WHE is getting numerous inquiries referencing the Lahontan Herd Management Area (HMA) near Carson City, Nevada. Many expressing concern that no action is being taken as the roundup plan is set to decimate the HMA down to a mere 7-10 wild horses. WHE did take legal action.
Update: Lahontan from WHE volunteer Colette Kaluza
Update on the status of the Lahontan Herd Management Area (HMA), and the Lahontan Wild Horse Gather Preliminary Environmental Assessment (EA). In April 2025, Bureau of Land Management (BLM) announced the draft Gather-EA, covering 9,687 acres, and a larger area around it, approximately 304,705 acres in Lyon and Churchill counties, 40 miles east of Carson City, Nevada. BLM Carson City District Office invited public comment and input through the BLM National NEPA Register April 10 until May 12, 2025.
Wild Horse Education (WHE) submitted formal comments as an organization and on behalf of its members worldwide.
Thereafter, BLM Sierra Front Field Office completed the EA and Finding of No Significant Impact, and issued the Decision Record for the Gather-EA on July 18. The current status of the EA, under the National Environmental Policy Act (NEPA), is “In Progress – Decision and Appeal Period” until August 17.
Simply put, the final Lahontan Herd Management Area Wild Horse Gather Plan-EA is just a population growth suppression plan, with wild horse removals and fertility control, not to ensure the survival of the herd that will be pushed far below genetic viability ensuring the demise of the herd.

WHE has formally filed legal briefs and Appeal of BLM’s final Decision to the Interior Board of Land Appeals (IBLA), a land use federal court. The “Appeal period” is the first step for legal action concerning land use decisions (wild horses and burros included).
One compelling issue for an appeal on the Lahontan horses is around this point: “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.”
Our article posted April 21, 2025 talks about comment periods on draft plans, what comment periods are and are supposed to be, and sample comments for the public to make specifically for Lahontan horses.
The so-called “Appropriate Management Level (AML)” was set in 1991 in Herd Management Area Plan (HMAP), and updated
2003 (before “modern day” wild horse organizations were born), needs to be updated and opened up to today’s advocates. The absurdly-set AML of only 7-10 wild horses (allowed to remain and not genetically stable) in Lahontan HMA was to appease the large livestock permit that encompasses 100% of the HMA designated for horse use.
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The area the roundup “gather” will hit is far larger than the boundaries of the Lahontan HMA. In fact, the likelihood that more off HMA Horse Mountain horses would be captured than off-HMA Lahontan is highly probable. The larger Horse Mountain HMA (49,779 acres) has an AML of 78-118. The “gather area” is 239,431 (BLM-only) acres.
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In fact, BLM recognized the open nature and overlapping areas in their statement: “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.” But BLM did not recognize the Horse Mountain HMA, nor that the Gather-EA goes far beyond any real ability to distinguish individual horses as either Lahontan or Horse Mountain horses.
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Wild horse advocates are individuals with different objectives that are reflected in our comments, such as: providing management suggestions, research and data on genetic viability, critical habitat, and the actual overreach and abuse of administrative power and factual errors.
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Maps above: One is from the BLM gather plan showing the area of removal, the other shows that the removal area abuts Horse Mountain HMA not included in analysis but impacted.
From Fallon Post, “The Wild Horse Education organization submitted comments on the EA and also shared concerns on its website, arguing that the BLM is overreaching by including areas far outside the Lahontan HMA in its gather plan. The group warned that the plan could affect animals from neighboring herd areas that were not analyzed.”
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“The agency received 161 individual comment letters, largely from private citizens but also from wild horse and animal advocacy groups.”
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You may wonder what organizations or individuals commented. See
Appendix G.
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Commenting is worthy of your time. Even if BLM ignores you, your voice matters and we all must continue to speak out.
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If you do not see your name but feel you made a comment, it may be because you did a sign-on letter and your comment is not counted individually. If you do a click-and-sign letter provided on social media or elsewhere, your comment will not be counted in the NEPA system as an individual comment, and therefore does not demonstrate the actual volume of public interest, but dilutes the potential power of strength in numbers.
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Comments 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 can be a big deal. It is something WHE, or other organizations, can use in a courtroom.
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Thank you to the organizations and individuals who commented in May for the Lahontan horses!
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Because comment periods are to identify areas of conflict, provide information BLM may not have — 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.
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Our wild ones are part of the system of public lands. There are numerous layers to keeping wild horses in the wild that involve a lot of vigilance and continued engagement.
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This update is not “marketing language,” but where the intent is to help you understand the steps of federal land management processes and where this herd sits in that process at this time. Words matter.
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Colette Kaluza, Wild Horse Education welfare team assistant director
None of our work is possible without your support.
Thank you!
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