Comments: DOI-BLM-NV-B010-2022-0019-EA Roberts Complex Wild Horse Gather-EA

This PEA is inadequate and represents the severe neglect given to wild horse and burro management in the Roberts Complex (Kobeh HA) area. The 1989 Land Use Plan (LUP) may be the oldest in country. Every document noted, including the 2004 FMUD, is rooted in the LUP that was finalized around the time that the Code of Federal Regulations (CFR) for wild horses was completed and does not incorporate the final rules. The internal BLM handbook for wild horse and burro management was finalized nearly 20 years after the LUP. 

Until the LUP is amended, or an HMAP-EA is created, to address the known deficits in the LUP surrounding the Roberts Mountain Complex, this PEA for a ten-year gather plan is simply dereliction of the duties implied in the 1971 Wild Free-Roaming Horses and Burros Act. The PEA is simply the definition of "arbitrary and capricious. "

The PEA must be remanded and rewritten as an LUP amendment or HMAP-EA that tiers to a Gather-EA. 

Thank you,