The Rock Springs Complex in Wyoming consists of the Great Divide Basin, Adobe Town, Salt Wells Creek, White Mountain and Little Colorado Herd Management Areas (HMAs). “Rock Springs” is the name of a complex of HMAs and the location of a holding corral. 

Many of you are writing to us confused about the “comment” period out for the July roundup of Adobe Town and Salt Wells Creek and the permanent removal of 3,624 wild horses. 

The layers of new documents, challenges and more new documents, has many of you confused… and it should have you confused as two new comment periods open (scroll to red text at bottom of article for info on new wild horse related comment periods for Rock Springs and one for Callaghan).

QUESTION: What does the Resource Management Plan (RMP) amendment do? 

The official approved decision:

• The Rock Springs Field Office (RSFO) portion of the Adobe Town HMA will revert to HA status and be managed for zero wild horses. In the Rawlins Field Office (RFO) portion of the HMA, all checkerboard land and the portion of the HMA north of the existing Corson Springs southern allotment boundary fence (see Map 3) will revert to HA status and be managed for zero wild horses. The remaining lands (within the RFO) will be retained as an HMA and managed with an AML of 259 – 536.
• The entire Great Divide Basin HMA will revert to HA status and be managed for zero wild horses.
• The entire Salt Wells Creek HMA will revert to HA status and be managed for zero wild horses.
• The boundary of the White Mountain HMA would remain the same as Alternative A and would include checkerboard land. This HMA would be managed with an AML of 205 – 300. The White Mountain HMA would not be managed as a non-reproducing herd; however, population growth suppression strategies would be implemented to limit population growth rates for this herd.

Appropriate Management Levels (AML) under this plan amendment would be 464 to 836 wild horses, a roughly 60 percent decrease from previous AMLs of 1,481 to 2,065, for all of the HMAs in the checkerboard combined. 

Below: To give you an idea of the history of “land designated for use by wild horses and removed” in Rock Springs see the slideshow below. The first slide (red boundaries) is the original designation. The “blue line” boundaries are where BLM decided they would “manage” (citing things like “terrain too rough”). The red “x” map shows the changes in the RMP amendment. It should be noted that the RMP amendment does not include repatriation of HA land (original boundaries) that would be legal to do to replace lost acreage in the amendment. 

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QUESTION: So if the RMP was approved in 2023, but challenged in court, how did BLM do roundups in Rock Springs (White Mountain) last year (2024)?

The White Mountain roundup in 2024, was conducted under the 2021 Gather EA for Adobe Town, Salt Wells Creek, Great Divide Basin, White Mountain and Little Colorado Herd Management Areas (known as the Rock Springs Checkerboard)This plan did not “tier to” the new RMP, but the old one (and the parameters of this roundup were approved in both the old and new, basically allowing it to happen).

QUESTION: How can BLM put out a gather plan if the RMP is still in court?

The RMP amendment for wild horses just had a hearing in the Tenth Circuit court of Appeals. That means that advocates lost the case at the district level and had to Appeal. While the Appeal (to overturn the lower court) has not had a verdict yet, the lower court ruling stands.

A Resource Management Plan (RMP) is not actually an approved action. It gives approval for an action to be proposed: guidelines for management in a district. So basically an RMP re-states collective landscape level planning documents (mining, livestock, wild horses/burros) and creates a guideline for what future management would contain. So the RMP amendment approved planning for zeroing out and reducing AML amending the existing RMP. A “Gather-EA” is the planning that approves the actual population growth suppression (roundups/fertility control).

In a nutshell: At Rock Springs, the RMP amendment lays the foundation for the scope of any new “Gather plan” to zero out. A ten-year “gather plan” already exists from 2021 to “get to AML.” So BLM does not need a new roundup plan to do a roundup, but do need a new one if they move ahead with “zeroing out” these areas.

BLM also feels pretty confident that the Appeals court will side with them. The confidence may be premature. Although a very hard hearing to listen to there are things to note. Specifically, even though BLM was saying the RMP did not technically approve a roundup that advocates were challenging, the court did seem to understand that when BLM does create a roundup plan that advocates would be precluded under law from challenging the frame that allowed it (something the lower court did not consider). However, the court also recognized that the HMAs existed in the first place because of an agreement of the checkerboard with permittees, that withdrew their consent in 2013. It usually takes a few months post-hearing to see the ruling. (Rock Springs is a really unique situation and we do not blame you for being confused.)

