
Ep #50: A Win for Wild Horses: Shutting Down the Adoption Incentive Program
March 31, 2025
Ep #51: Comment Against the Zeroing Out of Wyoming’s Checkerboard Herds
April 21, 2025by Carol J. Walker April 14, 2025

People often ask me “Why is it important to submit comments for actions that the Bureau of Land Management is proposing for our wild horses when it seems as though they never listen to comments from the public?”
It is important because without comments from the public, the BLM can say that no one is opposed to their actions. And yes in fact they do make changes sometimes to Environmental Assessments based on response from the public. And if there is any hope of making changes to the way BLM manages our wild horse on our public lands, I am going to be there pushing for it, demanding it, every step of the way. I hope that you will be there too.
There were two public comment periods opened for the Checkerboard Herds which are Adobe Town, Salt Wells Creek, Great Divide Basin and White Mountain. Since BLM already conducted a devastating roundup in White Mountain last August, it is not one of the herds they plan to roundup starting July 15. They plan to remove 3,624 wild horses from Adobe Town and Salt Wells Creek.
Part I
The Resource Management Plan Amendment in Rock Springs and Rawlins which was finalized in May 9, 2023 https://eplanning.blm.gov/eplanning-ui/project/2009946/510 changed the way that these herds will be managed. All of Salt Wells Creek Herd Management Area has been changed to a Herd Area, managed for zero wild horses. All of Great Divide Basin Herd Management Area has been changed to a Herd Area managed for zero wild horses. The Rock Springs portion of the Adobe Town Herd Management Area has been changed to a Herd Area managed for zero wild horses, but the Rawlins managed portion of Adobe Town will remain a Herd Management Area with a greatly reduced Appropriate Management Level of 259-536instead of 610-800 wild horses. The last roundup in these herds was conducted in 2021.
White Mountain Herd Management Area was initially designated to be left alone and not zeroed out under the RMP, but to not be managed as a non-reproducing herd and left with an Appropriate Management Level of 205-300. However, since then, the Rock Springs Grazing Association has announced that they have withdrawn their consent for wild horses to be allowed in the Checkerboard, and we initially heard that there would be an amendment made to the RMP this year to change the status of this herd to a Herd Area managed for zero wild horses. This has not happened yet, but we just found out by the BLM’s own count, after the roundup there were only 79 wild horses left, which is BELOW the low Appropriate Management Level, below the number needed to maintain the herd, and a clear path to extinguish this herd.
Our team, led by American Wild Horse Conservation and including Animal Welfare Institute, Western Watersheds Project, Kimerlee Curyl, Chad Hanson, and me, Carol Walker, represented by Eubanks and Associates, sued in May, 2023 to prevent this zeroing out of the herds. We lost in District Court, but appealed to the 10th Circuit Court. In March of this year I attended the Oral Argument in Denver where Bill Eubanks representing us as well as attorneys representing two other groups presented arguments in front of a panel of three judges. These judges have not yet ruled so we do not yet know what the final outcome will be.
Even though the decision has not yet been made, BLM released the plans for roundups starting July 15, 2025. The judges are aware of this, but it could take several months before they issue a decision. The BLM is clearly confident that the court will rule in their favor, or they are jumping the gun to appease the Rock Springs Grazing Association, or both.
The first of two documents that the BLM has released with a roundup plan is a DNA which is a Determination of NEPA Adequacy for Adobe Town which states that BLM can take this action without further analysis because they already have their 10 year plan released in 2021 to bring the herd to low Appropriate Management Level of 259 and use PZP for contraception on 129 mares that are to be released. They estimate there are 2438 wild horses in Adobe Town and they plan to remove 2179.
I completely disagree with this. Please comment for the BLM to take no action.

- First, a 10 year plan should not be in place – every time an action is taken, there should be an opportunity for public comment. There should be a full NEPA analysis done of the area and impacts and new population counts done. The “low AML” number is not the number before the RMP amendment was put into place – it is the new number and if we win our lawsuit, the low AML number should revert to 610. If they are going to use the 2021 documents then they cannot just randomly change things without doing a new Environmental Assessment. No plan should be finalized until after the 10th Circuit Court has ruled.

