Scoping comments are open for the conglomerate of the Triple B Complex and the Antelope Complex that spans a land base larger than the states of Rhode Island and Connecticut combined. The BLM notes: “The Antelope Complex is approximately 1,183,340 acres and the Triple B Complex is approximately 1,632,324 acres for a total of 2,815,664 acres.” However, the actual project area covers existing HA areas (lands designated for use but removed for use prior to any actual landscape level analysis and subject to removals and inclusion in any potential mitigation an HMAP should begin to address. Any resulting proposed action tiering to this HMAP will cover nearly 4 million acres, in fact.

Simply put: BLM is exceeding their authority to make one HMAP for two distinct complexes… particularly of this size and geography that does not physically conjoin. We must have two distinct HMAPs.

BLM has provided an absurdly short comment period for the public of 30 days to submit comments on the “management review.” Click HERE to go to BLMs page to access the document and “participate now” button. 

We are getting a lot of emails asking us for guidance or for us to publish our comments so you can use them for your comments. Creating comments for any gather plan EA or HMAP scoping can be a painstaking process that takes time. When we are talking about one of this immense scale (that likely exceeds BLMs authority in the first place) we will be crafting our comments up until the last minute.

The massive acreage of this scoping period demonstrated in a map that spans nearly to Wells NV south to McGill and then nearly to Eureka NV. The issues in the distinct Antelope Complex are different than the many of the issues in the distinct HMAs of Triple B.

Example of site-specific distinction:

In many of the areas in the Antelope HMA utilization is primarily from sheep and not horses and BLM does not distinguish.

In the NW corner of Triple B wild horse use patterns have been impacted by expanding mining (BLM provides no maps showing the footprint of mining) and new fences for both mining and livestock (BLM provides no fencing map).

In truth BLM has been forcing wild horses to use less and less of their designated territory for decades and then creating site-specific “emergencies” due to confinement and loss of access to habitat… and then hitting the entire area with a roundup. That is the truthful expression of “historic management evaluation.”

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The “maps” showing “utilization” simply have a date the map was created, not dates of utilization reports or even links to see actual copies of the reports. Do these numbers come from a report intended to assess the livestock grazing permit or specifically assess impacts from just horse use? Just because “BLM says” their interpretation, the data must be made available for public inspection… the entire purpose of NEPA public participation. Public participation is not simply to say “ok,” part of the process is to point out deficits in analysis. We have no way to know.

What we do know from being on the ground is that horses are moving due to impacts BLM approved where they noted horses would “move out” of an area and “no harm done” (like mining and new fencing for livestock). BLM never addressed any mitigation or “allowance” for herds needing to seek resources elsewhere during long and short term disturbances.

Example: Moving north into Maverick-Medicine during a mine expansion creating greater impacts to resources outside the project area of the mine… causing removal. We think that is a significant impact BLM never addresses in any mining EIS because there is no HMAP. If the HMAP comes “out of the gate” without even having maps showing existing and pending mining footprints, BLM has no intention of ever even recognizing the damage and we are in for a fight.

Triple B

Our team members are working hard to complete extensive comments and continue our fight for TWO of our last remaining large herds in the entire western U.S. 

You can help us by signing on to the letter below. (This is a distinct action from commenting on the scoping plan and we will give you sample comments for scoping as the due date nears.)

We, the undersigned, respectfully request that BLM extend the comment period for the Antelope Complex and Triple B Complex HMAP (DOI-BLM-NV-L060-2025-0001-EA) out to 60 days. Scoping of this size and intensity represents the largest and most complex ever presented by the BLM Wild Horse and Burro Program. Scoping of this depth is akin to a scoping for mining and requires ample time for appropriate participation. 

Before proceeding, BLM must consider that they are exceeding their authority by combining two distinct complexes into one HMAP. The court has already determined that a gather plan is not a management plan (HMAP) and BLM needs to see them as distinct processes. The court already recognizes the assertion BLM themselves reiterated: HMAPs may be prepared for a single HMA or a complex of adjacent HMAs where animal interchange occurs. The distinct Triple B Complex and the distinct Antelope Complex do not meet any of the guidance parameters for one HMAP but meet the guidance for two distinct and carefully analyzed HMAPs. 

BLM must not simply provide a “point on a map and number” as presenting data. Each study/data point referenced must be accompanied by a date and link to the actual data sheet. Please promptly provide data required for appropriate public participation and a sound HMAP. Without this information the HMAP process is hollow. At the very least, BLM must compile this information and make it available for viewing onsite with enough time provided to review the data before close of comments.

Click HERE to sign on to the pre-comment letter. 

Or you can send your own letter to the emails noted on the BLM ePlanning page to request the appropriate extension of time.

Our team is working hard to craft relevant comments for this scoping. We are also working on other open comment periods and will have more for you soon.

We are also working hard on the ground and in the courts. We need your support to keep fighting back to protect and preserve our wild ones.

Thank you for keeping WHE running for the wild.

There are several ways you can support WHE from gift shopping to stock donations. Learn more HERE.