Before proceeding, BLM must consider that they are exceeding their authority by combining two distinct complexes into one HMAP. The court has already determined that a gather plan is not a management plan (HMAP) and BLM needs to see them as distinct processes. The court already recognizes the assertion BLM themselves reiterated: HMAPs may be prepared for a single HMA or a complex of adjacent HMAs where animal interchange occurs. The distinct Triple B Complex and the distinct Antelope Complex do not meet any of the criteria for inclusion in a single HMAP. 

The court has ruled that an HMAP and gather EA are distinct documents for distinct purposes. 

An HMAP must analyze management options such as when would all domestic livestock be removed to protect habitat for wild horses, what does TNEB look like, removing obstacles to better distribute populations and (actually) allow for population exchange between HMAs. 

The HMAP must disclose how AML was set (data, formula) and how forage allocations are determined (not simply by saying the LUP made a determination when the LUP is NOT and landscape level analysis and did not disclose any data or equation used to set AML). (NAS Reviews 1980-2013: AML is not scientifically sound nor transparently set)

BLM has not released a single data point demonstrating that any roundup that has ever occurred in these complexes has moved toward achieving TNEB in any fashion. Therefore BLM has not demonstrated that historic practices with the stated purpose of achieving AML have ever worked. Therefore, BLM must suspend these practices and analyze alternatives such as limiting profit driven uses such as mining and livestock. 

BLM has not provided any data on the use of fertility control within either complex and has already begun retreating with GonaCon causing permanent infertility even before determining any necessity. 

The sheer lack of actual knowledge of how wild horses use the complexes (seasonal movement, critical habitat, site-specific foaling and breeding season) must occur before alternatives for management can be crafted responsibly. 

All removals and fertility control must cease until sufficient data is collected to craft responsible alternatives when the HMAP goes through the prescribed revision period in ten years.

Thank you.