Your voice may be one small voice. Your voice is also unique, a “one in a million.” Your voice matters.
WHE engages processes from field, into courtroom, outreach to Congress. WHE also provides the public with in-depth reporting and our archive is filled with articles that you can use to inform your own work no matter what layer of the “wild horse and burro” world you are working in (accessible through the search bar in the upper right hand corner).
We also try to create new articles that answer questions in our inbox and are issue and action specific.
Question: I do not have a lot of time but want to do more than just sign a petition or send a pre-formatted letter, what can I do?
Right now you should be reaching out to Congress to address the upcoming 2026 Appropriations debate. That debate will determine the spending directives of every federal agency including BLM. The Appropriations bill is a law. Remember in the debate in 2004, Senator Conrad Burns (R-MT) created the entire debacle of opening the door to selling wild horses and burros without limits (slaughter) through the spending debate. The bill language amended the 1971 Act and since that day, every single year, we now have to fight to prohibit funding to stop open sales to slaughter.
Calling your reps as the debate kicks into gear this year is no small thing…. it is, beyond any shadow of a doubt, an issue of life versus a gruesome death. (More info here on SAFE and Appropriations)
The “Comment Period”
Before we answer questions about the comment periods that are open on various draft plans BLM is working on for wild horses and burros, we really need to give you some “plain talk” about what “comment periods” are and are supposed to be.
Comment periods are not like “voting” on something (more comments for makes it happen, more against and it does not). Comment periods are to identify areas of conflict, provide information BLM may not have (like research, range data, etc.) and to provide information in support of one “alternative” planned action over another. BLM is supposed to modify the final document based on relevant public input.
If BLM fails to appropriately address relevant comments, an appeal can be filed in the Interior Board of Land Appeals (IBLA), a land use federal court. The IBLA has differing procedures and restrictions then federal civil courts. But you have to “exhaust administrative procedures” before going to district federal court. In order to “take BLM to court” in the way most people think of it, first you need to provide “comments.”
Question: If the comment period is really the first step in litigation, something most people are not going to do, why participate?
As a member of the general public with limited time, reaching out to your reps in the House and Senate on bills like the Appropriations bills, is probably the most important thing you can do (as we said in the first section of this article). It lets your local lawmakers know what is important to you.
However, when you comment on proposed plans (roundups, mining, grazing) you might not litigate that plan, but an org like WHE is probably going to if BLM does not address relevant factors. Comments might not be a “vote,” as BLM like to point out, but numbers do represent significant areas of importance, conflict and concern that must be addressed. “Significance” can be measured by the validity of a single person commenting that provides site-specific data or overlooked law. It can also be demonstrated in numbers. A significant number of people saying the same thing is something an organization like WHE can point to in a courtroom. If an organization is litigating for a herd you follow and commented on, you can also contact that org and get involved even if all you are doing is sharing posts and articles with your friends raising awareness of the specifics of how the “fight to save wild horses and burros” has to be done.
The “fight” to save wild horses and burros has never been a simple thing. Our wild ones are part of the system of public lands. They are the only beating hearts, living and breathing, directly managed by BLM (Note: Cows are not managed by BLM, the grass and land is). There are numerous layers to “keeping wild horses wild” that involve a lot of vigilance and continued engagement.
So if you have the time, commenting is not worthless even if BLM ignores you. Your voice matters.
Carter Reservoir, Buckhorn, and Coppersmith Gather Plan
The FINAL gather plan for Carter, Buckhorn and Coppersmith has been released. This is the stage where public comment has now closed, BLM has supposedly analyzed every relevant comment and changed the removal plan accordingly. This is the stage where those that commented can now file an Appeal. (Yes, WHE commented, extensively.)
Our inbox is blowing up. Over the last few days there have been social media posts claiming that BLM has made a decision in the Final Plan to open sell Carter horses to slaughter and kill them.
We need to take the time to address this issue on our website as it will continue to pop up on social media for every herd (now that Carter has drawn attention to it).
BLM CANNOT MAKE THAT DECISION IN A GATHER PLAN. BLM DOES NOT MAKE THAT DECISION IN THIS GATHER PLAN. BLM is quoting the (amended) 1971 Act in response to comments that want to see mustanging back, horses sold off or killed, etc. BLM includes that provision in all Gather Plans to remind people that decision is a Congressional funding determination (please take the action in the second section of this article).
This section is copied from a 2021 gather EA (the same as is in the 2025 Carter, Buckhorn, Coppersmith):
Euthanasia or Sale without Limitations: Under the WFRHBA, healthy excess wild horses can be euthanized or sold without limitation if there is no adoption demand for the animals. However, while euthanasia and sale without limitation are allowed under the statute, for several decades Congress has prohibited the use of appropriated funds for this purpose. If Congress were to lift the current appropriations restrictions, then it is possible that excess horses removed from the Complex over the next 10 years could potentially be euthanized or sold without limitation consistent with the provisions of the WFRHBA.
