Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Posted on January 20, 2016 by Protect Mustangs

Email: blm_ut_sulphur@blm.gov

Copies: jwhitloc@blm.gov, tchristense@blm.gov, eburghar@blm.gov
January 19, 2016
Cedar City Field Office
176 E DL Sargent Drive
Cedar City, UT 84721
Project Name: Sulphur Wild Horse Gather Plan

Document: Environmental Assessment — Preliminary

NEPA ID: DOI-UT-C010-2015-0011-EA
This letter responds to your request for substantive comments and new information that BLM-Cedar City should consider regarding the subject Plan. I submit mine as an interested party in behalf of the wild horses of the Sulphur Herd Management Area (HMA).

I support the use of radio collars to track the horses and the construction of a fence along Highway 21 for the safety of both horses and humans. However, I urge you to cancel the roundup-and-removals, discontinue PZP treatments, correct the fraudulent population-estimates, and take other specified corrective actions.

I suggest the addition of another alternative: Increase the AML, collar the horses, fence the Highway but remove interior fences, conserve apex predators, and install guzzlers throughout the HMA.

As for the proposed alternative, if BLM has confidence in the WinEquus population-growth modeling, then please note that the “removals only” alternative yields a median-trial average herd-size that is nearly 24% lower than the proposed alternative — 318 versus 417. As for PZP injections, they should be abandoned because they are dangerous to the mares, to the foals (born and unborn), and to the staff and volunteers that handle the pesticide.

For ease of reference, here are the links to the documents at issue:

News Release — 2015 EA

http://www.blm.gov/ut/st/en/info/newsroom/2015/December/EAsulphurwildhorsegather.html

News Release — 2015 Public-Safety Removals

http://www.blm.gov/ut/st/en/info/newsroom/2015/february/public_safety_concerns.html

Sulphur Gather Environmental Assessment — Preliminary

http://www.blm.gov/style/medialib/blm/ut/natural_resources/wild_horses_and_burros/general.Par.73121.File.dat/Preliminary%20Sulphur%20Gather%202015%20EA_12_18_15.pdf
REASONS CITED FOR GATHER-REMOVE-CONTRACEPT PLAN
Overpopulation, Forage Limitations

BLM lists overpopulation and forage / water limitations as the need for the proposed action. The “overpopulation” in this case merely means “over AML”. And because the AML is arbitrary and unscientific, it is meaningless. Range-conditions function as natural feedback to wild horses, allowing them to self-regulate their numbers. That is how Nature works. BLM is meddling unnecessarily. The intervention that is needed would be to offset the impact of livestock-grazing — eliminating interior fences that block wild-horse movement and installation of trick-tanks (guzzlers) to capture and store precipitation.
The Proposed Action

BLM-Cedar City plans to conduct two-to-four helicopter-style roundups-and-removal operations over the next 10 years to bring the herd’s alleged overpopulation down to the low-bound of the arbitrary management level (AML) — 165 horses on 265,675 acres — and maintain it there. BLM claims there are “excess” horses but the EA does not reveal the number. Instead, the EA goes on and on about the historical numbers and removals. Not even a “ballpark” figure is listed for how many horses BLM would remove initially, some sources have mentioned “over 500.”

BLM further plans to forcibly inject all of those few mares it plans to allow back into the HMA with PZP-22, the long-acting version of the pesticide. PZP is known to sterilize after as few as three injections in mares, or after just one shot in fillies that have not yet reached puberty. And the EA states that BLM plans to administer PZP treatments to yearling fillies.

http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p
Baseless and Biased Assumptions

A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed

Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes,
Ignorance of the new study that found the effective birth-rate averages 10 percent,
Ignorance of the new data showing “hands-off” management results in 5-to-8 percent growth,
Failure to include studies — both old and new — that reveal PZP’s damaging impacts, and
FRAUDULENT POPULATION ESTIMATES
Birth Rate versus Herd-Growth Rate

Before we examine BLM’s reported herd-growth rates of this HMA, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. BLM claims an average birth rate in wild-horse herds of about 20% a year. But herd-growth is unlikely to reach 20 percent a year. Here’s why: Horses die.

An independent study reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival rate is just 10 percent. Cedar City’s claim that 95% of the Sulphur foals survive is not credible. It is just self-serving for administrative convenience in equating the birth rate to the growth rate. That wrong assumption has been disproved. Moreover, I note that the 2013 inventory counted 25 foals born out of season. That anomaly was likely due to the PZP treatments, which research by Ransom et al. (2013) disclosed.

http://www.ncbi.nlm.nih.gov/pubmed/23383018

However, CCFO failed to include that study as a reference; and although it did cite another Ransom et al. study (2010), it was not included in the EA’s “References” section either.

Births outside the normal parturition-pulse put the survival of both the mares and foals at risk.
Adult Wild-Horse Mortality Rate Must Be Factored

But it is not only foals that die. Adult wild horses also perish. They succumb to illness, injury, and predation. Indeed, the EA claims that 8 horses were found dead in 2015. The adult death rate must be taken into consideration. Adult mortality is at least as high as the 5% a year for horses that die in short-term holding, where they are fed, watered, and provided care.

Given the 50% foal mortality-rate, and the 5%-or-higher average annual death rate of adult wild horses on the range, herd growth could not increase 20% a year, and a herd-population could not double in 4 years — refuting yet another BLM myth. But BLM ignores mortality — foal and adult — in its population-estimates, which exaggerates the numbers it posts.
The Herd-Growth Rate Must Necessarily Be Lower Than the Birth Rate

In light of the high foal-mortality rate and the expected adult wild-horse mortality rate, the herd-growth rate must always be lower than the average 20% birth rate. However, herd-growth rates many times higher than 20% — which would necessarily mean birth rates substantially higher still — are routinely found in BLM’s population data, including the year-to-year figures for Sulphur HMA and other HMAs under Cedar City Field Office’s jurisdiction. Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — that is one of the ways BLM creates the false impression of a population-explosion.
Stochastic Events Also Reduce Herd Growth

BLM also fails to consider another factor limiting herd growth — stochastic events — which are random catastrophes such as wildfires or contagious diseases or pesticide treatments that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.

There was such an event recently in Kazakhstan, where 120,000 endangered Saiga antelope — half the world’s population — died off suddenly and inexplicably.

http://www.latimes.com/science/sciencenow/la-sci-sn-saiga-antelope-die-off-20150531-story.html

Imagine if such a catastrophe were to befall the Sulphur herd. Note that the Saiga deaths involved antelope-mothers and their calves. What if Sulphur’s few fertile mares and their foals perished all of a sudden, leaving mainly stallions and sterile old mares? BLM must proactively manage the herd per IUCN International Union for the Conservation of Nature guidelines, if only in case of stochastic events.
Maximum AML Set Below Minimum Viable Population

But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear — via fictitious figures — to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP, including Sulphur. What is the MVP? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the 265,675 acres of the Sulphur HMA.
Phony Population-Estimates

According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.

http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html

Let’s do the math.

718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).

