We are currently in the midst of the second step of the process for the Red Desert Complex proposed EA and HMAP update... and I am feeling more than a little bit over-whelmed by all that needs to be dealt with here.

Now is the time you can submit more detailed comments regarding the proposed action than you might have during the scoping notice - these are possible things you may comment on or question & challenge for the BLM proposed plans:

- Impact on the horses and their land from this action.

- Competition and pressure from ranch cow and sheep grazing in regular pastures as well as in riparian areas.

- Competition and impact from current and expanding mining in wild horse lands.

- Impact from recreational use which include casual camping, CDT hikers, dirt bikes and bicyclists route travels, fall and winter hunting, casual day travelers.

- Re-evaluating and adjusting AML to meet scientifically proven healthy numbers.

- Returning the area known as Arapaho Creek aka 'the donut hole' to HMA status as it once was when within the Seven Lakes HMA.

Now is also the time to provide and submit any documents that will support your comments and statements.

I apologize to all of you, this blog is late being done, I am extremely over-whelmed and feeling a lot of feels.... as I write this I have a lot of anger and am horribly fearful that current BLM staff will be successful in side-stepping the real work and action that could and should be done when submitting an EA and especially when updating HMAPs.

The wild horses in this land have been failed by humans of all kinds for over 30 years now and this is our chance to finally repair what was undone so many years ago.

Submitting Comments:

In April the Wild Horse Specialist in Lander told me that anyone who did not comment during the Scoping Notice period would not have standing to comment on subsequent actions including the preliminary EA - after reaching out to national level BLM staff on another matter it is now unclear if that is true, and while I do not have a clear answer on this yet, I strongly encourage anyone who missed commenting on the Scoping Notice but wants to be involved - submit a comment!!

What is the worse that could happen... they dismiss and ignore your comment?

But - what if the Lander field office staff is incorrect in their statement and your comment is not dismissed but does actually become a part of the record?

What if you say something none of the rest of us thought to say or in a way we did not think to phrase it? Sometimes that one little tweak makes a big difference.....

All it costs you is time and a little bit of work to add your voice in the defense of wild horses and their native lands!

And trust me, we need EVERY - SINGLE - COMMENT that is related to this proposed action and HMAP update possible, the horses need us to comment!

In my previous Scoping Notice blog I walked you though the process to try and make it easier as it all can be intimidating, if you are new to this process here is a short recap:

The link to the 'Project Home' page:

https://eplanning.blm.gov/Project-Home/?id=6c9a6ab7-c027-f111-8341-001dd804183b

On the home page you will find a brief description of actions and deadlines for comments... you will also find contact info for one of the BLM public affairs contacts for any questions.

The deadline to submit comments for this action is July 13 2026.

Clicking on 'Documents' will bring you to the documents related to this action available for review to help understand and prepare what and how you want to comment... some of these are documents we already reviewed for the Scoping Notice.

Mostly you want to review the 2026 Red Desert Complex Preliminary EA, the Green Mountain RA HMA Eval from 1993, and the Great Divide RA HMA Evaluation 1994 documents.

The 2026 EA is obnoxiously exhaustingly long at 249 pages - thankfully you don't need to read all of it.... you will need to sort through and read way more than will make you happy, it helps if you start by sorting it into sections (you can either print the entire thing and sort it by section - or - if you are tech smart you can download and separate the PDF document by section) and then dig into the sections that you actually want to comment on - FYI the new HMAP is buried in the EA, as is the 2025 census count, and just for fun they have bombarded us with the genetic report repeatedly as individual documents and in the EA.

Once you have studied all that you want to sort and read through and have a messy headache and far too much irritation at it all, and when you have assembled your thoughts into some sense of order and found the supporting documents for your arguments - you are going to click on the 'Participate Now' and submit your comment.

Be as detailed as you want to be.... or not be.

Simple factual statements are wonderful, picking one thing to focus on is okay, and if you are submitting a long comment with documentation then there is also the option to upload supporting documents!

Please do not skip commenting because you feel like whatever you have to contribute is not enough.... all of it matters and each of us have a unique voice with a unique perspective and belief of how we should be managing and protecting our wild horses on their wild native lands.

Okay - lets get started examining this bugger!!

Excess Animals Argument:

The word excess in and of itself is obnoxious..... wild horses are not inventory like pencils in a box to be disposed of - they are living, breathing, and sentient beings that are natural, native, and necessary to these lands!

To the actual argument and how to address it... that BLM is planning a roundup and removal of 'excess' horses because the census report shows four of the HMAs to be over their BLM assigned AML.

