Heart of “Wild Horse Country” (Callaghan comments due April 14)

By Laura Leigh on March 29, 2025

Upfront: Our wild ones need your voice! Callaghan “Complex” HMAP Scoping

Scroll down to blue text for Adobe Town comment period info

An area where Wild Horse Education has been engaged with for over a decade is now under threat.

We rarely talk about the wild ones in the “heart of wild horse country.” The state of Nevada has more wild horses and burros than all other states combined. In the heart of the state lies remote and rugged country where large herds of wild horses still exist.

We have tried not to talk publicly about our engagement in these areas too much for fear of drawing unwanted attention.

For over 15 years, the majority of these horses have lived without the upheaval caused by helicopter capture. Some of the stallions that led bands when we began advocating for these horses have grown old and died free… their offspring now the dominant stallions in their prime. Young fillies we saw as newborns, now carry the herd wisdom as lead mares and aunties and are navigating the rapidly changing landscape.

This area in the heart of wild horse country bears the historic markers of mustanging and the resentment after the 1971 law was passed and violence persisted. Report from 2015 includes background of illegal activity in the area.

The video below last roundup of the Callaghan Complex in 2010 (fiscal year 2011). The last roundup in this area took place as we began our battle in the courts to gain access to information and roundups, before there was daily observation… but we went every day. There was no “convoy” the public followed. In winter storms we were given directions to travel deep into the area to temporary corrals. When our founder, Laura Leigh, was taken to trap she was kept behind mountains, refused to leave and sat there all day long… and went back the next day and the next. She was adamant that BLM needed to begin to afford the public daily viewing. It took six-years, up and down the court system, but today the right of the public to view operations is now recognized.

The “hide and seek” played to view this roundup is what drew our founder to continue to observe and engage annually for the herds in this area.

Today, we need your voice to help us make a strong stand to gain a real management plan for these herds that begins to address all of the wrongs of the past.

BLM has opened Scoping for a Herd Management Area Plan (HMAP) for what they are calling the Callaghan Complex. They are saying: “The Callaghan Complex is comprised of the Bald Mountain, Callaghan, South Shoshone and Hickison (portion North of U.S. 50) Herd Management Areas.”

However, the Callaghan Complex has historically consisted of the Callaghan HMA and New Pass-Ravenswood. All of the underlying planning BLM notes apparently “approved” management of the historic complex. IMPORTANT: BLM has removed ALL prior gather-EAs and other documents for the old “Callaghan Complex” (and every HMA in the new complex) off any web portal. You are entirely obstructed from doing and comparisons between documents.

The map above may not be the easiest to read. But it shows how BLM left the best, primarily lowland areas, out of boundary lines, and then removed more territory (the slashed) from horse use. Yet, in fact, throughout history, wild horses have always used the areas in outside the boundaries. Those are the areas heavily coveted by mining and livestock. These boundary lines always represented politics, not facts. Today, BLM is trying to justify managing as a complex claiming “exchange.” Either horses have always used those areas or they don’t. BLM is trying to have it both ways in typical “management through contradiction” fashion.

It appears, by plain reading of the “management evaluation” online, that BLM recognizes they can change aspects of historic management through the creation of the HMAP.

Yes, they can. In an HMAP BLM can change boundary lines (if flaws in historic data are found), determine when livestock would need to be limited or removed, change AML and more.

However, if you read their evaluation report, even the wording of statements are directed toward creating a gather plan, not a management plan.

Last year we won TWO lawsuits that set clear precedent that BLM has illegally delayed creation of management plans. The court recognized that the HMAP sits between the Land Use Plan at the top and any gather plan BLM might draft at the bottom. The HMAPs BLM has crafted in response to the lawsuits, are essentially gather plans that continue to fail to even disclose how Appropriate Management Level (AML) was set.

WHE is in the courts now on several cases that address compliance issues with existing HMAPs and we are beginning additional lawsuits to obtain management plans (real HMAPs), not just retitled gather plans.

It looks like in this area BLM intends to simply craft another gather plan with a different name… and set up yet another lawsuit. We will be ready.

