Pancake, 2023

There are two active Scoping periods open for public comment for wild horses:

• Scoping for a Gather Environmental Assessment (EA) for the Rock Springs Herd Areas (HA) that were previously designated as the Great Divide Basin, Salt Wells Creek and Adobe Town Herd Management Areas (HMAs)
• Scoping for the Herd Management Area Plan (HMAP) EA or EIS for the Pancake Complex.

Rock Springs Gather-EA comments are due July 8 and can be found HERE

Pancake HMAP (EA/EIS) comments are due July 15 and can be found HERE

Both are scoping periods: “Process by which lead agencies solicit input from the public and interested agencies on the nature and extent of issues and impacts to be addressed and the methods by which they will be evaluated.” (CEQ guidance, 1981).

Scoping is your chance to help determine what is included in the draft plan (that you will get an additional comment period on) and what type of analysis is done.

However, the resulting draft will outline very different proposed actions: Rock Springs will analyze the action of “gather” and the Pancake draft plan will outline “management” including goals and objectives any “gather plan” created afterwards might claim to be needed to achieve.

A gather plan is not a management plan. This fact that has been ignored by BLM for decades and was finally recognized in the courts this year as distinct.

Any scoping comment you craft for either document, in order to be considered a substantive comment that would require BLM to conduct an analysis response, needs to be crafted to suit the nature of the proposed action.

Example using “fire fuel”:

“How would removal of all of the wild horses in the areas BLM proposes to revert to Herd Area status (zero out) impact fire fuels as this was never addressed in any HMAP?” This would be a way to phrase it for the Rock Springs scoping that plans to remove all horses from Great Divide Basin, Salt Wells Creek and Adobe Town Herd Management Areas (HMAs).

“What is the number of wild horses needed to create a beneficial impact to reduce fire fuels and how can populations be distributed through water improvements to increase that beneficial use?” This would be a way to phrase a comment that addresses the same subject in the HMAP for Pancake.

When commenting on both documents including additional site-specific information regarding your comments will make them more effective. If you have information that can correlate removals to fires, areas of increased forage production and fire risk, these would help to show relevance of your comment.

In both the HMAP scoping and the Gather-EA scoping, you can also include comments of an economic nature. In others words, horses bring tourist dollars. How would each proposed action be impacted?

Wyoming

In May of 2023, BLM finalized the amendment to their Land Use Plan (LUP) to zero out a large portion of the wild horses in Rock Springs. The scoping for the Gather-EA proposes a multi-year removal plan of an estimated 4,876 wild horses beginning in fiscal 2025 (Oct. 1).

Pancake, 2024

Recently there was a scoping for an HMAP for the Blue Wing complex. The scoping packet for Blue Wing contained a mere 4-page “analysis” of current management (basically farcical in nature). For Pancake BLM provides 17 pages where they assert conclusions and provide little in the way of actual data. Neither even come close to the 82-page assessment provided by BLM when they did scoping for the Pine Nut Mountains. There is not a lot of time to craft comments that address aspects of management, goals and objectives for the complex. If you are crafting comments, you can use some of the concepts from the article on Blue Wing to get you started. We will get more specific sample comments and articles up when our team has time as we crunch deadlines.

As both comment periods draw to a close we will bring you additional information and sample comments before the deadlines. However, these are two important comment periods active now and we wanted to make sure you knew they were active.

Sign-on letters would not be appropriate for participation in the scoping process. If you want to participate, you need to send an email or post a letter in the mail in order to have your comment recognized.

Rock Springs Gather-EA comments are due July 8 and can be found HERE

Pancake HMAP (EA/EIS) comments are due July 15 and can be found HERE

Looking both of these over a few times will help you familiarize yourself with the area, the underlying issues and prepare you to draft your unique input.

We will have additional articles coming soon on both of these important comment periods.

Thank you for being an active advocate.

Our wild ones deserve to live free on the range where both herd and resources are protected and free from abuse. 

Thank you for keeping WHE on the frontline in the fight to protect and preserve our treasured wild ones.