I am not going to argue that the horses are over AML, infrared census counts are pretty clear and are harder to challenge than the previously used methods of statistical census counts... it is both amazing and scary how very detailed infrared cameras are.

That said infrared is not perfect, not because I think the count is terribly faulty, but because they are a technical tool and they can only count the horses where they are found at the time of the flights - and that is not necessarily the entire picture as there is an element of understanding the herds and their seasonal habits that is missing.

But that is not really the point here.... the actual question here is - can BLM remove horses for the only reason that they are over reportedly over AML?

If that is their only measure then the answer is - no!

In a footnote of this EA is stated that BLM does not have to prove range degradation to the range for a removal as per "Interior Board of Land Appeals (IBLA) in Animal Protection Institute et al., 118 IBLA 63, 75 (1991)"

It is a cute footnote... it is not the end of the discussion.

There are many more recent references, court cases, and even written BLM policy that should be referred to for this discussion.

Over the last several years this particular issue has been challenged in comments on EAs and then in court litigation.... a quick search will find that advocacy groups such as Friends of Animals and AWHC have been in litigation on this issue for some time now.

And, sadly research will also show that at each ruling that went against them BLM has learned how to side-step and use language or implement plans that meet the letter of the law in order to accomplish their initial plans or goals of removal.

That does not mean in this particular proposed EA they (BLM) can dismiss the idea that they have to prove range degradation and remove horses purely for being reportedly above their assigned AML numbers.

BLMs own Wild Horse and Burros Management Handbook outlines expectations regarding this part of their management.

When we examine the documents provided in the Scoping Notice we find that the range has been steadily improving over the last several years... this despite claims from the Lander field office Wild Horse Specialist that too many horses exist now and that there were too many horses left on the range during the 2020 roundup and removal.

Additionally BLM staff stated in Scoping Notice documents that they would not examine forage use or degradation of any other users on the range - only horses were being held accountable for range use and degradation.

This is not acceptable, BLM is responsible for managing for multiple use, something they constantly remind us when stating that the horses do not exist alone on the range in an attempt to justify removals - I think that is rather the point - it IS multiple use and ALL users must be held accountable for usage, degradation, and damage.

Multiple use in the desert includes wild horses, wildlife, cows, sheep, mining activity, and recreationists that range from dirt bikes to rock collectors.

All of these parties participate in using and effect the land.

In my 15+ years of time in the desert I have observed mining reclamation and expansion, bicyclists and CDT hikers camping in various places, cows camped out on water holes like it is Sunday morning church, sheep grazing on a dry and drought affected pasture, and sheep herders riding ATVs across the hills completely off any 2-track and creating new trails with permanently damaged sagebrush and forage.

Where is the discussion of these effects on the range?

BLM cannot simply look at a population spreadsheet and initiate a gather due to high reported AML numbers, excess determination requires BLM to prove that the horses are causing a disruption to the TNEB [thriving natural ecological balance] and must provide the monitoring data showing that active degradation.

And they must also show monitoring data for all other users.

If a herd is over AML but the local ecosystem remains healthy, stable, and shows no signs of resource degradation, the agency lacks the administrative justification required by its own handbook to order a standard gather and removal.

Policy requires the local field office to synthesize multiple years of climate data, vegetation mapping, and resource conditions to legally defend the gather against public and judicial scrutiny.

These standards have not been met for this proposed action.

To be clear, I am not asking that we wait until their is serious damage to the range to adjust whatever needs to be adjusted to keep it healthy and thriving - we want a healthy thriving landscape for wild horses and other natural wild inhabitants.

But..... as the range at this time shows improvement, per BLM data, over the last several years there is clearly not a need to remove horses to maintain land health.

Additionally range use, degradation, and damage cannot be laid solely at the hooves of wild horses, it is a multiple use land and all users must be held accountable and also should be asked to adjust to ensure a healthy and thriving landscape.

Drought & Water Resources: -

An argument will be made by BLM for removal of wild horses due to drought in the desert.... it is referenced in this preliminary EA and it also states in the handbook as acceptable in emergency situations.

If the threat existed that horses were going to die of dehydration I would fully support measures to prevent that from happening.

But that is not where we are at right now, yes, we are currently two years into a drought with recent winters having had little snow-fall, and we have not had normal spring and early summer rains.

It is dry and the land is showing the effects... grasses had a short growth period that thankfully were boosted by late spring snows, and everything in the desert including wild horses are moving in variable migration patterns, as they move to follow available water sources that ebb and flow with the seasons and storms.

