Comments Needed for BLM’s Wild Horse Removal Plans for the Red Desert Complex in Wyoming

When the BLM announced the Scoping Document for the Red Desert Complex over a month ago, it was presented as providing new plans for managing the five Herd Management Areas: Stewart Creek, Green Mountain, Crooks Mountain, Lost Creek and Antelope Hills as well as the Herd Area of Arapahoe Creek in the Red Desert Complex in Wyoming. This was important since no new planning had been done since the 1990s. However, in the Environmental Assessment there is very little planning and it becomes clear that the true motive for these documents is a roundup before any planning is done to remove 1800 or more wild horses from the Complex.
BLM needs to do the actual planning and analysis BEFORE scheduling the roundup and removal of these horses.

Some of the vital things for the BLM to actually study and document is the impact of wild horses on the land, the impact of livestock grazing on the land, even though the BLM says that it is “difficult to quantify.” Yes indeed it is if you do not actually measure it. Does that mean you should not bother? I would say no.

Regarding the drought and wild horse usage there needs to be an actual measurement of the amount of water each animal on the range consumes – for example horses drink 7 gallons a day compared to a cow-calf pair consuming 40 gallons per day.

The impacts of all the multiple uses need to be considered – wild horses, other wildlife, livestock, mining, recreation. Simply saying something is outside the scope of this document does not make it true. AMLs, changing status of an HA to an HMA, measuring usage of forage and water, all those things should be considered in this plan.

I have been visiting the Red Desert Complex since 2016 and observing and documenting the horses at least 5 trips per year each year. The wild horses are currently in excellent condition, yes the snowpack is the lowest on record for 2026, but there is currently sufficient water and forage. With climate change, drought conditions need to be planned for and considered.

Ideally, every person that comments on this management and removal plan will read the entire 249 page document, and you should if you have the time.

Here is where to read it: Red Desert Compex EA – Go to Documents.

I’m going to give you what in my opinion are some of the most important points to focus on – but please use your own words. These are merely a suggestion of what to consider.

1. This is not a Herd Management Area Plan, it is a roundup and removal plan. Before any wild horses are removed, the actual HMAP plan needs to be developed, stuidied and implemented. No roundup should be scheduled at this time.
2. No Action Alternative should be selected for the roundup.
3. Appropriate Management Levels for each Herd Management Area need to be raised to at least 100-150 horses.
4. Arapahoe Creek, which is in the middle of the Complex and allows wild horses to move between each HMA, allowing for genetic viability and provides water and forage for all the animals, should be restored to HMA status.
5. Water use and forage use should be studied for all of the animals living in the complex. Wild horses should not be scapegoated for drought conditions or for any and all range degradation – there must be separate measurements and proof.
6. If the BLM proceeds with a roundup, no GonaCon or spaying of mares or gelding of stallions should be employed. These are all permanant sterilization meaures that cannot simply be “adjusted” at a later time. If birth control is to be employed, PZP should be the only method.
7. Sex ratio skewing of 60-40 stallions to mares should not be employed. It disrupts wild horse families, resulting in excessive fighting and instability.
8. The disposition of the wild horses after removal needs to be considered. With over 60,000 wild horses in holding facilities and documented cases of horses going to slaughter after being sold, keeping them on the range where they currently live is the safest place for them to live, and the most cost effective solution.

Please submit your comments by July 13. You can submit more than one comment and you can comment even if you did not comment during the Scoping period. Your comments matter, and the horses depend upon us to speak up for them.

You can submit your comments online here: Comments Submission Link

Click on the green Participate Now button.

If you would like more information from someone who has spent 15 years visiting the Complex and has done extensive background research, go to Angelique Rea’s blog:

Angelique Rea’s Blog on Red Desert Complex EA