Before you ask: What happens if the Tenth Circuit rules the RMP is remanded back to the lower court or invalid? Would there be no roundup? 

The roundup at Adobe Town/Salt Wells of over 3600 wild horses to “reach AML” scheduled this summer is NOT tiered to the new RMP. It will not be impacted by any ruling. Zeroing out of Salt Wells and Great Divide basin and the NW corner of Adobe Town would be impacted, but not a “gather to reach AML.”

More below. 

QUESTION:

OK, My head hurts now. So what is happening NOW and what can I do? 

BLM has just released TWO documents relevant to the scheduled roundup this summer and The Rock Springs Complex

1. A Determination of NEPA Adequacy (DNA) for a large roundup this summer at Adobe Town was released for public comment. A DNA basically states that BLM can do the action without additional analysis because underlying planning is sufficient. The comment period will close April 28, 2025. 

The DNA: Remove Adobe Town Herd Management Area (HMA) to the low Appropriate Management Level (AML) of 259 wild horses and apply “immunocontraception” (PZP). BLM estimates that “in and around” Adobe Town are 2438 wild horses. “Under the Proposed Action a total of 2,179 adult wild horses would be gathered and removed from the Adobe Town HMA, consistent with the selected alternative in the associated Decision Record (Alternative II, the Proposed Action). In keeping with that alternative , of the 2,438 wild horses, 2,179 would be permanently removed from the HMA and approximately 129 would be treated with fertility control treatments, (though only immunocontraceptive vaccine use would be used under this action) and released back into the HMA.”

The DNA for the summer roundup at Adobe Town is tiered to the same gather plan BLM gathered White Mountain under in 2024, It does NOT tier to the RMP Amendment and would not be impacted by any ruling in the Tenth Circuit. 

You can read the DNA and comment HERE by clicking the green “participate now” button. Relevant comments would address any new information BLM did not consider. This is not a new roundup plan, but an action proposed under an existing plan from 2021. The comment period will close April 28, 2025.

2. BLM has released a Gather Plan to “Remove Excess Wild Horses from Herd Areas Previously Designated as Herd Management Areas” that includes: Great Divide Basin, Salt Wells and Adobe Town (the part they are zeroing out). The comment period will close April 30, 2025, at 4 p.m. MST. 

“The purpose of the proposal is: 1) to remove excess wild horses from Herd Areas that have been determined to be unsuitable for the long-term management of wild horses due to the presence of interconnected private lands, and 2) to remove wild horses from private lands within these Herd Areas, as requested by the private landowner. ”

This plan involves removal of all wild horses in this area (currently estimated at 2,755) and is a direct result of the 2023 RMP revision awaiting a decision by the Tenth Circuit.

BLM will need to finalize this new roundup plan (Gather EA) before zeroing out. If the Tenth Circuit overturns the lower court, BLM cannot approve the “zero out” in this draft plan.

You can read the documents and comment by using the green “participate now” button HERE. The comment period will close April 30, 2025, at 4 p.m. MST.

SAMPLE: This is the document where you can state in your comments: 1. The underlying RMP that reverts these areas to Herd Areas (zeroes out) is still being challenged. BLM should wait until any court ruling determines the validity or remands back to the lower court for further clarification. 2. BLM must analyze relocation to neighboring zeroed out Herd Areas that have not been analyzed to reversion back to active management as a fiscally responsible alternative to a holding facility. 3. BLM must not use Motorized Vehicles in any removal operation until the annual hearing releases an analysis of findings. 

We hope this article helps answer your questions. We are getting a lot of them in our inbox about Rock Springs! 

Scoping for a Herd Management Area Plan (HMAP) is underway for a new proposed “Callaghan Complex” in central Nevada. Comments close April 14. These herds have been one of the areas of focus of our advocacy at WHE. For 15 years there have been no helicopters. We need a fair management plan to be formalized that addresses all of the deficits of the past. Please learn more and get involved HERE.

WHE has focused our attention filing a defense for our wild ones where there were no other active cases (examples: WHE has active litigation at Stone Cabin, Antelope and Triple B, Three Rivers (burros), Blue Wing (horses and burros), Pancake, the “CAWP” welfare policy, and more). Although WHE has commented on planning, litigation in Rock Springs is not currently carried by WHE. Three other organizations filed three different lawsuits on the RMP (that combined into one) referenced in this article.

There are a lot of herds that need the attention of advocates and we are stretching to reach as many as we can. 

All of our work is only possible with your support. We thank you for keeping the critical work we do at WHE running for our wild ones.