This is improbable. Even if 87% were only the birth rate, it would be 335% higher than the 20% birth rate that BLM claims as average and which the independent study by Gregg et al. confirmed. Surely, herd growth — births minus deaths — could not be that high.

BLM attributes the impossibly-high estimate to “improved inventory methods.” But as has been pointed out to BLM previously, the “mark-resight” method, conducted by helicopter, appears to overcount the population. Indeed, as the report by the specialty-contractor who conducted the Red Desert Complex (Wyoming) census emphasized, there are assumptions and caveats that must be considered when evaluating the numbers, including the potential for having double-counted due to “horse activity (moving).” The method itself exaggerates the numbers.

http://www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html
Population and Gather Reports — The Data

Discrepancies were evident per a review of the …

HMA and HA Statistics reports for the Sulphur herd from 2008-2015,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in CCFO’s News-Release for 2015’s public-safety gather,
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2016

The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made initially, which caused them to compound. The beginning-of-the-year figure for 2015 — the pre-gather estimate — was per the BLM’s pre-safety-gather News Release.

Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
2008 250 435 + 87 BLM estimated foal-crop @ 20%.
Falsely equated it to the herd-growth rate.
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
——
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
Falsely equated it to the herd-growth rate.
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
Falsely equated it to the herd-growth rate.
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
—–
267 Post-gather estimate = 38+22+207

2011 267 + 53 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
PZP would not have affected mares
—– already pregnant when inoculated.
320 End-of-year estimate = 267+53
2012 320 + 64 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
But that birth-rate estimate was wrong.
PZP was at maximum effect and
—– would have reduced the foal-crop.
384 End-of-year estimate = 320+64

2013 384 +334 BLM estimated foal-crop @ 87%
Falsely equated it to the herd-growth rate.
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal-crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
Falsely equated it to the herd-growth rate.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 End-of-year estimate = 718+144-30-2
2015 830 Public health and safety excuse used
to justify removing 100 wild horses
without an EA.
February – 101 Number removed — plus 2 horses
said to be “domestic.”
The subject EA states: “Currently there are
approximately 200 head of wild horses that
are within 6 miles of Highway 21. These
horses are continually on the highway in search
of space, forage and water.” EA pdf-page 28
My comments: So, 200 took the place of the
100? Implausible. Wild horses roam. It’s their
nature. That’s why a safety-fence is needed.
—–
729 Adjusted population estimate
2015a 729 146 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
– 8 Deaths
—–
867 End-of-year estimate = 729+146-8
2016 867 173 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
—–
1040 Possible pre-gather estimate = 867+173
The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.
Not the First Time Population-Estimates Were Found to Be Flawed

In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …

125 %
131 %
153 %
157 %
249 %

Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.

Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it portrayed an incorrect picture — an exaggerated picture — of the herd’s population.

Recommendations: Stop the inflammatory rhetoric. For example, the EA warns, ominously: “If horse populations were allowed to continue to double or triple throughout the HMA, wild horses would utilize all of the available AUM’s allocated for other resources.” EA pdf-page 27 Scare tactics have no place in a legitimate EA. Stop the nonsense.
Societal Impact of Inflated Population-Data

The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly local elected officials and permittees — in an uproar over a false “overpopulation” that BLM’s faulty figures portray.

BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
County Commissions Pass Resolutions, but Commissioner Goes to Jail

The EA cited the resolutions that local county commissions have reportedly passed, demanding that BLM reduce the herd to AML. However, one of the ringleader-commissioners, Phil Lyman, was recently sentenced to jail after having been convicted of conspiring to operate off-road vehicles on public lands closed to off-road vehicles, and operation of off-road vehicles on public lands closed to off-road vehicles. He and a co-conspirator must pay their share of $96,000 in damage caused and serve 3 years probation.

Federal prosecutor Jared Bennett asked the judge to sentence Lyman to a “limited but reasonable” prison term to promote respect for the law and to deter others from committing the crime. Lyman knew the ride was illegal and he used his political office to recruit others to participate, he said.

http://www.deseretnews.com/article/865643995/Judge-sentences-San-Juan-Commissioner-Phil-Lyman-to-10-days-jail-3-years-of-probation.html?pg=all
Bogus Data Inflames Local Ranchers and Costs Wild Horses Their Freedom

The EA states that there have been requests over the past two years from land owners adjacent to the Sulphur HMA for removal of wild horses. These requests most surely came from renegade ranchers, such as LaVoy Finicum of Arizona who, inspired by Cliven Bundy, has gone public with his refusal to recognize BLM’s authority, to pay his grazing fees, and to comply with season-of-use. In Nevada, in addition to Cliven Bundy, Kevin Borba and Dan Filippini blatantly defied BLM’s authority; yet they too were pacified with concessions. BLM enables and rewards such bad behavior by caving in to it. There are likely permittees in Utah emulating Bundy, Borba, Filippini, and Finicum.

http://www.stgeorgeutah.com/news/archive/2015/11/01/mgk-finicum-blm-dispute-bundy/#.VjeBkW7ko1c

The EA’s proposed removals of wild horses and pesticide-treatments on the few allowed to remain appear designed to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by fictitious figures on herd-growth.
Bundy Brothera and Finicum Lead Armed Takeover of the Malheur National Wildlife Refuge

Ammon and Ryan Bundy, along with LaVoy Finicum are the “spokesmen” who have commandeered the Malheur Wildlife Refuge. Armed for battle, they continue, as of this writing, to occupy. Using Federal vehicles and machinery, they tore down a fence built to keep trespass-livestock out. They come and go as they please, even soliciting snacks and coffee creamer (French Vanilla) from supporters. The situation is out of control. BLM and FBI appear to be kowtowing to the rebels.

Here are excerpts from a news report:

The militants occupying the Refuge asked Harney County ranchers to tear up their leases with the Bureau of Land Management and stop paying the federal government to graze cattle on public land.

“I’ve done it. Cliven Bundy’s done it,” said LaVoy Finicum, an Arizona rancher and the militants’ defacto spokesman. “Now is the day. Now is the time. Are you going to wait for tomorrow? For next week? Next month? Next year? When? When will you stand up if not now?”

Finicum invited the ranchers to cancel their leases with the BLM at a ceremony before the media at the refuge on Saturday. He said two ranchers, one from New Mexico and another from Harney County, are scheduled to void their contracts publicly.

Ryan Bundy went on to emphasize his view that breaking away from the federal government means ranchers wouldn’t have to follow federal laws, like the Endangered Species Act.

LaVoy and the Bundys also acknowledged their proposition is risky. They said any rancher who joined them would get protection from the armed militants ….

http://www.opb.org/news/article/ammon-bundy-oregon-grazing-blm-finicum-crane/
QUESTIONABLE CAWP, FALSE REASSURANCES
CAWP Condones Abuse

The Comprehensive Animal Welfare Program (CAWP) for rounding up wild horses has farcical features. For example, hitting, kicking, striking, and beating a wild horse “in an abusive manner” is prohibited. The guidelines do not define at what point such mistreatment would be deemed “abusive” and, at any rate, there are no consequences identified for violating the prohibition.

