HERD MANAGMENT PLANS

*Something to remember when submitting comments 

Herd Management Area Plans (HMAPs) do not constitute instruments of resource allocation.

They do not possess the legal authority to alter existing allocations of resources, including but not limited to authorized livestock grazing levels.

Rather, HMAPs function to ratify, endorse, or give administrative sanction to resource allocations already established through prior land use planning decisions or permits.

Accordingly, modifications to livestock grazing authorizations cannot be effectuated through a decision related to a wild horse or burro gather.

SILVER KING HMA HERD MANAGEMENT EVALUATION

Comments due June 23, 2025

 AML and Resource Availability

The Appropriate Management Level (AML) is currently set at 128—a figure that is disproportionately low given the available resources. What will it be after the new HMAP is published? 128

Wild Horse Forage Allocation

The Silver King horses currently receive 1,536 Animal Unit Months (AUMs) annually. How much forage will they receive under the new HMAP?

1,536 AUMs annually—unchanged

 Legal Basis for Forage Disparities

What statutory authority justifies allocating the majority of forage to livestock in a designated HMA?

There is no clear statutory warrant for this disproportionate allocation. It stems from administrative precedent rather than legal necessity.

The draft HMAP fails to address fundamental imbalances in the management of the Silver King HMA. It maintains inequitable forage allocations, reinforces a livestock-first management regime, and relies on population control measures that prioritize cost-cutting over ecological integrity and statutory mandates under the Wild Free-Roaming Horses and Burros Act of 1971.

I urge the BLM to reconsider this HMAP in favor of one that reflects a fairer distribution of resources, greater transparency in land-use decision-making, and genuine commitment to protecting wild horses as integral components of public lands.

Written comments may be emailed to BLM_NV_EYDO_SilverKingHMA_MgmtEvaluation2025@blm.gov (preferred); or delivered to the BLM Caliente Field Office, Attn: Tyler Reese, PO Box 237, Caliente, NV 89008. The comment period will close June 23, 2025.

For more information, contact Tyler Reese, Wild Horse and Burro Specialist, at 775-726-8137 or treese@blm.gov.

MORE INFORMATION