Pancake Complex: Pancake and Sands Springs West Herd Management Areas (HMA), Jakes Wash Herd Area (HA), Monte Cristo Wild Horse Territory (WHT)
Our team is busy addressing the numerous flaws in the BLM Wild Horse and Burro Program.
Far too often the flawed on-range program, ground zero, the place where the “wild story” truly exists, gets lost. A helicopter flies (without enforceable welfare rules) or more formerly wild horses or burros are failed by the BLM and land in a kill-pen auction, again. These symptoms of the disease create a palpable outrage. “Getting to AML and using mashups of infertility procedures to keep it there” does not cure the broken on range program, it sweeps the decades of injustices under a rug. (Learn more)
You can take action to impact some of the worst symptoms. You can click HERE to help create desperately needed guardrails on the $30. million coming from USDA to “get to AML and keep populations low.”
The Government Accounting Office (GAO) Audit of the sale program (slaughter loophole) request has been sent by the Congressional Wild Horse Caucus. We thank all of you that took action. We will update you when we hear more.
Once a plan is finalized by a federal agency the only way to impact that plan is through litigation.
Our team is working very hard. Many of you have asked questions. It is impossible to answer questions adequately regarding lawsuits in simple soundbites. We are working to get updates out for each case that includes where in the process each case stands.
We did a long explainer about Carter, Buckhorn and Coppersmith as BLM appeals to the Ninth Circuit to obtain a “review of the Preliminary Injunction” that halted that roundup slated to start September 1. We cannot shorthand an update. Please read HERE.
You can find a similar article regarding Devil’s Garden. That case is nearing conclusion. Please read here.
Above: Disturbing content WARNING. Our team has been visiting these wild horses a long time. But when a colt snapped it’s leg on the first day of the roundup, everyone knew “Pancake” was not just something you have for breakfast, it was a herd of wild horses in desperate need of voices.
Pancake Complex: Pancake and Sands Springs West Herd Management Areas (HMA), Jakes Wash Herd Area (HA), Monte Cristo Wild Horse Territory (WHT).
Pancake Complex: Phase 2 Enters Final Briefing
The fight for Nevada’s Pancake Complex wild horses has entered its next decisive phase. In 2024, we won a landmark federal case against the Bureau of Land Management (BLM). The court found that BLM had unlawfully delayed creation of the legally required Herd Management Area Plan (HMAP) for the Pancake Complex for decades, and that BLM failed to adequately analyze the effects of large-scale wild-horse removals on wildfire risk.
The new lawsuit—Pancake Phase 2—seeks accountability to the 2024 court win.
The case is moving through summary-judgment briefing. At this stage, the court will review the administrative record and decide whether BLM’s planning document complies with the Wild Free-Roaming Horses and Burros Act, NEPA, the prior Pancake court order, and the Administrative Procedure Act.
These final filings will close this round of briefing before the court considers the motions for final judgement. The court will either call for a hearing or rule on the extensive briefing.
Pancake HMA wild horses
What is this about?
The Pancake Complex is not a blank slate for BLM. In the 2024 ruling, Judge Miranda M. Du found that BLM had unreasonably delayed a mandatory duty to prepare HMAPs. The court described BLM’s decades-long failures as “nothing short of egregious” and ordered BLM to prepare and approve HMAPs for the Pancake Complex within one year.
The court also vacated and remanded the Pancake Gather Environmental Assessment, Record of Decision, and Finding of No Significant Impact for BLM to reanalyze foreseeable effects of gather alternatives on wildfire risks and determine whether those effects could be significant.
Central issues
According to the Phase 2 challenge, BLM’s March 2025 document does not fulfill the court’s mandate because it does not provide a genuine, data-driven HMAP. Plaintiffs contend that the document retains the same low AML from the prior gather framework without showing the data or methodology used to set it; fails to establish a credible range baseline; does not explain what a Thriving Natural Ecological Balance (TNEB) looks like in the Pancake Complex; and does not provide meaningful triggers for livestock reductions or removals when ecological conditions deteriorate.
