The Bureau of Land Management (BLM) is taking public comments on the “Silver King Wild Horse Gather and Herd Management Area Plan” Preliminary Environmental Assessment (EA), NEPA No. DOI-BLM-NV-L030-2025-0011-EA.

The comment deadline is May 29, 2026.

To review the documents and submit comments online, go to the BLM NEPA project page for Silver King: Project Home Page – BLM National NEPA Register. Use the project page to review the Preliminary EA and submit comments electronically, and include the NEPA number DOI-BLM-NV-L030-2025-0011-EA in your submission.

What and where is Silver King?

The Silver King Herd Management Area is in eastern Nevada, in Lincoln County, about 60 miles south of Ely and roughly 20 miles northwest of Caliente. It covers about 575,000 acres of mostly public land managed by the Bureau of Land Management (BLM).

This is classic Great Basin high desert: sagebrush, pinyon‑juniper, steep canyons, and scarce water sources that both wild horses and wildlife depend on. The area is also heavily used for private livestock grazing, off‑road races and ATV recreation, and is under growing pressure from energy and other development.

BLM has set the “Appropriate Management Level” (AML) for Silver King at just 60–128 wild horses on those hundreds of thousands of acres. As of March 2026, BLM estimates there are about 595 wild horses in the area, and it is proposing a long‑term plan that would authorize repeated helicopter roundups and removals to drive the population back down to AML.

Silver King also has special importance in the history of public access and accountability. Our litigation arising from the 2010 Silver King roundup helped establish a landmark First Amendment precedent recognizing public and press access to observe wild horse gathers. Laura Leigh, founder of Wild Horse Education, played the central role in that legal fight, and the case continues to shape access to gathers, facilities, records nationwide and has been held as a press-freedoms gold standards case far from wild horses and burros.

Exercising your rights and peaking out for Silver King is important.

Silver King

Today, BLM is presenting one combined document as both a long‑term Herd Management Area Plan (HMAP) and a gather‑and‑removal Environmental Assessment (EA) for Silver King. We are concerned that the document still functions as a roundup EA, while the supposed long‑term management plan is pushed into a short, generic appendix that could almost be swapped with another HMA. (We just published comments for scoping for Eagle across the highway from Silver King, due May 21)

A real Herd Management Area Plan is supposed to be about the long-term goal for the herd and its habitat, not just how many horses BLM wants to remove right now. That means an HMAP must analyze how forage and water are allocated on the range, including livestock AUMs, wild horse use, and livestock season of use across the allotments that overlap the HMA. The “gather plan” that takes up all the space in the EA is about a removal. The HMAP (lumped into an Appendix with zero site-specific analysis) is supposed to determine what factors would trigger a removal analysis, like: how was AML set and is it actually appropriate?

The approach BLM is taking is backwards.  The HMAP needs to be the baseline document and any gather, if actually proven to be necessary, should be a shorter document tiering to the actual data-analysis in the HMAP.

Things like season of use for livestock is extremely relevant. If seasons and numbers of livestock turnout interfere with protecting wild horses the regulations do call for restricting livestock use. An HMAP is where that discussion would take place. If it is shown that any livestock restriction is needed, the HMAP can create a land use plan amendment (even though BLM is contradicting current guidance claiming it does not).

Livestock is out all year in Silver King (BLM likes to pretend that only wild horses/burros are on the range all year. Livestock is too.)

An HMAP is supposed to analyze the goal of any removal. Here the goal is to achieve 62x’s the forage for livestock than for wild horses.

The Wilson Creek grazing decision (9 allotments) authorizes even more AUMs for livestock and additional fencing. The draft EA includes data from 2017, before the grazing decision (which is in active appeal).

Sample comment letter — adapt this in your own words

To: Bureau of Land Management, Caliente Field Office
Re: Silver King Wild Horse Gather and Herd Management Area Plan Preliminary Environmental Assessment, DOI-BLM-NV-L030-2025-0011-EA
Deadline: May 29, 2026

I submit this comment in opposition to the Silver King Wild Horse Gather and Herd Management Area Plan Preliminary Environmental Assessment. The draft does not disclose or analyze a lawful, site-specific Herd Management Area Plan for Silver King; instead, it repackages a gather-and-removal plan as an HMAP by attaching generic planning language in Appendix XII while the body of the document remains organized around immediate removal, fertility control, sex-ratio manipulation, and repeated gathers to drive the herd to AML.

