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Re: Comments on Stone Cabin Complex & Little Fish Lake HMA HMAP / Gather Plan Environmental Assessment, DOI-BLM-NV-B020-2025-0009-EA
Submitted to: Bureau of Land Management, Battle Mountain District, Tonopah Field Office
1553 S Main St.
Tonopah, NV 89049
Dear BLM,
I am submitting this public comment on the Stone Cabin Complex and Little Fish Lake HMA HMAP / Gather Plan Environmental Assessment, DOI-BLM-NV-B020-2025-0009-EA. This document should not be adopted as a long-term Herd Management Area Plan because it does not function like a real HMAP. Instead, it appears to relabel the earlier 2023 gather plan while carrying forward the same AMLs, the same core removal framework, and the same lack of site-specific analysis required for a true HMAP.
The EA itself acknowledges that BLM has not updated the Stone Cabin HMAP since 1983, yet this new document does not explain how it amends, implements, or replaces that earlier plan. It also does not analyze the five sub-units, monitoring methods, forage-use factors, movement studies, and other management architecture described in the 1983 HMAP. A new title and a summary table do not transform a gather plan into a lawful HMAP.
This is not a real HMAP
The purpose and need in this EA is narrowly written to reduce wild horses and maintain populations within existing AMLs. That is a gather objective, not the broader planning purpose required for a true HMAP that should evaluate habitat conditions, livestock overlap, mining, water distribution, monitoring methods, and whether current AMLs are even appropriate.
No meaningful change from 2023
This EA does not appear to make any substantive change from the 2023 gather plan. The 2025 document carries forward the same AMLs, the same low-AML removal approach, the same fertility suppression concepts (including surgical sterilization in a gelding component), and the same lack of analysis of the 1983 HMAP’s five sub-units.
Just calling the document an HMAP does not solve the problem. If BLM wants to issue a true HMAP, it should prepare one that is data-based, site-specific, and transparent about how management decisions are made.
Litigation is selectively presented
This EA discusses legal background selectively and leaves out important litigation that directly affects this planning area. Public review is incomplete when the agency references some cases but omits the active Wild Horse Education appeal involving the force of 43 C.F.R. § 4710.4 and omits the Colvin appeal, which seeks removal to low AML on this same range.
That matters because the EA’s preferred approach mirrors the low-AML outcome sought in the ranching litigation, while failing to disclose that this is still being litigated. The document also fails to address the district court findings regarding delay of an HMAP for Saulsbury and the continuing Ninth Circuit issues tied to Stone Cabin.
AML and forage must be data-based
The EA says BLM will not adjust AML, even though the EA itself notes that the existing AML figures were carried forward from an old settlement into underlying planning rather than from a complete, transparent monitoring system under the 1983 HMAP. If AML is not being re-evaluated with current data, then every removal alternative built around that AML is on unstable ground.
There is a major imbalance between forage allocated to livestock and forage allocated to wild horses at low AML. Before approving long-term removals, BLM should provide a transparent forage-allocation analysis, evaluate whether livestock use should be reduced under 43 C.F.R. § 4710.5, and complete a current rangeland health assessment.
Welfare and helicopter capture need real analysis
BLM should not rely on broad statements about welfare while avoiding site-specific analysis of helicopter capture and holding conditions. The EA reports thousands of comments opposing helicopter use at the motorized-vehicle hearing, yet responds only with the conclusory statement that no changes to the SOPs were warranted.
That is not enough. Any gather plan should analyze conditions such as foaling season, terrain, air quality, heat index, travel distance, roping limits, and holding risks, and it should openly acknowledge that CAWP standards have never been formalized through a public rulemaking process. The 1983 HMAP’s required foal-incidence surveys in January and July are especially relevant because they could have helped establish an evidence-based foaling season needed to evaluate helicopter use lawfully and responsibly.
The EA also fails to note the resolution passed by Nye County against any helicopter capture taking place in the county. A large portion of the area covered in this EA is in Nye County.
Rewilding and repatriation were not seriously analyzed
The EA should not dismiss these concepts by treating them as the same thing. BLM improperly conflates the terms rewilding and repatriation of HA lands: repatriation means re-evaluating Herd Areas for renewed use where habitat can support wild horses, while rewilding is a broader management approach that considers reducing competing extractive uses and managing more of the landscape primarily for wild horses and wildlife.
This intentional misuse of the terms has provided no actual analysis on either subject or factual basis for dismissing either as an alternative. An HMAP can, in fact, trigger a LUP amendment to allow for either or both.
Requested action
I respectfully ask BLM to:
- Withdraw this EA as a long-term HMAP because it is not a true HMAP.
- Defer long-term planning until the pending Ninth Circuit litigation affecting Stone Cabin and related areas is resolved.
- Prepare a real HMAP that uses current science, transparent monitoring, and the 1983 HMAP’s sub-unit framework.
- Reevaluate AML and forage allocations using current data rather than rolling forward historic agreements.
- Analyze livestock reductions, repatriation, rewilding, and a high-AML alternative as real alternatives.
- Provide meaningful site-specific welfare analysis before authorizing helicopter capture or long-term holding strategies.
Thank you for considering this comment.
Sincerely,
