Stallion nuzzles his young curly son who is now living in a bachelor band.

Comments are due for the (seemingly newly designated) Callaghan Complex on 9/3/ 2025. 

We are receiving emails asking that we provide some direction on the comments due for the “Callaghan Complex.”

The BLM announcement and homepage on their website states this is a “Scoping period.” That is not correct. 

08/04/2025-BATTLE MOUNTAIN, Nev. –The Mount Lewis Field Office has developed a Herd Management Area Plan (HMAP) and Gather Plan Environmental Assessment (EA) for the Callaghan Complex. The Callaghan Complex is comprised of the Bald Mountain, Callaghan, South Shoshone and Hickison (portion North of U.S. 50) Herd Management Areas. A 30-day public scoping period will begin on 08/04/2025 and will end on 09/03/2025. 

When you go look for the document to comment on, it is a Draft Environmental Assessment (EA)  it is claiming it is a “Herd Management Area Plan/Gather Plan.” (click highlighted text to go to BLM website)

What seems to be causing even more confusion is that BLM loaded an editable Word doc, not a Final pdf file. This seems to be adding to the confusion as it makes you think this is not a formal document. (We have had people ask if BLM wants us to actually edit the document or create a new one)

We emailed BLM today to let them know that the website and announcement were misleading and confusing many people. Reviewing a BLM draft EA requires a lot of time to formulate very specific responses. We have asked that they fix the error with a clear objective (commenting on a draft EA) and begin the comment period again.

Many people may be providing generalized comments thinking this is a “Scoping” and need to be provided an opportunity to fix their comments.

You can also email Sam Ault at sault@blm.gov , the person BLM has listed as contact for this project and ask that the comment deadline be extended.

If you want to be involved but have little to no time, you can sign onto our public letter., click HERE

We know this is a long article some of you may not have time to read.

If you are crafting your own comments, you can bookmark this page to read when you have more time.

If you want to be involved but have little to no time, you can sign onto our public letter.

These comments will not count as individual comments by BLM, but will stand as a collective. Our team is still working on our comments and will be working up until the deadline. You can use the sign-on comment letter to craft your own or simply sign-on. If you craft your own to submit use the green “participate now” button on the BLM site HERE. 

The Problem with the new Callaghan complex EA (and just about every other planning document for wild horses and burros in the country), in a nutshell:

• Essentially, nothing about these Herd Management Areas (HMAs) were originally based on anything to do with how horses use the range, basic data or even logical sense. 
• An overwhelming number of HMAs in our country were created through agreements with permittees and counties after the 1971 Wild Free-Roaming Horses and Burros Act (WFRHBA) Act passed. Boundary lines and numbers of wild horses and burros that would be tolerated created the “interim” framework as agencies claimed in the beginning they did not have enough information to create data-rich management plans. As data was collected these numbers and boundaries were supposed to be revised, transparently and with full disclosure.
• No actual landscape level reviews ever happened. BLM simply retyped the agreed to framework into land use planning and called it “affirmed.” Instead, of ever fixing anything, BLM copied and pasted the original agreements in Resource Management Plans (RMP) to “affirm” the agreements, not to figure out what was fair or even remotely data-based. Please remember, an RMP is NOT a landscape level analysis but a meshing of existing landscape level plans.
• In fact, in many HMAs BLM has never actually collected any actual data on horses in these HMAs beyond flights to find out if they are over the agreed to numbers and where the horses are so they can do a roundup.
• Most Land Use Plans (LUP) that incorporate the AML (number allowed on the range set in agreements with livestock in the 70s and 80s) are over 20 years old.

In the case of this magically formed Callaghan Complex, this Land Use Plan (LUP) was signed when: George Bush had just become President, Ted Bundy was just executed, the Space Shuttle Discovery was still flying, the Exxon Valdez oil spill occurred in Alaska, Nintendo just released the “Game Boy,” Walt Disney World just opened, and Rain Man won 4 Academy Awards.

To say this land use plan is dated is an understatement. Yet, it still drives wild horse removals on your public lands, prioritizes outdated and destructive industries, and serves as a clear reminder that the wild horse and burro program has still not updated to “color-tv” technology.

A Herd Management Area Plan (HMAP) is the ONLY management document that was codified into law. It is the ONLY landscape level analysis document for wild horse and burro management where you, the public, can have input on management. 

One of the things this document is supposed to do is disclose data and methodology for management. Examples: How is AML set and when would it be reevaluated? How is forage allocation done (how much in the entire area and what is the method for dividing it between livestock, wild horses/burros, wildlife)? How do the horses move in the area and what is essential habitat? What is spring function and what improvements are needed to distribute population? Are the boundary lines based in range data or based in agreement? Nowhere has BLM disclosed any of this information or analysis. No planning document in the record contains a disclosure even though BLM cites those documents are “where that decision was made.” 

The HMAP is the only document where the public can have input on subjects outside of removals. There is no other place where a landscape level analysis would include actual management of a living species where we, the public, would gain information and be able to provide input. 

BLM illegally delayed creating Herd Management Area Plans (HMAP) to actually analyze and update the baseline (demonstrated in repetitive litigation). Now that BLM must do HMAPs, they are just creating extremely data-poor gather plans (much less info than plans done for roundups before) and calling them HMAPs.

If this is what BLM wants to move forward with, we will be adding Callaghan Complex to the growing list of active lawsuits. This so-called “Callaghan Complex” may be the most egregious and absolutely lazy plan of all. 