2. Wild horses are still foaling throughout the summer and fall in this area. Conducting a helicopter roundup in mid July will risk harming heavily pregnant mares and newborn foals.
3. The winter of 2022-2023 was the harshest and most devastating to all wildlife in this area since 1973. Adobe Town was the epicenter of the worst deaths, and probably half of the wild horses in the area died, right after the roundup in 2021. There is no possible way that there are that many horses in the HMA.
4. I have grave concerns about how many horses will be removed especially after the White Mountain debacle where they left only 79 wild horses at the end of the roundup when the minimum they were supposed to leave was 205. Despite my requests and concerns they did not do a count of the horses left immediately after the roundup when it would have been easy to return horses to leave the herd at 205. The count immediately afterward is common practice for BLM. If this herd is rounded up it is imperative that a count is done immediately to ensure the herd is not taken below the low AML prior to the RMP Amendment of 610 wild horses.
5. Last, what will happen to the horses once they are removed? BLM never considers this in their proposals. Given that the holding facilities are full to bursting with over 68,000 wild horses and given that Project 2025 calls for killing the wild horses in holding facilities, this zero out roundup plan will likely mean a death sentence for these 2179 wild horses that would be removed.
You can make your comments online and view the documents here:
Click on the green “Participate Now” button to submit comments in your own words. As always, I recommend you do this rather than sign onto a form which will BLM will count as one comment no matter how many hundreds of people sign on
Comment here: https://eplanning.blm.gov/eplanning-ui/project/2037060/570
The deadline for this comment period in Adobe Town is April 28, 2025.
Please feel free to use any of my suggestions and comments to make your own.
Part II

The next comment period is for the zeroing out of Salt Wells Creek, Great Divide Basin and the Rock Springs managed portion of Adobe Town.

“The purpose of this proposal is:
- To remove excess wild horses from Herd Areas that have been determined to be unsuitable for the long-term management of wild horses due to the presence of interconnected private lands, and
- To remove wild horses from private lands within these Herd Areas as requested by the private landowner.
This plan includes removing all wild horses from these areas, estimated to be about 2755, and this is a plan to zero out the herds entirely, leaving no wild horses.
This zero out plan is a direct result of the Resource Management Plan Amendment being finalized in May, 2023. If the 10th Circuit Court rules in our favor and overturns the RMP, then the BLM cannot proceed with the zero out plan.They can, however, conduct a roundup down to the previous low AML numbers of 251 for Salt Wells Creek, 415 for Great Divide Basin and 610 for Adobe Town, but this would require a new Environmental Assessment.
A survey of the areas was conducted in fall 2024 to winter 2025 and the numbers in each area are said to be: Adobe Town (Rock Springs portion) 736, Salt Wells Creek 1125 and Great Divide Basin 894. Because of the RMP amendment all wild horses in these areas are determined to be excess and need to be removed.
1. The main point that needs to be made here is no plan should be finalized and no roundup activities should be conducted until the judges make their decision.
BLM may say it’s going to take several years to completely zero out the herds but you can be pretty sure they will do everything they can to take every single horse this year, and what will be left will be a completely gutted herd with a handful of horses.
2. No Action Alternative – BLM will not conduct a roundup – this is the one to select.
3. There has been no determination that due to the presence of the horses that a thriving natural ecological balance does not exist – it is simply that the RMP has been revised. Zeroing out these herds is a violation of the 1971 Wild Free-Roaming Horses and Burros Act.
4. Adobe Town has only about 10,000 acres out of almost 500,000 acres that is in the Checkerboard – yet they plan to zero out more than 1/4 of the area, 118,164 acres because the horses would ”constantly stray onto private land.” No this is not how the Act works. Section 4 says if a private landowner requests horses be removed from private land they should be removed – not that you can remove them IN ANTICIPATION of their straying.
5. The BLM considers “foaling season” to be between March 1 and June 30 and prohibits helicopter roundups during this time. But foaling season continues all summer and into fall and it is not safe or humane for small foals and heavily pregnant mares to be chased by helicopters.