But - if it is so dry that horses should to be removed, why are there cows and sheep grazing at almost full capacity of numbers?

When I spoke with the Lander office Wild Horse Specialist in April he stated that they had sent drought letters out to grazing permittees and that those permittees had indicated they would voluntarily not graze at their full allotment of livestock this year.

In a couple of areas I am observing fewer cows than usual in pasture allotments but in most of the areas there are the same number of cows as usual on the range.

The answer is at least partly that there are man created water sources for the livestock, there are a few water tanks out in the desert with wells that pump water either using a gas generator, electricity, or solar power ensuring that the livestock have easy access to a consistent water source.

The complaint is (from BLM and ranchers) that wild horses congregate around these water tanks and disrupt the ability of cows and other wild life to drink - this is one of the most ridiculous myths created and has gained a lot of traction with those who don't like sharing resources.

I have SO many videos proving that the horses don't run cows, sheep, or any natural wild life off of water - either at water tanks, creeks, streams, or springs.

This also is not the driest the desert has ever been.... it feels harsh to us I think because for a few years there were some very bitter wintery winters with deep snows and very rainy spring months that led to incredibly lush landscapes and plentiful water sources - I often forget that when I first began visiting wild horses in the Red Desert it was very very dry, it had been in drought for something like 10 years, and yet the horses were absolutely fine, they had both the man managed and natural water sources that they knew how to find.

Just for the sake of argument... lets say we are in a drought so severe that almost all natural water sources are dry, and that wild life, wild horses, and livestock are forced into sharing limited man managed water tanks.

What does that mean?

The complaint is that the horses are bunching up in the areas where the water tanks are which results in over-grazing of the surrounding area pastures.... okay - but is that not what the cows are also doing? Cows travel far fewer miles in a day than horses will between a grazing area and water source.

And finally, if the concern is that horses are bunching up around limited water sources and adding stress to the surrounding landscape, why not develop additional water sources scattered widely throughout the HMAs?

Found in the 2014 Lander RMP: 4128 BR 15.1 - 'Maintain sufficient year-round water sources to sustain wild horses. Evaluate all proposed range improvement projects to benefit wild horses for impacts to other resources and uses.'

Right there in black and white.... BLM is responsible to maintain sufficient year-round water sources to sustain wild horses.

And of course it is not quite that simple. Development of any new water sources must be examined for impacts on the land, the natural wild life, and on the wild horses themselves - in government it is rarely simple straightforward and easily or quickly accomplished - but it is within their own most recently completed RMP that water sources are to be maintained in order to sustain wild horses in the wild.

Rawlins has its own separate RMP that seems at first glance to be fairly vague but still mentions developing water sources for wild horses, and as per the South Herd Eval report provided to the public in the Scoping Notice period, the Rawlins office has been actively developing water sources for wild horses.

**RMP = Range Management Plan

Fertility Control:

I support a well thought out program that involves ensuring properly administered use of it - and yes I know many of you reading this just rolled your eyes and a few of you probably just dismissed me as part of the problem and stopped reading... if you are still here, thank you for considering this part of wild horse management.

To me it is as simple as that we no longer live in a world without fences, highways, or human encroachment - we have been shrinking the islands these wild horses are assigned to from the moment those islands were created.

And that is not going to change or go away.

We shrink their actual boundaries by building homes, we take away their forage with mining and other energy development, and we require that they share grazing and water sources with cattle and sheep herds - yes - in a perfect world all rancher grazing is removed from HMAs, maybe someday that happens but we are not there today.

And in those limited lands horses do not self-regulate their breeding... their natural instincts are to always produce new foals every year - the foaling rate may change at times with variable influences, but very VERY rarely will you observe a year without at least one or two new foals joining the herd.

And the reality also is that as much as I believe BLM should acknowledge yearly wild horse mortality rates, it is rare that there are more death than births.... it absolutely happens and these events should ALWAYS be acknowledged by BLM - but generally birthing rates are usually higher than deaths.

But - if there is an active, carefully monitored, and successfully ongoing fertility control program in an HMA then you would see death and birth rates be just about equal and resulting in very little, or no need at all, for removal of wild horses from the area.

Also - the very harsh reality is that predators are a very small % of the equation with some HMAs having no predators at all that can take down a horse - sorry - but as someone who spends intense time on a range that has wolves and mountain lions - only one of those predators is a threat to wild horses, and mountain lions are in only a small portion of this complex.

