A Call to Arms (More or Less)

Great Divide Basin cpr

Starting today, the above photo will be in a gallery for the month of August as part of the Cloud Foundation Art Exhibit & Fundraiser.  It is not my most popular photo, but I’m really proud of it and glad that it made it into the gallery.  It’s my kind of photo, you see – plain bay mares in the Great Divide Basin casually strolling towards water on a serene Sunday morning.


Yet all I can think about is that while that print is hanging around on a wall, those mares may finds themselves galloping across that range in terror, chased down with a helicopter, taken away from their home, and separated from their family band forever.

third group 12
Adobe Town Roundup, November 2013


A couple weeks ago the BLM released their roundup schedule for the rest of the year.  There was no small amount of hullabaloo over three specific herds – Adobe Town, Salt Wells, and Divide Basin.  For while the rest of the schedule was fairly tame (for BLM standards) and primarily consisted of smaller removals of horses that were outside the boundaries of the established herd management area, the planned removal numbers for the Red Desert herds were downright shocking.  The numbers on the chart read that the BLM was going to zero out Divide Basin and Salt Wells, and take over 1/3 of the remaining Adobe Town horses.


The plan looks a little something like this:

WY BLM Adobe Town HMA  w/ Salt Wells 8/20/14 8/24/14  177 177 Horses  WY State Office
WY BLM Salt Wells HMA w/ Adobe Town 8/24/14  8/28/14  228 228 Horses  WY State Office
WY BLM Divide Basin HMA 8/28/14 9/10/14  541 541 Horses  WY State Office




Reading these numbers, it felt a little like the world was crashing down, like I was stuck on a calving glacier just waiting for my feet to fall out from under me so I could hit the icy punch of the water while the ice crashed down on my head.


And yet, how much worse is it for the horses?  They don’t even see it coming.  The horses are busy living their lives as best they know how.  They will be busy storing up fat for winter and then suddenly BAM!  Running for their lives, permanently separated from their families, spending the rest of their lives in government holding.  If they are lucky the horses removed won’t be euthanized or slaughtered by an organization that was ordered to protect them, but who now is looking for easy escapes for a problem that they themselves created.  It’s sick.


If you are me, the only way to combat that sickness is to dive into the numbers and type out a few feelings.  Let’s break all of this information down in a comprehensive way.  This roundup is a little more confusing than others, after all, which is exactly why it must be stopped and stopped quickly.

Divide Basin Bachelor
Divide Basin Bachelor



(For those of you who are not interested in me rambling no for a thousand words or so, feel free to skip down to the bottom for the section on how you can help)


First we have to start with the basics.  For any roundup, the BLM follows a process known as NEPA.  NEPA stands for National Environmental Policy Act, and the short of it is that federal agencies like the BLM are required to write Environmental Impact Statements (EIS) on how their plans may impact the environment.  In the wild horse world, these are often referred to as Environmental Assessments (EA).


The NEPA process is a fairly consistent one.  If the BLM wants to roundup horses, they first issue a scoping statement, letting the public know that they are starting to plan on the roundup and giving thirty days to provide input and comments on the roundup plan.  After that thirty day comment period the BLM writes up an EA and then submits that to the public.  The public then has another thirty days to comment on the finalized EA.  After that comment period has closed, the BLM must log and internally respond to all of those comments before issuing a Finding of No Significant Impact (FONSI) document and a Decision Record.

That’s a lot of boring info, I know.  Here, give your eyes a break with some beautiful Divide Basin bachelors



For wild horses lovers the process can be explained in more simple terms.

Step 1. BLM wants a roundup and they tell everyone.  Advocates respond by disagreeing with the BLM’s plans, and are summarily ignored.

Step 2.  The BLM releases an official document with “options” for how they plan to conduct the roundup.  Advocates respond by pointing out all the flaws in their logic.

Step 3.  The BLM has to read all of those comments and explain in internal documents why they are choosing to ignore them.

Step 4. The BLM declares they will use the most invasive and drastic roundup plan in their list of options.

