Wild Horse Education

Roberts Mountain PEA open for comments (by request)

Many of our readers are asking that we post information about the Roberts Mountain Complex Preliminary Environmental Assessment (PEA) open for comment through September 20th. 

You can find the PEA (DOI-BLM-NV-B010-2022-0019-EA) and associated documents at this link: https://eplanning.blm.gov/eplanning-ui/project/2020326/510

Wild horses in the area of the Mt. Hope mine, the Kobeh HA


The area of the proposed plan by the Battle Mountain district Mount Lewis Field Office (MLFO) is one of the places in the western U.S. where an illustration of the absolute neglect given to management planning for wild horses, while other interests go to the top of the stack, is easy to illustrate.

When the 1971 Wild Free-Roaming Horses and Burros Act was passed to protect wild horses and burros “on the land they now stand,” the next step was determining where each district would manage horses. This was basically decided through survey methods now referenced as “windshield surveys.” You drive around in your truck and make pencil marks on a map. The person given this task often simply drew boundary lines around the bottom of mountains and left livestock grazing allotments in the valleys on public lands outside the boundaries where wild horses “would” be managed (to appease grazing interests or satisfy personal relationships). The person originally given this task in this field office even made a recommendation that only one small area in the entire field office should be managed for wild horses to reduce conflict. It should be noted that this field office contains more wild horses than most states (outside Nevada) do.

The Kobeh HA, the area the horses actually stood, was divided into multiple HMAs that had no logic behind them. Essentially, the HMA boundaries were drawn to reduce conflict with livestock. The BLM admits this (that is how obvious the flaws with the boundary lines were).  A few years later Highway 50 was fenced off, cutting off the northernmost segment of the Fish Creek HMA creating an area without a year round water source. Still, the agency never amended the Land Use Plan or created an HMAP-EA to rectify the problems with the boundary lines of the Roberts, Whistler, Fish Creek, HMAs. Instead they just started referencing the area as the “Roberts Complex,” but still considering wild horses moving through the lowlands “off-HMA” or “trespass.” (This is not the “Fish Creek” HMA most of you are aware of south of highway 50, this is a segment north of highway 50.)

Over time massive mining moved into the area. The most well known is Mt. Hope. Another mine in the area is Gold Bar. Gold Bar pumps about 22,800 gallons of water per hour, 547,200 gallons per day. The Mt. Hope plan approves 7,000 gallons per minute. The plans for these mines minimize the impacts of the water table draw downs. A stream can dry up with as little as a 1 foot draw down. Just these two mines increased truck and human traffic. Legal action against these mines (that do not do one single well or change in placement of roads to minimize impacts to wild horses) is extremely intense and and you face both government and mining attorneys (we tried and then joined an environmental coalition). The agency never fixed the Kobeh HA fiasco and never did any amendment to the Land Use Plan or creating an HMAP-EA to allow for appropriate mitigation.

Roberts Mountain


The area along the north side of the Highway 50 corridor is the preferred route of the Greenlinks transmission line. This project is being fast tracked, in part, to fuel the energy dependent industries like Blockchains and Tesla in the Virginia Range. Many of you are familiar with Blockchains as the site of a partnership for fertility control for state horses that occupy the Blockchains property. We think everyone knows what “Tesla” does and the controversy surrounding the Lithium mining in Nevada (where Tesla owns mineral rights). The transmission line is planned right through the Roberts Complex.

We sit at a time in history where the drive for minerals is accelerating, on top of the drive that already existed, with no changes to the 1872 mining laws and practically no effort to actually protect wild places and wild things; like amending a 40 year old land use plan or creating an HMAP to protect a few herds in the heart of wild horse country.

We have to create a conversation that addresses the costs to wild places. Not just a conversation that addresses “the one with the most money in the room.”

BLM has met with ranching and environmentalists on water issues and sage grouse. BLM has ignored all attempts by Wild Horse Education, including those through a formal scoping process to amend the 1989 Land Use Plan, since 2012 as they coddle “preferred partners.” 


Comment periods are not a vote or popularity contest; the number of comments that say the same things will not be counted by the BLM.

Specific comments addressing flaws in process and analysis are supposed to be addressed by the agency prior to creating a finalized version of the Preliminary EA. If these comments are not addressed, you are allowed an opportunity to appeal through the land use courts (legal briefs, just like a federal civil filing, you send to the Interior Board of Land Appeals). If you cannot find resolution, you can file in federal civil court. In other words, comments are the first step toward litigation where you need to meet additional requirements of law (like the parameters of “Standing”) to have your issue heard.

Many of you are asking that we create comments for the public for this PEA. The reason you are given a “30-day” window to comment is so that you can craft substantive comments or to gain information that the agency did not include in the PEA so you can craft complete comments.

We have sent an email requesting information vital to our ability to participate fully in the process. When we get that information we will complete our comments.

If the issues in this PEA are not addressed by BLM, we do plan to take legal action. 

You can sign onto the letter below that we will use to demonstrate public interest in the Roberts Mountain Complex and the interest in being included in appropriate planning processes.

General public comments: 

This PEA is inadequate and represents the severe neglect given to wild horse and burro management in the Roberts Complex (Kobeh HA) area. The 1989 Land Use Plan (LUP) may be the oldest in country. Every document noted, including the 2004 FMUD, is rooted in the LUP that was finalized around the time that the Code of Federal Regulations (CFR) for wild horses was completed and does not incorporate the final rules. The internal BLM handbook for wild horse and burro management was finalized nearly 20 years after the LUP. 

Until the LUP is amended (or an HMAP-EA is created) to address the known deficits in the LUP surrounding the Roberts Mountain Complex, this PEA for a ten-year gather plan is simply dereliction of the duties implied in the 1971 Wild Free-Roaming Horses and Burros Act. The PEA is simply the definition of “arbitrary and capricious. “

The PEA must be remanded and rewritten as an LUP amendment or HMAP-EA that tiers to a Gather-EA. 

You can click here to add your name.

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Categories: Wild Horse Education