BLM adding that to the final gather plan for Carter is NOT unique.
Carter is not on the gather schedule at this time. Funding for the 2026 roundup schedule will be approved in the 2026 Appropriations debate. The fiscal year begins October 1 (2025 fiscal year funding ends the last day of September). EVERY herd your have commented on from Bullfrog Burros to Carter, is in line for removal in 2026. We will keep you posted. (Fiscal 2025 roundups ahead)
Open Comment Periods
Lahontan Herd Management Area Wild Horse Gather Plan (NV). This is a “population growth suppression plan” that includes removals and fertility control. The comment period will close May 12.
As we have not written yet about this EA, we will include a bit of a discussion.
The area consists of 6,937 acres of BLM land and 2,641 acres of a mix of private and other public lands for a total of 9,578 acres. The AML was set in 1991 in a Herd Management Area Plan (HMAP), Environmental Assessment (EA-NV-030-90-025) and decision (BLM 1991), (before “modern day” wild horse organizations were born). The AML was set at 7-10 wild horses allowing for straggles as BLM felt they could not effectively “zero out” the area to appease the large livestock permit that encompasses 100% of the HMA designated for horse use.
If you look at the two maps above, you can easily see that the area a roundup will hit is far larger than the boundaries of the Lahontan HMA. In fact, the likelihood that more Horse Mountain “off HMA” horses would be captured than off-HMA Lahontan is highly probably. The larger Horse Mountain HMA (49,779 acres) has an AML of 78-118. The “gather area” is 239,431 acres.
In fact, BLM recognizes the open nature and overlapping areas by stating this: “The HMA boundary is unfenced, and wild horses are present on lands outside of the HMA. Therefore, the gather area extends beyond the HMA and overlaps the following (livestock) grazing allotments: Adriance Valley, Cleaver Peak, Desert Mountain, Horse Mountain, Lahontan and Truckee-Virginia.”
However, BLM has not recognized the Horse Mountain HMA nor the fact that this draft EA goes far beyond any real ability to distinguish individual animals as Lahontan or Horse Mountain.
So a very simple relevant comment you can provide would sound like: “If BLM insists on crafting a gather plan that far exceeds the boundaries of a single HMA, by 25 times the size of the actual HMA, is more than likely to include individual animals from another HMA BLM has not included in any analysis, BLM needs to reevaluate the boundaries of the planning area. BLM could include the other HMA in analysis. BLM could craft a Lahontan specific plan and a distinct plan for off-HMA. However, this EA far exceeds any logical scope. BLM cannot simply use a Lahontan Removal plan to rid itself of responsible management of Horse Mountain and surrounding areas.”
As you use your distinct voice and talk about what you want, remember when you comment there are different objectives: providing management suggestions, research and data on things like genetic viability and critical habitat. Another is to address the actual overreach and abuse of administrative power and factual errors.
Comments are due May 12. You can participate through the BLM website by clicking the green “participate now” button. Only individual comments will count. If you use a click and sign letter provided on social media, your comment will not register as an “individual” in the system demonstrating public interest.
click image to learn more about “AML”
Rocks Springs (WY), two open comment periods (We have written extensively about this due to the confusion over the multiple types of proposed and challenged plans in this area)
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).
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.
A simple relevant comment addressing precision of paperwork would sound like: The RMP Amendment creates new circumstances where the RMP the 2021 gather plan utilizes for the authority to conduct this roundup is no longer valid. This may, in fact, invalidate the authority within the existing gather plan the DNA has determined sufficient.
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 COMMENT: 1. The underlying RMP that reverts these areas to Herd Areas (zeroed out) is still being challenged. BLM should wait until any court ruling prior to crafting a gather plan that may be a waste of taxpayer funding should the RMP amendment be invalidated. 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.
Remember, when you feel overwhelmed and that you are only one voice, remember in advocacy you are never alone. Your voice is part of a movement, a collective voice… and your voice matters.
We do not just work to expose what is wrong, we fight back. When others stay silent or simply post on social media, many of you have also come to rely on WHE to push hard in legislation and litigation. WHE might not be the biggest org., but we take a big bite.
Our team needs your support.
We have just been offered a $10,000 match to kick off fundraising for our field and investigative team. From range through holding, boots-on-the ground through detailed tracking through Freedom of Information Act requests and analysis. We must identify all that is wrong so we can fight to fix it. The information we gain creates a foundation for our litigation team.
We have until May 1, the “Big Day of Giving,” to meet the challenge.
Thank you for keeping WHE running for our wild ones!
Categories: Wild Horse Education
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