Step 5. Roundup

This Mare was Removed 11/25/13
This Mare was Removed 11/25/13



EAs vary from office to office, but here is an example of a fairly standard one that you will see for the herds in Southwest Wyoming.  Note that while some offices out of Nevada are lazier, I mean, “less thorough”, 103 pages is not an uncommon length for an EA.  They are supposed to evaluate every possible angle of their desired roundup.


When the 2014 roundup schedule came through, it was very odd to see Adobe Town, Salt Wells, and Divide Basin on there.  The BLM had issued a scoping notice, the first step, for Divide Basin back in December of 2013, but no EA had been released.


And that was still more than the BLM had released for Adobe Town and Salt Wells.  The BLM hadn’t even bothered with the very first step of the NEPA process for those two herds, and yet they were planning on taking 405 horses between the two areas?  And they were planning to do so in a little over a month?


As soon as I saw that information, I called Jay d’Ewart, the Wild Horse & Burro Specialist for the area.  He chuckled and told me that they were waiting for Washington to finalize everything before they released the information.  Now I like Jay.  I really do.  He is a genuinely good man, and he does care about the wild horses in his own way.  But man do I get sick of the half-truth BLM BS sometimes. I wonder how many hundreds of thousands of our tax dollars go towards training BLM employees to evade and say nothing.


Last Friday afternoon (just in time for it to be too late for advocates to do anything before the weekend) the Rock Springs released their plan.  Here is the link, but I’m also happy to translate it into English for everyone to save time.  In a nutshell this says:


“The Rock Springs Grazing Association (RSGA) asked us to remove all these horses immediately, and we said yes, so therefore we don’t have to follow the rules on this and can just roundup as many horses as we want in this area whenever we feel like it.”

This stallion and his yearling daughter were both removed in November, along with 587 other horses in the area.  That still isn't considered enough by the RSGA and BLM, who will not be happy until they are all gone from these herds
This stallion and his yearling daughter were both removed in November, along with 587 other horses in the area. That still isn’t considered enough by the RSGA and BLM, who will not be happy until they are all gone from these herds


Okay, it’s a little more complicated than that because it requires that you understand a little bit more about the Rock Springs Grazing Association.  The RSGA are modern day cattle barons. They are rulers of the range in that area of the country, whether that range technically belongs to them or not.  In 2012 the RSGA filed a lawsuit with the BLM demanding that the BLM remove all horses from three herds in the area, since parts of the areas where the horses were allowed happened to be on checkerboard land.


The checkerboard is an area where for every one square mile of public land there is one square mile of private land.  Much of this private land is owned by oil and gas companies like Anadarko and Shell.  Members of the RSGA own some of this land too, and they also lease the public sections from the BLM and those private companies to graze their massive herds of sheep and cattle.  To better understand them, I suggest you check out this link to a simply fabulous Andrew Cohen piece on the issue.


In April 2014, the BLM signed a Consent Decree with the RSGA.  Rather than fighting tooth and nail, the way the BLM will do when wild horse advocates bring lawsuits, the BLM agreed to the RSGAs demands.  Specifically, they agreed to remove all the horses located in the checkerboard land.  What is more, the BLM not only decided to remove the horses from the checkerboard land, but also agreed to remove every single horse from Divide Basin and Salt Wells.  Nearly half of those herds are outside of the checkerboard land, but the ranchers are still allowed to graze their cattle and sheep in those parts through leases.  And hey, why go halfway when you have the opportunity to take everything?

Salt Wells bachelor stallion napping in a draw


So now that we are all on the same page, let’s go back to the part where the RSGA demanded the horses leave, allowing the the BLM to break the rules.  They are calling this change in plans a “Categorical Exclusion”.  It can be read here:


For those of you who don’t want to read the 11 pages (and I can’t blame it, it makes me want to spit nails), the general idea is that the RSGA complained that the BLM was “out of compliance” with the decision of a lawsuit that the BLM didn’t even try to fight.  So therefore the BLM is within their right to remove every single horse from the checkerboard in Divide Basin and Salt Wells, and to bring Adobe Town below the lowest allowed number of horses.


