To: BLM Lander and Rawlins Field Offices, Wyoming
Re: Preliminary Environmental Assessment, Red Desert Complex Wild Horse Gather and Herd Management Area Plan (DOI-BLM-WY-R050-2026-0012-EA)

We, the undersigned members of the public, are commenting on the Red Desert Complex plan. Wild horses and burros are a public lands issue — these animals and this land belong to all of us, and the law gives us a right to take part in how they are managed. 

We are asking BLM to do the real analysis before deciding, and to fix the following problems before this plan is finalized. Predetermination of the outcome is more than apparent in how BLM has drafted the EA after Scoping. 

1. Don't zero out Arapahoe Creek without doing the analysis

The plan would remove every horse — more than 260 animals — from Arapahoe Creek and other areas outside the herd boundaries, while leaving those same areas fully stocked with cattle and sheep. Zero horses and full livestock is not balance. BLM cannot zero out horses this way without first studying the "thriving natural ecological balance" the law requires. BLM is relying on historic movement to maintain low AMLs in individual HMAs in the complex. By zeroing out Arapahoe Creek BLM invalidates any asserted viability of AML.  BLM should do that study, or drop the zero-out. 

2. Compare water use honestly

The plan blames drought on the horses but never measures how much water the other animals use. A cow-calf pair drinks about 40 gallons a day; a wild horse drinks about 15 — and BLM's own cited research in this very document puts horses even lower, near 7 gallons. By BLM's own numbers, cattle use far more water per animal. The plan also never addresses any specifics on the drought it keeps invoking, even though Wyoming's 2026 snowpack was the lowest on record. Before deciding who to remove, BLM should add up the water use of horses, cattle, and sheep side by side, under the real drought conditions. A determination must be made to identify triggers for education and removal of livestock. 

3. Do a real management plan — and follow it

This document calls itself a Herd Management Area Plan, but it refuses to do the planning a real one requires. When the public asked BLM to look at adjusting livestock to protect water and forage, the agency said no because that "would require a land-use plan amendment." But that is exactly the kind of honest result a real plan can reach. A court has held that "a removal plan is not a management plan" (Leigh v. Raby, 2024). BLM should do the analysis and follow it where it leads — even if that means amending the plan. An HMAP can amend a Land Use Plan and these comments are not outside the scope of an HMAP. 

4. The purpose and need is overly narrow and simply states a predetermined conclusion. 

The purpose and need is defined as removing wild horses to the low end of AML "as expeditiously as possible." Both action alternatives (A and B) reach that same low-AML endpoint; they differ only in whether fertility control is applied or removal is used alone (EA at lines 491–503). When every action alternative produces the identical outcome and only the method varies, the agency has not analyzed a range of alternatives — it has analyzed a single predetermined result. See 40 C.F.R. § 1502.14(a) (agency must "rigorously explore and objectively evaluate all reasonable alternatives").

A note on predetermination

These are not three small oversights. Together they show a plan written backwards. The law (the National Environmental Policy Act) says the analysis must come first and shape the decision — environmental documents may not be used "to rationalize or justify decisions already made." But this plan says up front that it "does not address setting or adjusting AMLs" and "does not address adjusting livestock use." It treats horse numbers set under land-use plans from 2008 and 2014, based on herd evaluations more than thirty years old, as fixed. Both action alternatives reach the same endpoint — remove horses to the low number — and every alternative that might change that result is ruled "outside the scope." When a plan is built to protect a conclusion instead of test it, that is predetermination, and it is exactly what the law forbids.

We are not asking BLM to reach our preferred answer. We are asking BLM to actually analyze before deciding, and to let the public's comments matter.

Our request

Please do not finalize this plan as written. Correct these problems and let the public comment on a corrected version. The people who own these lands and these animals deserve a decision built on real analysis — not a conclusion reached before the questions were asked.