I submit the following comments re: Jackson Mountain HMAP Scoping, DOI-BLM-NV-W030-2025-0002-EA

• BLM must not allow any helicopter drive trapping until data determines an actual foaling season to maintain compliance with the prohibition against helicopter capture during this fragile time. BLM has provided no data at all on foaling season.
• BLM claims "multiple water sources. they monitor," but includes absolutely no data on flow rates and not even a water inventory map. You can note the lack of disclosure that completely contradicts every statement BLM uses in ever announcement of a roundup for Jackson where they state "water is extremely limited." BLM must provide additional data before finalizing any HMAP. 
• BLM must disclose data and the equations used to set AML and forage allocation. No FMUD actually discloses any formula or data. AML must be evaluated as distinct viable populations for North Jackson and South Jackson as, in fact, there is little to no exchange between these populations. BLM must disclose data and not reiterate interpretations of nonexistent data. 
• At no time has BLM analyzed the impact of wild horses in the Jackson Mountains on fire fuel and used that data as a factor for setting AML. 
• A Management Evaluation Report should demonstrate clearly the impacts of past management actions. The report BLM has presented does not define TNEV nor demonstrate that any removal, at any time, in Jackson Mountain has achieved TNEB. BLM should either provide that data or abandon removals altogether and propose alternatives to removal. 
• BLM has never analyzed § 4710.5 Closure to livestock grazing. and this analysis must be included in the HMAP.
• An HMAP both informs and complies with underlying planning. As no HMAP existed when the FMUD and LUP were created, the HMAP can trigger a revision to those documents if analysis demonstrates the necessity. Just as a mining EIS can trigger an LUP revision, so should an HMAP. If analysis demonstrates that lawful management of Jackson Mountain requires changes to the LUP, the determinations should not be reject and instead a revision process begun.

Thank you,