We have always known that this case is going to be a hard one to explain to the public.

The history of Callaghan is long and includes a U.N. judgement, a massacre of hundreds of wild horses, the oldest land use plan in the country, a protest camp by livestock, and a district famous for kicking things down the road. The HMAs in Callaghan are all very distinct pieces of a story that reads like an entire Ken Burns style documentary on the history of the West. 

As with most large HMAs and complexes the public seems to only focus on them when the helicopter flies. The HMAs in the Callaghan Complex are now center stage.

We are going to start a series of articles on Callaghan, the MAs, the issues and more. There are a lot of unexplained issues in Callaghan. BLM does not address any of it. So we will.

From AML to boundary lines and so many things in between, the Callaghan Complex is an important story to know and an important fight to fight.

Let’s start with a few numbers. (The next article will talk about the lawsuit and motions.)

BLM is refusing to release any HMA-by-HMA breakdown regarding removal numbers for the upcoming roundup. BLM is absurdly saying they are “leaving it to the contractor.” Let’s take a look at the numbers and why this is really important to know before we get more in-depth. 

So many of you are asking about “the numbers.” 

The Bureau of Land Management wants the public to trust how it manages the Callaghan Complex — 1.1 million acres across the Bald Mountain, Callaghan, and South Shoshone Herd Management Areas. Trust them concerning areas they “designated” and all the acreage in between. That means trusting its numbers.

So let’s look at the numbers. Not ours. Theirs. Every figure. used below comes straight from BLM’s own 2025 Callaghan Complex Management Evaluation Report.

Charted year over year, those numbers don’t behave like a wild horse population.

They behave like a number being adjusted — by shifting survey methods, by removals BLM won’t claim, perhaps some really shady goings on, and by pressures on the range BLM refuses to study.

We’re not asking you to take our word for it. We’re asking BLM to explain its own data.

After a 2013 National Academy of Sciences review found BLM’s old aerial counts missed up to a third of horses, BLM started correcting its counts upward in 2014. That’s why the early years appear to explode: South Shoshone jumps 114% from 2009 to 2010, Callaghan 68%. Those aren’t real foaling rates — wild herds grow about 7–20% (after a large scale roundup) a year. The method changed by adding padding, not the population.

Fine. Raw counts do miss animals.

But here’s the problem: if you inflate the population count with a correction factor, you have to apply that same factor to the Appropriate Management Level (AML) — the target BLM manages down to. This is Algebra 101, not complicated. But BLM didn’t do it. 

So every “horses over AML”  is measured against an obsolete baseline. That’s not science. That’s a thumb on the scale to achieve one goal: remove as many wild horses as you can get away with. 

Drops BLM won’t explain

• 2015–2016, Callaghan: −17% (512 to 425). No documented gather that year. This is when the neighboring Dann ranch horses were rounded up — and BLM insisted it took no BLM horses. Its own data says otherwise. What removes that many horses that do not show up in counts elsewhere? It was either an illegal removal or another massacre.
• 2024, west side: Bald Mountain −78% (940 to 205) and Callaghan −31% (1,147 to 787) in a single year — with no authorized gather of any size and no operative environmental assessment. Where did roughly 1,100 horses go?

• BLM’s own files admit the unexplained losses — and the airplanes

  This is not the first time the numbers in this complex did not add up, and BLM has known it for decades. Its own decision documents for the 2008 South Shoshone removal — the only roundup in that HMA since the 1971 Act — contain admissions BLM has never reconciled with its current management (Wild Horse Education, South Shoshone HMA Report, 2015):

  • BLM wrote that “the Bald Mountain and South Shoshone HMAs are the only HMAs in the Shoshone-Eureka Planning area that exhibit a low or negative growth rate that cannot be explained by gather activities, fertility control or inherent movement patterns.” In other words, BLM itself documented that horses were disappearing from these exact HMAs for reasons it could not account for.
  • BLM acknowledged “anonymous reports… of airplanes herding wild horses in the Bald Mountain and South Shoshone HMAs,” and stated “it is possible that wild horses are being shot or killed by other human means, although carcasses have not been discovered.” (Carcasses were discovered and BLM employees know where the pits are.)
  • The historical record is grim: dead horses determined to have been shot were found in Bald Mountain as early as 1980; between 1987 and 1989 over 500 carcasses were documented in Lander County, “no less than 266” of them in Bald Mountain and 7 in South Shoshone, with veterinarians concluding most “died from gun shot wounds” — and the cases were dismissed for insufficient evidence (Wild Horse Education, 2015).

BLM has known these numbers don’t add up for decades. BLM refuses to look at it and calls any comment referencing these truly disturbing facts “outside the scope” of the plan they assert gives them the authority to use radically unexplained counting methods to set a roundup target. (They were going to fix it in the 2012 Land Use Plan update and stopped. Then they were going to fix it in 2016 with HMA-specific HMAPs and stopped.)

Its own 2008 decision documents called Bald Mountain and South Shoshone the only HMAs with negative growth “that cannot be explained,” and noted anonymous reports of aircraft herding horses and suspected shootings. There is also significant predation (lions) BLM refuses to look at. It never resolved any of it.

