Run again and again into a later in subfreezing winter weather during helicopter drive trapping, Eagle Complex roundup

(Videos and photos in this article are all from roundups in the Eagle Complex)

Comments are due to BLM by May 21, 2026.
Project page: BLM ePlanning — Eagle Complex HMAP

If you have followed Wild Horse Education’s work for any length of time, you already know Eagle. You know the mare run by helicopter as she was actively losing her foal. You know the foals separated from their mothers and never searched for. You know the horses run to a lather in sub-freezing temperatures. You know the helicopter contractor performance failures, year after year.

Video: viewer discretion advised, not for children

You also know that none of those incidents happened in a vacuum. They happened because BLM has never written an actual Herd Management Area Plan (HMAP) for the Eagle Complex. Instead, every few years BLM rolls out another gather Environmental Assessment (EA), removes another wave of horses, and walks away — leaving the underlying land-use issues (livestock, water, fences, fire, recreation) untouched.

That cycle is what an HMAP is supposed to fix.

Eagle, subfreezing and run back and forth and back and forth into a lather. Two helicopters and multiple roping teams were pushing multiple groups all over the valley.

BLM has now opened scoping for an Eagle Complex HMAP. Scoping is the front-door public input stage — before BLM picks an alternative, before BLM writes a draft EA or EIS. What goes into the record now shapes everything that comes after. And BLM has already signaled, in its own April 2026 Management Evaluation Report, that it intends to repeat the same templated, gather-driven approach it just used at Silver King, Callaghan, Antelope and Triple B.

We cannot let that happen at Eagle.

The Eagle Complex sits on the Nevada–Utah border and is made up of three Herd Management Areas (HMAs):

A few things you should know about those numbers:

• AML for Eagle was “reaffirmed” (or retyped) in the 2008 Ely Resource Management Plan, by combining the former Wilson Creek and Deer Lodge Canyon HMAs with no disclosure on how those numbers were set in any document.
• AML for Choke Cherry and Mt. Elinor was set in 1983, based on horse counts from 1971–1982. It has never been revised and methodology never disclosed.
• BLM estimates the current Complex population at roughly 2,093 wild horses without any census maps or raw data. BLM is using the same method where an overcount has come to light in our legal action at Desatoya.
• The Eagle Complex is dominated by the Wilson Creek livestock grazing allotment — Wilson Creek alone overlaps 47% of the Eagle HMA, with 54,070 permitted livestock AUMs. The Wilson Creek grazing decisions are currently the subject of administrative and judicial review, and portions remain stayed pending Administrative Law Judge action. WHE is a party along with our partner at WildLands Defense.

In other words: BLM is trying to write a 10-year management plan for wild horses on top of grazing decisions that are still being litigated. That alone should give every member of the public pause.

All signals point to the fact that this will just be a gather plan with a different name. This should solidify the “pause” and you should be ready to take action.

BLM repeatedly tries to represent livestock as “not out all year” and that is somehow why wild horses are responsible for all damage. Chart showing that most of the livestock is in fact out all year, or out during the most fragile times of the year for range (growing season for plants).

Chart below shows forage allocation and the “low AML” goal BLM says is “fair multiple use” that will be written into the draft plan with zero disclosure in how this allocation was made and zero analysis of current data. Please note that the chart does not include the Wilson Creek (9 different grazing allotments spanning the Eagle Complex and Silver King across the highway) that creates more AUMs for livestock.

BLM’s April 2026 Management Evaluation Report:

• Frames wild horses as the singular cause of rangeland damage without any proof. 
• Repeats the demonstrably wrong claim that “changes to livestock grazing cannot be made with a wild horse management decision,”
• Invokes the 2025 Greater Sage-Grouse Plan as a lever to drop wild horse AML if horse use is identified as a “significant causal factor” after giving more grazing and fencing to livestock.
• Relies on 2017 Wilson Creek rangeland health determinations that BLM itself attributes to a combination of livestock, wild horses, elk, drought, pinyon-juniper encroachment, halogeton, and fire — not horses alone.

This is the moment to put BLM on notice. A different title on the same gather plan does not make it right.

How to write a strong scoping comment

Scoping comments are about issues — not policy preferences. You are telling BLM what it must analyze. The stronger your comment is on specific, on-the-ground issues, the more weight it carries in the administrative and judicial record.

