Pancake, 2024

Earlier this year we won a massive court ruling that clearly demonstrated that BLM has not created management plans as required under law. Removal plans are not management plans. A “Gather Environmental Assessment (EA)” analysis a removal (and other population growth suppression). A Herd Management Area Plan (HMAP) is supposed to address so much more. In this instance, the court also found that BLM’s “gather plan” was deficient because it did not appropriately analyze the the impact of removing so many wild horses on fire fuels. So the court invalidated the “gather-EA” as well. In March of 2024, the court gave BLM one year to complete the HMAP.

Today, BLM has announced that they reviewed all of the scoping comments BLM received, appropriately analyzed input and released a Preliminary Herd Management Area Plan for comment. BLM has given the public only 29 days to comment.

BLM did not release a draft HMAP, in fact of language, they released a draft gather EA (nearly identical to the one they released before). It seems BLM has only one way of seeing wild horses… remove them. It seems it is really hard for BLM to get out of the “copy/paste” rut and actually do their jobs. 

Historically BLM has just released roundup plans and erroneously called them a management plan. Now, BLM has released a management plan that simply regurgitates a roundup plan…. with no discussion of actual management beyond removal/fertility control (and even that has no depth of analysis beyond that in any gather plan). BLM has simply done what they always do and completely disregarded their responsibilities.

If you compare the 2021 Gather-EA, the one the court invalidated, with the 2024 HMAP, the only apparent differences are the lengthy list of preparers and the superficial notations on mining and energy. The “analysis” in both is just a list of plans for other things a “removal and fertility control plan” needs to tier to.

Shame on you BLM. 

We are going back to court.

We knew simply winning a case to open a door closed to advocacy (involvement in management beyond removal) for 40 years was just the beginning of the actual fight to protect wild horses and the land they need to survive.

However, we did think BLM was going to make some meager attempt to address factors that they cut the public out of addressing for 40 years. They made no attempt at all.

BLM made absolutely no attempt at all to craft a document that discloses range data, formulas used to craft forage allocations and AML (the number of horses they allow on the range), identifying critical habitat or even addressing actual foaling season using data. BLM did not analysis at all that would address codes and regulations like § 4710.5 Closure to livestock grazing.and triggers that would clearly establish when livestock need to come off the range to protect wild horses. (In the Pancake Complex both sheep and cattle overwhelm the range during the fragile growing season for grasses and BLM fails to analyze triggers for even changing livestock turnout dates!).

Even a basic Allotment Management Plan (AMP) or management plan for other species like big horn or elk give so much more detail on the needs of animals on the range. When dealing with wild horses BLM is required, by law (§ 4700.0-6 Policy. Wild horses and burros shall be considered comparably with other resource values in the formulation of land use plans). Without any real HMAP the ability to even begin to “compare” goes out the window and the assertion of multiple use remains a multiple ruse.

BLM does not even include any mapping of fencing, mining footprints, identification of critical habitat and waters. There are no actual rangeland health reports or links to anecdotal observation sheets… nothing.

Wild horses being removed while cattle graze, February 2022, Pancake Complex

As we are working hard on the Antelope Complex and Triple B Complex in court and in scoping for management, we sit on the eve of a massive and unjustified roundup beginning at Triple B (across the highway from Pancake). Our team is working vigilantly to meet court deadlines, meet comment deadlines and get into the field to monitor the roundup. Roundups at Triple B have been notoriously brutal and were the site of the first court case in history against abusive conduct.

We knew there would be a need to address deficits in any HMAP the BLM (same district as Triple B) created. However we did hold some hope that the fight would be about defining an HMAP and not simply having to fight again to get them to craft a real HMAP.

It is obvious that BLM wants to keep advocacy out of any discussion involving actual management of a public resource, a living species, and just continue to create plans to remove them to suit permitting for private pockets.

We are ready to drill down into this sham of an HMAP to set up (unfortunate, but necessary) litigation. It appears BLM is thumbing their noses at both advocates and the courts. We will offer you sample comments as the due date draws near.

If this were a management plan for anything else… you would not only have at least 60 days to comment, but BLM would be running numerous events to answer your questions and guide you. For wild horses? BLM is simply cutting every corner they think they can get away with.

The time is now to set up the fight to protect this herd. BLM is moving quickly. It looks like BLM is trying to push this “gather plan in the guise of a management plan” through to get this herd onto the removal schedule before we can stop it. The time to fight back is now.

Together, we can hold them accountable. Our wild ones have only the voices of advocates. The agency tasked with their protection has completely lost any recognition of the words analysis, equity, fair and balanced participation and basic integrity.

We are working under hard deadlines and will have more for you very soon. 

Our ability to continue to fight is only possible with your support. 

As the year comes to a close WHE has been asked if we have a calendar for sale. In fact, we added a new design to our calendar selection and have several other gift items in out storefront you can access HERE.

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 sincerely grateful for your support. 

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.