6. Salt Wells Creek is home to the largest number of rare wild curly horses. Zeroing out this herd would remove this rare wild horse population, and since the only other herd in Wyoming with wild curlies has been taken down to 79 horses, this is the last herd that contains these rare genetics. These horses should not be zeroed out.

7. Last, what will happen to the horses once they are removed? BLM never considers this in their proposals. Given that the holding facilities are full to bursting with over 68,000 wild horses and given that Project 2025 calls for killing the wild horses in holding facilities, this zero out roundup plan will likely mean a death sentence for these 2755 wild horses that would be removed.
This comment period ends April 30, 2025 at 4pm MT. You can read the documents and comment here online by using the green “Participate Now” button.
Comment here: https://eplanning.blm.gov/eplanning-ui/project/2032715/570
As always I request that you use your own words instead of signing onto a form which the BLM counts as 1 comment even though hundreds of people have signed onto it. You are welcome to use my suggestions to make your own comments. Please submit your comments in the links I have provided, NOT on this blog post. The only way BLM will be able to register your comments is from their site.

95 Comments
Carol has perfectly laid out already all of the key points. I 100% agree with her points, and completely against these constant removals!
Thank you.
Carol, I am heartbroken over the treatment of our wild horses. It has become very emotional for me on how the greed and avarice continues and our government keeps looking the other way.
I let my congressman know even though I live in the Midwest. It is so frustrating to see that nothing seems to happen in favor of the wild horses.
I understand. Unfortunately it can get worse. Hang in there – we just need to keep fighting for them.
Please save the wild horses. Do not keep getting rid of them. I m praying for them. I am sure they are not hurting anyone.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
I agree with Carol I find it disgusting that everything we as humans touch we destroy those horses deserve to live there. The genetics they want to destroy is so sad.
I totally agree that the BLM removals be postponed until the Courts Rule on the Checkerboard HMAS in Wyoming. I do not support LOW AML’s and Non Producing Herds treated with Gona-Con. I am asking BLM to consider Relocating the Salt Wells Creek Curly Horses if they have to be removed from Salt Wells Creek. I agree that the Public Needs to be able to comment on ALL Helicopter Removals S scheduled by BLM.
Please submit your comments here: https://eplanning.blm.gov/eplanning-ui/project/2037060/570
I agree with Carol. No more roundups
Please do not kill these precious animals these blood lines date back to the 1700 and should be preserved as
PART OF American history..
And adopting is not for the regular person WHO THINK THEY CAN JUST GET ON N GO ..
.I suggest for adopters there should be more education on how to break and train these gifts from God..They can not be adopted on a wim of someone who wants a horse because they haven’t been touched ..they are the way god made them ..and should stay that way ..but I think it would help to educate people to have the horses at least tiped trained before theybtake them..personally I would have to board out..and alot of facilitys are not equipped with those stalls needed ..and being tip trained would help get the owner time to find a proper trainer to make them into safe riding horses keep them out of the slaughter pipeline
.and with education on what’s involved in owning and caring for them …..please realize ..we would not be here today without them ..and the military still uses them today…these animals could be used as a benifit for veterans with PSTD since horse therapy is approved thru the Veterans Administration
They are NOT to be thrown away and killed because they are not usefull..put the right people in the right places to help them succeed and be beneficial to people who need them.
.PLEASE PLEASE
.do not kill them or ship them to someone who will..
They got us here pulling the wagons and got us thru wars..look at Sgt reckless ..make these animals safe and usefull ..come up with some program for adopters either educatiing them on how to train them and make them safe or maby..help with the expenses of boarding and maintaining
.which id be truly interested in both ideas and id love to own 1 again ..these make great saddle horses when trained right and made safe..id be proud to own 1 myself if the expense for boarding wasn’t so much…that is what priced me out of owning now..im a 50 owner but my horse have passed ..we need young people to get interested because some 1 needs to take my place when I go and my head of horse knowledge will be gone …I truly BEG of you.
