April 3 2026 a press release was posted by BLM for the Red Desert Complex in central Wyoming, stating a planned action of updating a 30yr old HMAP and removing 'excess' wild horses from the complex.

We the public have until May 4 2026 to submit our comments, and it is critical that each of us submits a comment related to this planned action by the deadline.... why?

A few reasons:

1) these are public lands managed by a government agency and you the taxpayer want your voice to be included in any decisions made!

2) this is an action that could potentially change how wild horses are managed in this complex for many years!

3) if you do not submit a comment related to this planned action by the deadline, you will not have standing to comment in any future comment periods that follow, in this particular planned action - I seriously cannot stress to you how very incredibly important this is.... this was stated to me directly by BLM staff, so please, comment!

So, I know it is ever so intimidating to submit comments (even if you have been doing it for years), to fully understand what is being proposed (there is a lot of reading and deciphering of information), and then to sum it all up in a way that will not be dismissed by BLM staff when they are reviewing submitted comments - hopefully this blog will help a little!

** As a side note - some of this may be repetitive to those of you that have been involved in this battle for years.... there are others that are new to this part of advocating, and I remember being confused for years about all of it, and so I am taking a very basic approach and walking through the steps - please be patient if you already know all the things, not everyone does, and I want to simplify it as much as possible.

Lets start with website links that will help you find information!

First link is the press release from BLM, this is the formal notice of planned action and has links to the project page, it also has the contact information for BLM public relations person, Allegra Keenoo.

I met Allegra during roundup and removal operations and she was helpful when I had questions, something I very much appreciated at the time, and I hope that she is still the kind person who helps the public find information.

Her phone is 307-775-6318 and email is [email protected]

The project page shows Tyson Finnicum as a contact, he also was a BLM public relations person at roundup and removal operations and I thought him to be helpful when I had questions..... his phone is 307-261-7521 or email is [email protected]

Any questions or clarifications on this proposed action can be directed to either Allegra or Tyson... of course you can also contact the respective managing BLM field offices of Lander or Rawlins.

Here is the link to the press release:

https://www.blm.gov/announcement/blm-seeks-input-management-wild-horses-red-desert?fbclid=IwY2xjawQ97DVleHRuA2FlbQIxMQBicmlkETE4azQ0R1lNb2czN2oyZEhuc3J0YwZhcHBfaWQQMjIyMDM5MTc4ODIwMDg5MgABHtbmDOzHaeOuQNeaaiXHCsgTqRLQeZsQQcSzFy8FdtqsFoGSpwdhEFNW_tT0_aem_HCVxmexAzddKfNyfreBB0w

The second link is to the NEPA project page. This page will bring you to the initial Project Information where you can then click on links for documents and to submit your comments for this planned action.

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

Once you are in the Project Home page you can click on the Documents link and will see the below screen, listing all current documents provided by BLM related to this planned action, that have been posted for you the public to review.

At this time we have only been provided the Scoping Notice, Evaluations of the 'North Herd' and 'South Herd', and the genetic monitoring report from the most recent roundup in this complex completed in 2020, with the report completed in 2025.

We have not been provided with the HMAP that is in planning for update or any other documents referenced in either of the field office evaluations.

Once you have read all there is to read, mulled it over and considered and weighed all the information you were able to gather and sort through, you will go into the Participate Now and then will submit your comment on this proposed action.

A few things to know.... if you have by chance already submitted a comment and realize you forgot a point (this happens to me more than I want to admit!), or just want to add something, you are allowed to submit additional comments!

If you have done lots of research and have historical, scientific, or other documents that support your points, you can upload those with your comment!

Pease do not feel like you must have documentation to support your comment, a well thought out comment with honest and factual information that is related to this action is absolutely great too!