Another example: The roundup–helicopter–the CAWP okays the use of helicopters — is not allowed to hit a wild horse. (There is plenty of video-footage showing that such ramming occurs.) If the helicopter hits a wild horse, what to do? The CAWP says: Document it! Again, there are no penalties for such abuse.

Yet another example: The helicopter-pilot must not drive wild horses to the point of exhaustion. The attending veterinarian–if there is one (the CAWP requires one be present but the EA says there “may” be one)–must “check for signs of exhaustion.” And …? And, nothing. Just check. No penalties.

One more example: The CAWP allows electric prods to be used on the horses “no more than three times during a procedure … except in extreme cases with approval ….” Who’s counting? Who is able to supervise properly in the chaotic conditions of a wild-horse roundup? Hotshots are abusive and should never be used. Ever.
BLM Lies about Impact of Abusive Roundup

The EA’s standard wording disinforms the reader that virtually all negative impacts of roundups disappear within hours to several days of when wild horses are released back into the HMA. That is false. Please refer to the report linked below. I recommend BLM add it to the “References” section after studying it and reforming your methods accordingly.

http://thecloudfoundation.files.wordpress.com/2010/04/bruce-nock-report-final.pdf
BLM Fails to Address Results of Helicopter Hearing

The EA states:

As required by regulation [43 CFR 4740.1(b)], a public hearing was held in Price, Utah on December 8, 2015 and will be held in subsequent years to discuss the use of helicopters and motorized vehicles in the management of Utah BLM’s wild horses and burros. … Comments received from the Preliminary Environmental Assessment (EA) and at those public meetings will be considered and, if applicable, will be addressed in management actions, NEPA documents, and decision documents using the most current direction from the National Wild Horse and Burro Program. EA pdf-page 44

I submitted detailed, substantive comments for the hearing. By now, BLM should have acted upon them and made reforms.
BLM Lies about Foal Weaning

In more standard wording, the EA states: “Nearly all foals that would be gathered would be over four months of age and some would be ready for weaning from their mothers. In private industry, domestic horses are normally weaned between four and six months of age.” EA pdf-page 37

Please note that in “private industry,” foals receive special feed and supplements, and they would be sheltered from the elements. In the wild, foals nurse for many months longer than in domestic settings, where the profit-motive leads breeders to wean early — a traumatic event for both foals and their dams.
Increased Foaling Rates?

BLM claims to need to reduce the wild-horse population. Yet the EA states: “Achieving the AML and improving the overall health and fitness of wild horses could also increase foaling and foaling survival rates over the current conditions.” EA pdf-page 36 This is an example of BLM’s eagerness to justify the unjustifiable. But in so doing, BLM belies its own contentions.
BLM Lies about Population Growth

In looking for every reason not to adopt any alternative but the proposed one, BLM insists repeatedly that unless mass-removals and PZP treatments are conducted, “… wild horse populations may increase at a faster rate and exceed the high end of the AML ….” EA pdf-page 38 However, that contradicts the WinEquus population-projections, which show a higher median-trial population for the proposed action.
BLM Lies about PZP Safety

The EA claims PZP injections would not affect unborn foals. That is false.

Sacco et al. reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. These findings were disclosed in 1981. Yet, PZP is regularly administered to pregnant and lactating mares, who transfer the destructive antibodies to their fetus, via the placenta, and to their foal, via mother’s milk.

If mares are injected with PZP while pregnant or nursing, these fillies will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when such fillies are injected as yearlings, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized in utero or while nursing.

http://www.ncbi.nlm.nih.gov/pubmed/7328557
BLM Lies about Gender Ratio

The EA warns that gender-ratios could become lopsided if the proposed action were not taken: “Near normal populations exhibit a 1:1 sex ratio. Population shifts favoring males could occur as males are better adapted to compete for resources during changing environmental conditions.” EA pdf-page 41

But BLM also advises that, for the WinEquus population-modeling trials, one of the assumptions employed was: “Sex ratio at birth: 58% males.” EA pdf-page 90 Further, I note that following the 2008 gather, 12 females and 17 males were returned to the range, giving males a 59:41 percent advantage to the males. Finally, bachelor-stallions are more successful in escaping from helicopter-roundups. They have no mares and foals to protect. So, the roundup-method itself creates a post-gather herd skewed to more males than females.
BLM Uses Obsolete Range Assessment Technique

The EA states that the “Key Forage” method was used to evaluate range-conditions. The full title of that approach is the “Key Forage Plant” (KFP) method. However, KFP is obsolete, having been replaced by the Landscape Appearance method as far back as 1996. Moreover, per Technical Reference 1734-7, Ecological Site Inventory, such qualitative assessments “may result in reduced accuracy, limiting use of the data.” If for only this reason, I cannot rely on the EA’s representations regarding conditions in the Sulphur HMA.
BLM Lies about Year-Round Wild-Horse Presence

The EA states that wild horses do more damage because they are present year-round as opposed to livestock, which supposedly are not. However, inspection of the Active-Use chart EA pdf-page 20 reveals that nearly 49% of the livestock allotments are used year-round, and 67% are used 8-to-12 months. Further, actual-use is whatever the permit-holders self-report. Going back to the rogue ranchers in open rebellion against BLM, it is likely that real use is much higher than “actual.”
BLM Hauls Water but Fails to Install Guzzlers

BLM states that water is the limiting factor for wild-horse populations, and claims to have hauled 160,000 galllons of water into the HMA last summer for the wild horses. EA pdf-page 20 What this points to is the need for guzzlers — trick-tanks — to capture and store whatever precipitation there is.
BLM Falsely Blames Wild Horses for Damage to Riparian Areas

In its zeal to condemn the wild horses, BLM lumps wild horses in with livestock as responsible for damage to riparian areas. Yet, the EA also notes that it “is not the nature of wild horses to rest exceedingly at water sources.” EA pdf-page 53 Stop the false accusations. Your bias is showing.
BLM Plans to Use Barbed Wire for Safety Fence

Horses and barbed wire do not mix. Yet, the EA states that barbed wire will be used for the fence along Highway 21. That is not good enough. You need to use appropriate materials that pose less risk of injuring the horses.

Here are some links to information on the various types of fences and their price-ranges. Note: I have no connection whatsoever with any of these groups.

http://horseandrider.com/article/field-guide-to-horse-fences-13317

http://www.progressivecattle.com/topics/facilities-equipment/4793-building-fence-a-yearly-job-on-every-ranch

http://www.extension.iastate.edu/agdm/livestock/html/b1-75.html

http://www.rammfence.com/fence/coated-wire-fence/coated-wire-fence-rolls/high-impact-raceline-coated-wire.html
BLM Notes Interior Fences Block Wild Horses

The EA admits, without further explanation: “Construction of fences within Sulphur HMA boundaries could inhibit the free-roaming nature of wild horses.” EA pdf-page 42 It is time to remove interior fences, not to install more. This matter needs to be resolved.
Finally, Some Truth-Telling

It was refreshing to encounter at least some truthfulness in the EA:

At the turn of the century, large herds of livestock grazed on unreserved public domain in uncontrolled open range. Eventually, the range was stocked beyond its capacity, causing changes in plant, soil and water relationships. Some speculate that the changes were permanent and irreversible, turning plant communities from grass and herbaceous species to brush and trees. EA pdf-page 43

BLM needs to stick to the facts and cease blaming wild horses for what livestock already did.
——————————————-

Please consider these substantive comments and new information — new to BLM — and make the necessary course-corrections and reforms.
Sincerely,

Marybeth Devlin

Conversation about fertility control with Brett Hass, retired biologist previously with NSA (part 1)

Posted on January 19, 2016 by Protect Mustangs

Don’t let pesticides like Gonacon™, PZP or SpayVac® manage native wild horses to extinction. The Spin Dr.’s and some ignorant horse advocates are pushing fertility control on underpopulated wild horses. Know the truth and expose those spewing the spin.