Relocate them off these lands if you want 0 herds ..but do not kill them ..they have lasted since the 1700s they are tough and hearty could survive about anywhere if relocated ….but Please do not kill them
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
I think it is a tragedy for the next generation. We are removing some of Gods most beautiful creatures. For my Grandchildren to never have the spiritual experience of seeing ACTUAL wild horses roam and be free is again a tragedy and CAN be avoided. There has to be another solution
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
I also agree with Carol and support protecting these horses. Please stop the unnecessary roundups. Thank you.
Wild horses live free and run free !
Please keep it that always for the life and love of our wild horses.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
These horses are as much apart of out nation’s heritage as are bald eagles. These horses need to be preserved so that future generations can enjoy this rich heritage too. Please keep them free!
It is important to preserve these wo wonderful horses. They should live free and wild and not be removed only because of profit interests. These horses are a symbol for America
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
These horses need to be protected and preserved. They are our National Heritage.
Horses are our heritage. We need to protect them so they can stay wild and preserved.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Protect our wild horses by leaving them alone! They are living history that you are killing by reckless helicopter roundups (even during failing season!) and all for the benefit of money grubbing landowners – protect our free range and the horses that have called it home for centuries!
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Leave the horses in peace. tell ranchers to use their land not ours.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Disgraceful, cruel, totally unacceptable and unnecessary. Leave them be – they deserve to be wild as God intended.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Please leave these herds alone. You’ve destroyed enough herds already. Some of these mustangs are worthy of leaving alone. Where are you going to put them? I think most holding facilities are already maxed out.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Leave the wild horses alone. Fat lazy Livestock owners need to keep their livestock on their own property not public lands.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Disgraceful, cruel, totally unacceptable and unnecessary. Leave them be – they deserve to be wild as God intended.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Carol
Thank you so much for writing the suggestions. I know what to write now. Pray you guys win the case for the Wyoming horses
Thank you – me too!!!
The west would not have been settled without horses.
Is this the way the BLM shows the respect they deserve?
These corrupt and heartless practices have got to stop.
There are thousands of mustangs already barely surviving in the over crowded, under cared for holding pens.
This is insanity.
Gathering more mustangs that the BLM will let die in filthy, infectious conditions. Tearing families apart. Killing pregnant mares and newborns by running them into the ground with helicopters.
Hiring sadists under the guise of “wranglers”. Rep. Titus caught them from photo documentation. None of us will believe this was an isolated event.
He. Just. Got. Caught!
The advocates in the West are screaming for change.
How much longer can the corruption last?
Not one of these “officials” have a clue of the ethics and morals they trampling over.
Stand down.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Leave the wild horses
alone.!! They
Were there before humans came in.
Stop the round ups until the BLM can set a plan in place for the mustangs languishing in holding pens.
And NOT a slaughter truck to Mexico!
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
WHY do so many of these commenters ignore the fact that it does NO GOOD to comment HERE!
This happens every time and Carol, you always state that in the body of the post as well as here.
I hope the many people who post here also go to the link & do some good!!
The whole Project 2025 issue should cause folks to rise up as they did way back in 1971. But too many are unaware of the exactly what it says.
Will Comment.
Thank you Maggie. Look for my podcast I’ll be doing with Deb Coffey on Project 2025 in May.
Will do – super to hear from Deb Coffey AND you
Thanks,
Magie
Please leave this band of
Beautiful wilds alone..
They are hurting nobody.
No more bloodbath..
Tell people to eat beef..
Horses are not meant for
Human consumption.
Why does the BLM recklessly ignore their remit to protect and preserve the wild horses of the USA? Because of the ranchers who are on their board exercising undue influence on government business. How is this legal? It is not. The ranchers are the enemy of the horses when they should be their champions! Study after study shows the beneficial impact of free ranging horses on the range biome. Horses are used for conservation grazing everywhere in the world, they eat what the cattle and sheep don’t. So can we not educate the ranchers? They actually need the horses to help preserve the health of the range. Cattle and sheep grazing harm it. Long term the grazing quality will be useless, so wake up ranchers!