This distinction matters. An HMAP is supposed to establish the long-term objectives and management framework for the herd and its habitat, not merely justify removal to a previously asserted number. Here, BLM has not produced a real management plan for Silver King. It has produced a recycled gather EA that relies on an AML range of 60 to 128 horses repeated from earlier decisions without the current, in-depth, site-specific evaluation that BLM’s own handbook requires for a lawful HMAP or AML review.

The record described in the draft shows no current HMAP-level analysis of forage, water, cover, and space; no site-specific inventory of springs, pipelines, troughs, fences, cattle guards, barriers, or movement corridors; no meaningful analysis of drought and current land-health conditions; no analysis of whether existing livestock allocations and seasons of use are compatible with wild horse habitat needs; and no real plan to protect the Silver King herd over time. BLM cannot call this a management plan when the actual planning work has not been done.

The agency is also wrong to suggest that an HMAP cannot create a change in an LUP or RMP. BLM’s own handbook, as quoted and analyzed in the submitted record, states that HMAPs must conform to the applicable land use plan and that if the proposed management strategy is inconsistent with the LUP, the LUP should be amended, or the proposal modified or rejected. In other words, an HMAP may require an amendment or revision when the existing land-use framework does not provide what is necessary to manage and protect the herd and its habitat. The draft’s contrary framing is a legal error that infects the alternatives analysis and improperly excludes livestock closures, forage reallocations, habitat protections, and other necessary management tools from meaningful review.

More broadly, the draft keeps wild horses as a minute, constrained use within their own designated range rather than asking the planning question the law requires: what management framework is necessary to preserve and protect wild horses in the area designated for them? The proposal begins from removal to a very low number and works backward, instead of analyzing what habitat protections, livestock restrictions, fencing changes, water protections, route restrictions, and land-use changes are necessary to maintain a healthy, self-sustaining Silver King herd on its range. That is backward planning, and it does not satisfy NEPA, FLPMA conformance requirements, 43 CFR Part 4700, or BLM’s own H-4700-1 handbook as described in the record.

For these reasons, BLM should withdraw or substantially revise and recirculate this draft before issuing any decision. At minimum, BLM should:

1. Separate the HMAP decision from any immediate gather/removal decision, including separate analysis, findings, implementation language, and appeal treatment.

2. Prepare a true, site-specific HMAP in the body of the NEPA document, not a generic appendix, addressing herd objectives, habitat objectives, monitoring, adaptive management triggers, and specific implementation measures.

3. Conduct and disclose a current AML evaluation based on present conditions and site-specific data rather than simply repeating the 60-128 figure from prior planning documents.

4. Analyze forage allocation, water, cover, space, livestock AUMs, and year-round livestock seasons of use as central HMAP issues.

5. Analyze and disclose the use of 43 CFR 4710.5 and 4710.6 tools, including temporary or permanent livestock closures, seasonal restrictions, water-source protections, and removal triggers for unauthorized livestock where needed to protect horses and habitat.

6. Correct the erroneous statement that an HMAP cannot trigger an LUP/RMP amendment and instead disclose that amendment or revision may be required where the HMAP’s management needs conflict with the existing plan.

7. Fully analyze off-road races and motorized recreation as direct HMAP issues, including route maps, seasonal timing, closure triggers, restrictions, and protections for foaling, water, movement corridors, and anti-harassment enforcement.

8. Supplement the record to disclose and analyze the Wilson Creek grazing situation and its effect on assumptions, habitat conditions, and cumulative impacts within the HMA.

BLM should withdraw and recraft the Silver King draft because it is not a true HMAP at all, but a recycled gather plan built around removal to an unevaluated AML, while failing to analyze livestock AUMs, year-round livestock season of use, forage and water allocation, the regulatory tools for livestock restriction under 43 CFR 4710.5 and 4710.6, the need for LUP/RMP amendment, the impacts of expanding off-road racing, and the site-specific habitat measures necessary to actually protect wild horses on their designated range.

To submit comments online, go to the BLM NEPA project page for Silver King: Project Home Page – BLM National NEPA Register. Use the project page to review the Preliminary EA and submit comments electronically, and include the NEPA number DOI-BLM-NV-L030-2025-0011-EA in your submission.

Written comments may be emailed to BLM_NV_EYDO_SilverKingHMA_HMAP@blm.gov (preferred); or delivered to the BLM Caliente Field Office, Attn: Tyler Reese, 1400 Front Street, PO Box 237, Caliente, NV 89008. The comment period will close May 29, 2026.

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 Silver King. 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 29.

The horses at Silver King need your voice.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 just published comments on the Scoping for the Eagle Complex that sits across the highway from Silver King. Those comments are due May 21. Learn more and participate HERE.

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.