Read the entire Gonacon™ Pesticide Fact Sheet

Interview

John Cox: Brett, you’re a retired biologist, previously with the NSA for how many years?

Brett Hass: 46 long years John. We met in Vietnam, when we a lot younger my friend (smiles). We were doing wildlife and vegetation studies in your AO (area of operations). That was my first assignment with the NSA, as a matter of fact.

John Cox: Let’s cut through all of that. What do you think of Gonacon™ and some of the other fertility controls BLM is using?

Brett Hass: As usual, and as government agencies do and BLM and DOI are extremely guilty, they pretend that science guides its wild horse and burro management strategies. So the agencies involved go forth and resolve issues, supposedly, with experimental drugs–in this case GonaCon™. The question is, in reality, does it resolve anything at all, or is it simply to further experimentations with this drug and the wild horses the most expendable of situations currently?

The problem is very obvious, with the first-time use of an experimental drug, they act like children with a new toy–but this toy is extremely dangerous, to not only the horses and actually lead them to extinction, but the environmental consequences are apparently neglected entirely? (shakes his head negatively). . .

But let’s get real, the very absence of science contradicts any time of sound reasoning for its use whatsoever. So once again we have a government agency, using a Nazi-Type experimental fertility drug on horses and other wildlife–without knowing, or even acknowledging for that matter, what the long-term consequences are–or in perception–the problems that will arise in its actual use.

There is no resolution, as I reviewed the population situation and see first hand there is no over-population if wild horses just within the BLM numbers alone; but livestock, that is a completely different matter, in reality.

John Cox: In your appraisal of the information you’ve read, would you, as a tenured Wildlife Biologist for over 50 years, use this drug?

Brett Hass: Absolutely not! There is no pertinent reasoning to use it right now and especially on wild horses or much of anything else for that matter. Our wildlife and environment is simply too important to be so frivolous with such activity, especially an unknown situation, as fertility drugs used in our natural environment. But as you say, ignorance is quite something, and our government seems to portray ignorance quite well, and frankly the only situation they seem to be competent to accomplish.

Much more on this discussion with Brett Hass later . . .

Below is the original PZP Pesticide Fact Sheet before HSUS seems to have lobbied the EPA to make changes to the chemical class. It’s still only approved as a pesticide to manage pests. PZP is made from slaughterhouse pig ovaries mixed with modified freund’s complete adjuvant.

(American wild horses used in fertility control experiments)

© John Cox, printed with permission

John Cox is a Vietnam Vet, living in the mountains of the Pacific Northwest who writes about the environment. He’s passionate about saving America’s wild horse herds and wolves.

Read John Cox’s blog at: https://prophoto7journal.wordpress.com

Have you read about the Gonacon™ Experiment on the Water Canyon herd and the UNLUCKY 11 orphans? It all started as a PZP proposal and went down the slippery slope. . . Read about it here: http://protectmustangs.org/?p=8488

Protect Mustangs comments against spaying wild mares in Wyoming

Posted on January 14, 2016 by Protect Mustangs

——– Original Message ——–
Subject: IMPORTANT White Mountain & Little Colorado EA Comments
From: <X@protectmustangs.org>
Date: Thu, January 14, 2016 4:02 pm
To: blm_wy_whitemtn_littleco_hma@blm.gov

BLM Rock Springs Field Office
WMLC Scoping Comment
280 Highway 191 North
Rock Springs, WY 82901

Email to: blm_wy_whitemtn_littleco_hma@blm.gov
Fax: (307) 352-0329

January 14, 2016

Dear Public Servants at the BLM:

We represent thousands of supporters who love America’s wild horses in Wyoming and request you halt your plans to spay wild mares for the following reasons and others:

1.) We object to using tax dollars to experiment on, forcibly drug with PZP, SpayVac® or Gonacon™ and / or sterilize America’s wild horses on the White Mountain herd management area located in Wyoming (http://www.blm.gov/wy/st/en/field_offices/Rock_Springs/wildhorses/whitemtn.html) or elsewhere.

2.) We do not want federally protected wild horses to be used for research experiments using radio collars, devices in tails and spaying America’s federally protected wild mares. Research and Sterilization is a form of harassing wild horses. This is heinous and cruel. The public is outraged and they are calling for nationwide protests to bring awareness to this wrongful act against American wild horses.

3.) Wild horses found in the White Mountain and Little Colorado HMA’s are not “excess” according to the Wild and Free-Roaming Horses and Burros Act of 1971. For example, there is only 1 wild horse per 6,000 acres in White Mountain. The BLM fraudulently inflates population growth (see: http://protectmustangs.org/?p=8551) and never performs a real headcount.

4.) We support natural selection and we are against fertility control especially before reintroducing the natural balance of predation because America’s wild horses deserve to live on public land set aside principally but not exclusively for their use according to the law. Allowing more than 50 to 1 units of livestock to wild horses is unfair and goes against the 1971 wild horse protection act. We request you follow the law and give America’s wild horses and burros back all the public land you have taken from them since 1971.

5.) Fertility control, such as spaying and/or PZP, will destroy the beloved White Mountain herd’s genetic viability, wreck havoc on their behavior and social structure–so therefore we are against it.

6.) PZP sterilizes after multiple use and we do not want these wild horses sterilized by way of PZP either

7.) Spaying to sterilize a wild mare can cause complications, infections and death. Even petMD advises against it. Below is an except from their article:
Why You Don’t Spay When the Animal Eats Hay
by Dr. Anna O’Brien

“Spaying a mare is a more complicated medical procedure than gelding, involving entering the abdominal cavity. Although there is more than one way to spay a mare, each resulting in the removal of the ovaries, the procedure tends to be painful and there can be scary complications, such as bleeding from the ovarian artery, which can be difficult to control.

More recently, many veterinarians elect to spay mares using laproscopic methods, which means using small incisions and inserting small cameras on the ends of lasers to view the ovaries and remove them. . .