There are currently four documents provided for public review at this time:

* Scoping Notice

* Genetic Analysis report from the 2018/2020 RDC roundup and removal

* North Red Desert Complex HMAP Evaluation

* South Red Desert Complex HMAP Evaluation

It is causing confusing and is odd and awkward with the evaluations being broken into North and South, possibly maybe hopefully the EA will show as one document, and that the evaluations were simply done separate as it is two field offices under two separate districts and with two different wild horse guys that have their own work styles, and maybe it was easier for them to do it this way.

But... it could also be an indication that in the updating of the HMAP maybe there is some intent of changing how this complex is managed, if that is the intent then this is a fundamental change to how the HMAs in this complex are managed now, and brings into question long-term sustainability as these HMAs are inter-dependent on each other for the over-all herd health.

The scoping notice is your first document... a simple two page notice of intent to update the 30+ year old HMAP for Antelope Hills, Crooks Mountain, Green Mountain, Lost Creek, and Stewart Creek HMAs, more commonly known as the Red Desert Complex [RDC].

Also noted is the intent to remove 'excess' wild horses.

It tells us that an EA is being prepared for this planned action and that comments from the public on this scoping notice is due no later than May 4 2026.

Next is the Genetic Analysis, completed from samples taken during the RDC 2020 roundup and removal.... it shows the report to have been completed April 2025.

I really have not dug into this document... I am not a scientist and so a lot of it is confusing to me, I think it is an important thing, but not necessarily vital for scoping comments - if there is something that does need to be addressed in this comment period this blog will be edited.

We do not want to ignore the New World Iberian influence in Lost Creek HMA, it is mentioned in the evaluations that an error occurred during the genetic testing, however, the New World Iberian influence is not proven only through genetic testing - there are specific physical characteristics that identify the influence and there is a protocol that is to be followed when looking for and identifying the New World Iberian, it is to be preserved and it is not as simple as a genetics test that decides whether or not this influence still exists in the complex, specifically in the Lost Creek HMA.

North Red Desert Evaluation: Antelope Hills, Crooks Mountain, and Green Mountain HMAs managed by the Lander Field Office

**Arapaho Creek also is managed by the Lander Field Office

This is the longest of your documents to read through with 43 total pages, which is actually not too terrible as a good part of it is range images, graphs, charts, and maps.

It is pretty basic reading, with discussion of AML, fertility control options, roundup plans, water resources, grazing impacts, along with listing of various documents and BLM regulations.

It is noted that the HMAs are managed as a complex as the HMAs are adjacent to each other and there is 'animal interchange' between them.

AMLs for these HMAs were last established in 1993 and 1994 - we want to challenge those established AMLs with the most recent scientific studies showing the need for larger herds to ensure viable genetics and a healthy herd.

This becomes especially important if there is an intent to no longer manage this as an inter-dependent complex, allowing for and expecting the horses from the five HMAs to mix and intermingle with each other, with three HMAs in the complex low AML set to 60 and high AML of no more than 80 horses, it is critical that they be allowed - and encouraged - to migrate and interact with each other.

The wild horse specialist also argues that not counting foals as part of the horse population leads to incorrect population estimates in March vs actual population count in Fall - this seems to be the beginning of an argument to be able to count foals as part of the population during a roundup and removal, something that has been argued in court, and lost by the BLM.

The evaluation states that the Lander office was aware of a high mortality rate in the winter of 2022/23 but that they were unable to do a census count until 2025.

Budgets are short and a flight was not likely going to be approved for any kind of census count without a planned roundup - however - it was possible to observe from the ground living horses and the change in known herds, as well as documentation of death easily found in the first few weeks after snows began melting.

I know this personally from documenting individual mustang death and mustang family bands that died within feet of each other that winter, across several HMAs and Arapaho Creek, and I observed this by simply driving regular roads and 2-tracks.

I also observed changes in known horse herds and individual family bands.

It is then noted that the winter resulted in the horses moving greater distances in search of food, and that with fences under snow they crossed greater distances without restriction, with an additional statement that wild horse behavior causes them to seek new territory when the population is too high.

