Red Desert Scoping: DOI-BLM-WY-R050-2026-0012-EA | Comment Deadline: May 4, 2026
Submit at: https://eplanning.blm.gov (search: DOI-BLM-WY-R050-2026-0012-EA)

Scroll to bottom for simplified talking points. Read the article for basic takeaways from our teams first read of the scoping material. If you are crafting your own comments, we hope this article helps.

Please remember any “click and send” or sign-on letter is meaningless at this level of providing public input, 

WHY THIS SCOPING COMMENT MATTERS

The Bureau of Land Management has proposed a Herd Management Area Plan (HMAP) for five wild horse HMAs spanning the Red Desert of Wyoming:

• North Complex (Lander FO): Antelope Hills, Crooks Mountain, Green Mountain HMAs (~333,694 acres)
• South Complex (Rawlins FO): Stewart Creek, Lost Creek HMAs (~419,000 acres)

What will not be discussed, unless advocates demand it, is:

• Whether AML was set using sound, current science and evaluation
• Impacts on water from livestock and mining operations compared to wild horses and noting wild horses have a lower impact on this resource (how droughts should be mitigated)
• Whether the range management plans governing this area are couched in dangerously out of date land use plans for a region now in record-breaking drought and changing environmental conditions
• Evaluation of complex boundary lines (repatriation of HA in whole or in part)
• A long-term preservation strategy that benefits a genetically sound wild horse population

This is a scoping comment — meaning now is the time to tell BLM what it must analyze. Scoping is not about arguing outcomes. It is about ensuring the analysis is complete, honest, and legally defensible.

If you do not raise an issue in scoping, it may be harder to raise it later.

Below: During the last Red Desert Complex roundup local photography favorites like “Blue Zeus” and “Big Band” were captured. One of the most memorable events during the operation was the tenacity of a black stallion and the trust his band placed in him as he continued to evade capture and they followed him to freedom. 

THE DROUGHT CONTEXT BLM CANNOT CONTINUE TO IGNORE

The Red Desert is in crisis — right now, before any HMAP decision is even drafted.

• Wyoming’s April 1, 2026 snowpack was the lowest on record since 1981 — just 49% of median peak SWE, the worst in 45 years of recorded data. (drought.gov, April 9, 2026)
• 82% of Wyoming SNOTEL stations are in snow drought. Snowpack peaked 29 days early. Twenty-five percent of stations have already melted out — 30 to 62 days ahead of schedule.
• The North Platte, Upper Bear, and Upper Green River Basins — watersheds that feed the Red Desert — are in severe snow drought with SWE at or below 50% of median.
• Sweetwater County (South Red Desert) was designated a USDA Natural Disaster Area in August 2025 due to D2–D3 drought conditions. (USDA FSA, August 27, 2025)
• Fremont, Natrona, and Carbon Counties (North Red Desert) are in D1–D2 drought, with conditions that worsened in the four weeks preceding the March 2026 assessment. (NWS Riverton, March 12, 2026)
• January through March 2026 was the driest start to a year for the contiguous United States since 1895. (U.S. Drought Monitor)

Wild horses will face life-threatening water shortages this summer. And when they do — when they concentrate at the few remaining water sources, when riparian areas show stress — BLM will point to population numbers “over AML” and call the horses the problem. The HMAP must not be allowed to lock in that narrative without a full and honest analysis.

On summer range:

• A wild horse uses about 15 gallons of water per day (about 450 gallons per month).

• A cow‑calf pair uses about 40 gallons per day (about 1,200 gallons per month).

That means cattle use about 2.7 times more water per AUM than wild horses, yet BLM completely fails to look at this fact when determining suitable rangeland allocation of forage. An AUM (the forage eaten by a cow/calf pair or one horse) is the only measure for stocking numbers and season of use. As the West faces repetitive drought, this equation needs a hard look.

Fix and plan water infrastructure for horses
BLM often removes horses for “water stress” without fixing broken springs, failing pipelines, or fences that block horse access to water. Ask BLM to map all water developments in these HMAs, fix problems, and commit to keeping enough reliable water for the horses that remain, before any removals.

Ask who is the better drought‑adapted user
Because horses use far less water per AUM than cattle, they may actually fit drought‑stricken rangelands better than full livestock use. Ask BLM to analyze whether keeping more horses and reducing livestock (or changing season of) use might better “protect a thriving natural ecological balance” under long‑term drought. Under the Wild Free-Roaming Horses and Burros Act as Codified, BLM has that authority within an HMAP (that would trigger a land use plan amendment particularly if the LUP fails to look at changing conditions such as drought).

