Wild Horse Education

Black Mountain, ID (Comments due June 13)

Comments on the BLM Gather Environmental Assessment (EA) for Black Mountain, Hardtrigger and Sands Basin Herd Management Areas (HMAs) are due by June 13. You can find the EA HERE.

BLM plans to capture, treat with various methods of fertility control, permanently remove, wild horses for ten years under this plan. They assert this will achieve a “Thriving Natural Ecological Balance” (TNEB) in the 3 HMAs managed by the Owyhee Field Office.

To make a comment you can use the “participate now” button on the EPlanning site. 

BLM Idaho has historically lumped removal paperwork into some format that combines HMAs that sit on the westernmost side of the state. (Example: 2009 removal paperwork for Four Mile and Sands Basin.) In 2020, BLM finalized a distinct Environmental Assessment (EA) for Four Mile and did a roundup in 2021. (video below from 2021)

In May of 2022, BLM began a scoping period (done before a draft assessment is prepared for public comment). The scoping period covers Sands Basin, Hardtrigger, and Black Mountain HMAs. Scoping would cover  “a variety of methods would be evaluated for use to achieve AML including aerial, ground gather and bait trap removal operations of wild horses from the HMA’s. Fertility control treatment to mares using either Porcine Zona Pellucida (PZP) or GonaCon may occur.” The scoping document suggests doing removals in 3-year cycles, very much like Reveille (learn more about Reveille).

In April, BLM placed Black Mountain on the roundup schedule as they plan to capture 110 through helicopter drive trapping methods, treat 8 mares with fertility control and release them back (along with 8 studs).

A draft EA that would approve that roundup was only released in May, a month after putting one of the HMAs (Black Mountain) on the schedule. BLM has to allow a 30 day comment period (closing June 13), approve a final EA and then allow a 30 day appeal period (that should be allowed time to run its course). Instead, BLM is ramming through a removal of wild horses after a very wet winter and the range is teeming with grasses.

The capture operation BLM has planned for September of this year would essentially involve every single wild horse that BLM estimates is on the range. BLM estimates the population in Black Mountain to be 104, prior to the 2023 foaling season. 

BLM has set the AML for Black Mountain at 30-60 wild horses. The September operation would essentially leave 16 (after release). The AML was essentially set for administrative convenience back in the early 80’s after the 1971 Act was finally codified into law. The same stocking level (AML) for wild horses was carried over into the 1999 Land Use Plan (and livestock remains the dominant use of grazing land).

To learn more about what an Animal Unit Month (AUM) is, you can read about it in an article that delves deeper into wild horses, livestock and the AUM HERE.

It should be noted that Idaho only manages 6 HMAs for a total of only 640 wild horses on a total of 418,000 acres in the entire state. BLM administers about 12 million acres of public land in Idaho with livestock allowed to graze 11,500,000 acres of that land. This makes it easy to understand how wild horses are given minimal land and minimal forage even within that land. Wild horses are not the most impactful issue when it comes to trying to achieve a TNEB on public lands.

Sample comments:

BLM must prepare a transparent and inclusive Herd Management Area Plan (HMAP) to determine management objectives for herd and habitat prior to creating a Gather-EA. 

BLM has not revealed data that would be included in an HMAP nor allowed public input on these matters. BLM can only omit an HMAP if the parameters of an HMAP are met elsewhere. In this instance, they are not. 

    1. Calculations of up-to-date AMLs for the Complex wild horse HMAs to replace the “administratively set” AMLs for “administrative convenience” as required under legal mandates and supported by the Interior Board of Land Appeals.
    2. Revise livestock AUMs and forage calculations and utilization (utilizing up-to-date USDA livestock weight and forage consumption rates [USDA ISSN: 0499-0544, October 22, 2020]) necessitating updating the presented Complex wild horse AMLs and providing future RMP revisions for livestock AUMs and grazing allotments.
    3. Identification of specific/only population growth suppression (PGS) strategies, specific implementation plans, triggers for PGS actions, and identification/studies of cumulative PGS effects on wild horse behavior and health/mortality. (An unidentified and compound assertion of a plan is insufficient).

You can add whatever you like. The comments above are suggestions to get you started.

To make a comment you can use the “participate now” button on the EPlanning site. 

The purpose of comments is to show where BLM failed in data analysis or processes. Commenting on an EA sets up your appeal if BLM fails to address a substantive comment in their final EA before the EA becomes “full force and effective.”

Taken in spring of 2023 showing range and herd health.

BLM needs to begin to craft actual transparent management planning.

BLM is mandated to manage, not remove. Removal could be a tool of management… but remove and stockpile is not management.

“Gathers” are not management. Population growth suppression (fertility control) is not management. 

Only when BLM identifies the herd, how it uses the range, how to protect habitat critical to the survival of the herd, genetic stability that protects each herd and its unique connection to the history of the landscape…  can management actually begin. 

Thank you for keeping us in the fight.


Categories: Wild Horse Education