Comment Against the Zero Out of Wyoming’s Checkerboard Herds

by Carol J. Walker April 14, 2025

People often ask me “Why is it important to submit comments for actions that the Bureau of Land Management is proposing for our wild horses when it seems as though they never listen to comments from the public?”

It is important because without comments from the public, the BLM can say that no one is opposed to their actions. And yes in fact they do make changes sometimes to Environmental Assessments based on response from the public. And if there is any hope of making changes to the way BLM manages our wild horse on our public lands, I am going to be there pushing for it, demanding it, every step of the way. I hope that you will be there too.

There were two public comment periods opened for the Checkerboard Herds which are Adobe Town, Salt Wells Creek, Great Divide Basin and White Mountain. Since BLM already conducted a devastating roundup in White Mountain last August, it is not one of the herds they plan to roundup starting July 15. They plan to remove 3,624 wild horses from Adobe Town and Salt Wells Creek.

Part I

The Resource Management Plan Amendment in Rock Springs and Rawlins which was finalized in May 9, 2023  https://eplanning.blm.gov/eplanning-ui/project/2009946/510 changed the way that these herds will be managed. All of Salt Wells Creek Herd Management Area has been changed to a Herd Area, managed for zero wild horses. All of Great Divide Basin Herd Management Area has been changed to a Herd Area managed for zero wild horses. The Rock Springs portion of the Adobe Town Herd Management Area has been changed to a Herd Area managed for zero wild horses, but the Rawlins managed portion of Adobe Town will remain a Herd Management Area with a greatly reduced Appropriate Management Level of 259-536instead of 610-800  wild horses. The last roundup in these herds was conducted in 2021.

White Mountain Herd Management Area was initially designated to be left alone and not zeroed out under the RMP, but to not be managed as a non-reproducing herd and left with an Appropriate Management Level of 205-300. However, since then, the Rock Springs Grazing Association has announced that they have withdrawn their consent for wild horses to be allowed in the Checkerboard, and we initially heard that there would be an amendment made to the RMP this year to change the status of this herd to a Herd Area managed for zero wild horses. This has not happened yet, but we just found out by the BLM’s own count, after the roundup there were only 79 wild horses left, which is BELOW the low Appropriate Management Level, below the number needed to maintain the herd, and a clear path to extinguish this herd.

Our team, led by American Wild Horse Conservation and including Animal Welfare Institute, Western Watersheds Project, Kimerlee Curyl, Chad Hanson, and me, Carol Walker, represented by Eubanks and Associates, sued in May, 2023 to prevent this zeroing out of the herds. We lost in District Court, but appealed to the 10th Circuit Court. In March of this year I attended the Oral Argument in Denver where Bill Eubanks representing us as well as attorneys representing two other groups presented arguments in front of a panel of three judges. These judges have not yet ruled so we do not yet know what the final outcome will be.

Even though the decision has not yet been made, BLM released the plans for roundups starting July 15, 2025. The judges are aware of this, but it could take several months before they issue a decision. The BLM is clearly confident that the court will rule in their favor, or they are jumping the gun to appease the Rock Springs Grazing Association, or both.

The first of two documents that the BLM has released with a roundup plan is a DNA which is a Determination of NEPA Adequacy for Adobe Town which states that BLM can take this action without further analysis because they already have their 10 year plan released in 2021 to bring the herd to low Appropriate Management Level of 259 and use PZP for contraception on 129 mares that are to be released. They estimate there are 2438 wild horses in Adobe Town and they plan to remove 2179.

I completely disagree with this. Please comment for the BLM to take no action.

1. First, a 10 year plan should not be in place – every time an action is taken, there should be an opportunity for public comment. There should be a full NEPA analysis done of the area and impacts and new population counts done. The “low AML” number is not the number before the RMP amendment was put into place – it is the new number and if we win our lawsuit, the low AML number should revert to 610. If they are going to use the 2021 documents then they cannot just randomly change things without doing a new Environmental Assessment. No plan should be finalized until after the 10th Circuit Court has ruled. 

2.  Wild horses are still foaling throughout the summer and fall in this area. Conducting a helicopter roundup in mid July will risk harming heavily pregnant mares and newborn foals.

 3. The winter of 2022-2023 was the harshest and most devastating to all wildlife in this area since 1973. Adobe Town was the epicenter of the worst deaths, and probably half of the wild horses in the area died, right after the roundup in 2021. There is no possible way that there are that many horses in the HMA.

