Wild Horse Education

Comments Open: Lake Pleasant Herd Management Area Plan and Population Control

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Submitting Comments on the Draft Lake Pleasant HMAP and Population Control Plan

The comment period on the draft Lake Pleasant Herd Management Area (HMA) Plan and Population Control Plan is open through January 21, 2026. BLM notes that this period includes the ePlanning migration window from January 15–19, 2026, when the public will not be able to submit comments.

EDIT: The system has been down for a week. It is finally functioning again and BLM has extended the comment period until 1 a.m. Mountain Time Saturday  or Midnight tomorrow, Friday (1/23/26), Pacific Time. 

In addition, the comment count dropped from before the system went down to when it went back up. We suggest resubmitting comments in case they were lost. 

Please note the “Participate Now” button is now a dull blue button (not bright green) under the Project Name and is no longer on the line next to the document you are commenting on. In addition, documents no longer open in a new window for you to read online, they automatically download to your device. So be aware each time you click the button a document downloads. If you have auto downloads blocked you will not be able to see documents. Yes, this is a really BAD part of the update for those of you that need to read online due to low storage capacities. 

If you plan to comment, we strongly suggest submitting before January 15. Whenever BLM “updates” its systems, technical issues are almost guaranteed. If you must comment after the 15th, consider submitting both through the BLM ePlanning portal and mailing a printed backup copy (not accepted as official but may serve as record documentation).
Mail copies to:
BLM Hassayampa Field Office
2020 E. Bell Road
Phoenix, AZ 85022

You can find associated documents and the “participate now” button HERE.

Sample comments summarized at the bottom of the piece. SCROLL DOWN to the last section.

Background on the Lake Pleasant HMA

The Lake Pleasant HMA, managed by the BLM Hassayampa Field Office in Phoenix, Arizona, spans 103,478 acres of mixed public and private land about 30 miles northwest of downtown Phoenix. Its dry, rugged terrain is well suited to burros.

The HMA has one of the few existing Herd Management Area Plans (HMAP) in the country, approved in 1999. Its underlying Resource Management Plan (RMP) is also unusual—it recognizes population decline in the area, one of the concerns that led to passage of the 1971 Wild Free-Roaming Horses and Burros Act.

How Commenting Works

Comment periods are not popularity contests. Whether one comment or 50,000 are submitted on the same issue, they count as a single substantive point. Final decisions are not based on volume but on clearly stated, relevant, and evidence-based arguments.

If BLM fails to address such substantive comments, its decision can be appealed and litigated in federal court. For this reason, informed comments citing data gaps, procedural errors, or inconsistencies are the most powerful.

Note: In June of 2025 BLM did Scoping prior to doing the draft Environmental Assessment (EA). If you participating in Scoping you can start crafting your comments on the draft EA by looking to see if BLM responded to the subject you commented on and carrying those comments further with additional information if BLM analysis is is insufficient or missing.

Key Points YOU want us to cover

AML is high on the list for most of you.

In the revised HMAP and Population growth plan BLM does make a disclosure of how they are evaluating AML. You can find that document as an attachment to the EA HERE. Most BLM plans will never even admit that they did not actually set a data-based AML and just rolled in predominantly “interim” AMLs reached through agreements with permittees into land use planning. What is AML? more here.

Appropriate Management Level (AML)

Many are focused on how BLM determines the Appropriate Management Level (AML). In this EA, BLM admits the AML was not originally set through analysis and Decision Record, but was an estimated AML of 166–208 burros. The revised plan changes it to 140–250, claiming the figure is “based on available forage.”

However, a crucial piece of data is missing: BLM does not disclose actual available AUMs (Animal Unit Months) or how those AUMs are allocated among burros, wildlife, and livestock. This omission is significant.

  • Ask for the full breakdown of available AUMs and allocations among burros, wildlife, and livestock (and the methodology used for that breakdown) to determine appropriate allocation of available feed and sustainability.

We did the math and according to BLM’s own data, burros could consume 1,680–3,000 AUMs based on their population range—compared to 8,074 AUMs for livestock. Without clear forage allocation data, it’s impossible to validate the proposed AML as sustainable for the Herd Management Area (HMA).

IN ADDITION: The diet of burros throughout the West is really varied and speaks to the adaptable nature of burros. The EA states for this area diets consist of “… in the Pea family with 44.11% of total read abundance, followed by grass (Poaceae) family (18.24%) and mustard (Brassicaceae) family (8.19%). The EA states, “Based on this stocking rate exercise, 500 burros could be sustained on perennial forbs and grasses.”

The way BLM presents the burro diet here might seem specific enough. However, in context of setting a stocking rate “based on grasses and forbs” the information has a fatal flaw. The “pea family” is incredibly diverse and includes various plant types, not just herbaceous forbs (non-grass-like flowering plants). It also includes shrubs like Desert Broom and Gorse and acacia, honey locust and carob trees; all eaten by burros.

The EA tells you that that BLM does NOT consider shrubs and trees in their forage analysis even though their own data indicates that the burro diet is primarily (likely) shrubs and trees. 

ASKING for the data on shrubs and trees (the burros primary diet) and that the data be considered would be a relevant comment … and then BLM can tell you why they feel it is not relevant to stocking rate. The information is still substantive to demonstrate the accuracy or inaccuracy of their determination. If their determination is simply a guess that the lower number will keep burros in the HMA without analyzing other factors like season of use of livestock, barriers like livestock fencing or water improvements, what they feel and guess is not appropriate analysis. If the burro diet is primarily pea family shrubs and trees, it is relevant.

