I submit the following comments re: DOI-BLM-AZ-P010-2025-0019-EA, Lake Pleasant Herd Management Area Plan and Population Control

1. I request BLM to clearly confirm that the public cannot submit comments during the ePlanning migration window, January 15–19, 2026, and explain what contingency measures are in place to prevent loss of public input. 
2. Please extend or adjust the comment period to fully compensate for the days when the system is offline and inaccessible to the public. Of note, the system went down on January 10.
3. I object to adopting an AML range of 140–250 burros without a transparent, quantitative disclosure of total available AUMs in the HMA and how those AUMs are allocated among burros, livestock, and wildlife. I request a table showing: total usable forage (AUMs), AUMs allocated to livestock (currently 8,074 AUMs), to burros (approximately 1,680–3,000 AUMs at the proposed AML range), and to wildlife, plus the methodology used.
4. I request that shrubs and trees be fully incorporated into stocking-rate calculations for burros. BLM’s AML justification relies on “available forage” but omits shrubs and trees, even though its own diet data show heavy burro use of pea-family plants, which include shrubs and trees, not just herbaceous forbs. 
5. I challenge the EA’s dismissal of “remove or reduce livestock” as an alternative pointing out that the HMAP can inform and trigger amendments to the Resource Management Plan under applicable regulations, and that refusing to analyze livestock reductions is a procedural flaw.
6. I request analysis of: (1) reduced livestock AUMs, (2) changes in livestock season of use, and (3) removal or modification of livestock fences and water developments as tools to keep burros within the HMA and reduce off-HMA conflicts and vehicle collisions.
7. I request mapping and analysis of barriers within the HMA—fences, roads, water distribution—that may be pushing burros outside the HMA, with specific management actions to remove or modify those barriers
8. I oppose helicopter gathers for burros except in true emergencies (e.g., wildfire), and ask BLM to analyze and disclose the risk of Capture Myopathy in burros, using that scientific term rather than vague references to “stress.”
9. The Comprehensive Animal Welfare Program (CAWP) standards currently lack explicit heat-index and air-quality thresholds, even though both factors are critical to Capture Myopathy risk, and request that such thresholds be established and applied.

 Respectfully Submitted,