Cortez Pit Expansion (Callaghan Complex and every other HMA in the region)

Cortez Pit Expansion Project

Project: Cortez Pit Expansion Project, DOI‑BLM‑NV‑B010‑2026‑0021‑DNA
Operator: Nevada Gold Mines LLC · Office: BLM Mount Lewis Field Office, Battle Mountain District
Comment deadline: August 19, 2026
Submit: BLM ePlanning “Participate Now” · Contact: Eugene Gilseth, egilseth@blm.gov, (541) 471‑6638

How to use these: These are drafts to adapt, not to copy verbatim. Comments carry more weight when they are in your own words and tie the impact to a specific 43 CFR 3809 duty (prevent “unnecessary or undue degradation”) or a NEPA gap (a DNA that fails to take a hard look). Pick the points that fit, add your own observations, and be specific. Personalize the greeting and sign with your name and town.

Short comment (drop‑in, ~150 words)

To the Mount Lewis Field Office:

I am submitting comments on the Cortez Pit Expansion Project (DOI‑BLM‑NV‑B010‑2026‑0021‑DNA). I object to approving this Plan of Operations on a Determination of NEPA Adequacy. The proposal adds dewatering wells and pipeline and authorizes continued pumping of up to 36,100 gallons per minute, yet it does not disclose the effect of that dewatering on the springs, seeps, and wells that wild horses in the adjacent South Shoshone, Bald Mountain, and Callaghan Herd Management Areas depend on. Under 43 CFR 3809.415, BLM must prevent unnecessary or undue degradation. Dewatering that dries water sources wild horses cannot leave, and increased haul‑road traffic through and near occupied range, is exactly that kind of degradation that must be analyzed. BLM must analyze these impacts in a current, project‑specific NEPA document — not a DNA — and must account for the unexplained loss of wild horses already documented in these herds. Please deny approval until this analysis is complete. BLM must complete a real HMAP fir wild horses to outline measures for mitigation.

Respectfully, [Name, Town, State]

If you want to write your own comments, you can read the points below and make them your own. You must submit through the BLM portal by clicking the Participate Now button. There is no petition to sign as it would not be counted by BLM.

Comment Point 1 — Water loss / dewatering and wild horses

The Proposed Action expressly adds “dewatering wells and pipeline” and continues pumping up to 36,100 gallons per minute — on the order of 58,000 acre‑feet per year. The DNA does not analyze how this drawdown affects the springs, seeps, and shallow wells that wild horses rely on in the neighboring South Shoshone, Bald Mountain, Callaghan, and Hickison HMAs (that BLM has created an administrative construct to treat as “one thing.”)

  • The Cortez mine cluster has already pumped more than 620,000 acre‑feet cumulatively from Crescent Valley (Nevada Legislature, Hydrogeology of the Humboldt River Basin).
  • The Cortez Hills EIS itself concluded a spring at the base of Mt. Tenabo would dry up from deep dewatering and not recover within 100 years (an area of historic significance to native tribes of the region).
  • Wild horses are legally confined to their HMAs (16 U.S.C. § 1333); when a water source dries, they cannot relocate to find another. Loss of water is loss of habitat.

Request: BLM must map every spring, seep, well, and pipeline‑fed water source within the projected cone of depression, disclose predicted drawdown at each, identify which wild‑horse water sources are affected, and commit to enforceable replacement or mitigation. A DNA that omits this analysis does not satisfy NEPA or the “unnecessary or undue degradation” standard of 43 CFR 3809.415.

Comment Point 2 — Traffic, haul roads, and direct harm to horses

Recent Cortez approvals include a “wider haul road” and new road corridors “to reduce truck traffic between Cortez and Goldrush mines,” and this expansion reclassifies haul‑road and power/water‑line corridor disturbance. Increased heavy‑truck traffic on district roads creates direct and cumulative impacts on wild horses that the DNA does not address.

  • Vehicle strikes: Haul trucks and light vehicles moving at speed on unfenced range roads kill and injure wild horses. Great Basin Resource Watch has documented “increased heavy truck traffic and dust” as a recognized mining impact in these valleys.
  • Fragmentation and barriers: New and widened roads, pipelines, and power lines fragment movement corridors and can cut horses off from water and forage — the very “inherent movement patterns” BLM elsewhere claims to protect.
  • Dust and forage: Road dust degrades forage and water quality along travel routes horses use daily.