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Leave the wild herds ALONE! They are one of the last free historical representations in America. They should be PROTECTED not MURDERED.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Save the checkerboard wild horses. They are previous to America. Stop the round ups and kill pens.
Stop the removal of the checker board wild horses
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Absolutely against the zeroing out of these checkerboard wild horses!! For many good reasons but most of all the land belongs to them not just the ranchers and cows
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Please don’t let them wipe out our horses
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Yeah tomorrow please don’t take away our Treasures
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
These herds are part of our National heritage. It’s more important now than ever as we are quickly losing our freedoms, to protect the freedoms of these magnificent animals. No more round ups!! They are abusive and horrific to see. Leave the wild herds alone!!
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
This is the most stupid way to go about this.
It is not a problem for any one except the greedy rich
ranchers. Let the wild
beings stay at their homes !!!
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Let wild horses stay on the land that is their
home…
Why do we need to take from the wild horses on land they have roamed on for hundreds of years to make room for the cattle herds run by corporations most likely. The wild horses have more say to be there than the cattlemen. It’s not even like u want to take a small amount you want to blanking take them all away. The blm works for the people not themselves or the park managers. There is absolutely no need to desacrate the herds over someone’s pocketbook. STOP ✋!!!
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
The American people want these horses protected. The roundups should be against the law. Money and greed are in power.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
it is illegal to remove wild horses. It costs tax payers millions, it is very inhumane to use helicopters. Babies and others get killed or euthanized. The pens are inhumane. So many get sold to slaughter which is horiffically inhumane. All for greed of BLM
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Agree 100% with Carol’s points. Leave our Wild Horses Alone! I am completely against these constant removals and wasted taxpayer money.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
I submitted a comment. Thank you for your continuing work to keep wild horses wild.
Thank you!
LEAVE THE WILD HORSES ALONE 💔
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
these wild horses are a part of our American heritage. Please do not round up these horses and zero out this herd. There’s very few things in this great country of ours that we can cherish from our past history. these beautiful creatures deserve to live wild and free without the horrendous helicopter round ups. The splitting up of families and falls from their mother’s is heartbreaking again, please do not zero out or round up this herd.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
This country was built on the backs of horses & burros. This is how we thank them? I don’t agree with the removal of the Salt Basin horses. From wild and free and beautiful to a horrible round up? It’s apparent we can please leave many horses still in place. Wild & free as they should stay. Carols plan outlines all the necessary measures.
To destroy these Wild Horses is to kill what naturally belongs here, Cruel to them and horrific ! Let us preserve the beauty and spirit that God gave to us in these magnificent noble animals.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Please let these beautiful wilds
That have survived this far on
There own run free…it’s
Heartbreaking to see and hear
The terror as there being chased
Bye choppers..then slaughter..
When is it ever going to end.!
Please save the wild horses.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
Thanks for heads up on the critical importance we get our strong and well-founded comments in to oppose these outrageous plans to decimate Wyoming’s and some of America’s greatest remaining mustang herds! Thanks for your intelligent and knowledgeable guidance on what points to bring up in addition to my own. These are critical times and for Wyoming and for America to lose its wild horses would be an utter disaster!
Thank you Craig!
Stop these round ups immediately. I do not want any tax payer money used to fund this program of rounding up wild horses by the BLM.
Please use the links in this post to send your comments to the BLM. They will not be reading your comments here.
We made the same mistake in Germany to round up all wild horses. Now only 1 herd is left and they are protected as much as possible. Do not make the same mistake 🐎🙏
Leave them alone!!!
I am totally against the existing management guidelines and procedures for our wild horses. LEAVE THEM ALONE! It is inhumane and unacceptable. There are other and better methods for controlling the size of the herds
Please submit your comments here: https://eplanning.blm.gov/eplanning-ui/project/2037060/570
They can’t do this! For so many reasons.
Please don’t wipe out this herd! The greed that the ranchers have is destroying the Mustang herds!
Please make sure comments are submitted to official BLM site, unfortunately commenting here will not make a difference