Wild Horse Education

National EA on Roundups (comment deadline: July 2)

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The strongest record we can build starts with you, right now, in this comment period.

How to comment (Deadline: July 2, 2026, 11:59 p.m. Pacific)

BLM asks that comments include your name and address, your organization (if any), the document title, and specific facts and reasons. Personal, specific comments carry far more weight than form letters — so please put the sample below in your own words.

CLICK HERE FOR SAMPLE COMMENTS or just SIGN ON and we will submit a single comment sheet that includes all signees. 

BLM’s National “Gather Plan”: What It Really Is, and Why We’re Ready to Fight It

The Bureau of Land Management (BLM) has opened a public comment period on a national-level document that could reshape how every wild horse and burro roundup in the country is approved.

It is wrapped in the language of “efficiency” and “consistency.” But from where we sit — after years of litigation that forced BLM to the table again and again — this looks like something very different.

We believe this is BLM building a shortcut: a way to approve roundups without ever doing the honest, on-the-ground, data-driven analysis the law requires.

We are not going to let that happen quietly. Comments are due Thursday, July 2, 2026, at 11:59 p.m. Pacific Time. You can find the document HERE.

Below is what this is, what it isn’t, and exactly how you can help.

Hotshot (electric prod) still being used to speed up loading

What BLM says it’s doing

BLM wants to write a Programmatic Environmental Assessment — a “PEA.” In plain terms, it is one big national study of the effects of the tools BLM already uses to reduce herds: roundups (gathers), removals, and fertility control like vaccines, gelding, and sex-ratio manipulation. (Yes, usually when you see the acronym “PEA” it stands for Preliminary Environmental Assessment, this one is different.)

BLM says this national PEA “would not authorize any on-the-ground activities.” Instead, future local roundup decisions would “tier” off it — borrowing the national findings so the local review can be shorter.

That is the part that should concern every person who cares about these animals.

What we believe is really happening

In 2023, Congress imposed new page limits on environmental documents: just 75 pages for an Environmental Assessment, and 150 pages for the more rigorous Environmental Impact Statement (Bipartisan Policy Center; ICF).

Here is the maneuver we are watching unfold. By pre-loading the effects analysis into one national document, BLM sets itself up so that a future roundup decision can be crammed into a thin EA — we have seen them attempt to fold an entire Herd Management Area Plan and a gather decision into roughly 58 pages  — instead of doing the full Environmental Impact Statement a program of this magnitude demands. (WHE carries several court cases that include this very issue: a short-changed and inadequate gather EA instead of using an EIS. track).

Picture what a future “gather EA” would then look like: a claim of overpopulation, a reference to a national set of “approved gather methods and standards,” and a signature approving removal. No fresh look at the actual herd. No current data. No honest accounting of the boundary or the science. No actual in-depth Herd Management Area Plan (HMAP) that would make up the gap (and why we are fighting so hard in court on HMAPs, right now.)

That is not a “hard look.” That is a rubber stamp.

Smoke so thick it is hard to see while BLM has no Air Quality standards.

What BLM’s own rules require — and what this PEA tries to skip

This is the heart of it. BLM’s own Wild Horses and Burros Management Handbook (H-4700-1) is crystal clear about what must happen before a roundup. A national effects study cannot substitute for any of it:

  • AML must be based on real data. Establishing or adjusting an Appropriate Management Level requires “an interdisciplinary and site-specific environmental analysis and decision process (NEPA) with public involvement,” including “an in-depth evaluation of intensive monitoring data” — grazing use, range condition and trend, actual use, and climate data, with “a minimum of three to five years of data” preferred (BLM Handbook H-4700-1, §4.2.2).
  • Excess must be proven before removal. Before any gather, the officer “shall first determine whether excess WH&B are present” by analyzing grazing utilization, range trend, actual use, climate data, and current population inventory (H-4700-1, §4.3).
  • Herd Management Area Plans matter. HMAPs, prepared under 43 CFR 4710.3-1, set the actual herd and habitat objectives — and they require their own site-specific NEPA process with public involvement (H-4700-1, §2.5.2; Wild Horse Education, “What is an HMAP?”).

