I want to give you a heads up that another brutal Fort McDermitt roundup is being planned for late summer or early fall 2015 in Nevada. Due to our successful 2013 lawsuit, the United States Forest Service is seeking public comment due March 23, 2015, in accordance with the National Environmental Protection Act (NEPA), on the proposal to remove unauthorized tribal horses. Please send in your comments.
How will the Nevada brand inspectors identify unbranded federally protected wild horses who have migrated off the neighboring Little Owyhee herd management area? This is of great concern to the public at large.
Despite many wild horses being rescued in the mad scramble of 2013 too many truckloads went to slaughter. Horse advocates won’t tolerate the kill-buyer parking lot rip-offs any more. Those Facebook ransom pages won’t be supported this time around either. It’s time for the community to come together with advance planning.
We’d like to work with the tribe to ensure the Fort McDermitt horses don’t end up getting slaughtered for human consumption abroad. It would be a tragedy for these nice horses to end up eaten in foreign countries when they can make nice riding ponies and therapy horses. Those who wouldn’t be a good match for working with people could be distributed to Eco-sanctuaries. People around the world want to experience the Old West and native wild horses hold that allure.
The Forest Service is ignoring the ecological benefits of free-roaming horses on public land. Wild horses reduce the risk of catastrophic wildfires and help reverse desertification. Despite new methods of holistic land management, the feds continue to scapegoat wild horses for range and riparian damage caused mostly by cows and sheep.
We stopped the ongoing brutal roundups at Fort McDermitt from Sept 2013 until now based on the feds’ NEPA violation. Protect Mustangs and Citizens Against Equine Slaughter sued over the agreement that called for years of cruel roundups. At least now we have advance notice of the proposed roundup. Please contact us via email if you want to help. Our email is Contact@ProtectMustangs.org
Though the USFS didn’t participate in the Fort McDermitt roundup, the USFS-McDermitt agreement was left on the table. Our lawsuit was about their failure to conduct NEPA. Protect Mustangs and Citizens Against Equine Slaughter got the illegal agreement scrubbed out on Sept. 3, 2013, after the roundup cases filed by other groups had been lost/dismissed in mid-August. To ensure transparency of future roundups we requested the United States Forest Service conduct NEPA and give notice if they should roundup Fort McDermitt wild horses again. Now they are doing it.
In accordance with our settlement agreement, Protect Mustangs received notification of another Fort McDermitt roundup and we are sharing the news with you so you can take action.
Citizens Against Equine Slaughter and Protect Mustangs file preliminary injunction (August 24, 2013): PLAINTIFFS’ MOTION FOR PRELIMINARY INJUNCTION AND MEMORANDUM IN SUPPORT
Horses saved and horses lost at Native American horse auction (August 17, 2013): http://protectmustangs.org/?p=5023
Official request to terminate roundup agreement, request DNA testing, separate unbranded wild horses, etc. (August 15, 2013): http://protectmustangs.org/?p=4969
It’s time to join forces to save the Fort McDermitt free-roaming horses from going to slaughter. Last time we had no advance notice. Today we do. Let’s make the most of it–for the horses!
Many blessings,
Anne
Anne Novak
Executive Director
www.ProtectMustangs.org
Anne@ProtectMustangs.org
Baby Spitfire was born out of a miracle rescue. Her papa was brutally slaughtered shortly after 41 wild horses in Wyoming were rounded up in the March 2014 BLM stealth roundup and were quickly sold off by the WY Livestock Board at auction to the most prominent slaughterhouse in North America–who slaughters wild and domestic horses for human consumption abroad.
Mark Boone Junior (Bobby Elvis on Sons of Anarchy) and Anne Novak found the only mustangs left alive at the slaughterhouse yard–14 young and terrified wild horses. Thanks to everyone’s prayers and good vibes they resuced the WY14 back from the slaughterhouse before they were live-shipped and turned into sashimi over in Asia. Read about the rescue here: http://protectmustangs.org/?p=6775 .
Little did they know that a member of the WY14 was carrying a little treasure through all the turmoil and terror.
Please help with a tax-deductible donation for the hay drive to get a semi-load of hay for the WY14-15. They are all growing and need more hay!
Welcome Spitfire! You will carry on the bloodline that those dumb bureaucrats at the BLM thought should be disposed of. SHAME on them.
Please donate and share the Hay Drive http://www.gofundme.com/HayDriveWY14Spitfire so the rescued wild horses can meet their goal quickly. The WY14 and Spitfire thank you for helping them survive and grow strong!
Roundups occur to PZP the wild mares with a pesticide for birth control!
Send in your public comments and be a voice for America’s wild horses and burros! Ask for management levels to rise for genetically viable herds to survive and for holistic management for all Herd Management Areas. Speak for the voiceless today.
Proposed Collection of Information on Wild Horses and Burros; Request for
Comments.
AGENCY: Bureau of Land Management, Interior.
ACTION: 60-day notice and request for comments.
SUMMARY: In compliance with the Paperwork Reduction Act, the Bureau of Land
Management (BLM) will ask the Office of Management and Budget (OMB) to approve
the information collection (IC) described below, and invites public comments on the
proposed IC.
DATES: Please submit comments on the proposed information collection by May 11, 2015.
