Triple B

The comment period is open for Antelope Complex and Triple B Complex Herd Management Area Plan (HMAP) draft “Gather and Herd Management Area Plan). The homepage on the BLM website can be found HERE. You can access the documents HERE. As is becoming typical for this particular district(s), they have not set up the green “participate now” button you use on other BLM projects and instead provided an email and mailing address: Written comments may be emailed to BLM_NV_EYDO_Antelope_Triple_B_Complexes_HMAP@blm.gov (preferred); or  delivered to the BLM Bristlecone Field Office, Attn: Sadie Leyba, 702 North Industrial Way, Ely, NV 89301.

The comment period will close June 29, 2025. Scroll down to red text for sample comments to get you started. Only comments submitted individually will count. Petitions and sign-on letters will not be addressed by BLM. 

On their own, each one of these complexes represent some of the largest in the nation. Each one is made up of Herd Management Areas (HMAs), Herd Areas (HA or areas designated for wild horses and burros but not managed) and public lands areas not designated for, but always used by, wild horses. Combined they represent acreage larger than Connecticut and Rhode Island combined. The Project Area is located in southeastern Elko County and northern White Pine County, comprised of 3,870,919 acres. It contains wild horse management units consisting of the Antelope HMA, Antelope Valley HMA, Goshute HMA, Spruce-Pequop HMA (collectively called the Antelope Complex (approximately 1,183,340acres) and the Triple B HMA, Maverick-Medicine HMA, and Cherry Springs Wild Horse Territory (collectively called the Triple B Complex (approximately 1,632,324 acres). The County boundary is also the boundary dividing the Elko and Ely BLM Districts within the Project Area. 

Any other project of this scope and intensity (acreage and numbers and time) would be required to engage in scoping meetings prior to drafting an Environmental Impact Statement (EIS), an actual in-depth analysis where an Environmental Assessment (EA) is a superficial look. (In 2017 other groups did go to court on the EA/EIS issue but focused on the gelding component as “scope and intensity” and lost the case. This precedent is an issue in our current litigation against the 2017 gather-EA, but will not be an issue on the HMAP (if BLM does not rectify the issues prior to finalizing any plans, we are preparing to litigate the HMAP). Since the 2017 gather-EA was finalized over 14,000 wild horses were removed from this area accounting for nearly 20% of all wild horses captured since the EA was finalized. Saying any plan created lumping these two complexes together is the largest in the nation is really an understatement. Please remember, any time you hear the words “scope and intensity” it means size of acreage and impact coupled with time. (Say a plan authorized removal of 200 and BLM tried to take 500, the numbers alone violate scope and intensity .)

During scoping for this “HMAP,” we did point out to BLM that they were exceeding their authority by creating one HMAP for both complexes due to the fact that there is (literally) zero population exchange. Here, BLM has the authority to create a management plan for the Antelope Complex and a distinct plan for Triple B; both outside and self-determined guidance documents and BLM themselves (in court) concur. The court already recognizes the assertion BLM themselves included in both written and oral arguments: HMAPs may be prepared for a single HMA or a complex of adjacent HMAs where animal interchange occurs (“a complex”). The distinct Antelope and Triple B complexes do not fit that definition by any stretch. 

Even this one purely procedural comment based on geography and simplistic fact was ignored when BLM drafted their new gather plan and slapped a new name on it calling it an HMAP.

An HMAP is the foundational management plan that is the ONLY landscape level planning document noted for wild horses and burros. An HMAP is not a “one size fits all” and needs to include detailed disclosure of how AML is set and criteria for re-evaluation, identify critical herd habitat to allow for appropriate mitigation from plans for things like mining, water improvements, etc. All of the things that are “outside the scope” of a gather plan. BLM can do a gather plan at the same time as an HMAP, but an HMAP and gather plan are two different things.