These statements are true.... the horses ALWAYS cross fences and cattleguards when snows are deep and drifts are hard packed over them - this is nothing new.

And horses will fill in the empty spaces across the land - that is true of any and all wild creatures, it is nature behaving in way that it is supposed to, it is not an absolute indication of over-population of horses.

I swear to you on all that I hold holy, at this time there is not an over-population of mustangs in the Red Desert Complex, and the reason they are being seen in areas not noted or documented before (by BLM), is multi-faceted.

The harsh winter forced a migration for survival during the snowy months, it also saw horses that had lost their entire herd frantically traveling miles farther than normal looking for any other horse that was alive, and it continues to force migration as more stallions than mares survived, and those stallions are searching for mares.

Currently we are in a drought, and they are adjusting again, traveling to where there is natural water sources when cattle are gone and human maintained water tanks are turned off for 6-8 months.

And sometimes wild horses travel and migrate just because... for reasons that are only theirs to know and understand.

It is literally in a mustangs DNA to find a way to survive.... they will migrate and move and adjust accordingly to what is occurring around them.

Livestock Grazing:

The evaluation states that livestock grazing has been reduced from historical grazing levels over the past decades in each allotment, it is unclear if this is referencing cattle/sheep grazing allotments or the assigned HMAs.

I would like to see documentation proving reduced grazing... if BLM states that grazing has been reduced, there should be documentation available.

Mining:

The evaluation states energy mining has a minimal impact on wild horses, at this time that is fairly accurate, but it does not discuss expectation of if/when uranium mining begins in one or more of the HMAs.

Uranium mining is no longer a pit mining type activity, but even still as surface mining it results in a significant loss of grazing acreage.

There are uranium mines in reclamation or dormant status in the Green Mountain HMA, along with a few oil wells, all are found at the western end of the HMA, this is not where the majority of wild horses will be found in the Green Mountain HMA, but there are a fair number of wild horses currently wandering around this area.

Their are also a few oil wells in a small part of Crooks Mountain HMA, not where most of the HMA horses typically are found. There are more oil wells on top of Crooks Mountain but this is outside of the HMA line.

There has been some uranium testing occurring along the Antelope Hills and Lost Creek HMA borders (that I personally am aware of), and there is a small oil field in Antelope Hills that stretches across a few miles.

It is not massive, but it is big enough to have taken some grazing areas, and if/when new uranium mining begins there will be more wild horse forage acreage lost.

Range Conditions & Forage Utilization:

This actually got examined here and I cannot tell you how shocked I was to see this!

This is supposed to be done for every single EA when proposing a wild horse roundup, but recently BLM offices have been skipping this step and not been challenged nearly enough on that failure to monitor range usage and provide the reports.

It is a pretty boring read and I am not going to get into it too deeply for the scoping comments, but there is important information here, and I encourage you to take your time to read through and understand what is reported.

For scoping comments I will focus on that only wild horses are being discussed in range usage, damage, or degradation - specific to but not limited to - riparian areas.

With the very ridiculous statement "The purpose of this management evaluation is not to parse out impacts by resource uses."

This is unacceptable - range use and impact by ALL users is necessary to accurately assess what damage may occur and the impact of each user.

It is not acceptable to ignore the impact of cattle and sheep grazing across the forage and water resources, including riparian areas.

Wildlife are natural and expected to be in these same places but their impact also needs to be recognized and measured.

It is unfair and an obvious bias to examine ONLY wild horse use of these areas.

South Red Desert Evaluation: Stewart Creek and Lost Creek HMAs managed by the Rawlins Field Office.

This document is a fairly quick read with only 26 pages, a fair bit of it is repetitive from the North Herd Eval with variations noted for the two HMAs managed by the Rawlins office as well as graphs, charts, and maps attached.

It is noted that there is an RMP amendment for Greater Sage Grouse that provides guidance for wild horse management, but this document was not provided for the public to review, which we need to be able to do.