Request: BLM must analyze wildlife/wild‑horse vehicle‑collision risk, impose and enforce speed limits and wildlife‑awareness measures on all haul and access roads within or adjacent to occupied HMA range, require reporting of any wild‑horse vehicle strikes, and evaluate road/pipeline fragmentation of movement and water access.

Comment Point 3 — Loss of land / habitat and cumulative “clearance”

The project reclassifies roughly 580 acres of disturbance and adds new waste‑rock facilities. Standing alone this looks small, but it is one increment in a district where NGM’s Deep South expansion already added ~3,800 acres of disturbance and 4,279 acres to the plan boundary, and where Goldrush, Robertson, Fourmile, and multiple exploration projects are expanding simultaneously.

  • Every acre of pit, waste rock, and infrastructure permanently removes forage and cover from a landscape wild horses cannot leave.
  • BLM analyzes each mine action and each roundup separately, obscuring the combined footprint on the herds.

Request: BLM must prepare a genuine cumulative‑effects analysis addressing the combined habitat loss from all Cortez‑district mining actions together with the wild‑horse removals in the same herd areas — not treat them as unrelated. NEPA requires consideration of connected and cumulative actions; a DNA tiered to older, single‑project analyses cannot meet that duty.

Comment Point 4 — Unexplained wild‑horse losses next to the mine district

BLM’s own population data show that in 2024, with no authorized gather and no operative EA, Bald Mountain dropped 78% (940 to 205 horses) and Callaghan dropped 31% (1,147 to 787) — roughly 1,100 horses gone with no accounting. BLM’s decision documents concede that Bald Mountain and South Shoshone “exhibit a low or negative growth rate that cannot be explained by gather activities, fertility control or inherent movement patterns.”

These are the same herds bordering the Cortez mine district and its dewatering. Before authorizing more disturbance and pumping here, BLM must determine whether mining‑related impacts — drawdown, fencing horses off water, traffic, and disturbance — are contributing to these documented, unexplained losses.

Request: BLM must disclose and investigate the unexplained population losses and low birth rates in the adjacent HMAs and analyze the expansion’s contribution to them before approval. Are there unauthorized removals or environmental contamination? 

Comment Point 5 — Wrong NEPA vehicle (DNA) and outdated baseline

BLM proposes to approve this Plan of Operations through a Determination of NEPA Adequacy, relying on prior analyses rather than current, site‑specific review. Conditions have changed materially: new adjacent mines, expanded dewatering, drought, wildfire, and a major wild‑horse roundup underway in the same area in 2026.

Request: BLM should decline to rely on a DNA and instead prepare, at minimum, a current project‑specific Environmental Assessment (and consider an EIS) that takes a hard look at water resources, wild horses, traffic, and cumulative effects with up‑to‑date baseline data.

Comment Point 6 — No valid HMAP means no mechanism to mitigate these impacts

Mitigation for foreseeable impacts to wild horses — from mining, dewatering, roads, fences, and livestock — is supposed to be established in the Herd Management Area Plan (HMAP) for each herd, the site‑specific management document required under BLM Handbook H‑4700‑1. For the herds bordering this mine district (South Shoshone, Bald Mountain, Callaghan), no valid HMAP exists. The document BLM approved in February 2026 is a rushed gather plan, not a real HMAP: BLM placed all HMAP content in a generic appendix, cited a “page limit,” and stated it could not perform the full analysis and would do it “someday” (Wild Horse Education, July 11, 2026). A real HMAP process, by contrast, exists to “identify measures to avoid or minimize environmental harm” and “identify potential mitigation” (BLM Red Desert Complex HMAP).

This is not a side issue for the mine — it is central. The Cortez‑district EIS work was already underway (Robertson EIS scoping in August 2023; Deep South ROD and Robertson Final EIS in 2024) before BLM rushed the Callaghan gather plan and emptied South Shoshone. Because there is no genuine HMAP with a baseline, herd‑habitat objectives, and mitigation triggers, there is no document that can require the mine to mitigate its foreseeable impacts on the horses — no protection when dewatering dries a spring, when a widened haul road bisects a corridor, or when infrastructure fences horses off water.

Request: BLM must not approve additional disturbance and dewatering in this district until a valid, site‑specific HMAP is in place for the affected HMAs that establishes baseline conditions, herd‑habitat objectives, and enforceable mitigation measures for foreseeable mining, road, water‑development, and grazing impacts. Absent that, the DNA cannot demonstrate that impacts to wild horses will be avoided, minimized, or mitigated as NEPA and 43 CFR 3809 require.

Key facts to cite (with sources)

 

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