In red are areas designated for horse/burro use after the 1071 Act passed called Herd Areas (HA). The blue is where BLM redrew the boundaries into Herd Management Areas (HMA) under discretionary authority (meaning they simply could without a Congressional directive or change in law; they can also change them back the same way through the HMAP)

Issue: Red Desert “north/south” redesignation and adjacent historic horse use areas (Arapaho Creek HA)

Nutshell: When BLM slices the Red Desert into a “North” and “South” complex without changing the overall acreage, it is making choices about which nearby lands “count” for wild horse management and which are left out. Areas like Arapaho Creek, where wild horses have lived for generations, sit right next to the Red Desert HMAs and could legally be brought back into wild horse management, but that option will not be considered unless the public demands it in this HMAP process.

Technical: Historically, BLM has managed Antelope Hills, Crooks Mountain, Green Mountain, Lost Creek, and Stewart Creek “collectively as the Red Desert Complex,” with gathers and EAs treating the five HMAs as a single complex. Current scoping materials and public communications now refer to a “North Red Desert Complex” and a “South Red Desert Complex,” without identifying any direction in the governing land use plans (RMPs) that requires this new two‑complex structure. If BLM is, in practice, re-designating the Red Desert from a single complex into north and south complexes at its own discretion, that re‑framing has direct implications for which adjacent lands are considered “within” the wild horse management landscape and which are effectively excluded from analysis.

The Wild Horses and Burros Management Handbook H‑4700‑1 makes clear that decisions to “change HA boundaries, to designate HMAs for the maintenance of WH&B, or to remove all or a portion of an area’s designation as an HMA must be made through a LUP amendment, revision or new RMP.” The handbook also states that “all or part of an HA may be reconsidered for designation as an HMA through LUP” when conditions support it. The implementing regulations likewise provide that “[t]he authorized officer shall prepare a herd management area plan, which may cover one or more herd management areas,” and tie HMA and range designations to the land use planning process. (An HMAP can trigger an LUP amendment and the “two complexes” presented in scoping will change the underlying LUP making additional changes easier.)

The Wild Free‑Roaming Horses and Burros Act further directs the Secretary to “protect and manage wild free‑roaming horses and burros as components of the public lands” and authorizes the Secretary to “designate and maintain specific ranges on public lands as sanctuaries for their protection and preservation,” where he deems such action desirable. Nothing in the Act limits that authority to the original set of HMAs; to the contrary, it contemplates ongoing designation and maintenance of ranges and management areas where wild horses and burros occur and can be sustained.

In this context, it is highly relevant that Arapaho Creek, immediately adjacent to the Red Desert HMAs, has a long history of wild horse use, was recognized by BLM as part of the managed complex in prior gather operations, has wild horses within it during previous and recent census, and is now treated as an HA area from which horses have been removed (“the donut hole”) even though wild horses continue to use the area.

If BLM is now re‑framing the Red Desert as a “North” and “South” complex and effectively formalizing which lands are “inside” or “outside” the complex for long‑term management, the HMAP EA is precisely the stage at which the agency must: (1) disclose and analyze any implicit re-designation of the each complex boundary; and (2) evaluate whether adjacent historic use areas such as Arapaho Creek HA should be considered for full or partial re‑designation as HMAs or as part of a wild horse range, consistent with the authority granted to the Secretary under the Act and the procedures in H‑4700‑1.

Request: The EA should (a) clearly describe whether BLM is formally redesignating the Red Desert into a North and South complex and identify any corresponding changes in HMA/HA boundaries; (b) analyze the status of Arapaho Creek HA and other adjacent lands with historic and ongoing wild horse use, including whether current conditions meet the four essential habitat components identified in H‑4700‑1 to sustain wild horses over the long term; and (c) evaluate, as a reasonable alternative, full or partial re‑designation of Arapaho Creek HA (and other suitable adjacent acres) to HMA or wild horse range status through a concurrent or subsequent LUP/RMP amendment, as authorized by the Wild Free‑Roaming Horses and Burros Act and required by H‑4700‑1 for changes to HA/HMA designations.

A full AML review grounded in current conditions

The Appropriate Management Levels for the Red Desert HMAs were established:

• North Complex: 1993–1994 (EA# WY-036-EA3-010 and WY-037-EA4-122), reaffirmed in the 2014 Lander RMP
• South Complex: Similar vintage, reaffirmed in the 2008 Rawlins RMP

These determinations predate:

• • The current drought cycle
  • The 2022 record drought
  • The 2025 Sweetwater County disaster designation
  • Wyoming’s 2026 record-low snowpack
  • Any meaningful accounting of mining water consumption

 The North evaluation acknowledges: “In general, there is adequate water to supply wild horses year-round, but drought conditions and high horse numbers can cause high numbers of horses to concentrate at a few primary water sources especially late in the summer.” That acknowledgment — drought + concentration = impact — is not followed by any analysis of whether those same sources need repair or additional sources could be created to better distribute wild horses (and perhaps analysis of fence removal to increase distribution).