There are various other documents reference that have not been provided within the project page for the public to be able to review.

There is no reference in this report to the changes in population or wild horse habits due to the harsh winter of 2022/23, which I do not know why as both Lost Creek and Stewart Creek saw significant death of and behavior changes in wild horses.

Livestock grazing is noted to have been reduced from historical levels just as it is in the North Herd evaluation, with no verifying documentation provided.

Mining:

The report notes there are active uranium mines in the complex, with the expectation that mining operations will expand in the near future, oil and gas wells are also noted to be present in the HMAs, with minimal impact on the horses.

There is a fair sized oil and gas field in the southwestern area of Lost Creek HMA, it extends beyond the actual HMA itself, and the horses do not seem to spend a lot of time around the wells.

Current uranium mining is most active here, with the Lost Creek ISR mine being active and expanding, the majority of the buildings for this mine exist in Arapaho Creek rather than Lost Creek, but the mining operation itself is expanding in all directions and has been for a few years now.

In addition there is ongoing testing for uranium in both Stewart and Lost Creek HMAs, with the expectation that there will be additional future mining.

This will result in loss of grazing and forage acreage for the horses.

Water:

The South Herd Eval report states there are recent water source improvements with other possible additional sources to be developed for wild horses.

The Rawlins office has even developed a water source that is freeze resistant and so is available to horses in winter months, when most water sources are nothing but ice!

To be clear - wild horses know how to find moisture in a drought, this is hardly their first time seeing a dry winter or summer, and they are built to survive.

But - with human encroachment continuously shrinking their ability to roam and changing the landscape with the constant development of energy mining, it is more challenging than ever for horses to do what they need to do.... they are restricted by fences and highways, they have lost acreage to various development, and their land has also felt and responded to the pressure from human development.

Wild horses are in a constantly evolving island created by humans, it is our responsibility to fill in the gaps of what has been taken, restricted, and lost due to human encroachment.

This approach by the Rawlins office of being aware of natural water resource availability, and then when needed developing additional water sources for the horses, should be a goal across the entire complex, not just one or two HMAs.

Fertility Control:

Stewart Creek currently is the only HMA in the RDC with a PzP fertility control darting program in place, but it is not discussed in the evaluation.

Because it was a new program for the Rawlins office no doubt there were challenges along the way, it probably has not gone as smoothly as hoped because there are always things to figure it when starting something new, but despite any hiccups and struggles I hope that this program is not being discarded with this EA.

I would also like to see darting programs in place in other HMAs across the complex.

I know many are unbendingly against any type of fertility control, but as we live in a time where the land is limited and the horses can only migrate so far, resources are also limited - even if all rancher grazing stopped and mining activity did not increase - the land and its resources are limited, a well planned and implemented fertility control program is the only best alternative to mass roundups available to us, at this time.

I feel we need to take a minute to discuss where in the reports it is stated that wild horses are encroaching on private property in a way they have not previously.....

Maybe - I don't claim to know every single acre and mile of the five HMAs because I am only human and no one knows all the things - but.... I have doubts.

There are several little pockets of private property in the RDC, there are a few rancher 'placeholder' property squares, there are a couple of rancher pastures, and some other random privately owned land, I have for years documented wild horses crossing through or staying for a season in these areas, but not necessarily taking up permanent residence on them.

There are changes... more people are spending time out here, some have bought a patch of property in the middle of wild horse lands and are attempting to live here either year around or as a summer vacation home, most recently there is a new house built on the western end of Green Mountain - with wild horses now grazing within a few hundred yards of this new home, the horses have never known it to be anything but a place for them to wander and be wild.

The horses have been in and out of the private land areas I have been observing for 15yrs now, there is nothing new in the horses behavior, it is something new in how or what humans are aware of and expect.

And that is my best summing up of the North Red and South Red Herd Evaluations.

There is of course SO much more that could and should be discussed but for the sake of this blog I am letting it go - for now....