I have very strong opinions on the type of fertility control.... I believe the only control that should be used is native PzP as it is known to be reversible when properly administered, it does not cause harm to humans and it does not cause sterilization in stallions, it should be used only in a well documented and maintained program that carefully tracks when and how often each mare is treated and ensures that each mare is allowed to have foals that will become part of the wild desert legacy.

I completely and absolutely disagree with BLM statements that the horses of the Red Desert Complex cannot be darted in the field in the same way that fertility control programs exists in several other HMAs across western states.

Wyoming BLM needs to stop being so weird and controlling about allowing volunteers to run a darting program, it is not a secret that BLM staff are not well supported by their superiors locally or the national office to be out spending the days, weeks, and even months it takes to run a successful darting program.

Other states have successful darting programs using volunteers, and they have volunteers darting wild horses in remote areas that are not necessarily easily accessed or where the horses are comfortable with human presence... it is doable, it has been proven, and it is past time for Wyoming BLM to get on board.

Mining:

BLM persistently states that mining in the Red Desert Complex has minimal impact, with only minimal ongoing mine operations, and little to no discussion of possible future mining operations.

Mining has an impact on wild horse range, I am not claiming that it takes a majority of their assigned acreage, and I am not necessarily blanketly anti-mining!

However.... neither should it be ignored, over the last few years years I personally have observed the Lost Creek uranium mine site growing and expanding into what is necessary winter foraging area that the horses especially depended on in harsher winters with deep snows.

In some places older pit mines have taken hundreds of acres out of grazing use... which may seem like a small thing in tens of thousands of acres, but what must be considered is that wild horses and other wild life are being pushed out of areas that once held winter forage or seasonal water sources, and now are competing with cows and sheep.

The horses are pushed out of necessary forage and water sources and then are further asked to stay out of the way of cattle and sheep grazing and water sources - there is no recognition or adjustment of that change for the horses.

When any mining activity expands across HMA and HA lands and the horses are pushed out of their normal patterns the answer should not be to remove more horses, the answer is to adjust the demands from humans on the land.

There is room for everyone in these vast lands, but it is the responsibility of man to recognize and adjust for the effects he has had, and everyone involved needs to work together for the better of the land and its natural and native inhabitants - and wild horses are one of those natural and native wild inhabitants.

Uranium mining is set to expand greatly in the desert.... with the approval of nuclear power plants in Wyoming, and with uranium being a natural resource across the supposed empty miles of the desert, it is easy to guess what will happen, and if you visit the desert you will see that it is already happening - even the untrained eye can discern the rapid expansion that is occurring.... there is further planned expansion that the untrained eye may not recognize but those with a background and understanding in these things have been discussing.

The BLM needs to acknowledge this trend, they need to provide information on how many acres are effected and altered by current mining in each HMA and Arapaho Creek at this time, how many acres have been placed in reclamation from past mining and how long that process is expected to take before the land is recovered enough to provide good sustainable forage, and they should also provide - either in the EA or as a reference document - all future proposed and planned mining activity in each HMA and Arapaho Creek for the next 10 years.

And they should also explain how they will mitigate for lost forage and water resources for the wild horses and other natural and native wild life in the desert.

AML [Appropriate Management Level]:

AML in the Red Desert Complex is an odd thing to understand.... and depending on your personal beliefs and understanding of the pattern of migration for wild horses, a change in AML may or may not be necessary.

Assigned AML per HMA is as follows:

Stewart Creek has an AML of 125-175 horses with a claim that this HMA is completely fenced in and the horses do not move in or out of the HMA.

Green Mountain has an AML of 170-300 horses with what is also the assumption that the horses do not migrate in or out of the HMA. It is worth knowing that Green Mountain is an expansive land area with various geographical and fence barriers that cause a separation in herds that result in slightly less than normal movement to other areas, or more limited migrational habits in the HMA.

Lost Creek and Antelope Hills HMA have an AML of 60-82 wild horses, these two HMAs actually share a common border, and several dozen of the horses cross between the two HMAs quite regularly.

Crooks Mountain has an AML of 65-85 wild horses. This HMA does not share a direct border with any other HMA and its horses tend to keep to themselves except for a few months out of the year when they mix in Antelope Hills and Arapaho Creek.

The three HMAs of Lost Creek, Antelope Hills, and Crooks Mountain clearly do not individually meet the scientific minimum of 50 breeding pairs of adult horses.... not even when at high AML - you will find in current and historical documents that these HMAs are set at this low AML with the assumption and expectation that these horses will migrate and mix together, allowing for genetic viability.

This is achieved most often by the horses crossing through Arapaho Creek.

