Scoping Comments
Re: DOI-BLM-NV-L060-2024-0013-EA
I respectfully submit the following scoping comments for the Pancake Complex:
AML was never set transparently at Pancake. BLM must provide rangeland data used to set the
current combined AML of 240-493 wild horses for the complex that spans more than 1 million
acres. Historic flaws created in the 40 years BLM has ignored HMAP preparation in the
complex. These flaws, such as AML, must be rectified and not perpetuated through the HMAP.
The average population numbers have exceeded 3500 without the herd showing any
deterioration in health. Data must be disclosed and triggers identified to raise AML.
Simply stating that the Jakes Wash Herd Area (HA) will not be analyzed because a Land Use
Plan (LUP) was created that set the AML of horses at zero, is not acceptable. Historically, Jakes
Wash has had wild horses living in the HA, is always included in the gather plan and has
numerous roundups just in Jakes Wash. This indicates that the area can support wild horses.
Please provide data and analysis that includes triggers and factors for setting an AML that
appropriately reflects reality: one greater than zero.
Water in limited in Pancake just as it is in every area in the West. BLM has approved mining that
is drawing down water tables and mitigated such factors by approving water improvements for
livestock. BLM must analyze appropriate water improvements for wild horse and wildlife use. H-
4700-1 3.4.1.4 provides appropriate guidance.
Pancake has an unusual population of both medicine hat and curly horses. The HMAP must
include a strategy to preserve these unique genetic traits that are important to both local history
and of cultural significance.
Actual foaling season must be identified through data. BLM has never defined actual peak
foaling season in the area. This data and monitoring must occur to protect foals from helicopter
drive trapping (prohibited during foaling season) and before BLM applies any fertility control that
can cause drastic changes to peak foaling seasons.
Tools being built through rewilding should be analyzed for suitability, particularly for the Monte
Cristo/Pancake area. This area is home to numerous species that could benefit from taking an
integrated multi-species approach. This area has a unique potential to preserve “wild Nevada”
for future generations.
Thank you.