As we battle out the issues at the Blue Wing Complex in the courtroom, BLM threw together a fast scoping period for a Herd Management Area Plan (HMAP) at the Blue Wing Complex. 

Scroll down for first action item highlighted in red.

Advocates have waited for 38 years to have a chance to comment on a management plan for wild horses and burros in this 2,283,300 acre complex. BLM ignored protecting wild horses and burros and their habitat, and carved up Blue Wing so intensely that half of the acreage, although designated for use by wild horses and burros, was “zeroed out” to accommodate for other uses. BLM set absurdly low AMLs through agreements, carried over those agreements and called those numbers “affirmed.” BLM never created any data-based AML on what the land can sustain that included equitable practices. 

Now, 38 years later and under pressure from an active court case, BLM presents an extremely data-poor set of documents for a scoping period for that actual management plan advocacy has waited slo long for. To us, this demonstrates that BLM is not doing this to serve the public interest and resource, but to attempt to use the scoping period to avoid another loss in court (like at Pancake). The documents presented for scoping could have been crafted in an afternoon. The lack of attention could lead us to no other assumption. 

When BLM did scoping for Pine Nut HMA, there were public meetings, data presentations and in-person question and answer sessions. When BLM did scoping for “Mustang Monument” sanctuary, there were public meetings, data presentations and in-person question and answer sessions.

Scoping for Blue Wing consists of a 5-page “data sheet (with no data), a run down on all the other planning documents for private interests that were created without compliance to any management plan FOR wild horses and burros and a map simply pulled from their roundup plan.

This scoping is literally a “rapid hack job.” (Earlier this week the Blue Wing case was transferred to the same judge we had in the Pancake case after we filed another brief and the judge originally assigned the case recused herself. Within 48 hours BLM announced this scoping period and, by the look of the “data” provided, crafted it in 48 hours.)

However, BLM has opened a door we hope ALL of you walk through. The HMAP process has been denied to you since the 1971 Act was codified into law. This platform, where you can address all of the significant issues you cannot address anywhere else, is what the pioneers in advocacy fought for. After the death of advocates like Velma Johnston, BLM took full advantage of the situation and began to simply omit these processes and others (at that time) did not even know they needed to fight for them. This is why “wild horses and burros are removed to suit all other interests” is not just a soundbite, the paperwork bears it out.

BLM should be running a meeting (as they did for Pine Nuts and Mustang Monument) that describes scoping, presents data, answers your questions. However, it appears they are simply not going to serve a “wild horse and burro public” in the manner they have in the past or they way they run scoping webinars for mining, sage grouse, corridor systems, etc. 

We will walk you through BLM scoping documents, give you direction on how to word comments for scoping and work into sample comments. An HMAP will be created through the National Environmental Policy Act (NEPA) process at either the Environmental Assessment (EA) level or the deeper Environmental Impact Statement (EIS) level. Please remember those words represent a level of analysis and not what is being analyzed. The word that comes before identifies what is being analyzed (example: a “Gather-EA” analyzes the action of “gather” only).

We are not the BLM will massive tax-payer staffing and access to avenues for outreach that they have. We will do our very best. 

We will present a series of articles that breaks this down. We will do this at the same time as we craft our own comments (and work on court briefing) in the short window BLM has provided. Comments are currently due June 1. 

Map BLM simply pulled from the roundup plan to include in scoping. This is the only map BLM provided.

What is scoping?

If you really want to get “down into the weeds” you can download the NEPA handbook and search “scoping.”

Basically, “the scoping period” is where BLM reaches out to stakeholders to identify what is important to include in analysis for a proposed action.

In the case of “scoping for an HMAP” the proposed action is “wild horse and burro management.”

BLM’s responsibility is to provide you will all relevant data.

Your responsibility is to provide identification of “significant” issues, areas that need analysis in order to make any determination of actions and provide data (or analysis of data provided by BLM) to support what you are asking for.

Essentially, if you have a subject you want to discuss, you can discuss it as a “significant issue” that needs further analysis (provide reason and data to support). We keep typing the word “significant” for a reason. That is the single scoping comment requirement. 

What has BLM provided for you to analyze and comment on for the Blue Wing HMAP to help you identify issues? 

BLM has really shortchanged this scoping process for Blue Wing. BLM provides extremely little information and does not even include a current conditions report or a single census flight map or one water inventory.

Blue Wing Scoping: provided a 5-page range summary that contained very little information, a letter that lists all planning documents (for everything else that were created without any compliance to protecting wild horses and burros that would have been outlined in an HMAP) and a general map pulled from a roundup plan. (click here)

Compare what is provided for Blue Wing to what BLM provided for the Pine Nuts: Summary of current conditions (89 pages were provided for Pine Nuts), numerous maps on each HMA, livestock grazing allotments, water inventory, vegetation communities, bi-state sage grouse, monitoring locations and population density, riparian function assessment mapping, wild horse inventory. (click here)

Before we present an article that contains sample comments for this HMAP Scoping, we ask that you join us in demanding equitable disclosure according to established process for HMAP scoping (the same as BLM does for others). BLM should only begin the 30-day clock after they provide appropriate material to the public. 

You can simply click HERE to sign onto the letter. 

Or you can email your own request to the contacts BLM has listed on the ePlanning page:  Wild Horse and Burro Specialist Garrett Swisher, email: gswisher@blm.gov  Chris Mitchel, email: cmitchell@blm.gov

Our letter: 

Blue Wing HMAP Scoping Disclosure and request for extension of time

We the undersigned expect BLM to conduct scoping for the Blue Wing Complex (DOI-BLM-NV-W010-2024-0027-EA) comparably to all other scoping processes and procedures.

Summary of Current Conditions

Project Vicinity Mapping for Complex and each HMA/HA

HMA/HA overlay with livestock grazing allotments

HMA/HA overlay with active mining

Water Inventory

Vegetative Communities mapping

Sage Grouse mapping

Herd Monitoring location map noting population density

Riparian function map

Most recent census map showing actual numbers seen

Once BLM provides the appropriate documents, BLM must extend the comment period out 30 days from the date of actual disclosure.