What is an HMAP?

A Herd Management Area Plan (HMAP) is the foundational management plan for each distinct herd, which discloses how Appropriate Management Level (AML) and forage allocation was/will be set, defines the herd and goals, analysis boundary lines and any and all actions to be taken including range improvements. In other words, the actual management plan. Everything on public lands has a management plan. The way management plans “comply and inform” other plans creates the legal framework that determines actions BLM takes. The lack of HMAPs for wild horses and burros is what causes the legal authority to remove them in order to create compliance with plans for other uses (livestock, mining, sage grouse, etc.) without those uses ever complying to any plan that protects horses and burros.

In terms most advocates would understand: everything you have commented on for the last 40 years and have been told it is “outside the scope” of the “gather plan.” Those of you that place the role of wild horses in fire fuel reduction at the top of your list? Those of you that want a real foaling season defined to stop helicopters from stampeding heavily pregnant mares and new foals? Those of you that want an analysis done that determines when a range would be closed to domestic livestock to protect herd habitat? Those that want Thriving Natural Ecological Balance (TNEB), that elusive stated goal of BLM defined? The HMAP is the place for these analyses (and many others) and inside the scope.

For lack of a better term, “the battleground” to actually fight for fair management has been denied for over 40 years and wild horses and burros have simply been given what is left over from, and removed to suit, private profit users of public lands.

It took litigation to open the door to the actual on range management planning. In 2024, WHE and our partner at RAN, won two lawsuits that clearly demonstrate that BLM has illegally withheld this critical planning document, the only one actually noted in the Code of Federal Regulations, and jumped directly to gather plans that need to tier to an actual management plan.

The first foundational court ruling won was at Pancake where we kicked the gather plan to the curb and the court found the creation of the HMAP was illegally delayed and BLM must complete one by April of 2025. The next battle has already begun as BLM tries to turn HMAPs into glorified gather plans without any disclosure of the data or analysis noted in official guidance documents. But we must take the battle into the next phase at Pancake. We have laid the foundation for the next battle and that battle will begin in a few short months. The first round in the HMAP fight set the precedent and must be defended.  The precedent holds the power to protect all of our herds nationwide.  We will fight for all of our herds and will not be content with a hollow HMAP.

By winning two cases we have solidified precedent that can be used, right now, for every herd. BLM recognizes this fact and has begun to release “Scoping” material for additional herds. Scoping is the first step. Usually when BLM does Scoping for projects in-depth data is presented and outreach meetings are held with the public. The Wild Horse and Burro Program is skipping this step and just doing copy/paste from gather plans, minimal Scoping and checking a box.

We are already fighting back in the courts. It is really important for YOU to understand why the HMAP is so critical. How everything BLM was supposed to do (like data-based AML) was simply done through special-interest agreements and carried over as jargon in land use planning and hidden from sight and then buried.

This is one of the most critical battleground of our lifetime in the fight to protect and preserve wild horses and burros on the range.

Wild Horses have always used territory extending to the dark purple lines. But BLM drew the HMA boundary at the blue line to satisfy VERY powerful permittees whose families had historically controlled much of the area and the much of the business interests in nearby Winnemucca, NV. It is really easy to see, by simply looking at the map, that BLM drew boundary lines to exclude most of the lower elevation forage used by cows, not by using any “science.” (It should be noted that BLM did NOT even include this map in their scoping packet. We pulled it from our file from prior litigation.)

Jackson Mountains HMAP Scoping: Comments Open Through March 4, 2025

BLM has begun scoping for the Jackson Mountains HMAP. The HMA is approximately 264,974 acres. Appropriate Management Level (AML) is how many wild horses/burros BLM will allow to remain on the range.  BLM says the AML of 130-217 wild horses was determined in early Final Multiple Use Decisions (FMUD) and carried over into land use planning. (We can tell you for a fact the FMUD decisions do not provide any actual disclosure of data or equations.)

Scoping has begun in the typically sloppy fashion in which the BLM Wild Horse and Burro Program usually operates. The press release stats comments are due March 4, the Scoping Statement says March 7. If you look at the Management Evaluation Report it is labeled “Antelope and Triple B” and not Jackson Mountains. The supposed “data” provided to the public for comment is simply copied and pasted from the gather plan and does not link to any data, but references interpretation of that data.

Jackson Mountain is made up of, rather literally, two very distinct populations. The 8,900 ft mountain, mazes of barbed wire for livestock and fences and roads for a very active mining complex have cut Jackson virtually in half. Any AML set for the HMA must be reevaluated as “Jackson North” and “Jackson South” or the fencing removed and the HA territory (designated for use by wild horses but not managed or zeroed out) returned.

BLM recognizes the fragility of the herd genetically since the boundary lines were drawn. Since that time expansion of mining and livestock (fencing, roads) has increased the risk. (Remember the more genetic alleles the greater the risk of loss, damage to the existing make-up. Low alleles demonstrate existing damage has been done.)