4. I have grave concerns about how many horses will be removed especially after the White Mountain debacle where they left only 79 wild horses at the end of the roundup when the minimum they were supposed to leave was 205. Despite my requests and concerns they did not do a count of the horses left immediately after the roundup when it would have been easy to return horses to leave the herd at 205. The count immediately afterward is common practice for BLM. If this herd is rounded up it is imperative that a count is done immediately to ensure the herd is not taken below the low AML prior to the RMP Amendment of 610 wild horses.

5. Last, what will happen to the horses once they are removed? BLM never considers this in their proposals. Given that the holding facilities are full to bursting with over 68,000 wild horses and given that Project 2025 calls for killing the wild horses in holding facilities, this zero out roundup plan will likely mean a death sentence for these 2179 wild horses that would be removed.

You can make your comments online and view the documents here:

Click on the green “Participate Now” button to submit comments in your own words. As always, I recommend you do this rather than sign onto a form which will BLM will count as one comment no matter how many hundreds of people sign on

Comment here: https://eplanning.blm.gov/eplanning-ui/project/2037060/570

The deadline for this comment period in Adobe Town is April 28, 2025.

Please feel free to use any of my suggestions and comments to make your own.

Part II

The next comment period is for the zeroing out of Salt Wells Creek, Great Divide Basin and the Rock Springs managed portion of Adobe Town.

“The purpose of this proposal is:

1. To remove excess wild horses from Herd Areas that have been determined to be unsuitable for the long-term management of wild horses due to the presence of interconnected private lands, and
2.  To remove wild horses from private lands within these Herd Areas as requested by the private landowner.

This plan includes removing all wild horses from these areas, estimated to be about 2755, and this is a plan to zero out the herds entirely, leaving no wild horses.

This zero out plan is a direct result of the Resource Management Plan Amendment being finalized in May, 2023. If the 10th Circuit Court rules in our favor and overturns the RMP, then the BLM cannot proceed with the zero out plan.They can, however,  conduct a roundup down to the previous low AML numbers of 251 for Salt Wells Creek, 415 for Great Divide Basin and 610 for Adobe Town, but this would require a new Environmental Assessment.

A survey of the areas was conducted in fall 2024 to winter 2025 and the numbers in each area are said to be: Adobe Town (Rock Springs portion) 736, Salt Wells Creek 1125 and Great Divide Basin 894. Because of the RMP amendment all wild horses in these areas are determined to be excess and need to be removed.

1. The main point that needs to be made here is no plan should be finalized and no roundup activities should be conducted until the judges make their decision.

BLM may say it’s going to take several years to completely zero out the herds but you can be pretty sure they will do everything they can to take every single horse this year, and what will be left will be a completely gutted herd with a handful of horses.

2. No Action Alternative – BLM will not conduct a roundup – this is the one to select.

3. There has been no determination that due to the presence of the horses  that a thriving natural ecological balance does not exist – it is simply that the RMP has been revised. Zeroing out these herds is a violation of the 1971 Wild Free-Roaming Horses and Burros Act.

4. Adobe Town has only about 10,000 acres out of almost 500,000 acres that is in the  Checkerboard – yet they plan to zero out more than 1/4 of the area, 118,164 acres because the horses would ”constantly stray onto private land.” No this is not how the Act works. Section 4 says if a private landowner requests horses be removed from private land they should be removed – not that you can remove them IN ANTICIPATION of their straying.

5. The BLM considers “foaling season” to be between March 1 and June 30 and prohibits helicopter roundups during this time. But foaling season continues all summer and into fall and it is not safe or humane for small foals and heavily pregnant mares to be chased by helicopters.

6. Salt Wells Creek is home to the largest number of rare wild curly horses. Zeroing out this herd would remove this rare wild horse population, and since the only other herd in Wyoming with wild curlies has been taken down to 79 horses, this is the last herd that contains these rare genetics. These horses should not be zeroed out.

7. Last, what will happen to the horses once they are removed? BLM never considers this in their proposals. Given that the holding facilities are full to bursting with over 68,000 wild horses and given that Project 2025 calls for killing the wild horses in holding facilities, this zero out roundup plan will likely mean a death sentence for these 2755 wild horses that would be removed.

This comment period ends April 30, 2025 at 4pm MT. You can read the documents and comment here online by using the green “Participate Now” button.

Comment here: https://eplanning.blm.gov/eplanning-ui/project/2032715/570

As always I request that you use your own words instead of signing onto a form which the BLM counts as 1 comment even though hundreds of people have signed onto it. You are welcome to use my suggestions to make your own comments. Please submit your comments in the links I have provided, NOT on this blog post. The only way BLM will be able to register your comments is from their site.