Plaintiffs also contend that the document does not adequately analyze impacts of large horse removals on wildfire fuels despite the prior court’s explicit remand order; does not meaningfully account for livestock use, water projects, mining activity, fencing, foaling habitat, and other cumulative pressures; and does not create enforceable standards for safe gather timing, winter conditions, drive distances, injury response, or foaling-season protections. The court has not yet issued a final merits ruling.
What a win could do
- Vacatur of the March 2025 plan if the court finds the document is not a real HMAP, fails to comply with NEPA, or does not satisfy the 2024 order.
- A requirement for a genuine HMAP built on a disclosed baseline, range data, habitat conditions, population information, forage allocation, water availability, genetic concerns, monitoring protocols, and enforceable adaptive-management measures.
- An actual AML analysis (not one asserted to have been done in another document where no actual analysis exists) requiring BLM to disclose how it set the Pancake AML and whether livestock allocations, habitat conditions, and competing land uses were properly considered.
- A meaningful wildfire analysis examining whether removing wild horses affects fine fuels, grass growth, wildfire intensity, fire spread, and post-fire ecological outcomes. (At what point does the population number reduce fire fuels and how removals impact that fire fuel load)
- Potential limits on future gathers if BLM lacks a valid environmental and management decision supporting additional removals.
- A stronger public voice through meaningful disclosure of assumptions and management choices before major decisions about AMLs, livestock preferences, mining impacts, water projects, and removals.
Wild horses being removed while cattle graze, February 2022, Pancake Complex
Pancake Phase 2 is about whether a court victory will produce real change on the range.
The 2024 ruling established that BLM’s failure to prepare an HMAP was unlawful and that it failed to take the required hard look at wildfire impacts from mass removal. Plaintiffs contend that BLM did not comply, instead recycling a low-AML, removal-focused framework without performing the management analysis an HMAP requires.
The Pancake Complex encompasses a total of 1,228,739 acres across central Nevada. These are not contiguous acres but arre cut with livestock fences making movement difficult where critical waters are cut off in the hottest times of the year. It is managed under a combined Appropriate Management Level (AML) of only 361 to 638 wild horses (361 is the goal, 638 is the goal for maximum allowed).
The largest area is the Pancake HMA, spanning 849,922 acres with an individual AML of 240 to 493 wild horses. The Sand Springs West HMA covers 152,277 acres and maintains an AML of 29 to 49 wild horses, while the Monte Cristo Wild Horse Territory consists of approximately 72,877 acres with a dedicated AML of 92 to 96 wild horses. The remaining 153,663 acres belong to the Jakes Wash Herd Area, which serves as a historically designated habitat but is currently maintained with an AML of 0 (regardless of suitability) and is not managed to sustain a wild horse population.
3 Pancake medicine hat wild horses (descendants of “old man”) WHE tracked after capture. They have found sanctuary with Rewilding America Now. There are no plans that even recognize the unique genetic heritage these herds represent.
This fight at Pancake is important to the future of wild horses at Pancake and throughout the West.
Onward.
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. Sincere Gratitude.
Limited Edition Shirt to help support our work. Only a few hours left on this batch.
Click image or click here to order a two-sided shirt and support our work.
Help Defend Against The Broken Promise
Fifty-five years after Congress declared wild free-roaming horses and burros “fast disappearing from the American scene,” federal agencies are still driving their numbers down on the public lands meant to protect them.
Relentless removals are aimed at herd targets roughly one-third below the numbers found when Congress acted in 1971.
And the failures do not end there. After more than five decades, wild horses and burros still lack enforceable federal welfare standards that protect them through capture, confinement, transport, and disposition. Agencies continue to remove them without ensuring they are safeguarded from the slaughter pipeline.
This 55th-anniversary shirt honors the work of Velma Bronn Johnston—Wild Horse Annie—and refuses to let the cause she ignited be erased. We are carrying the fight forward for freedom, mercy, justice, and the right of wild horses and burros to remain wild and free on their public lands.
All proceeds fuel continued advocacy.