In March of 2026, the BLM released a pair of Management Reports aimed at planning for the future of the North and South halves of the Red Desert Complex. The public can comment on the reports, and the voices of horse advocates have never been more important. The BLM's reports on the Red Desert contain no elements to improve wild horse herds or habitat. Instead, the agency used the reports to introduce unacceptable practices, including the castration and release of wild stallions. ***Comments are due on May 4, 2026 ***
Here’s our best advice on how to approach a comment:
Make it personal. If you’ve ever seen the wild horses in Wyoming, be sure to say so. Even if you plan to visit one day—if it’s on your bucket list—you can say that too.
Then urge the BLM along these lines:
As required prior to a gather, develop a Herd Management Area Plan (HMAP) for the Red Desert Complex in cooperation with interested communities: wildlife enthusiasts, horse advocates, county-based tourism boards and conservation-minded ranchers.
In the Herd Management Area Plan for the Red Desert, remove any proposals tocastrate and return gelded stallions. The plan to castrate and return male horses to the wild cannot remain for two reasons:
1. Geldings are not wild horses. Natural equine behavior depends on the ability of male horses to produce testosterone. When bachelor stallions assume roles within a harem, for example, their bodies experience a “sudden, sharp rise in testosterone concentration” (McDonnell & Murray, 1995, p. 577). Robbed of their ability to produce hormones, band stallions lose their families to competitors (King et al., 2022). In addition, castrated stallions experience a reduction in scent-marking activity. In the social world of wild equines, stallions use scent-marking as a means of “signaling competitive ability and resource holding power” (King & Gurnell, 2007, p. 30). Harem maintenance, scent-marking, and ability to shift testosterone levels are allnatural and necessary elements of wild horse behavior. By definition, a castrated horse is no longer a wild horse. Geldings find themselves unable to participate in the life of a herd. 2. Gelding a portion of a population has no long-term effect on fertility. Sarah King and a team from Colorado State castrated 42% of the male horses in Utah’s Conger herd in 2017. In their 2022 report on the research, the authors explain that the “foaling rate at Conger was reduced in the year following the treatment, but then returned to pre-treatment levels” as intact stallions took over the geldings’ former bands (King et al., 2022, p.1).
Build an HMAP that prioritizes reversible anti-fertility serums, and in herds like Green Mountain and Stewart Creek, where the horses are approachable, employ trained technicians to dart mares with handheld rifles.
In places where handheld rifles are not practical, make use of automated darting stations. Organizations like Wildlife Protection Management produce tools that make automated darting possible, in remote locations, and in places where teams of staff or volunteers are not available.
Use the bait and trap method as an alternative to helicopter roundups. The BLM uses bait-trapping throughout the West as a way to protect horses from injury, foals in particular. The horses of Wyoming’s Red Desert deserve no less than the safest and most humane gather methods.
Increase the presence of signs throughout the complex. At present, no signs mark the boundaries of the Red Desert herds. The HMAs also lack signs and interpretive stations at access points on routes commonly used by visitors. In the tradition of other Wyoming herd management areas, McCullough Peaks, for example, build informational kiosks to educate guests about the horses, their habitat, and the federal act that ensures their long-term conservation.
Use the HMAP process to balance the number of permitted animal-units-per-month (AUMs) across the Red Desert. In particular, the size of the Lost Creek herd is kept low without cause. For the sake of fairness, a reasonable HMAP will increase the proportion of forage allotted to mustangs to no less than 40% on the ranges identified as principally for equines in the Wild and Free-Roaming Horses and Burros Act (WFRHBA). Across the complex, the current Management Evaluation Report cites increasing “vegetation cover” and “biomass,” occurring alongside declining percentages of “bare ground” (pp. 26-23 North and pp. 11-14 South). The current report affords the BLM a unique opportunity to reapportion AUMs.
Finally, as a part of the broader HMAP process, conduct an ecological study to determine the carrying capacity of the herd area known as Arapahoe Creek. The borders of the Arapahoe Creek HA lie adjacent to all of the other herds in the Red Desert. Consistent with the decision to manage the region as a single, integrated “complex,” we must allow horses to pass through and remain in Arapahoe Creek. The steady presence of horses through the center of the complex will help to assure that mustangs from different HMAs can mingle and increase the genetic diversity of the herds—and in addition to concerns related to the health of the animals—the BLM also has a new statutory reason to revisit the decision to zero-out the Arapahoe Creek HA.
The July 15, 2025, ruling by the U.S. Court of Appeals for the 10th Circuit (American Wild Horse Campaign v. Raby) created a new imperative to justify the complete elimination of wild horses from established herd areas. As a result of the ruling, the BLM is now obligated to provide a record demonstrating how the presence of any horses in a herd area would prevent the agency from achieving a "thriving natural ecological balance.” Thus, new management cycles that include plans to remove all wild horses from the Arapahoe Creek HA must provide a transparent justification based on the TNEB standard.