. . . Then comes the question of population control, since I feel this is the strongest argument to spay and neuter dogs and cats. Although there is the problem of unwanted horses in the United States, you simply don’t have the hoards of stray horses roaming the streets as you do cats and dogs. Rare is the kid who comes in saying, “Mommy, look what followed me home. Can we keep this horse?” ‘

(From: http://www.petmd.com/blogs/thedailyvet/aobriendvm/2014/august/why-you-dont-spay-when-animal-eats-hay-31930)

8.) BLM has been inflating wild horse population estimates to justify removals and appears to be fleecing the American taxpayer. The Appropriate Management Level (AML) is a biased number favoring the livestock industry and does not represent the true carrying capacity for wild horses on public land. AML needs to be updated and management needs to be revamped to utilize the wild herds to reverse desertification. They are an asset.

9.) Where is the accurate and detailed headcount to justify BLM’s claims of excess? Where are the videos and/or facial recognition photographs cataloguing each individual wild horse in the herd management areas to ensure no double counting occurs?

10.) Tourists come to Wyoming from around the world to see the wild horses at White Mountain. They are easily accessible and inspiring. Experimenting on this herd or any other herd is wrongful, cruel and against the majority of the public’s wishes. Any claims you may eventually produce stating that you have not received thousands of hands off comments is a direct result of your poorly publicized proposal on a national and international level.

11.) In 2011, we sent one of our founding board members to Wyoming to study the White Mountain wild horses because we are interested in this treasured and accessible herd. Here is a slide-show on YouTube of the White Mountain Herd before the 2011 roundup:

12.) We want to be able to come to Wyoming to see, photograph, study and film the White Mountain and Little Colorado wild horse herds with foals exhibiting natural behaviors–without radio collars and other devices–and definitely not sterilized.

13.) We are also against radio collars because they are dangerous for wild horses for various reasons including but not limited to hooves getting stuck in collars causing injury or death, EMF related sickness, stress inflicted on federally protected wild horses which lowers their immune system and makes them more susceptible to disease, etc. The public will hold BLM accountable for any injuries or deaths related to radio collars or any other assault on the bodies of America’s wild horses during experimentation that is being white-washed as “research” or “studies”.

14.) I am making a documentary on wild horses and want to film the White Mountain and Little Colorado wild horses exhibiting authentic natural behavior. My documentary might end up being a series so I want to be able to come back to the White Mountain and Little Colorado herds to film them years later and document how the foals have grown up and joined their own family bands with foals of their own, etc. The public likes these sort of nature films.

15.) The proposed roundups for your proposed spay research / experiment would contribute to global warming with all the motorized vehicles used. The environmental cost is too great for this proposed research. The Bureau of Land Management must take actions to reduce global warming–not contribute to it.

16.) America’s wild horses are a native species having been returned to their native lands–if they ever all died out in the ice age. Fossil findings are pushing back the die out date. Now the theory of wild horses going extinct is being questioned. These are exciting times.

17.) Wild horses contribute to the ecosystem, heal the land and reverse desertification. They must not be sterilized. America’s wild horses are a resource who must be protected in genetically viable numbers to ensure survival–especially with environmental challenges ahead of them.

18.) The public is outraged about the BLM’s proposal to research and experiment on the White Mountain herd using Little Colorado as a control group. It’s clear the American taxpayers don’t want their tax-dollars to be used for cruel roundups destroying family bands, engaging in experimentation, sterilization and birth control assaulting their right to freedom. More than 20,000 people have signed our petition against the roundups and more are signing every day. (https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups)

We officially ask you to immediately stop your proposal to spay the White Mountain herd which you allege is research. Americans and citizens of the world do not want iconic wild horses of the West to be used as laboratory test animals.

Sincerely,
Anne Novak

.Anne Novak
Executive Director
Protect Mustangs

Read about native wild horses: http://protectmustangs.org/?page_id=562

Twitter: https://twitter.com/TheAnneNovak
Facebook: https://www.facebook.com/ProtectMustangs
In the news: https://newsle.com/AnneNovak

www.ProtectMustangs.org
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.

Slideshow of the White Mountain wild horses before the 2011 Wyoming roundup

Posted on January 14, 2016 by Protect Mustangs

Stop experiments, sterilization and risky birth control on America’s wild horses in Wyoming

Posted on January 13, 2016 by Protect Mustangs

Take Back the Power (© Protect Mustangs with Photo © Cynthia Smalley)

URGENT: Comments against experimentation, sterilization and birth control on a nonviable herd are due by 5 pm January 14

SUBJECT: “White Mountain & Little Colorado EA Comments”

EMAIL TO: blm_wy_whitemtn_littleco_hma@blm.gov
FAX: (307) 352-0329.

BLM Rock Springs Field Office
WMLC Scoping Comment
280 Highway 191 North
Rock Springs, WY 82901

In your own words tell the BLM the following:

1.) I object to using my tax dollars to experiment on, forcibly drug with PZP and / or sterilize America’s wild horses.

2.) I do not want federally protected wild horses to be used for a research experiment using radio collars, devices in tails and spaying America’s federally protected wild mares. Sterilization is a form of harassing wild horses and against the law.

3.) The wild horses found in the White Mountain and Little Colorado HMA’s are not excess according to the Wild and Free-Roaming Horses and Burros Act of 1971. There is only 1 wild horse per 6,000 acres in White Mountain. The BLM fraudulently inflates population growth (http://protectmustangs.org/?p=8551) and never performs a real headcount.

4.) I support natural selection and I am against fertility control of any kind because wild horses deserve to live on public land set aside principally but not exclusively for their use. Allowing more than 50 to 1 units of livestock to wild horses is unfair and goes against the 1971 wild horse protection act.

5.) Fertility control, such as with PZP and spaying, will destroy the herd’s genetic viability, wreck havoc on their behavior and social structure so therefore I am against it.

6.) I want to be able to come to Wyoming to see and photograph the White Mountain and Little Colorado wild horse bands with foals exhibiting natural behaviors–without radio collars and other devices–and definitely not sterilized.

7.) PZP sterilizes after multiple use and I do not want these wild horses sterilized.

Signed,

_________________________________________________

Date _________________________

Fear of sterilization used to push PZP on free roaming wild horses

Posted on January 13, 2016 by Protect Mustangs

BLM’s plans for sterilization include the slow extinction drug called PZP which sterilizes after multiple use

Since 2009 and surely earlier, the Bureau of Land Management (BLM) has always said they want to sterilize wild horses and burros. BLM and Secretary Sally Jewell want to use other forms of birth control besides PZP even though Congress has paid BLM to let Big Pharma experiment with PZP on our wild mares for decades.

At least one pharmaceutical company was hoping to use PZP for human contraception but since it’s not safe for the ovaries and makes wild horses sterile after multiple use, it’s not ideal for a human product.

PZP, Porcine Zona Pellucida, is made from slaughterhouse pig ovaries and mixed with adjuvant.

BLM never said they liked PZP for wild horse management. The truth is BLM thinks PZP is impractical and they don’t believe it works well. BLM doesn’t want to round up wild horses every 1 or 2 years (for native PZP or PZP-22) and be bothered with drugging wild mares at the “right time” of year. 90% of the herds on public land need to be rounded up to be darted with PZP. Only the ones who are almost domesticated and let people close can be darted in the field. The feds would rather use a one shot deal to sterilize wild horses or just geld (castrate) or spay them and toss them back out to die off and not reproduce.

