My comments are as follows:


  1.  The AML of 104 will not provide a viable gene pool. The National Research Council of the National Academies report of 2013  On improving the BLM Wild  Horse and Burro Program chapter 5,page 149,para 2,states that , theoretical studies suggest that a figure of closer to 5000 would be necessary to avoid inbreeding depression . Not a realistic figure given the space available and the man made barriers although two million acres of national forest gould support many many more horses than it seems are now present.
Also stated was that intact harem groups could be translocated to provide immediate influx of new genes,but there would be a long delay before the new genes would become effective.
Why go through all of that excess management when there is already intercommunication (or inter something) between the wild bands in place
2.  The wild horse territory in place of 14000 or 19000 acres (whichever is the correct figure) is far to small an area even for 104 horses. My observations of wild horses, spanning over 20 years,has shown me that a harem group of between 5 and seven horses of one stallion and 4 to 6 mares (not including foals or long yearlings) has a range of around 10 square miles. Throw in cattle allotments  covering most of the” Territory” and you have a non viable ecosystem. 
The Territory needs more -  territory.                                                                                                  3   In a Thriving Natural Ecological balance the key word is NATURAL. Cattle are not a native species and therefore do not contribute to a natural balance. I am not saying get rid of the cattle,but an imbalance in favor of cattle kind of takes the balance out of the equation.
4. In reading some of the comments and the draft, it appears that the tourist trade contributes to a large part of the economy from folks coming to see the wild ones. If money talks then,in the song sung by Lacy J. Dalton,”LET THEM WILD PONIES RUN”,


Thanks for the opportunity to express my views.