A few tips before you write:

1. Be specific. “Save the horses” is heartfelt but does not enter the analysis record in any meaningful way. “BLM must analyze the impact of Wilson Creek livestock allocations on wild horse forage and water” does.
2. Cite BLM’s own document where you can. When BLM’s Management Evaluation Report says wild horse dispersal happens because horses are searching for forage and water, point that out — that is BLM’s own admission yet they fail to provide any specific information about where, when and if new fencing is involved.
3. Identify what must be analyzed, not just what conclusion you want. NEPA is about disclosure and analysis. A comment that says “BLM has not analyzed X” is more powerful than “I do not agree with X.”
4. Personal observation matters. If you have visited the Eagle Complex, attended a gather, photographed water sources or fence lines, or witnessed welfare incidents, say so in your own words. Personal observations of named locations and named conditions go into the record.
5. Submit on time. Comments must be received by May 21, 2026.
6. Use your own voice. Copy-and-paste comments are counted but carry less weight than individually written comments. Use the sample below as a starting point and rewrite it in your own words.

Sample comment letter — adapt this in your own words

You can copy the text below as a starting point, but please change the wording, add your own observations, and explain why this matters to you personally. BLM is required to consider individual comments more carefully than identical form letters.

To: Bureau of Land Management, Caliente Field Office
Attn: Tyler Reese, Wild Horse and Burro Specialist
Re: Scoping Comments — Eagle Complex Herd Management Area Plan
Project page: BLM ePlanning — Eagle Complex HMAP

Dear BLM Caliente Field Office,

I am submitting scoping comments on the Eagle Complex Herd Management Area Plan (HMAP), covering the Eagle, Choke Cherry, and Mt. Elinor HMAs (approximately 760,779 acres). I am asking BLM to prepare a real HMAP — not another gather Environmental Assessment with HMAP language placed in a generic appendix.

1. Write a real HMAP, not a repackaged gather plan.
The Silver King, Callaghan, Antelope and Triple B, etc., “HMAPs” issued earlier this year are essentially gather EAs with a templated appendix. The language is so generic the project names can almost be swapped between them. BLM Handbook H-4700-1 requires HMAPs to address site-specific herd and habitat management — including forage, water, cover, space, and reproductive viability. I am asking BLM to put real, site-specific Eagle Complex content in the body of the HMAP, not in a one-page summary that points to an appendix.

2. Disclose the Wilson Creek livestock situation.
BLM’s own Management Evaluation Report shows the Wilson Creek allotment overlaps 47% of the Eagle HMA with 54,070 permitted livestock AUMs. The December 2020 Wilson Creek term permit renewal decisions are under administrative review, and portions are stayed pending Administrative Law Judge action. BLM cannot build a 10-year wild horse plan on top of grazing decisions that are still being litigated (in part because the grazing decisions do not mitigate impacts to wild horses because BLM failed to prepare an HMAP). The HMAP must disclose the litigation status, the suspended and non-use AUMs on every overlapping allotment, and whether any of those AUMs are being reactivated through BLM’s new “grazing flexibility” policy (IM 2025-011) and where new fencing is being placed.

3. Conduct a current AML analysis.
Eagle HMA’s AML of 100–210 was “affirmed” (retyped) in 2008. Choke Cherry and Mt. Elinor AMLs were set in 1983 based on 1971–1982 horse counts. BLM cannot lawfully carry forward AMLs that old into a new 10-year plan without a current, site-specific analysis under H-4700-1. The HMAP must show how AML was calculated in the first place, what share of forage and how it is allocated to livestock, wildlife, and wild horses, and whether the allocation still makes sense under current drought, fire history, and grazing conditions.

4. Do a real water inventory.
BLM must inventory and analyze every named water source — including Brown Spring, Lion Spring, Mud Spring, Tobe Spring, Kiln Spring, Buster Spring, and the Spring Valley riparian area on the Eagle HMA; Mud Spring, Log Cabin Spring, Rock Spring, and Rice Canyon Springs on Choke Cherry; and Paradise, Sawmill, and Gold Springs on Mt. Elinor. The HMAP must disclose which water sources are seasonal, which are fenced, which are privately controlled, which are inaccessible to wild horses, and where repairs, exclosures, or new developments are needed.

5. Analyze livestock closures and fence removal as HMAP tools.
Federal regulations at 43 CFR 4710.5 and 4710.6 allow BLM to close public lands to livestock — temporarily or permanently — when needed to provide habitat for wild horses, implement herd management actions, or protect wild horses from harassment or injury. BLM must analyze these tools in the HMAP, not declare them “outside the scope.” The HMAP must also map every fence, cattle guard, and exclosure that fragments wild horse habitat or restricts access to water, and identify which structures must be removed or modified.