Then there’s this fun sentence:  “In April 2014, the BLM, the RSGA, and the United States Geological Survey completed a simultaneous double count method census survey for the Great Divide Basin, Salt Wells Creek, and Adobe Town HMAs.”  Because, y’know, letting the RSGA participate in counting the number of wild horses is not a conflict of interest whatsoever.  If an advocate tries to get information about wild horse population surveys, they have to file a request through the Freedom of Information Act.  Meanwhile, the RSGA gets to participate in the process!


Anyway, the BLM provides the following approximate count based on a fly-over using a double count method:

Adobe Town:  566 horses, 10 in checkerboard

Divide Basin: 618 horses, 394 in checkerboard

Salt Wells: 728 horses, 402 in checkerboard (yeah right to both counts)




Now let’s refresh our memories and look at the planned removal numbers:

WY BLM Adobe Town HMA  w/ Salt Wells 8/20/14 8/24/14  177 177 Horses  WY State Office
WY BLM Salt Wells HMA w/ Adobe Town 8/24/14  8/28/14  228 228 Horses  WY State Office
WY BLM Divide Basin HMA 8/28/14 9/10/14  541 541 Horses  WY State Office


The BLM is saying they do not have to follow the rules because they are required to remove all the horses from the checkerboard land. And yet according to their own survey, 167 of the horses they plan to remove from Adobe Town are not in the checkerboard.  Even if the Categorical Exclusion was legally sound, the BLM would still not be able to justify taking the horses outside of the checkerboard land without going through the correct NEPA process.


And then there is Divide Basin to consider.  If the BLM counted a total of 618 horses in Divide Basin and only 394 of those horses are in the checkerboard, then why are they magically allowed to remove a total of 541 horses?  http://www.blm.gov/wy/st/en/info/news_room/2013/december/10rsfo-gather.html


What is more, per the current Range Management Plan, the Divide Basin is allowed to have 600 horses.  If you do not count foals (which the BLM did in the 618 figure), this herd is still within their allowed management level.  In any other herd, the BLM’s own legal documents would not allow them to conduct this roundup this year.

Divide Basin
Divide Basin


Finally, we get to Salt Wells.  Salt Wells… what can I say about Salt Wells?  Oh, I know.  How about we talk about the fact that I had to watch the BLM take 589 horses out of Salt Wells last November?  There is nothing left east of Highway 430.  If the BLM is allowed to take another 228 horses from Salt Wells, there will be nothing left west of there either.  I have reviewed their survey with its little dots on where the flyover spotted horses and frankly my dears, it is a load of hooey.


Make no mistake, dear readers, the BLM is planning on removing all the horses in Divide Basin and Salt Wells this year.  Their destruction is no longer a delayed process but rather a certainty.  They are doing this with none of the required documentation, in violation of the existing Range Management Plan.


There is a reason though.  This is a sneak attack, plain and simple.  The BLM has intentionally cut wild horse advocates off at the knees in a carefully thought out plan.  The only thing that can stop this is a lawsuit, and there simply isn’t enough time.  There is no time to scramble the jets, get the funds, bring the lawsuit, and stop everything.  Not when we have less than a month.

Salt Wells Mares
Salt Wells Mares



So… How Do We Stop This?

The decision to eradicate these herds was decided through a lawsuit.  The only way it will be stopped is with a lawsuit.  To that end, American Wild Horse Preservation Campaign and The Cloud Foundation filed a lawsuit yesterday afternoon.


Now I know we are all sick to death of lawsuits that rarely seem to work.  But this one has an excellent chance of succeeding.  It really, really does.  Consent Decree or no, this “categorical exclusion” is completely bogus.  The BLM tried to sneak this roundup on everybody because they know that they aren’t allowed to bring these herds below their allowed numbers but they want to try to get away with it anyway.