The governing RMPs are outdated. The 2008 Rawlins RMP and 2014 Lander RMP did not anticipate the severity or duration of current drought conditions. Under FLPMA, an HMAP both complies with and informs a Land Use Plan — and a Land Use Plan can and must be revised when it fails to reflect current resource conditions.

Demand: The HMAP process is an opportunity to identify where the governing LUP needs updating. Advocates must demand BLM use the HMAP process as an opportunity to update and amend the RMPs, particularly when it addresses drought, water source improvements and recognition that horses are more drought-friendly than cattle.

BLM’S OWN DOCUMENTS REFUSE TO DO MULTI-USER IMPACT ANALYSIS — AND THAT IS A PROBLEM

What advocates must demand: A genuine comparative analysis of all resource uses and their cumulative impact on water.

Both the North and South Red Desert management evaluations contain a striking disclaimer that appears almost word-for-word in each document:

“It is important to note that these HMAs are not exclusively used by wild horses… blame is often attributed to the ‘other’ users. As this relates to wild horses, it is clear that wild horses are contributing to impacts on the landscape, but they are not the only contributors.”

And then:

“The purpose of this management evaluation is not to parse out impacts by resource uses.”

Read that again.

The purpose of the evaluation — the document that will inform decisions about managing and removing wild horses under “multiple use” — is explicitly not to compare the impacts of different users? BLM acknowledges multiple users. BLM acknowledges shared responsibility. And then BLM declines to measure it.

This is not neutral. When you decline to analyze all users but propose to remove one of them (to the benefit of other users), you are making a management decision without the data to support it.

The South Complex makes this even starker. The evaluation notes the complex was upgraded from Failing to meet Proper Functioning Condition (FAR) to Proper Functioning Condition (PFC) in its 2022 watershed evaluation — but the reason given is that riparian areas were fenced to exclude livestock, not that wild horse numbers were reduced. The habitat improvement came from changing how livestock interact with riparian zones. Yet the evaluation’s water stress language is directed at horses: “Large populations of wild horses often strain these key water supplies and riparian zones… many run dry during summer.”

Demand: Advocates must demand that the HMAP EA honestly account for who is using what, and what management of each user has or has not been attempted. Then the HMAP must analyze and propose range improvements to mitigate increasing drought to sustain wild horse use (just as they would for livestock).

All of this points to the need to evaluate actual carrying capacity of the range, inclusion of Arapaho and AML.

2020 release after PZP treatment

You should craft your own unique comments. 

This article is intended to give you things to think about as you write. 

You can copy/paste your choice subjects from the following and expand on each premise. Keep in mind this is not a comprehensive list. You can add any subject in scoping: fire fuels, foaling season, any relevant issue you want BLM to include in analysis in the HMAP.

Build the HMAP around clear, measurable objectives

• • Define what “thriving natural ecological balance” means here in terms of water, habitat condition, wildlife presence, and wild horse herd health.
  • Set measurable indicators (e.g., number of functioning springs, riparian condition, minimum herd size for genetics) and specific triggers for management actions such as fence removal, water improvements, livestock reduction, etc. 

Do a full multi‑user water and forage analysis

• • Quantify forage and water use for wild horses, cattle, sheep, and mining operations, using comparable units.
  • Show, in tables and maps, how much each user takes and where.
  • Tie these to triggers to limit/restrict the most water-dependent uses during drought. Prioritize drought adaptable use.

Treat the Red Desert as a real biological unit, not just a paper “complex”

• • Map and analyze horse movement, barriers (highways, fences), and connectivity between HMAs.
  • If BLM insists on “North” and “South” complexes, it must show how horses actually move (or cannot move) between them and manage accordingly.

Put Arapaho Creek and other adjacent lands on the table

• • Explicitly analyze adjacent historic horse areas (like Arapaho Creek) for habitat suitability and current use.
  • Include an alternative that restores some of these lands to wild horse management (HMA/range) as part of the long‑term solution, not just keeps them as empty “donut holes.”
  • These areas are noted when “exchange” of population is needed and ignored as when the land base to achieve that exchange is inconvenient. The HMAP must reflect reality of use and utilize authorities to create data-based boundaries.

Fix the water infrastructure

• • Inventory all springs, wells, pipelines, troughs, and tanks; document condition and who can access each.
  • Build the HMAP around repair, upgrade, and strategic removal/relocation of fences and pipelines to spread horse use and relieve pressure points.

Use the HMAP to update the RMPs, not hide behind them

• • Identify every place where the Rawlins and Lander RMPs no longer match current conditions (drought, mining, horse use, wildlife).
  • Commit to RMP amendments where needed so that the HMAP and the land use plans actually match the reality on the ground and include a fully informed section for sustained wild horse management.

You can find scoping documents and the “participate now” portal to submit your comments by clicking this text. 

We thank you for being an active advocate and standing up for Freedom, Mercy and Justice.

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.