depth existing data must be made available for review as well as analysis of science-based management options. The lack of landscape level analysis is overdue.
Pancake has a population of both Damele curlies (the rarest of all curly genes) and Medicine hat paints (extremely rare). Both of these horses have a cultural significance: Damele Curlies to the history of settlement and the Medicine Hat to Native Americans. BLM currently has no plan at all to protect these traits.
BLM has never addressed how many horses should be on the range in Pancake so they can perform a beneficial use removing fire fuels
The CFRs require removal of livestock temporarily or permanently to protect the herd and habitat. BLM must analyze the Pancake complex to determine triggers for permanent removal of livestock.
Critical habitat for maintenance of horses must be identified, and seasonal movement needs identified, to create limits on industry and potential issues to be identified for mitigation. This analysis must be included in the HMAP as it would for any other grazing species. Horses are confined behind boundary lines and other species are not. This makes critical habitat identification and preservation even more important.
AML of 361-638 is absurdly low for a 1.2 million acre complex where exchange of populations is becoming more limited due to livestock and mining threatening any assertions of stability. Disclose an actual data-based equation for AML has been set. An evaluation to set a new science-based one, must occur. Populations in the complex have reached more than 4,000. A true AML would be somewhere between what BLM set through agreements with county and permittees and the actual number of horses that have lived in the area.
Thank you for the opportunity to comment.
Sincerely,