Silver King is at the “Scoping” phase. The first phase where BLM is supposed to identify issues.

You can find the scoping document for Silver King HERE. For some unknown reason BLM has not created a “participate now” button and prefers you email comments to  BLM_NV_EYDO_SilverKingHMA_MgmtEvaluation2025@blm.gov (preferred); or delivered to the BLM Caliente Field Office, Attn: Tyler Reese, PO Box 237, Caliente, NV 89008. The comment period will close June 23, 2025.

The Silver King HMA is located in northern Lincoln County, Nevada approximately 60 miles south of Ely, and 20 miles northwest of Caliente. The area consists of 574,962 acres of BLM land and 498 acres of a mix of private and other public lands for a total of 575,460 acres. BLM set Allowed Management Level (AML) of 60-128 wild horses. The arid area is heavily used by private livestock, pounded each year by off-road racing and expanding ATV recreation, as well as being targets for green energy like solar and geothermal.

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Above: Maps showing the original boundary lines drawn after the artificial construct was placed in the text of the 1971 Wild Free-Roaming Horses and Burros Act in order to pass the law (red lines) and the loss of territory as BLM decided where they wanted to “manage” (blue). The blue lines are the Herd Management Areas (HMA) of today. The red line areas are Herd Area (designated for horse/burro use but not managed).

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Even if you have never driven through the maze of livestock fencing that cuts off significant portions of the HMA to wild horses or seen the change in the landscape yourself from nearly “Mad Max” style off-roading in dry summer months, you can see the problems simply by looking at both sets of maps. The map above marked “utilization” does not differentiate livestock, wildlife and wild horse use. (Note: In the scoping packet BLM does NOT include a water inventory; if they did, you would really see that BLM is allowing wild horses to be cut off of significant and sparse water).

One issue involves wild horses that BLM considers “off-HMA,” claiming they are moving off because of “overpopulation.” In truth, horses have always been in these areas as it is historic range that was designated HA after the law passed. The HMAP should set an AML in these areas and stop the nonsensical claims that these horses are off home range.

The Secretary of Interior (the BLM) has the authority to set a number for management in HAs and turn them into HMAs. We have never seen this authority exercised. We have only seen further loss of territory as HMAs are turned into HAs (zero out).

In addition to the fencing you see in the map above, BLM is planning massive expansion of livestock projects under the “Wilson Creek” livestock grazing decision of 2021 (that is in the land use courts now and WHE joined with WildLands Defense and numerous plaintiffs). The “Wilson Creek Decision” is a massive livestock grazing decision impacts 35% of the Silver King HMA (formerly called Dry Lake, Highland Ridge and Rattlesnake), 76% of the Eagle HMA (formerly called Wilson Creek and Deer Lodge Canyon) and 56% of the Chokecherry HMA… and all of the HA land in between. This case is so massive the courts have broken it up into subsets (basically proving the point that BLM should have done an Environmental Impact Statement (EIS) or done multiple EAs instead on one (even the court had to break the case up into pieces). We are working now on a brief to notify the court and use the fact that BLM is finally addressing the HMAP issue to obtain a remand of the massive livestock grazing decision. The same will hold true with the HMAP Scoping. Either BLM has to wait until the Wilson Creek matter is adjudicated (in order to address valid planning for livestock) or drop the Wilson Creek plan until the HMAP for Silver King (as well as Eagle and Choke Cherry) is complete.

Did you follow that? This is really how “land use planning” is done. Land use planning is litigation and agreement driven. Land Use Planning (LUP) is not a landscape level analysis. Livestock files a lot more litigation that wild horse and burro advocates.

What you are seeing in the Silver King scoping packet does NOT include the additional obstacles presented by the Wilson Creek decision… and it does not discuss how BLM will mitigate these damages to the land designated for horse use.

Usually during a Scoping period is when BLM will hold outreach and education meetings, except for anything involving. Even telecommunications get scoping meetings. The exact district doing scoping for Silver King 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. BLM ignores the fact that if an HMAP found that expanding boundaries to include HA area that was zeroed out, as an example, an HMAP would amend the RMP/LUP.)

Scoping at Silver King, or any other herd, does not come with a meeting to explain anything. You get “same old, same old” zero real data, zero disclosure on how anything is actually set (boundaries, livestock fencing, AML) and then a big word salad that tries to turn an HMAP into a gather plan to “comply” with management plans for every private pocket exploiting your public lands and pushing horses/burros into smaller and smaller spaces.

During Scoping you can ask for whatever you want to, or present data to BLM they may not have. As with most of the “scoping” for HMAP that BLM has done, the (lack of) review and actual data involved in current management in the scoping report is tragically absent. The report (of the last 50 years of management) is only 14 pages. No disclosure of how AML is set and not even a water inventory so you can propose areas for water improvement projects (because those are all being given to livestock in the Wilson Creek decision?).

Sample comments to get you started listed below. Please remember, when it comes to commenting on BLM planning petitions and sign-on letters do not count as individual comments. You must submit your own to be counted.

We would suggest that you include these comments in your own unique words:

• BLM must include impacts from off-road racing and recreation. Limiting the size and time of year of any off-road racing activity must occur in the HMAP. “Foaling season” must be off-limits to off-road racing of any kind.
• There is active legal action against the 2021 “Wilson Creek combined grazing EA” that impacts over 35% of Silver King HMA (formerly called Dry Lake, Highland Ridge and Rattlesnake and those names are reflected in the grazing permits today) and surrounding HA land involved in this HMAP scoping. One of the main issues contained in legal briefing concerning wild horses is that the lack of an HMAP prohibits appropriate analysis of damages and mitigation. The HMAP must take a hard look at reducing livestock both to protect wild horse resources from livestock damage and as a potential mitigation for impacts from off-road racing and recreation and update LUP/RMP accordingly including the Wilson Creek grazing decision.
• No removal or fertility control should be considered until AML has been fully evaluated and methodology disclosed.
• BLM must include analysis to change HA status to HMA; Dry Lake, Highland Ridge and Rattlesnake HAs. The HMAP is the appropriate venue for this analysis as a key purpose of the HMAP is to inform land use planning and provide an avenue for amendment. 
• BLM must include a full breakdown of all AUMs available in the HMA, how much is given to livestock, wildlife and wild horses, and the reasoning why forage was allocated in the manner it was. The HMAP must also include triggers for re-evaluation of forage allocation including limiting or removing livestock.
• Any and all management actions taken at Silver King must be done transparently and with unobstructed access: gathers must have public viewing at every phase.
• We request a Scoping meeting like the one this district did for the Robinson Substation expansion. The public has a lot of questions and BLM has offered no opportunity for the public to ask them in any site-specific fashion, but expects the public to comment in a site-specific fashion.

You can find the scoping document for Silver King HERE. For some unknown reason BLM has not created a “participate now” button and prefers you email comments to  BLM_NV_EYDO_SilverKingHMA_MgmtEvaluation2025@blm.gov (preferred); or delivered to the BLM Caliente Field Office, Attn: Tyler Reese, PO Box 237, Caliente, NV 89008. The comment period will close June 23, 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. 

You can help by taking the action to comment for Silver King 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. 

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.