Our lawsuit for Pancake already demonstrated this fact and we are back in court addressing it again after BLM created a gather plan and called it an HMAP. Exactly what they are doing at Antelope and Triple B. BLM simply goes with the laziest route for administrative ease and to just keep running the status quo requiring the public to file repetitive litigation.

This is a screengrab of the draft HMAP for Antelope and Triple B. You can see BLM used the url (internet page name) for Pancake. BLM is just creating the exact same roundup plan, changing acreage and numbers, with zero site-specific analysis beyond roundup and stockpile. Abject failures.

Here is the 2017 Gather-EA, 361 pages https://eplanning.blm.gov/public_projects/nepa/84367/129074/157029/2017_Antelope_TripleB_Complex_Gather_Plan_508-Final.pdf

Here is the (draft) Gather and Herd Management Plan, 249 pages https://eplanning.blm.gov/public_projects/2034747/200630470/20134805/251034785/Antelope_Triple_B_Gather-HMAP_Preliminary_EA_508.pdf

How can the most in-depth management plan (HMAP) for an area be more than 100 pages shorter than a roundup plan? 

Because BLM did no in-depth analysis at all. Heck, they use mapping that notes “utilization” without telling you that utilization is not just created by wild horses, but blaming only wild horses. They give you an Animal Unit Month (AUM or the forage consumed by a cow/calf pair, 5 sheep, one horse, per month) because it sounds like a big number without telling how much forage is available in the complexes so you can see how little it actually is). They do not tell you how they arrive at the “allocated amount” of forage for domestic livestock that far exceeds that allocated for horses. (Is it based on how they use terrain? Is it based on distance to water? Or is it just based on how many cows someones great, great, great grandfather ran while turning the area into dust bowls? How much forage is estimated in the area and how is it divided up? No one seems to be able to answer that question that an HMAP should answer.)

Not one single “alternative” in this entire charade talks about one single subject outside of a gather plan. Not one. This is not an HMAP but a very sad example of just how lazy BLM is and the cause of any crisis the program faces today. 

Hotshot (electric prod) still being used to speed up loading

In addition, roundups in this area have demonstrated some of the most heinous conduct during capture our nation has ever seen. Nowhere are capture methods addressed beyond using the exact copy/paste used in the 2017 gather EA.

SAMPLE COMMENTS to use as a starting point to craft your own.

I am submitting relevant public comments re: DOI-BLM-NV-L060-2025-0001-EA

BLM ignored significant issues raised in scoping and must rectify the error. If the issues may be unclear to the public, BLM must complete public scoping meetings as it would for any other project, particularly a proposed management plan that reaches the level of scope and intensity as this one. Less significant projects, such as the Robinson Substation Expansion, receive far greater attention. BLM has always shortchanged wild horses and stakeholders and must rectify this issue moving forward.

BLM must complete a distinct HMAP for the Triple B Complex and a distinct HMAP for the Antelope Complex. BLM cannot rely on AWHC et al v Bernhardt, 3:18-cv-00059-LRH-CBC, where the court ruled against Plaintiff and allowed a ten-year gather plan to proceed. An HMAP and a gather-EA are not the same thing as stated in Leigh et al v Raby, 3:2022cv00034, and BLM’s own guidance documents clearly state that an HMAP can be crafted for a single HMA or group of HMAs where there is population exchange (“complex”). HMAP guidance is clear that these must be crafted as unique plans in order to gain the site-specific objectives of the process.

No alternative for this (supposed) HMAP includes a single action outside of alternatives used in a gather plan. BLM must voluntarily remand this asserted HMAP-EA and begin again. This draft is not in fact and purpose an HMAP, but a gather plan. BLM does not even disclose a basic metric to define the amount of forage in a single HMA in either complex and demonstrate the equation for how “Appropriate Management Level” was determined. There are no rangeland health reports linked, no water inventory/improvement plans, no identification of essential habitat and potential mitigation measures for the actively expanding mining and other projects, no determination of anything besides a copy/paste repetition of the 2017 gather EA (and even the 2017 gather plan is longer than this draft HMAP/Gather Plan that should be a more in depth landscape level management analysis).