We are now going to discuss the heart of the Red Desert Complex - Arapaho Creek.

Several years ago I learned a random bit of history of the Red Desert Complex that changed everything for me... it had not always been 5 HMAs with an HA in the middle - years before there was a very large single HMA called Seven Lakes.

At some point in time that one single HMA was broken apart and into the five individual HMAs we know to exist today, with the center of the HMAs - Arapaho Creek - being excluded from HMA status.

This is confusing as it is known, and expected, that the horses use this area and it was considered necessary for the wild horses of the complex to cross through and intermingle with each other, encouraging a healthy and genetically viable wild horse herd in the Red Desert Complex.

A few years ago BLM declared that Arapaho Creek would be completely zeroed out of any horses found there, these horses were targeted to be permanently removed during the 2018/2020 roundup and removal, despite that there were known horses to move in and out of this area from the complex HMAs.

Wild horses have been documented migrating in and out of Arapaho Creek from their respective HMAs and have been doing so for years, however, the Lander BLM field office continues to insist this is not an area wild horses should be found in, and plan on attempting to zero it out again.

I stand in complete and absolute opposition to this faulty plan.

I believe and have been arguing for years, that Arapaho Creek in fact needs to be recognized as natural and necessary wild horse land, and given HMA status.

The most obvious argument for this change is that it is a migrational area for the wild horses, I have documented horses from all five HMAs of the RDC migrating in and out of Arapaho Creek, often they move with the seasons following where there is water and best available grazing.... for several years Arapaho Creek is where horses from Green Mountain migrated to in winter, and then they returned to Green Mtn in summer.

I have documented horses wandering between Lost Creek and Arapaho Creek in summers, there were horses I knew only to be in Arapaho Creek, and another photographer knew only to be in Lost Creek!

I document horses regularly moving between Antelope Hills and Arapaho Creek as seasons change and fences are let down for migration.

The Crooks Mountain horses have been migrating in and out of Arapaho Creek across their mountain for years.... I could go on - you get the point - the horses move fluidly between the HMAs and Arapaho Creek.

It is a necessary land that the horses know to be part of their existence and survival.

When wild horses move across Arapaho Creek and into other HMAs it does not happen quickly - it does not happen in a week, a month, sometimes it takes more than a year of wandering before they find their way into the new HMA, and then they may stay in that HMA, or they may continue wandering.

In those years a bachelor stallion is going to encounter mares and perhaps a quick romance results in a new foal running around with his genetics.

A family band that has moved miles from their original birth home is now raising foals within a different HMA which allows new genetics to be introduced to that HMA.

This is all so very necessary to the health and genetic diversity of the RDC herd - this is how they stay mustang strong!

And of course in that migration, as they meander and wander along the trails that lead out of their HMAs and into Arapaho Creek, there are horses that decide they kinda like Arapaho Creek better.... and that is where they stay!

And as they and other bands wander along through Arapaho Creek, greeting other horses that are also wandering through from one HMA to the next, the genetics continue to be mixed among all of these different wild horse herds.

For the purposes of a healthy wild horse population in the Red Desert Complex, the horses need to be allowed and encouraged to naturally migrate, mix, and mingle.

Arapaho Creek must be considered a vital and necessary part of the Red Desert Complex - not a zero out area with no allowance for the presence of wild horses.

Thank you, for staying with me through this rather long rambling blog... hopefully it helped explain the process and now you know how and/or what you want to say when you submit your comments!

I hope you also see the possibilities.... it is daunting and concerning when these things come up - especially when there is discussion of removing wild horses from their wild land, but - it is also a good opportunity for us the public to be involved when our thoughts, suggestions, and our voice may have some influence in it.

In this particular process it is not just about the removal, it is about BLM examining how they manage wild horses in the Red Desert Complex, this particular action is not one that happens often, we do not want to miss this opportunity to possibly effect something good for the horses.

So we persist.... for wild lands and wild horses!