6. Stop saying an HMAP cannot amend the LUP/RMP.
BLM’s own Handbook H-4700-1 says the opposite. HMAPs must conform to the applicable Land Use Plan, and if the HMAP’s management needs conflict with the LUP, BLM must amend the LUP, modify the proposal, or reject the proposal. BLM must correct this language in the scoping record now, before drafting an EA or EIS.

7. Do not use the sage-grouse plan as a pretext to drop wild horse AML.
The 2025 Greater Sage-Grouse Rangewide Plan allows BLM to evaluate and adjust AML where wild horse use is a “significant causal factor” in not meeting habitat objectives. BLM’s own 2017 rangeland health determinations for the Wilson Creek allotment repeatedly identify livestock, elk, drought, pinyon-juniper encroachment, halogeton, and historic wildfire as causal factors — alongside wild horses. BLM cannot lawfully target wild horses while ignoring those other causes. A full analysis must be provided.

8. Conduct a site-specific welfare analysis.
The Eagle Complex has a documented history of severe welfare incidents during helicopter operations, including a mare run as she was actively losing her foal, foals separated from their bands and never recovered, and horses run to exhaustion in sub-freezing temperatures. BLM cannot rely on the Comprehensive Animal Welfare Program (CAWP) — which is policy, not a formalized rule, and whose on-range standards remain under development — or on the annual Motorized Vehicle Public Hearing, which produces no analytic document, to substitute for a real welfare analysis. The HMAP must include site-specific welfare prescriptions for the Eagle Complex, including a documented foaling window, temperature thresholds, and a public incident reporting process.

9. Prepare an EIS, not an EA.
The Eagle Complex covers 760,779 acres across two states, three HMAs, multiple stayed and contested grazing decisions, the 2025 sage-grouse overlay, documented welfare incidents, and a complex cross-state movement pattern. The lawful NEPA vehicle is an Environmental Impact Statement.

10. Separate the gather decision from the HMAP decision.
Any gather/removal decision must be a separate decision record from the HMAP adoption, with separate appeal rights and implementation timing. BLM should not implement an HMAP while appeals are pending.

Thank you for considering these comments.

Sincerely,
[Your name]
[City, State]

How to submit your comment

Comments must be received by May 21, 2026.

You have three options. Pick whichever is easiest for you.

Option 1 — Submit online (preferred by BLM):
Go to the project page and click “Participate Now”:
https://eplanning.blm.gov/Project-Home/?id=D55B594A-E02E-F111-8342-001DD803D7D3

Option 2 — Mail or hand-deliver:
BLM Caliente Field Office
Attn: Tyler Reese — Eagle Complex HMAP Scoping
1400 Front Street
Caliente, NV 89008

A few practical notes:

• Include your name and city/state. Anonymous comments may be discounted.
• Send one comment, not multiple copies. Sending the same comment to multiple BLM offices does not increase its weight.
• Submit before the deadline. Comments received after May 21, 2026 are not part of the scoping record.
• Keep a copy. Save what you submit. If BLM later issues a draft EA or EIS, your scoping comment is your foundation for further comment and, if necessary, administrative protest or litigation.

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Above: Just as the sun began to rise in 9 degree weather the ice on the panels that horses that had been run so hard they were soaking wet were kept in overnight.

What WHE is doing

Wild Horse Education has already filed detailed scoping comments — citing BLM’s own handbook, its own Management Evaluation Report, the Wilson Creek litigation posture, and the welfare record at Eagle. We are also notifying the court hearing the Wilson Creek matter that BLM is now belatedly trying to do HMAP planning on top of the contested grazing decisions — so the court can consider whether remand of the Wilson Creek decision is appropriate.

The strongest record is built by a lot of voices asking BLM to do this right the first time. Please take ten minutes, write your comment in your own words, and submit it before May 21.

The horses at Eagle have paid the price for a decade of paper plans and templated gathers.

This is the moment to ask BLM to write a real management plan. 

Thank you for being an active advocate!

— Wild Horse Education

P.S. We will be publishing comments on the draft for Silver King that sits across the highway from Eagle shortly.

We need your support to keep our teams engaging lawmakers, our team fighting in the court, our team ready to run the roundup schedule. 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.

WHE also has new shirts available. As foaling season hits the western landscape we designed two new shirts based on a mother’s love. Just click the images if you want to order one. All proceeds support the work of WHE.