Subscribe for 33¢ / day
Letters mailbox


Here is the stocking-density that BLM deems "appropriate" for wild horses in the Triple B Complex:

1 wild horse per 3,566 acres equals 1 wild horse per 5½ square miles

Cattle — Densely populated, highly concentrated

Here is the stocking-density that BLM deems "appropriate" for cattle in the Triple B Complex:

1 cow+calf pair per 231 acres equals 3 cow+calf pairs per square mile

Inverted allocation

Of the 93,070 animal unit months (AUMs) — grazing slots — available in the Triple B Complex:

87,406 AUMs — 94 percent — have been allotted to livestock

5,664 AUMs — 6 percent — have been allotted to wild horses

Rangeland Health Monitoring Used Obsolete Method

BLM blames the wild horses for any and every range condition not meeting standard, even though a century of overgrazing by livestock is the real culprit. To justify the Triple B roundup, BLM used an obsolete "ocular estimate" checklist that Technical Reference (TR) 1734-7, Ecological Site Inventory, warns "may result in reduced accuracy, limiting use of the data." The corrective action required is an Ecological Site Inventory to determine actual use — including trespass use. Actual use must be prorated by each animal-species present, including rodents and insects.


One of the dominant herbivores on the range are lagomorphs — jackrabbits, hares, and cottontails. All-three species are found in the project area. However, BLM neither determined nor factored in their impact on the range. A recent study in Utah found that jackrabbits were consuming 34 percent of the forage on local grazing-allotments.


In normal times, locusts — grasshoppers and crickets — consume 20-to-25 percent of the forage in areas where they are present. However, in times of outbreaks, they can eat nearly all of the green biomass. The USDA publishes an annual map showing areas of grasshopper-and-cricket infestations. Nevada — including the Triple B Complex area — appears to have experienced an outbreak in 2016.

Marybeth Devlin

Miami, Florida


Load comments