Click on map to see larger. We are going to talk about this map, a lot.

Let’s look at the map. The pink line is the “gather area.”

In fact, horses are in these areas and have always been in these areas. The pink line should be the original Herd Area boundary line. Because of agreements and “conflict” determined by the BLM employee in charge of this area in the 1970s and 80s boundaries were NEVER determined using any method that involved actual habitat utilized by wild horses, but for convenience. This individual only wanted horses managed in one place in the entire district, one of the largest districts in the West at 10.5 million acres. (We have seen the original recommendation and it reflected a position that the district did not have the resources to manage horses/burros in the entire district and that it would create too many conflicts with mining and livestock).

Through similar agreements acreage that lies between HMAs was not designated for wild horse management. If you look at the map above, the HMA boundary lines are all at the bottom of mountains. Cattle do not typical use upslope areas as the best and easiest grazing land is in the lowlands. Somehow, BLM decided that horses don’t use those areas (even though they were in those areas in 1971 and today) and excluded them from the best grazing land and necessary seasonal habitat.

BLM SAYS: The Callaghan Complex Appropriate Management Level (AML) were established through the Shoshone-Eureka Resource Area (SERA) Management Plan (RMP) Objectives (Shoshone-Eureka RMP Record of Decision dated 1986 and Shoshone-Eureka RMP Amendment, Record of Decision dated 1987). WHAT THIS MEANS: BLM retyped the numbers agreed to with the permittees, this is NOT a landscape level analysis of carrying capacity, 

Shoshone-Eureka RMP Record of Decision dated 1986 zeroed out North Shoshone HA (you can see in the map). The part that is not checkerboard was included in the zero out of wild horses because the permittee ran domestic horses (in contravention of the CFR § 4710.5 (b) All public lands inhabited by wild horses or burros shall be closed to grazing under permit or lease by domestic horses and burros.

Many of the areas between these HMAs (left out of the boundary lines) now look like an industrial center with all the increasing mining and mining traffic. These ares did not look like this in the late 80s. But since the fictional boundary lines for wild horses were drawn BLM could just give away the acres and water and not have to worry about even including the damage to critical wild horse habitat in the mine plan. This field office (Mt. Lewis) oversees 39,330 active mining claims. Mining is the big client in the Battle Mountain District and is treated, literally, like royalty.

This so-called management plan does not evaluate anything to do with baseline management. It does not look at AML, disclose original data for AML, boundary lines… zip, zero, zilch. 

BLM just wants to take this population down to the agreed to number in the 1980s of 323-552 on over 1 million acres.

The map above shows the field office, approximate location of this gather plan for newly created Callaghan Complex in red and noted a blue square that is gathered as part of another district.

Pretty easy to see that this one document of a mere 79 pages to cover over 1 million acres (where everything after page 68 is a list of sources of things they copied and pasted from) is simply lazy.

This is a gather EA. This is not an HMAP. 

BLM seems to have interpreted the court ruling that they need to do HMAPs as just changing the name of gather plans.

It is worth noting that this Complex did not exist prior to 2025.

There is literally no land use plan or management plan of any kind that actually analyzes if and how there is exchange between these Herd Management Areas (HMAs) and if they should (or should not) be managed jointly. In 2025, BLM just said they are going to do it this way and, in this document, does not provide actual data beyond anecdotal reasoning based on ease for any roundup they do.

South Shoshone, Bald Mountain, Callaghan, and Hickison (north) Herd Management Areas (HMAs), and the North Shoshone Herd Area (HA). These HMAs and HA are (all of a sudden, without analysis) referred to as the Callaghan Complex.

HMAs that encompass about 550,000 acres now considered “one thing” put together in a so-called management plan that seems to have ONLY one aim: to facilitate roundups on over 1,140,000 acres (more than twice the area within the HMA boundary lines that were drawn through agreement in the 1980’s, not through any data-set*). This gather plan (masquerading as management planning) has absolutely no objective beyond facilitating removals. BLM just wants to take this population down to the agreed to number in the 1980s of 323-552 on over 1 million acres.

This is a gather plan, not a management plan.

The BLM estimates there are now over 5,000 wild horses in these combined HMAs. At around 2,400 wild horses in this area, fire size and frequency began to drop… and so did reproductive rate. The agreed to number in the 1980s of 323-552 on over 1 million acres.

• This plan fails to look at AML at all.
• It fails to look at impacts on fire fuels and adjust AML accordingly or even mention the risk of fire could increase after the horses are removed!
• It fails to note that the majority of waters on their map are either not available to horses or are not functional year round.
• It fails to note that BLM created a recreation area that covers the entire South Shoshone HMA increasing the need to look at boundary lines as the impact pushes horses down.
• This so-called management plan does not even talk about repairing cattle guards or removing old fencing.

There are so many other things wrong with this HMAP. Even monitoring is not geared for management, only removal.

You can sign on to our public letter HERE.

Our team will be submitting very extensive comments and preparing litigation if it becomes necessary. These HMAs clearly show how BLM has failed to create a real AML. Here there is no gray area on how both boundaries and AML were never set using data.  If the maximum they say is 500 and there are 5000 and a removal is now proving necessary, AML is certainly not 500 but somewhere between 500 and 5000 and they refuse to even look at it for fear of violating an agreement that is over 40 years old?

WHE is committed to taking this as far as it needs to go to gain justice and some equity for our amazing wild horses that live in this area.

None of our work is possible without your support. 

Thank you for keeping WHE running for our wild ones!