You might be hearing spin and rumors once again from the growing group of BLM collaborators/advocates who used to fight for wild horse freedom but who now fight for PZP. They have invested in PZP as their pillar of management. Some are applying for grant money to monitor the herds on PZP.

Their fear based spin goes like this:

“If the BLM doesn’t use PZP to manage population for a zero growth then they will sterilize them.” This statement is FALSE. BLM already wants to sterilize them and PZP sterilizes after multiple use.
“If the BLM doesn’t use PZP to manage population for a zero growth then they will sell them and they will end up slaughtered.” This statement is FALSE. BLM wants to dispose of as many wild horses as possible. PZPed mares have been seen in the kill pens.
“If the BLM doesn’t use PZP to manage population for a zero growth then they will kill them.” This statement is FALSE. The BLM would face a wave of public outrage and protests if they announced plans to kill alleged “excess” wild horses.

Then there is the outright lie: “PZP is only a temporary measure to use until we can stop horses from going to slaughter.” No policy the government undertakes is ever quickly undone. If BLM were to start administering PZP to all the wild mares from starting at 18 months old, then this would take years to undo. The herds’ genetic viability would be wiped out. America’s wild horses would be managed to extinction for sure.

The coalition working for PZP-based management of wild horses called The American Wild Horse Preservation Campaign (AWHPC) used Return to Freedom sanctuary as their 501c3 fiscal sponsor for donations up until 2016. It seems Return to Freedom has also received a lot of money from BLM in the past. Was that for decades of PZP research?

PZP was approved by the EPA in 2012 as a “restricted use pesticide” based on The Humane Society of the United States’ (HSUS the AWHPC coalition member) application stating that wild horses are “pests” and a threat for various reasons.

The Humane Society of the United States and their wild horse partner known as The American Wild Horse Preservation Campaign have been throwing a lot of money at PR and marketing campaigns to push PZP on an emotional public. At some point it’s believed they spent a lot of money hiring a PR firm to get their “PZP for human management”, #Justice4Mustangs, #KeepWildHorsesWild message out. AWHPC uses a fundraising and advocacy program for their website, alerts, petitions, etc. called SALSA. Their pricing is outrageously high and rises based on the number of supporters connected to the platform. Their website is www.SalsaLabs.org

Even the docudrama AMERICAN MUSTANG pushes PZP on their target audience. It was made by a major donor and player at AWHPC. How can they push PZP pesticide on what they say in the film is a native species? Was the footage taken at 1:02–1:08 and 2:13–2:21 of wild horses in the care and control of Return to Freedom while being boarded at the feedlot in Fallon Nevada for close to 2 years?

The truth is wild horses are not overpopulated. BLM fraudulently releases crazy population numbers to fool your elected officials into giving them more money to wipe out America’s last federally protected wild horses on public land. You can read more about that here: http://protectmustangs.org/?p=8551 .

According to a press release from National Academy of Sciences (NAS) released June 5, 2013, “The U.S. Bureau of Land Management’s (BLM) current practice of removing free-ranging horses from public lands promotes a high population growth rate, and maintaining them in long-term holding facilities is both economically unsustainable and incongruent with public expectations, says a new report by the National Research Council.”

The NAS report states there is “no evidence” of overpopulation. Only tobacco science and spin backs up BLM’s population claim to justify roundups and fertility control/sterilization.

Sadly BLM collaborators like The Cloud Foundation–one of the leading PZP pushing groups and an active member of the American Wild Horse Preservation Campaign, doesn’t seem to be fighting BLM’s overpopulation myth anymore. They lost their way in 2011 when the group named after the Cloud the Stallion films on PBS seems to have abandoned the fight for America’s wild horses’ right to real freedom. It appears the Cloud Foundation and the filmmaker caved into pressure and the seduction of PZP–as being the “lesser of two evils.”

Now the Cloud Foundation is enticing their followers to speak out for PZP instead of BLM’s proposed radio collars and sterilization of the White Mountain Herd in Wyoming. What ever happened to speaking out for the federally protected yet voiceless wild horses and stopping BLM from managing them to extinction?

Wild horses want their right to real freedom. Forced drugging with PZP pesticide is an infringement on the core of wild horse freedom. It violates their right to let nature decide the survival of the fittest, who breeds and tortures the mares who will be raped repeatedly because she isn’t fertile yet comes into heat monthly.

Other groups are hoping for grant money to participate in more PZP related research.

Accepting the need for any kind of fertility control is a slippery slope because BLM and the Department of Interior will pounce on the opportunity to tell elected officials that the majority of the public wants birth control to fix their counterfeit crisis. Of course this isn’t true. The majority of the American public has no clue that their tax dollars are being used to fund cruel animal experiments and manage a wild species to extinction.

The Las Vegas Review Journal reported on the Western Governors’ Association Conference in December 2015 where the Department of Interior’s Secretary Sally Jewell briefed those present on the wild horse issue:

Jewell said that by law the horses cannot be killed. The population has grown to about 100,000, with roughly half now in holding pens.

Jewell said the government will continue to work [with] birth control methods, noting that the horses are “very good at reproducing.”

“We believe that birth control is a path forward that will help satisfy people that feel passionately on both sides of the issue,” Jewell said.

No Secretary Jewell, birth control will not satisfy people that realize BLM has inflated the population data to support their goal to remove as many wild horses as they can. The public feels passionately about wild horses’ right to be protected in the true spirit of the Wild and Free-Roaming Horses and Burros Act of 1971. We don’t want them forcibly drugged up with pesticides like PZP, Gonacon™, SPayVac®, brutally given chemical vasectomies and field spaying for birth control nor do we want wild horses and burros used for experiment and research.

The War on Wild Horses

Secretary Jewell basically informed the governors that wild horses are overpopulating like rabbits. When she spoke about birth control she wasn’t specifically talking about PZP. The head of the Department of Interior was talking about fertility control, period.

She worked as a power broker in the oil and banking industries before her stint as CEO of REI. Jewell’s goal seems to be to maximize resources on public land for profit. Wild horses and burros can slow down profit so they need to be wiped off the game board.

Secretary Jewell cast out an open invitation for universities and Big Pharma to experiment on our treasured wild herds with an incentive grant program.

The BLM is only out for big money. The federal agency can get more money from mining, fracking, for oil and gas as well as for renewables such as massive dirty solar farms, etc without wild horses out there.

The livestock and Big Ag lobbies are strong so BLM must be sure to leave them some crumbs. That’s why the Cattlemen’s lobby feels so threatened to share any grazing space or water–not that they ever liked sharing public land grazing with native wild horses.