BLM uses non-scientific statements to justify low AML. First they will claim a movement between populations (they cannot prove). In recent years BLM has started using the term “meta population” to sound scientific and then completely butchering what the term actually means. The term requires movement between contiguous areas in numbers substantial enough to stave off inbreeding.

But BLM just says “we will drop in a mare or two if we see inbreeding” as they did in Idaho and other areas last year (where the mares were older than 15 and loaded with two doses of GonaCon that has an efficacy for infertility of 4-10 years, longer than the expected life span of a wild mare). If inbreeding does occur, the genetic damage done takes generations to undo if the population numbers rise high enough and are not kept on the verge of disaster.

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Above: In 2012, we shut down a helicopter roundup in June as BLM tried to claim an “emergency” allowed them to violate their own prohibition against using choppers during foaling season. They tried to claim a tiny area filled with cattle (that were even walking into the trap) was in such a dire straight that they could hit the entire HMA. BLM lost the case. 

Identifying actual foaling season when BLM is prohibited from using helicopters to capture wild horses is becoming more and more important. BLM has been approving a mishmash of fertility control agents that all change the time of year mares will foal when (and if) fertility returns. As an example: Broad use of PZP in the Black Mountain, Hardtrigger and Sands Basin HMAs in Idaho has shifted peak foaling season to the fall (not spring and summer). This increased the risk to foals and mares with a newborn trampled to death on the first day of the roundup. 

Another issue at Jackson is water (an issue for everything in every western state). One of the reasons the original boundary lines were drawn to include a few lowland spots is for access to water. Fencing, roads, drawdown from mines, misuse of grazing land (particularly in the south), climate change have compounded the issue. BLM could rectify this by removing fencing and returning HA land and installing water improvements in higher elevations where livestock would not pound the area and destroy the flow.

Jackson Mountains

How do you craft comments?

BLM basically uses this boilerplate to define an appropriate comment: Public comments are most helpful if they are specific. The regulations (40 CFR 1503.3) state that comments on a proposed action “shall be as specific as possible and may address either the adequacy of the statement or the merits of the alternatives discussed, or both.” The most valuable comments are those that cite specific actions or impacts in the document and offer informed analysis of what is presented. 

When what is presented by BLM is far from “specific,” how can your comment be specific?

You can use generalized comments that note the lack of specific data given and point to a reason why BLM must supplement the evaluation report and/or delay any management action until data can support informed and adequate decision-making.

Sample Comments:

• BLM must not allow any helicopter drive trapping until data determines an actual foaling season to maintain compliance with the prohibition against helicopter capture during this fragile time. BLM has provided no data at all on foaling season.
• BLM claims “multiple water sources. they monitor,” but includes absolutely no data on flow rates and not even a water inventory map. You can note the lack of disclosure that completely contradicts every statement BLM uses in ever announcement of a roundup for Jackson where they state “water is extremely limited.” BLM must provide additional data before finalizing any HMAP. 
• BLM must disclose data and the equations used to set AML and forage allocation. No FMUD actually discloses any formula or data. AML must be evaluated as distinct viable populations for North Jackson and South Jackson as, in fact, there is little to no exchange between these populations. BLM must disclose data and not reiterate interpretations of nonexistent data. 
• At no time has BLM analyzed the impact of wild horses in the Jackson Mountains on fire fuel and used that data as a factor for setting AML. 
• A Management Evaluation Report should demonstrate clearly the impacts of past management actions. The report BLM has presented does not define TNEV nor demonstrate that any removal, at any time, in Jackson Mountain has achieved TNEB. BLM should either provide that data or abandon removals altogether and propose alternatives to removal. 
• BLM has never analyzed § 4710.5 Closure to livestock grazing. and this analysis must be included in the HMAP.
• An HMAP both informs and complies with underlying planning. As no HMAP existed when the FMUD and LUP were created, the HMAP can trigger a revision to those documents if analysis demonstrates the necessity. Just as a mining EIS can trigger an LUP revision, so should an HMAP. If analysis demonstrates that lawful management of Jackson Mountain requires changes to the LUP, the determinations should not be reject and instead a revision process begun.

You can add any comment you like.

BLM has not created a “participate now” button on their website for this HMAP. You need to send comments to: BLM_NV_WDO_WHB@blm.gov and put “Jackson Mountain HMAP Scoping: DOI-BLM-NV-W030-2025-0002-EA” in the subject line.

Or you can click HERE and send the sample comments above through our interface. 

Our team is reviewing the document very carefully and crafting comments. Our final comments can be extensive and dozens of pages long. The comment period is the first step to engage in the process. If BLM fails to respond appropriately, this sets up litigation. As we review the document we will update you as time allows.

A lone stallion watches as all of the other horses in the allotment are pushed by the helicopter. North Lander, WY, 2024

Our team is working hard in the field and in the courts to protect and preserve our wild ones. Without your support, none of our work is possible. Thank you for keeping WHE running for our wild ones!