So many of the wild ones we knew and loved are gone now. Several, like this mare, killed for having blue eyes and a false assertion she was blind.

Many of you are aware that BLM rapidly crafted the HMAP scoping for herds that have been the subject of ongoing litigation since 2023 as Sunshine Man snapped his leg. Litigation WHE has active spans multiple subjects that include the failure of BLM to provide additional information and comment periods through supplementing the 2017 gather plan Environmental Assessment (EA). That might sound technical. But what it means is that BLM just keeps plowing forward 7 years after crafting a plan, removing twice as many as noted in that plan (a total of 12,000 or 19% of all wild horses removed nationwide), changing environments and has never even disclosed how many they are removing during each gather operation from each HMA under the largest gather plan in the nation. 

Once more, the distinct Antelope Complex and the distinct Triple B Complex are being lumped (again) into one document (probably illegal) to create the largest management plan in the country  (activities resulting from this plan will cover an area of over 4 million acres; bigger than Rhode Island and Connecticut combined).

Click HERE to sign on to the pre-comment letter  that we will be sending to BLM this week regarding that so called “plan.”

But in the meantime, BLM is rushing to hit this area with another devastating roundup set to begin November 1. As our case continues to address underlying issues we did file documents in court this week objecting to the way BLM is manipulating both the administrative process (where the public can provide input) and the facts surrounding small site-specific issues to try to justify hitting the entire complex before the underlying case receives judgement. 

Does BLM play games or actually make a reasonable effort to create sound decisions? 

Wanna play a game? (much like 3 level chess)

Level 1: We are arguing in the courts, right now, that in 7 years BLM has doubled the number of horses removed then the original 2017 Environmental Assessment notes (over 12,000 in both complexes). This accounts for 19% of all wild horses caught by BLM in the last 7 years. Just the removal of this massive number of horses changes the environmental conditions (as well as approvals of massive mining, large die off of all animals due to the harshest winter in the area in decades, and more) and BLM should have, and easily could have, done a supplemental review under NEPA or, if conditions had changed dramatically, a new removal plan would have been required. BLM also just completed an “emergency” removal in one of the HHMAs in Triple B at Maverick Medicine last month. BLM is using those conditions (where they already removed 106) to justify hitting the entire complex in a mass removal. The public, and the public resource, deserves a reasonable effort by BLM to release data and a new analysis.

Level 2: As we are working hard to get all of the documents together for the courts, BLM then adds an insanely short comment period (30 days) for the HMAP. There are egregious issues with the scoping including a failure to link to any data they assert creates conclusions, lumping 2 noncontiguous areas into one HMAP, no maps that shows fencing or mining footprint for mitigation strategies. On inquiry, BLM has said they will only include that information in the draft HMAP (when it is too late to propose additional alternatives to the ones they create). (Movement here is at the same exact moments as movement in the courts creating a massive amount of documents to review.)

Level 3: We are receiving documents through Freedom of Information Act requests (FOIA) or through direct requests and in the field. Our field work shows the only areas where any “hardship” truly exists is where BLM already did the emergency. The rest of the complex is still fragmented with only 3 large groups seen on over 1.6 million acres and the rest are solo horses or small groups of 2 or 3 (stallions that found a mare or 2 or another stallion to hang out with). The range looks pretty good except where livestock has been out or mining expanding rapidly and new roads gut the area.

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Above: One of the few bands in the area shattered during the last roundup when only 1 member of this family escaped capture.

You can see by looking at the 3 levels that work to protect two of our last large areas from being wiped out is intense.

“Wiped out?” 

Play the next round (because this feels more like a BLM game than any professional effort by a federal agency to “manage” anything transparently)

As we are trying to get all the information to the court this week in several briefings, we are also working on comments for the HMAP Scoping for Antelope Complex and Triple B Complex. The “Management Review document” in the scoping process did not include a census. So we asked for the actual census of both complexes… in typical fashion, we received incomplete information; we only got the flyover from Triple B.

It took a long time and two volunteers to “count up the dots” on the map. Both counts matched. 

• • Maverick-Medicine including out of HMA  646
  • Triple B including out of HMA  1,168
  • Cherry Springs Including out of HMA  20
  • TOTAL  1,834

If no wild horses died of any cause and the herd reproduced by 20% in 2024, a direct count result would be around 2201. We know BLM said “dozens died” and they removed 106 in an emergency (that continues to repeat every few years because BLM refuses to address an ongoing issue with water) in September.

So let us conservatively say that 128 are no longer in the complex leaving 2073.

We know BLM ran that number through a computer modeling program (that we are not privy to the metrics of).

BLM says that even after computer modeling they can be “off” by 25% up or down. BLM does not reflect “estimate” as a “range.” They add the 25% and more from modeling with no allowance that they are over estimating.

Even if a few horses are returned, BLM plans to use GonaCon (4-10 years of efficacy) on older mares that will probably die before they have another foal. On 1.6 million acres are a few hundred, non-reproductive horses, really fair management and protection? Is this really “expanding safe fertility control” or is it a path to a slow die off of one of less than a handful of our last large herds in the U.S.?

Looking at the direct count and comparing it to BLMs estimate in the HMAP Scoping packet, do you think the public should have been provided additional information through a supplement to existing NEPA (the 2017 Gather-EA) or a new Gather-EA to comment on?

Are you outraged that BLM finally gives you a chance to comment on actual management planning through HMAP scoping (where the data they gave you for scoping will be woefully inaccurate if they do this roundup; even before the due date for comments)? You should be. We are.

BLM plans to remove 2,255 wild horses from the Triple B Complex without even telling you how many they are taking from each HMA and never, ever, giving you any data that determines the horses left in Triple B are “excess.” The legal definition of “excess horses” is NOT a number over AML but involves multiple factors. 

If you are not playing “3 Level Chess” like we are, how could you, the public, even get an inkling of how “off” all of this truly is? 

This little one and family are in the target zone

Our team is truly heartsick over what is likely to befall these horses. BLM continually claims that removing them is “for their own good” or that they are “better off” being captured than risking being wild. 

BLM constantly claims that die off on the range is negligible when doing growth estimates. Repeated FOIA investigations by our team continue to show that from trap and into holding, 12% (or 1 in 9) will die in the first 6 months in BLM care. After Blue Wing, the death rate of burros sent to Indian Lakes rose to 13.8% in the first 3 weeks!

Are the wild horses of Triple B in more danger on range or in BLM care while the public continues to wait for a landscape level disclosure of data and a real management plan?

This is why we fight. This is why we will simply not stop until we have fair management, real transparency and enforceable welfare rules. No matter how long or hard the fight, we will not leave our wild ones without a voice. 

Our wild ones truly need all of us to speak out, step up and never, ever, give up. 

By request we have relaunched the “Freedom and Justice” t-shirt and, by request, we added the preamble to the 1971 Act to the back. You can order a shirt by clicking here and, if you want to add a donation to support our work you can during checkout.  

If you would like to make a direct contribution to help us continue to be in the field and pay the bills to keep pushing hard in the courtroom, we are grateful for your support. Without you, none of our work is even possible. 

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.