Links of interest:

Wild horses may be spayed in Wyoming (Associated Press): http://www.denverpost.com/news/ci_29323218/wild-horses-may-be-spayed-wyo

PZP is an EPA approved RESTRICTED-USE PESTICIDE that sterilizes wild horses after multiple use so it’s risky for long-term herd survival. See information here: http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

Info on PZP sterilizing mares: The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus), Princeton http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p

The Horse and Burro as Positively Contributing Returned Natives in North America (American Journal of Life Sciences): http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12

Cloud Foundation collaborates with the BLM to drug Pryor Mountain wild horses with PZP: http://www.blm.gov/pgdata/etc/medialib/blm/mt/main_story.Par.31432.File.dat/TopStoryHorse.pdf

Protect Mustangs speaks out against the Cloud Foundation’s PARTNERSHIP with BLM using risky PZP that could terminate natural selection: http://protectmustangs.org/?p=4941

Wildlife Ecologist, Craig Downer, speaks out against using PZP in the Pryors: http://protectmustangs.org/?p=4178

Secretary Sally Jewell claims the majority of Americans want fertility control for wild horses: http://www.reviewjournal.com/news/las-vegas/homeland-security-wild-horses-among-topics-governors-conference

7 Questions About Wild Horses for Interior Secretary Nominee Sally Jewell (The Atlantic): http://www.theatlantic.com/national/archive/2013/03/7-questions-about-wild-horses-for-interior-secretary-nominee-sally-jewell/273706/

Energy Think Tank calling the shots for public land: http://www.energyxxi.org/energy-works-us-0

Forum on PZP for Wild Horses & Burros on Federal Land: https://www.facebook.com/groups/ForumPZPWildHorsesBurros

Wild and Free-Roaming Horses and Burros Act of 1971: https://en.wikipedia.org/wiki/Wild_and_Free-Roaming_Horses_and_Burros_Act_of_1971

U.S. looking for ideas to help manage wild-horse overpopulation (Washington Post): http://wapo.st/1OOARTe

BLM Fakes Population Growth to Wipe Out America’s Wild Horses

Posted on January 12, 2016 by Protect Mustangs

The feds’ mustang population “data” is a fraud

By Marybeth Devlin

While pretending to rely on the assumption that herds grow 20% a year, the Bureau of Land Management (BLM) posts numbers up to 8 times higher than that to justify roundups, which are pre-scheduled on a rotation-basis, seeming to target particular herds. For instance, the Agency recently claimed that the famous Kiger herd in Oregon grew from 21 horses to 156 horses in just four years — an increase of 643%, which equates to a yearly average increase of 160%, which is 8 times higher than the 20% BLM supposedly uses. [1] Such growth is biologically impossible. Kiger is not an isolated example, although it is the worst found so far. Here are some other phony figures on population-growth recently claimed by BLM to make it appear that gathers were necessary:

Blawn Wash (UT)
297.4 % increase in 3 years, averaging 99.1 % per year

Fish Creek (NV)
80% increase in one year

Green Mountain (WY)
281% increase in four years, averaging 70.3% per year

Stewart Creek (WY)
311% increase in four years, averaging 77.8% per year
But herd-growth is unlikely to reach even 20 percent a year. It is important to understand that the birth-rate is not the same as–and should not be equated to–the population growth-rate. Here’s why: Horses die. An independent study reviewed BLM roundup-records for a representative sample of four herd management areas composed of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth-rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival-rate is just 10 percent. Further, adult wild horses also perish. They succumb to illness, injury, and predation. Their death-rate must be taken into consideration as well. But BLM ignores mortality–foal and adult–in its population-estimates. Given the 50% foal mortality-rate, and the 5% or higher average annual death-rate of adult wild horses, herd-growth could not increase 20% a year, and a herd-population could not double in 4 years–refuting yet another BLM myth.

Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates–that is how BLM creates the false impression of a population-explosion. But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear–via fictitious figures–to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP.

BLM also fails to consider another factor limiting herd-growth–stochastic events–which are random catastrophes such as wildfires or contagious diseases that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.

Now BLM is distributing grant-money to universities and researchers to study more ways of dealing with the phantom overpopulation. All manner of sicko experiments are being carried out on the wild horses, such as treating them with endocrine disruptors and sterilizing them surgically. Why? Because BLM is a corrupt agency. It invented this counterfeit crisis to create a sense of urgency, which will pressure Congress to give the Agency extra money to “solve” a non-existent problem.

TAKE ACTION: Sign and share by email the Petition to Stop the Wild Horse and Burro Roundups and Slaughter here: https://www.change.org/p/defund-and-stop-the-wild-horse-amp-burro-roundups

Contact your elected officials to make them aware of BLM’s fraudulent population claims to get funding for wild horse roundups and warehousing at great taxpayer expense: http://www.contactingthecongress.org

Click “Like” https://www.facebook.com/ProtectMustangs for updates and alerts

Visit www.ProtectMustangs.org for more information and click on the donate button help fight the injustice! You can make a difference.

Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.

(Photo by BLM. Roundup paid for with your tax dollars.)
Addendum:

[1] Using simple division to calculate the average increase is how most people would “do the math”–dividing the percentage increase (643%) by the number of years (4). Expressing the average that way is readily understandable. However, another way of calculating it is what is called the “compound annual growth rate” (CAGR). Per that method, herd-growth can be likened to compound interest that you earn on a savings account; except of course that horses do die, which complicates the computations. But for now, let’s assume that horses never die, because that’s the assumption that BLM makes.

Using the free, online CAGR tool linked below, you would enter Kiger’s beginning population–21–and its alleged ending population–156–and the number of years that had passed–4. Then press the “Calculate CAGR” button, and the tool will compute the compound annual growth rate. For the Kiger herd, the CAGR is 65%, which is “only” 3.25 times higher–instead of 8 times higher–than 20%.

Here is the tool to compute CAGR:

http://www.miniwebtool.com/cagr-calculator/?present_value=100&future_value=200&num=4

Here are the other herds cited and their CAGRs. Fish Creek stays the same because its growth is just for one year.

Blawn Wash (UT)
38 = Population-estimate 2012
151 = Population-estimate 2014, including new foals

297.4 % = Percentage increase in three years
99.1 % = Simple average annual growth-rate
58.4 % = Compound annual growth-rate (CAGR)

Fish Creek (NV)
256 = Population-estimate 2013
461 = Population-estimate 2014, before foaling season (January)
80.1% = Percentage increase in one year

Green Mountain (WY)
258 = Population-estimate post-gather at the end of 2011
982 = Population-estimate in 2015 — including that year’s foals*

281.0 % = Percentage increase in four years
70.3 % = Simple average annual growth-rate
39.7 % = Compound annual growth-rate (CAGR)

Stewart Creek
124 = Population-estimate post-gather at the end of 2011
509 = Population-estimate in 2015 — including that year’s foals*

311.0 % = Percentage increase in four years
77.8 % = Simple average annual growth-rate
42.3 % = Compound annual growth-rate (CAGR)
* BLM’s population-modeling criteria said foals were not included in the AML. Evidently, they were.

Further Insight into Calculating Population-Growth

At the link below, you will find a discussion posted by the University of Oregon, providing a comparison between the simple average and the compound annual growth-rate methodologies for calculating annual percentage population-growth.

As will be readily apparent, the simple average approach is “straight-line” and … simple. Forgive yet another pun, but the average person can easily understand it and “do the math.”

The compound annual method, on the other hand, is extraordinarily complicated to compute, which is why the online tool is almost a necessity.

