We, the undersigned, respectfully request that BLM extend the comment period for the Antelope Complex and Triple B Complex HMAP (DOI-BLM-NV-L060-2025-0001-EA) out to 60 days. Scoping of this size and intensity represents the largest and most complex ever presented by the BLM Wild Horse and Burro Program. Scoping of this depth is akin to a scoping for mining and requires ample time for appropriate participation.
Before proceeding, BLM must consider that they are exceeding their authority by combining two distinct complexes into one HMAP. The court has already determined that a gather plan is not a management plan (HMAP) and BLM needs to see them as distinct processes. The court already recognizes the assertion BLM themselves reiterated: HMAPs may be prepared for a single HMA or a complex of adjacent HMAs where animal interchange occurs. The distinct Triple B Complex and the distinct Antelope Complex do not meet any of the guidance parameters for one HMAP but meet the guidance for two distinct and carefully analyzed HMAPs.
BLM must not simply provide a "point on a map and number" as presenting data. Each study/data point referenced must be accompanied by a date and link to the actual data sheet. Please promptly provide data required for appropriate public participation and a sound HMAP. Without this information the HMAP process is hollow. At the very least, BLM must compile this information and make it available for viewing onsite with enough time provided to review the data before close of comments.
Thank you.