Since that time many of you have commented and urged others to comment. Livestock interests are using this to push for a national “get to AML and fertility control” through outlets like Western Ag Network.
It is important to remember that many states, counties and livestock groups tried to litigate “programmatically” and lost (like the NACO suit WHE Intervened because programmatic challenges are not allowed. This PEA opens a door once sealed shut. Many of you remember they then joined the Ten Year to AML (later Path Forward) push that has led to the largest roundups since the passage of the Wild Horse and Burro Act with a the “backdoor to slaughter” push through incentivized adoptions (now defunct) and the Sale Program to facilitate large scale removals. All of that happening as BLM continues to refuse to do real site-specific management planning and is engaging in a constantly changing avoidance approach as WHE continues to litigate.
This PEA is an attempt to make a runaround to achieve those goals faster by avoiding the exact site-specific analysis required by law that creates the framework for courtroom challenges.
Deadline: July 2, 2026, 11:59 p.m. Pacific
HOW to comment:
- Online (BLM preferred method): BLM ePlanning project pageHit the “Participate Now” dark button near the top of the page (BLM’s new interface is absolutely no user intuitive).
- Email: BLM_HQ_260_WHB-PEA@blm.gov
- Mail: Bill Parks, WHB Information Specialist, BLM Oklahoma Field Office, 201 Stephenson Parkway, Suite 1200, Norman, OK 73072
This is NOT a draft plan. The document on the BLM page is a “Scoping document.” Scoping sets the boundaries of the entire analysis. Scoping begins the road where we can hold BLM accountable for later — in the draft comment period, and in court.
- Scoping (RIGHT NOW — closes July 2). Public tells BLM what to study. ← You are here.
- BLM writes a draft PEA. It may fold in scoping comments or add alternatives (or completely ignore comments as the outcome is likely predetermined)
- Public comment period on the DRAFT PEA. This is a separate, future comment window — a different article, a different deadline.
- Final PEA. BLM responds to substantive comments and finalizes.
- Site-specific decisions “tier” off the final PEA. Future roundup EAs borrow from it
However, the Final PEA will be a battleground where organizations like WHE step back into a courtroom for another 3-way fight between BLM, livestock and advocacy. It is highly likely that will be where this leads.
Stripped of the acronyms and complexity, here is what BLM is actually proposing:
- A single, national Programmatic Environmental Assessment (PEA) that studies the effects of the population-reduction tools BLM already uses: gathers, removals, and population growth suppression (fertility control vaccines, gelding of males, and sex-ratio manipulation) and do not forget that BLM is already trying to approve plans that spay mares, glue oviducts closed and more experimental and dangerous ideas.
- Its stated purpose is to lower populations “to the lower thresholds of the established appropriate management level (AML) ranges” — reaching low AML across the herd management areas and herd areas (0 horses or burros).
- BLM says the PEA “would not authorize any on-the-ground activities.” Instead, future local roundup decisions would “tier” off it — using the national findings so the local review can be shorter. (creating shorthand that would skirt site-specific analysis currently required by law).
BLM has put only three preliminary alternatives on the table:
- Alternative A — No Action: essentially leave herds unmanaged except for emergency gathers.
- Alternative B — Proposed: gather and remove to low AML, then apply fertility control, gelding, and sex-ratio adjustment. (This is BLM’s preferred path.)
- Alternative C — Gate-cut gathers: remove animals up to a set number without regard to age, sex, color, or conformation (which is basically just a roundup with no fertility control. because roundups are the primary way BLM applies fertility control and the only time they do a release)
❌ This is NOT the CAWP welfare standards
The Comprehensive Animal Welfare Program — BLM’s still-unfinalized humane-handling standards — is not formalized by this PEA. This document does not put the draft welfare standards out for comment and does not make them enforceable. Our concern remains that BLM will gesture at “approved standards” in a national document as if they were binding, when they are not. That fight continues separately, and we are not letting it go.
To learn more you can read our June 3rd article HERE.
To participate in scoping:
- Online (BLM preferred method): BLM ePlanning project pageHit the “Participate Now” dark button near the top of the page (BLM’s new interface is absolutely no user intuitive).
- Email: BLM_HQ_260_WHB-PEA@blm.gov
- Mail: Bill Parks, WHB Information Specialist, BLM Oklahoma Field Office, 201 Stephenson Parkway, Suite 1200, Norman, OK 73072
Every court case we bring, every mile we travel to cover roundups or assess a herd, every win, every action we take is only possible because of your support.
Our deepest gratitude for helping to keep the fight moving forward.