Stop the BLM’s Illegal Plans for the Checkerboard Roundup II – Comment by Friday April 22

by Carol Walker, Director of Field Documentation, WHFF – as published on

Checkerboard Roundup 2014

Less than 2 years ago, the Bureau of Land Management illegally rounded up and removed 1273 wild horses from 2.4 million acres of public and private lands in Wyoming. 71% of this land is public land. At least 100 federally protected wild horses were killed during the roundup and in the months following it as they were warehoused at BLM facilities. The BLM is proposing to do this again this fall, and are using the same precedent that they did last time. They are using their right to remove wild horses from private land to justify and enable them to remove wild horses from public lands as well. This is illegal and must not be allowed to stand.

This plan to remove wild horses from the Checkerboard lands in the Herd Management Areas of Adobe Town, Salt Wells Creek and Greek Divide Basin is driven by the greed of the ranchers in the Rock Springs Grazing Association who seek to treat the public land as if it were their private land. Permit grazing is a privilege, not a right. Land swaps should be forced to occur in this area to consolidate private holdings and public ones separately in order to enable grazing of wild horses on public lands.

In this action the BLM is also violating the Federal Land Policy and Management Act (FLPMA) by lowering the numbers of wild horses allowed to live in these three Herd Management Areas (Appropriate Managegent Levels) without using a land use planning process to amend the governing Resource Management Plans (RMPs).

The BLM is using flyover data from their counts of wild horses in April 2015 to justify this removal:

Here is what the BLM told us in October, 2014  – the remaining numbers of wild horses in Adobe Town, Salt Wells Creek and Great Divide Basin after the Checkerboard Roundup:

Adobe Town: 519
Salt Wells Creek: 29
Great Divide Basin: 91

All of these figures are below Appropriate Management Level, or AML for each of these Herd Management Areas.
The new figures from the 2015 April flyover are:

Adobe Town: 858
Salt Wells Creek: 616
Great Divide Basin: 579

And what exactly is the explanation behind this massive discrepancy? Even with all the mares and stallions in each Herd Management Area giving birth to twins, there is no possible way that there was such a huge jump in population sufficient to trigger this roundup. Conveniently there are no photographs during the flyover “The survey lead indicated his reluctance to use photography,as it requires additional circling around groups that could cause air sickness.”

Here is how you can comment – please do this by April 22 4:30 pm Mountain Time:

Written comments should be received by April 22, 2016, and should be emailed only to

(Please include “Checkerboard Scoping Statement Comments” in the subject line),

or mailed to BLM Rock Springs Field Office, Checkerboard Scoping Comments, 280 Highway 191 North, Rock Springs, WY 82901.

Here is the Scoping Document:

Please DO NOT sign an online form letter. All of these will be counted by the BLM as 1 comment. If you actually want your comments to be read, counted and make a difference you must write your own letter and send it yourself.

Some points to cover:  It is illegal to use section 4 of the Wild-Free Roaming Horse and Burro Act which covers removal of wild horses from private lands to remove wild horses from public lands.

It is a violation of the Federal Land Policy and Management Act to remove wild horses from three Herd Management Areas to below AML for those areas.

There is a need for a census done by an independent, outside agency, not paid for by the Rock Springs Grazing Association, that includes photographs of the horses that are counted.

There needs to be a plan for land swaps to be made to consolidate private lands separate from public lands in the Checkerboard.

Any horses removed from the Checkerboard Area of their Herd Management Areas need to be returned to the public, non-checkerboard areas of their Herd Management Areas, not permanently removed and sent to BLM holding facilities.

Regarding conflicts between livestock grazing and wild horse use of lands in Wild Horse Management Areas:

  • 4710.5 Closure to livestock grazing.

(a) If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury, the authorized officer may close appropriate areas of the public lands to grazing use by all or a particular kind of livestock.

(b) All public lands inhabited by wild horses or burros shall be closed to grazing under permit or lease by domestic horses and burros.

(c) Closure may be temporary or permanent. After appropriate public consultation, a Notice of Closure shall be issued to affected and interested parties.

If the Rock Springs Grazing Association cannot come to an agreement on how many wild horses can live on the unfenced areas of the Checkerboard, then all of the public land within the Checkerboard and outside it in these three Herd Management Areas should be closed to livestock grazing.

The American public wants these wild horses to remain in their Herd Management Areas on public land, and to live out their lives wild and free, not suffering death and injury in roundups and stockpiled in holding facilities.


Western Turf Wars: The Politics of Public Lands Ranching


Be sure to read Mike Hudak’s book, Western Turf Wars

And listen to FREE podcasts that includes excerpts from the book:
1) Ranchers Mortgage Our Natural Capital
2) Politics Trumps Science in Range Management
3) Public Lands Ranchers Obtain Favorable Livestock Management
by Harassing Government Employees and Conservationists

4) Nature’s Aesthetics Fall to the Plague of Ranching
(also available as an essay in PDF format)


Praise for this book:

“If you care about our public lands, Western Turf Wars is a must read.”  —Howard Lyman, LLD, president and founder, Voice for a Viable Future; author Mad Cowboy: The Plain Truth from the Cattle Rancher Who Won’t Eat Meat and NO MORE BULL! The Mad Cowboy Targets America’s Worst Enemy: Our Diet


“The horrendous damage done to millions of acres of fragile public lands in the arid West by overgrazing livestock has been documented in a number of books, media articles, and scientific journals in recent years. Less often told is the real story about the ultimate cause of this devastation of our public heritage: the blatant and unconscionable wielding of political influence on the part of too many agency officials, politicians, and stockmen (and women) to keep those numbers (and damage) at unsustainable levels. This captivating and absorbing book puts it all together—and in such a special, compelling manner, that it has become one of the best environmental books I have ever read. It is the tale of some of the brave men and women who worked, against great odds, to protect the vast publicly-owned rangelands of the West that they loved. And because it’s told in their own words, through a series of interviews, it adds a unique human immediacy, and dimension—and power, to an unhappily too-familiar scenario.
“It’s a real page-turner; I literally could not put it down once I started reading. I kept on going, page after page, because I had to find out what was going to happen next—both to those courageous ones who dared to speak up against the abuses, and to the beautiful lands and native wildlife they strove to defend. I recommend it to anyone who cares about our public lands and who wants to understand better the forces and interests struggling over their ultimate fate.” —Brock Evans, president, Endangered Species Coalition; 1981 recipient, Sierra Club’s John Muir Award; vice president for national issues, National Audubon Society (1981–96); director, Sierra Club’s Washington, DC, office (1973–81), Northwest representative, Sierra Club (1967–73)


“The tales of terror that Hudak has assembled run through the mind like a wilderness snuff film. The story is a familiar one. Resource extractors bully the land managers and buddy up with the legislators to acquire privileged access to public lands. They keep below cost fees so low they are in effect welfare for ranchers, and they feign bogus compliance with paltry environmental regulations.” —Andy Caffrey, quoted from his review in Oregon Conifer (newsletter of the Oregon Chapter Sierra Club), spring 2008


“Interviews with 27 experts—all with extensive experience with or knowledge of public lands ranching—provide us intimate, accurate perspectives on just what ranching does to our public lands as well as how it affects us economically, socially, and politically. Special attention is focused on the political forces that keep stockmen arguably the most influential special interest in the rural West. If the western wild means as much to you as the Wild West, if you’re concerned about environmental destruction, about waste and injustice, then read Mike Hudak’s Western Turf Wars.” —Lynn Jacobs, author Waste of the West

mike_hudak     Mike Hudak, PhD, founded the nonprofit project Vibrant Public Lands (originally “Public Lands Without Livestock”) to increase awareness of the environmental damage caused by livestock production in the American West. From 1998 until mid 2000 his presentations throughout twenty states brought the issue to the attention of the Sierra Club. Subsequently, Hudak participated in negotiations that resulted in significantly strengthening that organization’s livestock grazing policy. Since that time, he has continued speaking throughout the United States at a variety of organizations, universities, and national conferences. His website now brings his articles, photo essays, and videos about public lands ranching to an even broader audience. The videos, short excerpts of the interviews that went into the making of Western Turf Wars, provide a unique contribution to our understanding of public lands management from the 1950s through the early years of the twenty-first century.

Mike Hudak earned his BA in mathematics and PhD in advanced technology from Binghamton University, as well as an MS in computer science from Northwestern University. As a former computer-industry researcher his work focused on the design of adaptive intelligent software. He served as Chair of the Sierra Club’s National Grazing Committee from 2008 until 2013 in which capacity he worked with the Sierra Club and other organizations to enact legislation that would reduce livestock grazing on public lands.