They justify this by saying: “Yet even if values of trees and shrubs were included, raising the number of burros to be stocked, it does not yet consider other factors such as current livestock management, wildlife, ecological processes like drought, and access limitation (distance from water, elevation/slope, barriers, etc.). ”

From the EA: “A range of 140- 250 is anticipated to maintain balance with other resources such as wildlife and wildlife conservation efforts, recreation, and livestock grazing,” …  “The ever-increasing competition has caused many burros to reside outside the HMA and therefore create public safety issues.”

They do not provide enough information to show that “other factors” are actually considered (besides determining that setting a lower AML for burros after not considering a main food source was enough to mitigate off HMA movement). Ask for the data and consideration of that data as noted in blue above. 

Livestock is a major “other factor” that is inadequately considered. 

On page 13, BLM rejects “Removing or Reducing Livestock within the Lake Pleasant HMA,” claiming it’s “outside the scope” of this plan. This is incorrect. An HMAP can inform and even trigger amendments to an RMP—it “conforms and informs” under federal regulations.

Remind BLM in your comments that:

  • It is within their authority to revise or amend land use plans as part of an HMAP.

  • The refusal to analyze livestock impacts constitutes a procedural flaw and weakens the plan’s credibility.

Ask BLM to:

  • Provide data on livestock seasons of use, as these influence burro distribution and are a likely cause of burros moving outside the HMA.   

  • Examine how livestock fencing, water access, and turnout timing contribute to burros leaving the HMA.

Despite acknowledging that rangeland degradation was caused by livestock overgrazing before the 1934 Taylor Grazing Act, BLM admits that no current rangeland health evaluations have been completed for the involved allotments. This admission strengthens the case that burros are not the cause of rangeland damage.

BLM treats the HMAP as if it were a “population control” or “gather” plan only. They do not even include season of use when noting livestock permits on pages 39/40. All they talk about is how livestock will not be impacted by a bait or helicopter roundup.

NOTE in your comments: BLM needs to look at how livestock impacts burros and potential mitigation if this is truly a management plan. 

Helicopter Capture

Helicopter roundups are never appropriate for burros except in genuine emergencies (e.g., wildfire). BLM’s own data show that Capture Myopathy—a stress-induced physiological collapse—is deadly and common in burros.

The EA substitutes vague wording like “emotional stress” for the scientific term “Capture Myopathy.” It also claims compliance with CAWP (Comprehensive Animal Welfare Program) standards, yet CAWP has no standards for heat index or air quality, both key risk factors in helicopter operations.

Relevant comments can include:

  • Request that BLM properly recognize and analyze Capture Myopathy as an impact.

  • Demand prohibition of helicopter capture methods for burros, except in emergency situations.

  • Ask BLM to include temperature and air quality thresholds in its welfare-assessment protocols to be included in the HMAP until CAWP is appropriately formalized.

 

In Summary

When submitting comments, focus on specific, data-supported questions and requests for missing analysis. Comments that highlight omissions, analytical flaws, or inconsistencies in regulatory compliance must be considered substantively. These are the voices that shape the record—and, ultimately, the outcome.

SAMPLE COMMENTS: 

I submit the following comments re: DOI-BLM-AZ-P010-2025-0019-EA, Lake Pleasant Herd Management Area Plan and Population Control

  1. I request BLM clearly confirm that the public cannot submit comments during the ePlanning migration window, January 15–19, 2026, and explain what contingency measures are in place to prevent loss of public input. 
  2. Please extend or adjust the comment period to fully compensate for the days when the system is offline and inaccessible to the public. Of note, the system went down on Januray 10.
  3. I object to adopting an AML range of 140–250 burros without a transparent, quantitative disclosure of total available AUMs in the HMA and how those AUMs are allocated among burros, livestock, and wildlife. I request a table showing: total usable forage (AUMs), AUMs allocated to livestock (currently 8,074 AUMs), to burros (approximately 1,680–3,000 AUMs at the proposed AML range), and to wildlife, plus the methodology used.
  4. I request that shrubs and trees be fully incorporated into stocking-rate calculations for burros. BLM’s AML justification relies on “available forage” but omits shrubs and trees, even though its own diet data show heavy burro use of pea-family plants, which include shrubs and trees, not just herbaceous forbs. 
  5. I challenge the EA’s dismissal of “remove or reduce livestock” as an alternative pointing out that the HMAP can inform and trigger amendments to the Resource Management Plan under applicable regulations, and that refusing to analyze livestock reductions is a procedural flaw.
  6. I request analysis of: (1) reduced livestock AUMs, (2) changes in livestock season of use, and (3) removal or modification of livestock fences and water developments as tools to keep burros within the HMA and reduce off-HMA conflicts and vehicle collisions.
  7. I request mapping and analysis of barriers within the HMA—fences, roads, water distribution—that may be pushing burros outside the HMA, with specific management actions to remove or modify those barriers
  8. I oppose helicopter gathers for burros except in true emergencies (e.g., wildfire), and ask BLM to analyze and disclose the risk of Capture Myopathy in burros, using that scientific term rather than vague references to “stress.”
  9. The Comprehensive Animal Welfare Program (CAWP) standards currently lack explicit heat-index and air-quality thresholds, even though both factors are critical to Capture Myopathy risk, and request that such thresholds be established and applied.

You can submit these yourself or use them as a template to write your own. You can find associated documents and the “participate now” button HERE.

OR you can simply sign-on to our “public letter” and we will submit the letter with signees by clicking HERE.

Every mile we travel to cover roundups or assess a herd, every court case we bring, every win, every action we take is only possible because of your support. Thank you for standing with us as we strive for justice, mercy and freedom.

Categories: Wild Horse Education