As of today (April 19 2025) we have 10 days left to submit comments to BLM re: the proposed Adobe Town HMA removal of 2,179 wild horses - here are a couple of thoughts as you prepare your comments:

1) This removal is planned using the newly revised HMA lines as set by the 2023 RMP amendment, which is currently in litigation as we are waiting for the 10th Circuit Court of Appeals decision re: the zeroing out of Salt Wells, Great Divide, and the shrinking of Adobe Town HMA. The most recent hearing was held in March and the court could take several months before issuing a decision.... it is inappropriate to plan and execute a removal of wild horses from areas that may still be considered part of the HMA, pending the court’s decision.

The opposition will argue that if the BLM loses this litigation they can 'just return horses' to the HMA. My response would be that the horses lives do not need to be (and should not be) disrupted for what can be delayed, not only does it disrupt the natural lives of the horses and result in unavoidable deaths for some, but it also spends tax payer money on something that could be reversed, which will cause further chaos for the horses and humans, requiring sorting out which horses will be returned to the wild, and once again disrupting the horses lives unnecessarily.

It costs nothing to pause this action until we have a decision from the court.

2) We would like to see the census count report, I asked and was told this was an infrared flight count and that they would provide the report to the public ‘in a couple of weeks’, it has been more than 2 weeks now since my request and the report has not been shared with me or the public.

There was an infrared count done in November 2022 and I have seen that report, I would like to also see the one stated to have been done in November 2024 - the winter of 2022/23 was especially harsh with a 50% or more loss in parts of the Red Desert Complex wild horses (my personal documentation), and the winter was known to be more harsh in southern Wy, especially in Adobe Town as stated by many, including ranchers and WY Game & Fish, but continuously denied by BLM staff.

I have had people contact me after that winter telling me they could not find any live horses where they knew them to be normally, and since have had others tell me of observing several wild horse bodies in Adobe Town following that winter - so I would really like for the public to be able to see that infrared report showing the data and maps of where they recorded 2,382 live wild horses in Adobe Town.

For reference the most recent counts completed in Adobe Town:

- 2019 statistical aerial flight count found 929 wild horses in Adobe Town followed by a roundup and removal in late 2021

- 2022 infrared aerial flight count recorded1633 wild horses in Adobe Town, this flight was completed before the snows became prohibitively deep with record sub-zero temps resulting in thousands of recorded deaths of ungulates.

- November 2024 aerial count finds 2382 wild horses in Adobe Town.

If there are 2,382 (assumed by BLM using herd growth statistics to now be 2438 in 2025) wild horses currently living in Adobe Town it would be helpful for the public to see this data for themselves.

3) July is still peak foaling season!

Years ago when the policy was written it may not have been, but that has changed, especially following the harsh winter of 2022/23 when surviving mares aborted or absorbed their pregnancy, and many were too emaciated to successfully breed in the normal early spring months.

There are other environmental factors that have changed when mares are successfully breeding and foaling the next year and all of it needs to be acknowledged and adjusted for, regardless of what is in the current BLM handbook.

I very much wanted to argue that there needed to be a new EA completed for this proposed removal in Adobe Town HMA, because this removal is related to the changing of the size of the HMA and the AML of allowed wild horses - and there is a stubborn part of me that believes it is still the right and correct thing to do.

There are a couple of extra smart people in my life that challenged me and asked a few key questions, and as I researched through the EA and the 2023 RMP, it became clear that the BLM was prepared for and addressed these expected changes in the EA and in the wild horse amendment to the RMP.

Per the final EA:

"At this time the Rock Springs and Rawlins Field Offices are in the process of amending their RMPs related to wild horse management (see Relationship to the Ongoing Wild Horse RMP Amendment in Section 1.1).

Because changes to wild horse management within these HMAs are likely to occur as a result of this RMP Amendment......

...... A Resource Management Plan (RMP) amendment for wild horse management is currently underway for the Great Divide Basin, Salt Wells Creek, Adobe Town and White Mountain HMAs. This RMP amendment is also analyzing possible changes to the AML for each of these HMAs."

I abbreviated from the full text of the EA as it is extremely wordy and a bit more than needed for this blog - you can read the full text in the final published EA.

And this per the final EIS and RMP published in 2023:

"The BLM hereby selects and approves the FEIS Proposed RMP Amendment Alternative (Alternative D) in its entirety, to address private land conflicts in wild horse management on checkerboard lands. Alternative D was developed based on the planning criteria described in Section 1.4 of the FEIS and refined in response to public comments on the Draft EIS and input from the Cooperating Agencies. This decision amends the Rock Springs and Rawlins Field Office RMPs as described in this section; the current RMPs will remain unchanged in all other respects:

• The Rock Springs Field Office (RSFO) portion of the Adobe Town HMA will revert to HA status and be managed for zero wild horses. In the Rawlins Field Office (RFO) portion of the HMA, all checkerboard land and the portion of the HMA north of the existing Corson Springs southern allotment boundary fence (see Map 3) will revert to HA status and be managed for zero wild horses. The remaining lands (within the RFO) will be retained as an HMA and managed with an AML of 259 – 536. ....

..... This analysis will include an in-depth review of intensive monitoring data including: grazing utilization, use patterns, Standards for Healthy Rangelands, trend monitoring, actual use, and climate data. BLM will prepare a site-specific environmental analysis, including opportunity for public comment, before making a decision to change AML within these HMAs. AML would not be evaluated each time a wild horse gather is proposed, but rather when a potential need for adjustment is indicated by monitoring data."

You can read the entire text in the final published RMP.

So while I may want to argue that a new EA should be done as Adobe Town HMA is now changed in size and AML per BLM, it was addressed in the final EA that the RMP amendment would likely alter the HMA and AML, and subsequently discussed in the RMP wild horse amendment.

Of course we can still comment asking for a new EA, however, as it has been discussed in both documents, it is unlikely a comment will be considered and it may possibly be dismissed as having been previously discussed by the EA and RMP.

To comment go to this link:https://eplanning.blm.gov/eplanning-ui/project/2037060/510

You can review the DNA document, then click Participate Now to enter and submit your comments, and you can also upload documents to support your comment.

I hope that this helps a little bit in forming your comments, I hope that you are able to take time and complete your own research as there really is a lot to weed through and understand, and each of us interpret things a bit differently.

I have no doubt there are other points to be made, these are just the ones that leap out at me and will be a part of my own comments - and if you have already left a comment and want to say more, you are allowed to leave more than one comment, so go for it!

Your comment does not need to be lengthy or scholarly, it should be factual and professional, and remember - to be silent is to consent.

Thank you for being a part of this journey, it is not for the faint of heart and it is not frivolous or fun, but it is necessary.