Wild Horse Education

Oil and Gas; a comment period


Fish Creek stallion, 2018

EDIT 2/14/19: This lease sale has been placed “on hold” with no date released on if/or when they will make any attempt to move forward.

Most other lease sales scheduled for March have been listed and will be open for bid.

BLM has not answered comments. The sale was suspended for the parcels noted in our comments. 

We remain perched to litigate and stop this sale to oil and gas should this sale be approved. 


Preface to publishing our comments on BLM BM Proposed Oil and Gas Lease Sale, 

This has been an extremely busy year from field work, media outreach, legal actions and constant struggle against a landslide of projects on public lands and legislation that has aimed to sweep public resources into the pockets of profit driven enterprises. Wild horses sit in that target zone.

These political moves have even included some of the most outrageous actions; the public, the people, simply have not mattered. National Environmental Policy Act, NEPA (the place for public input)  and Freedom of Information Act, FOIA (the place the public gains information) have also faced an assault.

In the last couple of weeks WHE has submitted three comment letters, two motions in our litigation and engaged with two media outlets working on long form pieces on wild horses. In addition we have been preparing for the next legislative session.

There are multiple open “comment periods” that we must complete prior to the end of the year. Comment periods are one of the ways in which a proposed action can be changed through public process. It is also a way to begin a discussion. If that “discussion” remains unresolved it sets the framework for legal action.

Litigation is used, most often, when all other avenues to resolve a dispute, disagreement or harm are exhausted. It is an expensive and extensive use of tim, emotional and financial resources. Unfortunately this seems to be the preferred method of conflict resolution by the BLM over the last two years with any environmental concern.

We feel the following EA may be of interest to our readers. It is an important example of much of what we are seeing west wide. 

The following EA notes a common theme: projects that impact an HMA are continually created on a faulty framework.  Wild horse management remains stuck in a time capsule. 

There is much to do in 2019 to protect our wild horses and the land they stand on.


Oil and Gas Sale Lease; Battle Mountain

Oil and gas sale leasing has been in the news along with many environmental issues including the resignation of the Secretary of the Interior, Ryan Zinke. Speculation on his replacement has become a headline for many news outlets. Public land issues are in the minds of Americans. It may be the only positive to come from the last two years for our public lands.

Many projects involving extractive industry and livestock are in the EA and EIS stage; the “comment phase.” Many others have already been approved. Some are in the protest or litigation stage. The last two years have been a runaway train, mach 5.

This particular EA proposes an oil and gas sale lease that overlaps multiple HMAs. The proposed action is based on an extremely outdated framework in land use planning. The land use plan in this district began a scoping period in 2010. The plans have not moved forward under a litany of excuses. This is a plan those of us at WHE engaged in. We have engaged in as many ways as humanely possible, even going above and beyond the normal course of action to rectify the deficits.

You can view the EA here: https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=174588

(our comments highlighted in blue below)

If you would like to send a comment the deadline is today, December 19th.
Mail or bring to the BLM Battle Mountain District Office, 50 Bastian Road, Battle Mountain, NV 89820, or to the Tonopah Field Office at P.O Box 911, Tonopah, NV 89049
Email to blm_nv_bmdo_2019OilandGasLeaseEA@blm.gov

We do apologize for publishing this within the 24 hour deadline. Time, particularly as the year ends, is always in short supply. This has been an entire year of time and resources in very limited supply. We simply ran out of time with all of the tasks “on the plate.”

Oil and gas is a big topic many of our readers are interested in.

This particular proposed action is based on a frame so antiquated even the technologies, that include modern fracking,were not part of imagined management when the frame this proposed action stands on. 

We present the letter as an example if you want to craft your own letter and as an archive so you can see how WHE comments. This comment letter is for a proposed oil and gas lease sale, March 2019. However, this format is typical of the type used by WHE for “comments” we send.

Short summary of our conclusion; we ask that BLM remove all parcels that include an HMA off the offering listing. In comments we create a supporting argument for that position and provide our reasoning.

Our comments:

DOI-BLM-NV-B000-2019-0004-EA  WHEComment_BM_OilandGas (Comments are now Closed)

If it becomes necessary to demonstrate a strong public interest against this proposed project we will publish an action item, a protest letter, you can sign onto. At this time we have sent in our comments. Comments are not a popularity contest; one or ten thousand are sufficient to point out the deficit in analysis.

We will update you on the status of our legal actions, field work and continue with the year in review as time allows.



This is also the most critical fundraising time of year. WHE has been offered a final match of 2018 by a very generous donor. From now through January 1, 2019 all contributions up to $10,000. will be matched dollar for dollar! We appreciate your support to continue our important work. 




Categories: Wild Horse Education