The appropriate management level for the Calico Wild Horse Herd was determined in final multiple use decisions in 1994. The carrying capacity was allocated to wild horses in these decisions 9 years ago. The Sonoma-Gerlach Final EIS and MFP III decisions (land use plan) required rangeland monitoring and allotment specific decisions on 3 and 5 year frequencies. Where is the data to support the Calico Wild Horse Herd Appropriate Management Level in the pending Gather Plan?

The Soldier Meadows Activity Plan EA in 1997 claimed that the Calico Wild Horse Herd had to achieve the 1994 AML to protect desert dace habitat in the West Black Rock HMA. No studies on wild horse impacts were conducted to justify the proposed action. What data collected since 1994 supports the proposed gather to the outdated 1994 AML for Calico Wild Horse Herd?

The Soldier Meadows/Paiute Meadow Allotment Evaluation and Environmental Assessment in 2000 included data collected up to 1999. No new or specific data to wild horse impacts were collected. These documents did not assess any rangeland monitoring data on the Leadville Allotment. How can the proposed Gather support adjustments in wild horse numbers without a Leadville Allotment Evaluation and Environmental Assessment?

2. The Calico Wild Horse Herd was gather and population dynamics were altered by selective removal criteria to meet the adoption program objectives in a previous gather.

Population data were collected in past gathers to determine the genetic and population dynamic character of this herd. How will this data be presented to predict the present population and impacts of the proposed gather?

The Calico Wild Horse Herd was determined to be a part of a complex of Buffalo Hills and East Black Rock Wild Horse Herds. Given the complexies of these herds, how will the unique character of the Calico Wild Horse Herd be descripted and maintained in the post-gather population?

It is uncertain when the last population census was conducted on the Calico Wild Horse Herd and how the 1997 population estimate was determined. The recruitment rates applied to population estimates are not supported by herd specific data collected by BLM. Assuming that the proposed gather plan requires an environmental assessment, how does the Field Office meet NEPA requirements with no new data or data that is 10 years old ?

Throughout many Field Offices, the Bureau has applied Fertility Control by the use of an immunocontraceptive vaccine. While the BLM has applied has applied these measures, what herd and what data supports the predicted outcome of these efforts?

The proposed gather to a 1994 AML does not appear to have supportive data to assure a viable Calico Wild Horse Herd. How can the proposed environment assessment comply with NEPA without supportive data? How can the proposed reduction in wild horses 40 percent below the 1994 AML be supported without any data in the environmental assessment?

In summary, the Wild Horse and Burro Act requires viable wild horse herds managed within their herd management area to meet a natural thriving ecological balance. The Sonoma-Gerlach land use plan obligated the Field Office to proper monitoring of rangeland condtions, wild horse population and livestock permitted use. The previous allotment specific decisions and environmental assessments suggest that none of these monitoring requirements have be fully met and lend very little support to the proposed actions affecting the Calico Wild Horse Herd.