As you can imagine, lawsuits are expensive. Wild Horse Preservation Campaign and The Cloud Foundation will stop this roundup, but they are going to need donations.  I’m not going to insult everyone’s intelligence by going full on telemarketer and using such lines as “Even if you can only donate five dollars, if everyone who reads this donates five dollars it will make a huge impact” (even though that is accurate, Mathematically speaking), because I get it.  I’m a single twenty-something with three horses to feed, a Gramma to help take care of, and an addiction to spending $150 in gas to drive up to Wyoming and hang out with wild horses once every month or so.  Money is tight for a lot of us, and I hate to feel like I’m making some complete stranger feel guilty or like they aren’t important if they are not able to donate money.  If you are that complete stranger:  hey, you are still awesome and you shouldn’t feel like you are being judged because seriously, humans need to stop judging each other so much anyway, am I right?


All I can say is that these horses are very special to me, and these herds mean a great deal to quite a few people.   I’d really appreciate it if you could try to help financially.  It’s annoying, but this is a case where making a bunch of phone calls and signing petitions simply isn’t going to work.  So if you can find that $5 or whatever, you can donate to whichever organization you like best by clicking the links below:

American Wild Horse Preservation Campaign: donate link

The Cloud Foundation:  donate link


Wining this lawsuit is not the end of the fight for Adobe Town, Divide Basin, Salt Wells, and White Mountain.  The big, mother of all fights, is still on the horizon.  But if we do not stop this particular roundup now, Divide Basin & Salt Wells will be gone forever.  There will be nothing left to fight for.  This may only be the first battle, but it is a critical one.  So let’s start strong, give these horses a chance, and stop this freaking roundup!

Divide Basin
Divide Basin stallion keeping a curious eye on me while also making sure I don’t try to get too close to his mares.

Published by Rachel Reeves

I am a photographer who currently lives in the great state of Colorado. I love going out and photographing wild horses in their natural habitat, and look forward to being able to share a glimpse their world with you.

6 thoughts on “A Call to Arms (More or Less)

  1. All I can say is… thanks. And I am so glad you are able to get your thoughts and feelings out there in a readable, organized, yet expressive way. Well done. Hopefully, many will be moved to respond because of this piece.

  2. On a positive note this is probably the best I have heard the NEPA process explained, and that includes some of my natrual resource professors. On what I hope is a possitive note I do think the “sneak attack” approach will back fire on the Rock Springs BLM due to the lack of EA. Since the BLM is only required to give the public time to respond, but not follow the recomendations it might give advocates more to work with. Lawsuits may be expensive, but at the very least it will buy advocates time to potentially delay the roundup. At least that’s what I’m hoping.

  3. I am really hoping that everyone donates. What the BLM is doing is illegal and now we need to prove it in court. So please along with saying your nice words, please make a donation to this cause. Thank you.

  4. The day that the BLM follows any rules will be the same day the moon is declared to actually BE green cheese! The National Academy of Science (NAS) — in the two-year scientific review of BLM ordered by BLM and paid for by citizens (a million dollars) which was delivered to BLM last summer and is still being ignored … called out BLM and reported BLM had never done an accurate census of wild horse herds, so there was no way they knew what they had to begin with. BLM has “fabricated” herd counts to appease Corporate Agriculture, Big Oil and fracking interests. NAS told us that. As well, NAS reported that the grazing ratios — for horses-to-cattle — were not followed in AMAs. Reports are that cattle outnumber wild horses 10-1. — BLM was assigned to “protect and manage” the free-roaming wild horses and burros by a LAW passed by Congress in 1971. Since then, BLM has been and still is in dereliction of duty, by LAW. How? Why? BLM’s misuse of funds alone should have the Office of Management and Budget on their case. The Atty. General of the U.S., Eric Holder, should be all over them not only for dereliction of duty by law, but for the inhumane cruelty visited on the wild horses by this ignorant group of ‘drugstore cowboys’ gone amok. It figures, when you realize that their leader, Interior Sec. Sally Jewell, is no scientist as she claims; but, has a background in Banking and Big Oil. Jewell is an insult to the very society to which she claims membership. Our president was snookered by advisers who touted Jewell, and who only tell the president what THEY want him to know! — We have a problem. The wild horses have a larger one of a continued life-and-death struggle against the very agency that was assigned by LAW to be their caretakers. Scope out the attitudes of people on this problem before you vote. REMEMBER IN NOVEMBER!

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: