Emergencies occur suddenly and require immediate action, according to Section 2.22 of BLM Handbook 4720 for removal of excess wild horses and burros from public lands.
Earthquakes and wildfires occur suddenly, droughts do not.
Section 2.21 defines escalating problems as conditions that deteriorate over time.
They are indicated by a decline in the amount of food or water available for wild horses and burros, which results in negative impacts to animal condition and rangeland health. These situations are normally associated with drought or animal numbers in excess of AML, can be detected in advance, and are managed through the normal gather planning (NEPA) process.
Further, these types of problems should be managed within the individual BLM State gather targets, to the extent possible, per 2.21.C. If you have to pull horses out of HMA X because of drought, you’ll need to forego the planned removal at HMA Y.
The next step would be to check the news releases for NEPA citations. If found, there was an attempt to comply with the statute, so those roundups, and the circumstances that led to them, probably didn’t qualify as emergencies.