A range being carved up

There has since been a Dann land change and directives to fast-track mining; mine expansion has exploded around this complex.

In the same period, BLM’s estimates don’t trend — they lurch, swinging 40–50% up and down year to year with no gathers to explain it. Bald Mountain even shows a string of suspiciously identical +19% years — the signature of a number calculated by assumption, not counted. The likely causes: broken detection math, horses moving across HMA lines under mining pressure and being counted as births and deaths, or mining impacts BLM simply refuses to study.

You can’t manage what you won’t measure. We asked BLM to take a hard look. It declined.

Below: If the charts above do not show things clearly for you, these charts outline percentages up and down.

Note from Leigh:

I have been monitoring the area a very long time and even volunteered inside this BLM office to address the shortage of personnel and organizing records and doing range monitoring.

When I monitored South Shoshone in 2015, as an example, forage and water were available throughout the HMA and the horses I saw were in good body condition — yet “some areas of historic use were showing little to no sign of wild horses” (Wild Horse Education, 2015). Horses were not leaving because the range failed them. They were gone for reasons the range cannot explain.

So when I point at unexplained drops in BLM’s population line, I am not speculating. I am repeating a concern BLM put in its own files — and never resolved. (In the court filings I explain a lot more, with more to come. BLM has not denied anything I have said. We will cover these issues in depth in more articles as the roundup approaches.)

Above: If you go to timecode 2:04 you can see that BLM will not even stop mining equipment from offloading nearly on top of trap… but will keep advocates over a mile away do to fear of “disturbance” and “upsetting the horses.” (Robert’s Mountain)

Fiscal 2024: the Roberts roundup, and horses pushed from the west

In 2024 BLM conducted a large roundup at Roberts Mountain, on the east side of this complex. The numbers going in were inflated, and the operation ended early — BLM stopped roughly 248 short of its own goal (Wild Horse Education, Roberts Mountain 2024). During that operation, a plane sprayed the aerial equivalent of “Roundup” weed killer in the same areas and at the same time the helicopter was pushing horses, and BLM allowed a mine to offload big-rig equipment nearly on top of the trap while the public was held more than a mile away (Wild Horse Education, Roberts Mountain 2024).

Now look at what BLM’s own numbers do on the west side in 2024, where there was no operative EA for Callaghan or Bald Mountain (meaning there was no authority to remove any horse):

• Bald Mountain: −78.2% in one year (940 down to 205).
• Callaghan: −31.4% in one year (1,147 down to 787).

There was no authorized gather of that magnitude in Bald Mountain or Callaghan in 2024. A herd does not lose 78% of its animals in twelve months by natural causes.

Did BLM use Robert’s Mountain to remove Bald and Callaghan? 

That would then beg the question: Is BLM’s refusal to look at numbers actually causing the identical horses to be counted in surveys in numerous HMAs? Is AML and population estimates in this district simply “bunk?” 

Everything I have seen both outside and inside (as a volunteer) points to “yes, it is bunk.”

This is either incompetence or intent — and either one demands answers

I want to be careful and fair: it is possible this is extreme incompetence and not intent — a survey-and-modeling apparatus so inconsistent that its own numbers cannot be reconciled year to year. But the pattern lines up too neatly with something else: a steady drive to reduce the wild horse population across all 1.1 million acres to near nothing, clearing the range as mining expands across it. If BLM drives this complex down to its target numbers, a person could comb this country for weeks and not find a horse.

Charting only BLM’s own numbers raises these questions. We did not invent the volatility; BLM published it. So we are asking BLM to do the one thing it has avoided:

1. Was each AML re-derived using the same detection correction now applied to the counts? If not, why measure “overpopulation” against an uncorrected baseline?
2. Confirm the 2009–2010 surges reflect the method change, not real growth.
3. What removed 87 horses from Callaghan in 2015–2016 if no BLM horses were taken?
4. Where is the inter-HMA movement analysis a “complex” designation requires?
5. Where is the assessment of mining, blasting, traffic, and aerial spraying on the herds?
6. What authorized the 78% and 31% single-year drops in 2024, where no operative EA existed?
7. Release the flight dates, raw counts, correction factors, and confidence intervals for every survey since 2009.
8. What has BLM done to investigate the aircraft-herding and suspected-killing reports in its own files?

Until BLM answers, its population estimates are not a basis for removals. They’re a set of unexplained numbers — and the public, the courts, and the horses deserve better.

This article just covers the unexplained numbers… but there is so much more at the Callaghan Complex yet to talk about. 

We are working on an article that explains the lawsuit. A lawsuit that is already hundreds of pages and exhibits is really hard to boil down into a “bullet point” style piece for the public without shortcutting the issues. We will publish it soon.

But just looking at BLM numbers should give the public real pause when BLM simply refuses to actually look at it themselves. 

Our lawsuit for Callaghan remains active. Other cases like Carter, Buckhorn, Coppersmith and Devil’s Garden and more, are all moving forward to create the stepping stones of precedent we need to, not only impact how one herd is managed, but to create tools needed everywhere.

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.