You can comment directly to BLM through the April 14th. You can access documents on the BLM website and send your comments directly to BLM by clicking the green “participate now” button, click HERE.

Sample:

Comments regarding BLM Scoping: DOI-BLM-NV-B010-2025-0006-EA

Information provided by BLM referencing water and forage (Rangeland Health Reports) is by vague reference only. BLM must include links to reports and a water inventory map.
BLM includes a “project area” map in the Scoping packet (one can only assume the map is for a proposed gather, not management plan). Please include maps of the identical area that show: allotment boundary fences, mining activity, recreation areas, sensitive species, water inventory.
BLM must provide links to all previous underlying analysis documents regarding the HMAs BLM intends to include in the newly created Callaghan Complex: Gather-EAs, Rangeland Health, FMUD, LUP
Cattleguards and gates on highway 305 are in disrepair or innappropriate. Mud from runoff routinely fills in cattleguards creating risks that horses will cross onto highway. Clear signs must be placed at each gate near the highway that the gate must remain closed.
Any HMAP in this area must include disclosure of how AML was set and a reevaluation of AML. The population growth charts demonstrate existing AMLs are too low. Simply saying “current populations show excess” (a statement for a gather plan), an HMAP should analyze “when” the existing population level began to demonstrate this impact. Current data indicates the existing AML is far too low and the real number lies somewhere between set AML and existing numbers.
BLM is simply not analyzing the impact of wild horses in fire fuels. In fact, post roundups fires were more frequent and larger than they were as population level grew. BLM must do an actual analysis and not simply make a statement geared toward the creation of a gather-EA. An HMAP is not a gather plan.
BLM must include analysis of utilization of Motorized Vehicles. BLM simply sites the required annual hearing as adequate analysis. Yet, at no time, has the annual hearing resulted in any analysis, report, notice, as required by the regulations governing hearings. Until BLM rectifies this error, management documents that include the contemplated use of motorized vehicles must include the omitted analysis if a roundup is a potential management option in the HMAP.
ZERO fertility control should be used until BLM creates thorough review of the impacts of substances like GonaCon in large complexes like the one they propose here. There is a real danger that fertility will not return leaving herds outside the realm of “sustained” management. How fertility control impacts foaling season and any return to establishing a foaling season” has not been studied and the use of GonaCon remains experimental. Until those impacts are determined, no GonaCon or other experimental substances should be employed.
Areas excluded for horse use (but were historically utilized) and areas zeroed out, must be evaluated for repatriation to address existing seasonal movement and to fix historic errors with boundary lines.
An HMAP is not a gather plan or other population suppression plan. An HMAP is a management document intended to inform Land Use Plans just as an Allotment Management Plan (AMP) for livestock or mining Plan of Operations would operate. (For these HMAPs, the LUP is over 40 years old, the oldest in the country and desperately needs revision informed by a balanced HMAP).

Sincerely,

The above listed comments are simply a fast suggestion to get you started. This is Scoping, not comment on a draft. You can literally comment on any aspect of management that the evaluation report got wrong or left off.

When Wild Horse Education completes final comments they are routinely dozens of pages long. These in-depth comments take time to craft and we are working on them. Engaging in comments presents BLM with an opportunity to rectify errors. If the errors are not rectified, engaging in comments is what begins the ability to litigate.

BLM has announced a 30-day public comment period on a Determination of NEPA Adequacy (DNA) for the Adobe Town HMA in Wyoming.

In May of last year, BLM approved a removal/fertility control plan for the wild horses in the Rock Springs Complex: Great Divide Basin, Adobe Town, Salt Wells Creek, White Mountain and Little Colorado Herd Management Areas.

A DNA is basically a document that says they can move ahead with the gather planned in July without doing any additional analysis. “The BLM proposes to gather and remove approximately 2,179 excess wild horses. The BLM is accepting public comments prior to the finalizing the DNA.”

The comment period will close April 28, 2025. You can access documents and participate by clicking the green “participate now” button HERE.

We will update this item with sample comments as time allows. We know many of you follow the horses at Adobe town and wanted to let you know as soon as we could.

We need your support to keep our critical work alive. We must keep active litigation running to conclusion and launch new cases as needed to keep a strong line of defense.