On November 4 we filed an emergency notice with the Department of the Interior and BLM Nevada to stop the helicopter roundup scheduled to begin November 16. It asks BLM to halt the roundup until it completes the environmental review it has not done.
The gather reaches four herd management areas: Antelope, Spruce-Pequop, Goshute and Triple B. The filing turns on one question: can BLM lean on a 2025 review that never examined an order signed on October 27? Here is what we filed, what it argues, and why it matters beyond this one roundup
What we filed
The filing is an emergency notice and a demand for supplemental environmental review. It is addressed to the Secretary of the Interior, the BLM Nevada State Director, and the Bristlecone and Wells Field Office Managers. It makes five demands:
Halt gather operations until the new policy shift is evaluated.
Complete a supplemental NEPA analysis covering Secretarial Order 3454.
Conduct site-specific environmental assessments for the rangelands actually targeted.
Analyze the cumulative impact of removing horses while adding cattle.
Respond in writing within five business days.
The timeline
BLM is relying on a programmatic environmental assessment issued in September 2025.
Secretarial Order 3454 was signed on October 27, less than three weeks before the gather. We filed seven days later.
Three problems with the review
The review BLM is relying on has three gaps, and each one is specific.
One review for 3.8 million acres. A single programmatic environmental assessment covers four herd management areas. No site-specific review was done for the valleys targeted this November.
Order 3454 was never analyzed. The order calls for expanding commercial livestock grazing. The 2025 assessment, written before the order existed, has no cumulative impact analysis of removing horses while adding cattle.
Tribal boundary conflicts. The Goshute HMA borders Goshute Reservation lands. The effect of a helicopter drive-trap gather on horses crossing that boundary was never analyzed.
Who the range is allocated to
The 2025 assessment never examines what happens when mass removal of horses meets expanded commercial grazing on the same rangelands. These are BLM's own figures, as cited in the notice. AML is the appropriate management level for horses. AUMs are forage months authorized for livestock.
AUMs To Horses
The standard appeal route cannot work on this schedule. The 30-day IBLA window cannot grant relief before November 16, and capture and removal cannot be undone.
The notice argues that under the Administrative Procedure Act, the requirement to exhaust administrative remedies is waived when the remedy cannot prevent immediate, irreversible harm.
We wanted to do this earlier with a full lawsuit. Evin with this legal advice or hiring a lawyer, kept running into road blocks as they run $500-1000/hour
BLM now has to answer. If it stays silent or denies the request, the notice treats that as a final agency action. That would open the path to an injunction in federal court before the gather begins.
This filing matters because of what it puts on the record. It asks whether one blanket review from 2025 can cover a policy order signed less than three weeks before a helicopter gather, on rangelands where horses are removed and livestock use is meant to grow. It also asks BLM to look at the Goshute boundary, where horses cross onto reservation land, before it acts.
Capture and removal cannot be reversed. That is why we filed 13 days ahead of the gather and not after it.
Follow what happens next at wild-horses-lives-matter.org.
Wild Horses lives matter is a 501 c 3 dedicated to saving our American Mustangs. We are a very small (me) one woman show, boots on the ground, who loves the wild horses .
Antelope HMA