The HMAP is the place to address issues like water emergencies faced seasonally in areas like Maverick Medicine as mining expands without addressing these issues (over 20 years) and making it worse every single year. Nowhere in the alternatives does BLM address this, or any other, water improvement. This is the exact type of neglect that an HMAP is designed to rectify (things outside the scope of “gather”).

IF gathers are to be considered as a potential management tool within the HMAP, BLM must provide an opportunity to address handling practices during gathers that this draft continues to fail to address. The Triple B Complex and Antelope Complex (distinctly) are unique in the world of wild horses in more than geography. Both have the distinction of being places where litigation was brought addressing inappropriate conduct. In one instance the roundup was shutdown, helicopter use forbidden to complete that operation and a warning by the Honorable Howard J. McKibben that “this court will be watching.”  Nowhere are capture methods addressed beyond using the exact copy/paste used in the 2017 gather EA that was proven inadequate. The annual Motorized Vehicle Hearings fail to meet the analysis requirement each year through a failure to address public comments and address operating procedures. 

These five comments above should be enough to get you started crafting your own.

You can add issues surrounding abusive conduct, the lack of analysis that addresses removals of wild horses on fire fuels, the lack of identification of an actual foaling season and how roundups in July in this area must be prohibited based on actual foaling season… whatever you like.

The homepage on the BLM website can be found HERE. You can access the documents HERE and review them as you craft your comments.

BLM has not set up the traditional green “participate now” button you use on other BLM projects and instead provided an email and mailing address:  Written comments may be emailed to BLM_NV_EYDO_Antelope_Triple_B_Complexes_HMAP@blm.gov (preferred); or  delivered to the BLM Bristlecone Field Office, Attn: Sadie Leyba, 702 North Industrial Way, Ely, NV 89301.

The comment period will close June 29, 2025.

Our team will be working on comments for the next couple of weeks and submit in-depth comments that both address our active litigation as well as on our active litigation that must now include this new gather plan. We are working as fast as we can for the wilds ones at Triple B and Antelope as well as our precious wild horses and burros throughout the West. From in-field documentation into the courtroom, our team is working hard.

You can help taking this action above and by contacting your lawmakers to address issues arising in the budget debate for fiscal year 2026 and protections against the outright killing of wild horses and burros and/or selling them without limits (slaughter). You can see more and take action HERE. 

You can learn more about “what a comment period is” and where it fits in the process by clicking HERE.

All of our work is only possible with your support. 

Your support keeps our teams in the field, our investigations running and our litigation alive. Together, we will take a strong stand to defend our precious wild ones.

A bit on scoping: Scoping is where BLM is supposed to take time to inform the public, answer questions and “identify issues and conflicts” and “potential alternatives” after outreach to the public. Usually during a Scoping “period” BLM holds meetings. There were no meetings during scoping for any of the wild horse and burro HMAPs. 

Livestock, mining, transmission lines all have scoping meetings. Even telecommunications get scoping meetings. The exact district doing scoping for this HMAP for wild horse management is holding a scoping meeting for expansion of a substation at Robinson on June 4. (An important note: If BLM approves the expansion of the substation, it will amend the land use plan. The substation does NOT comply with the current Resource Management Plan. But if approved, will amend the land use plan. An HMAP would do the same thing.)

ONLY with HMAPs for wild horse and burro management does BLM claim the Land Use Plan (LUP) or resource Management Plan (RMP) cannot be amended to include alternatives that represent anything outside the status quo. (NOTE: This issue is in front of the courts NOW as BLM basically simply tried to create a new gather plan and call it a management plan to attempt to comply with a court order last year at Pancake.)

We are doing our best to address the inequity and injustice in the courts. It certainly looks like our legal battle at the Antelope and Triple B Complexes is set to move to a whole new level.

We have to keep up the fight in order to gain actual management of our American wild horses. We will continue the fight until we gain justice.