And here is the uncomfortable truth BLM does not want in the spotlight: the majority of AMLs and HMA boundaries in this country were set through old agreements, not through the monitoring data the handbook requires (Wild Horse Education, “Bottom Line: AML”).

A national PEA risks laundering those stale, undocumented numbers forward — using them as the basis for removals without ever disclosing the data and methods behind them, because there often isn’t any. (However, to play “Devil’s Advocate,” if BLM tries to claim the “tools” are all approved at the national level it will be really hard for them to skirt continuing to avoid these subjects in any gather plan moving forward (in front of any judge in the country).

The question we know you’ll ask: “Is this the CAWP welfare standards?”

No. And that distinction matters.

CAWP — the Comprehensive Animal Welfare Program — is supposed to be BLM’s binding, enforceable set of humane-handling standards for gathers, transport, and holding (BLM CAWP page). But the gather standards have never been formalized. They were issued as drafts in 2015 under litigation pressure, and BLM promised to review them, revise them with veterinary science, put them out for public comment, and finalize them as enforceable rules.

That never happened. FOIA records confirm BLM formally adopted only the CAWP cover memo (Instruction Memorandum 2021-002), while the actual welfare standards remain unreviewed, non-binding internal guidance (Wild Horse Education; WHE FY2027 Appropriations Request).

This PEA does not formalize CAWP. It does not put the draft welfare standards out for public comment, and it does not make them enforceable.

Our concern: BLM will gesture at “approved standards” in this national document as if they were binding law, when they are nothing of the kind. BLM will use this national PEA to make a claim that “everything is approved at the national level” and pass the buck again.

The fight to formalize real, enforceable welfare standards continues separately, and we are not letting it go.

Moving so fast to “get numbers,” trailer doors were not secured

An open question: Will there be a public scoping meeting?

Every national-level planning effort we are aware of has included a public scoping meeting — a session where BLM explains the purpose and need and answers the public’s questions directly. This scoping notice announces no such meeting.

Wild Horse Education has contacted BLM to ask whether a public scoping meeting will be held. We believe one is essential given the national scope and the stakes. We will update you the moment we hear back.

Where we stand, right now

What could be challenged about the national PEA itself.

A programmatic document is not immune from court review.

If BLM finalizes this PEA as an Environmental Assessment for a program of this magnitude — tens of thousands of animals across 175 HMAs and 25.6 million acres — that choice itself is directly litigable: a “Finding of No Significant Impact” for a removal program this large can be challenged as the wrong call, with the law requiring a full Environmental Impact Statement instead.

The PEA can also be attacked for an unreasonably narrow range of alternatives (omitting a genuine minimal-removal or livestock-allocation alternative), for a purpose-and-need statement so narrowly drawn that it predetermines the outcome, and for failing to take a “hard look” at cumulative effects — including the role of permitted livestock — before concluding wild horses are the cause of range degradation. And because the PEA expressly invites future gather decisions to “tier” off it, any defect baked into the national document becomes a defect carried into every roundup built on top of it.

WHE is ready to take this challenge on and have already sent this on to attorneys to put on the pile of potential litigation.

RIGHT NOW the strongest record we can build starts with you, right now, in this comment period.

How to comment (Deadline: July 2, 2026, 11:59 p.m. Pacific)

BLM asks that comments include your name and address, your organization (if any), the document title, and specific facts and reasons. Personal, specific comments carry far more weight than form letters — so please put the sample below in your own words.

CLICK HERE FOR SAMPLE COMMENTS or just SIGN ON and we will submit a single comment sheet that includes all signees. 

WHE will do extensive comments to set up further action.

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. 

Categories: Wild Horse Education