What is important is that both are legitimate ways of describing the data.

http://pages.uoregon.edu/rgp/PPPM613/class8a.htm

It should be kept in mind that population-growth estimates must consider births and deaths, not just births. That’s one reason why the Gregg et al. study was so important — it established, per BLM’s own documentation, a slightly-less than 20-percent birth-rate and a 50-percent foal mortality-rate. So, a wild-horse herd growth-rate of, for example, 65%, would have to mean a birth-rate that was much higher than 65% to offset foal deaths (50%) and adult deaths (5%).

URGENT: Petition to stop violent wild horses roundups and stop sending them to slaughter!

Posted on January 11, 2016 by Protect Mustangs

Wild horses are a native species who must be saved!

Sign and share the urgent petition

Loopholes allow the BLM to sell thousands of wild horses to slaughter middlemen known as kill buyers to dispose of alleged “excess and unadoptable” American wild horses and this must stop now! Slaughter is cruel and inhumane.

This is what cruel roundups look like:

Roundups are the first step towards slaughter.

Craig Downer published the peer reviewed paper titled The Horse and Burro as Positively Contributing Returned Natives in North America.

The NAS report states there is “no evidence” of overpopulation. Only tobacco science and spin backs up BLM’s population claim to justify roundups and fertility control/sterilizations. . .

PZP is an EPA approved RESTRICTED-USE PESTICIDE that sterilizes wild horses after multiple use so it’s risky for long-term herd survival. See information here: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

Giving PZP to wild mares also results in foals being born late in the fall or winter and dying because they are too little to make it through a harsh winter.

Fertility control research trials are big business. Left unchallenged, wild horses and burros will continue to be lab rats for human fertility control research. This exploitation must stop!

We request an immediate halt to roundups for scientific population studies and studies on holistic management before it’s too late.

Wild horses are a returned-native species in America. Rounding up federally protected wild horses and burros has been documented as cruel. Warehousing them for decades is fiscally irresponsible. Sending wild horses to slaughter by selling them to middlemen is cruel and inhumane. Clearing wild horses and burros off public land–for industrialization, fracking, grazing and the water grab–goes against the 1971 Free Roaming Wild Horse and Burro Act put in place to protect the living legends of the American West. They must never go to slaughter.

We request you defund and stop the roundups immediately as well as reverse the Burns Amendment to stop unlimited sales of wild horses to slaughter.

There is no accurate census and the BLM figures do not add up. We request population studies for each herd management area (HMA) and each herd area (HA) because we are gravely concerned there are less than 18,000 wild horses and burros in the 10 western states combined. More roundups, fertility control/sterilizations and sales to slaughter will wipe them out because the majority are no longer genetically viable herds.

Wild horses are underpopulated despite spin from the forces that want to perform heinous sterilizations in the field. Humane fertility control could be looked at as an option only after scientific population studies have been conducted for each herd management area. The EPA approved restricted-use pesticides known as PZP and Gonacon have risks as do other drugs . . . Right now fertility control is premature, will destroy natural selection and could cause harm because wild horses are underpopulated in the West.

Field observers have noticed a worrisome decline in wild horse and burro populations since the BLM’s rampant roundups from 2009 to this day.

Kindly allow returned-native wild horses and burros to reverse desertification, reduce the fuel for wildfires and create biodiversity on public land, live with their families and inspire us with their spirit.

Right now America’s wild horses and burros are being managed to extinction. They need your help to stop the roundups and slaughter today.

Go to the petition on Change.org here and email it to your friends and family: https://www.change.org/p/defund-and-stop-the-wild-horse-amp-burro-roundups

AMORE was rescued from slaughter thanks to supporters

Posted on January 8, 2016 by Protect Mustangs

An American mustangs escapes a cruel death

AMORE’s owners never thought she would be bought at the auction by a Kill-Buyer who would sell her to slaughter. Someone who loved her braided her hair and made her look pretty hopping she would go to a good home. Poor baby ended up in the clutches of the killers!

Thanks to an angel named Clare Staples and with the help of Jim McQuillen, Protect Mustangs got her away from the killers!

Then the little mare got sick and had to stay in Quarantine in Oklahoma for about 2 months. She was well taken care of by Tonni and we are so thankful for her wonderful care. Now AMORE is ready to go back out West where she is from.

PROTECT MUSTANGS and AMORE want to thank everyone who pulled together to donate and share her Quarantine and Transportation fundraiser making it a success in less than 3 days. It takes a village and you all are part of this special rescue. We are grateful you are friends of AMORE. She sends her love and blessings.

AMORE is going to be safe in CALIFORNIA. She will live with some of the other mustangs from our Outreach Program. She’s about 15 years old now and when she gets older she will retire with the other mustangs and NEVER be at risk again of becoming meat on someone’s dinner plate in a foreign country.

If you are interesting in sponsoring AMORE and being a very special part of her life please contact Anne Novak at 415-531-8454.

Marybeth Devlin speaks out against PZP

Posted on January 5, 2016 by Protect Mustangs

Marybeth Devlin responds to PZP SPIN in High Country News titled: PZP: Where hope, science and mustangs meet http://www.hcn.org/articles/pzp-where-hope-science-and-mustangs-meet

Ms. Wilder is disinformed. PZP does not “cause eggs to reject sperm.” That hypothesis has been disproved. PZP is a registered pesticide whose mechanism-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that target and attack the ovaries. PZP’s antibodies cause the mare to suffer ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. Not surprisingly, estrogen levels drop markedly as the ovaries are slowly destroyed. But PZP’s adverse effects are not limited to the individual animal. As a recent study — which included the Little Book Cliffs, Colorado herd and the McCullough Peaks, Wyoming herd — found, PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Further, the same study disclosed that the pesticide causes a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recover their fertility after suspension of PZP. However, some mares never recover — they are left permanently sterile, and quickly too. Indeed, yet another study found that sterility could occur in some mares from just three years of PZP injections or from just one treatment if the pesticide were given to a filly before she reached puberty. Because PZP messes with the immune system, it ironically works “best” — sterilizes faster — if the mare has a strong immune system. But, conversely, PZP may not work at all in mares whose immune function is weak or depressed. So, the pesticide discriminates against the very horses that Nature has best equipped for survival against disease while favoring and selecting for the immuno-compromised. Worse yet, tests performed via radioimmunoassay indicated that PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques.

But there is no need for PZP or any other population-reduction measures. BLM’s wild-horse overpopulation “data” is a fraud. Reviews of BLM’s year-to-year growth-estimates for various herds disclosed biologically-impossible growth-rates. For instance, just recently in Oregon, BLM claimed that the famous Kiger herd’s population grew from 21 horses to 156 horses in just four years — an increase of 643%. Stealthily inserting bogus birth-rates into the data, then wrongly equating the birth-rate with the population growth-rate, and failing to factor in the mortality-rate — that is how BLM creates the false impression of a population-explosion. Another ruse BLM employs is restricting maximum herd-size below minimum-viable herd-size. Then, whenever a herd is made to appear — via false figures — to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70% of the herds are “managed” below minimum-viable size, including Spring Creek Basin.

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