My personal opinion is that each of these HMAs could see an increase in their assigned AMLs to at least 100-150 each, it may not necessarily require an adjustment in livestock grazing, and still maintain a healthy range.

I know many of you have asked for all livestock to be removed, and while that would simplify things for wild horses on many levels, it is not something I expect will happen soon, ranchers effectively own Wyoming politics and Wyoming government has some say in how public lands in Wyoming are managed.

No matter your opinion on whether or not AML should be increased - BLM staff is completely incorrect in stating that it is outside the scope of the EA and HMAP to adjust the assigned AMLs for the HMAs.

This is exactly the time to examine it.... it is a fair amount of work required for an increase in AML requires quite a bit of documentation of land use and range health data, but this is information that they should already have in hand.

It is not a quickly done process but it is not out of bounds for it to be considered.

Historically AMLs have been revised in previous EAs with the most recent one being the 2019 Fifteenmile EA where AML was increased.

And it is also discussed in the 2014 Lander RMP as an expectation that AML may be revised: "Update the Herd Area Management Plan as needed to meet herd health objectives, including Appropriate Management Levels, and to address impacts to other resources. Consider forage competition and evaluate overall utilization levels by all grazing animals..."

The only thing unclear to me is why current BLM staff believes AML should not be discussed and considered for revision.

Arapaho Creek & HMA Status:

It is no surprise that BLMs response was to refuse consideration of comments requesting that Arapaho Creek be given HMA status.

In my personal conversation with the Lander field office Wild Horse Specialist in April his statement was that Arapaho Creek would be not be considered for HMA status and would continue to be zeroed out.... he has made it clear for years that he does not intend to manage horses in this area.

But... the response from BLM is incorrect.

It is not outside the scope of an EA to consider and analyze this action but rather an EA is exactly when things like this should be discussed and considered.

Additionally it is not only an EA that is being done at this time, but also the updating of an HMAP from the 1990s, a document that outlines and provides guidance for future wild horse management of the Red Desert Complex.

This is precisely the time for this thing to be taken into consideration, discussed, analyzed, and revised - RMPs exist as guidance with the ability to amend when it is found that a revision needs to be done.

Amendments to RMPs are in fact expected to occur and are allowed - there is literal policy and protocol for it!

I am ending this particular discussion here, not because it is that short and sweet, but because what I have to write about Arapaho Creek is considerably longer, I will pick it up in a second blog that I will have out to you within the next week - promise!

This land has long been wild horse lands, I have 15yrs of personal observation and documentation of wild horses here, but you don't have to take my word for it - there are historical BLM documents of wild horses in this land.

And yes, in my next blog we will be discussing all of it.

Arapaho Creek is the heart and soul of the desert and it is necessary to the herd health of all five surrounding HMAs of the Red Desert Complex.

This action is an important one that should be taken seriously - it is a new EA and an update to an HMAP from the 1990s that affect five HMAs, one HA that should never have lost HMA status, and the lives of hundreds of wild horses.

So, will BLM recognize and acknowledge the suggestions and requests from the public, and take the time to consider and fully analyze those proposed actions?

Or will they instead bull-doze their way through this thing as if it were an inconsequential administrative action with no real thought or consideration for the future of wild horses and their wild lands.

The process of an EA exists for a reason.... that the public be aware of and have a voice in how their public lands are managed.

An EA action should never be simply about roundup and removal of wild horses, despite that it has become standard practice to treat it as such, but rather any time an EA is done there is the possibility and responsibility to reexamine, readjust, and improve the management of wild horses.

And it is especially important to take our time and be thorough as this also involves updating an HMAP from the 1990s!

Herd Management Area Plans are an important tool in guiding future management of wild horses and their areas - it should not be treated lightly or dismissed as something that cannot be revised to best fit the wild horses and their land.

And if in the course of the discussion of the current preliminary EA and HMAP there are things found that can and should be adjusted, that are in any way different than the most recent approved RMP, well that is why there is the ability to do RMP amendments!

So I leave you now with this blog - I will be returning soon with a more thorough discussion about Arapaho Creek.... this blog is plenty long enough already and Arapaho Creek requires a longer examination of it as a current and historical wild horse land.

Hopefully I have shared enough to help you feel comfortable in submitting you own comment in your own unique voice.... it is incredibly important that we each comment individually - it is better to be a thousand uniquely imperfect voices, rather than one form letter comment.

Thank you for being here, for your patience and perseverance, and for not ever giving up on this long ridiculously tedious battle to keep wild horses on their wild lands.