ADDRESSES: Comments may be submitted by mail, fax, or electronic mail.
Mail: U.S. Department of the Interior, Bureau of Land Management, 1849 C Street, NW,
Room 2134LM, Attention: Jean Sonneman, Washington, D.C. 20240.
Fax: to Jean Sonneman at 202-245-0050.
Electronic mail: Jean_Sonneman@blm.gov.
Please indicate “Attn: 1004-NEW” regardless of the form of your comments.
FOR FURTHER INFORMATION CONTACT: Sarah Bohl at (202) 912-7263.
Persons who use a telecommunication device for the deaf may call the Federal
Information Relay Service on 1-800-877-8339, to contact Ms. Bohl. You may contact Ms. Bohl to obtain a copy, at no cost, of the draft discussion guides for the focus groups and in-depth interviews described in this 60-day notice. You may also contact Ms. Bohl to obtain a copy, at no cost, of the regulations that authorize this collection of information.
SUPPLEMENTARY INFORMATION:
I. Proposed Information Collection
Title: Knowledge and Values Study Regarding the Management of Wild Horses and Burros.
OMB Control Number: 1004-NEW.
Frequency: On occasion.
Respondents’ obligation: Voluntary.
Abstract: The BLM protects and manages wild horses and burros that roam Western public rangelands, under the authority of the Wild Free-Roaming Horses and Burros Act (Act), 16 U.S.C. 1331-1340. The Act requires that wild horses and burros be managed in a manner that is designed to achieve and maintain a thriving natural ecological balance on the public lands. 16 U.S.C. 1333(a). Stakeholders and the general public hold a variety of views on how wild horses and burros should be managed. The BLM has determined that conducting focus groups, in-depth interviews, and a national survey will lead to a better understanding of public perceptions, values, and preferences regarding the management of wild horses and burros on public rangelands.
After reviewing public comments and making appropriate revisions, the BLM will include the discussion guides in a request for OMB approval. Upon receiving OMB approval, the BLM will conduct the focus groups and in-depth interviews. The results of focus groups and in-depth interviews will be used to help design a national survey, which will be the second and final phase of the research.
The BLM will prepare a draft of the national survey and publish a second 60-day notice and invite public comments on the draft national survey. After reviewing public comments and making appropriate revisions, the BLM will include the national survey in a request for OMB approval. Upon receiving OMB approval, the BLM will conduct the national survey.
Need and Proposed Use: The proposed research was recommended by the National Research Council of the National Academy of Sciences in a 2013 report, Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward. Conducting the focus groups and in-depth interviews will enable the researchers to characterize the range of preferences that exist for wild horse and burro management. The national survey will then assess the distribution of these preferences across the larger population. The research results will assist the BLM to more effectively manage wild horses and burros by providing information to:
Help evaluate the benefits and costs of competing rangeland uses and variousmanagement options;
Help identify areas of common ground and opportunities for collaboration with stakeholder groups; and
Communicate more effectively with the public and with stakeholder groups.Description of Respondents: The BLM intends to survey a variety of respondents for this project by conducting focus groups, in-depth interviews, and a nationally representative survey. For the focus groups and in-depth interviews, the primary respondents will be individuals belonging to a variety of organizations that have previously lobbied, commented on program policy or activities, or have otherwise sought influence with the BLM in regard to its wild horse and burro program. Representatives of wild horse and burro advocacy groups, domestic horse owners, wild horse adopters, the Western livestock grazing community, environmental conservationists, hunters, and public land managers will be included. Nine focus groups across three locations around the country and up to 12 in-depth interviews will be conducted with individuals from these groups. Focus group participants will be recruited by BLM’s research contractor through a variety of approaches tailored to the communities participating in the discussions. In addition, four focus groups (spread across two locations) will be conducted with the general public to explore public understanding of various terms and issues involved in wild horse and burro management so that the questionnaire for the national survey can effectively communicate the relevant topics.
II. Estimated Reporting and Recordkeeping Burden
The estimated reporting burden for this collection is 142 responses and 272 hours. There will be no non-hour burdens. The following table details the individual components and estimated hour burdens of this collection.
Activity
Estimated
number of respondents
Estimated number of responses per respondent
Completion time per response
Total burden hours
Focus Groups
130 (13 groups)
1
120 mins
15,600 mins/260 hrs
In-depth Interviews
12
1
60 mins
720 mins/12 hrs
Activity
Estimated
number of respondents
Estimated number of responses per respondent
Completion time per response
Total burden hours
Totals
142
272 hrs
III. Request for Comments
OMB regulations at 5 CFR 1320, which implement provisions of the Paperwork Reduction Act (44 U.S.C. 3501-3521), require that interested members of the public and affected agencies be provided an opportunity to comment on information collection and recordkeeping activities (see 5 CFR 1320.8(d) and 1320.12(a)). The BLM will request that the OMB approve this information collection activity for a 3-year term.
Comments are invited on: (1) the need for the collection of information for the performance of the functions of the agency; (2) the accuracy of the agency’s burden estimates; (3) ways to enhance the quality, utility and clarity of the information collection; and (4) ways to minimize the information collection burden on respondents, such as use of automated means of collection of the information. A summary of the public comments will accompany the BLM’s submission of the information collection requests to OMB.
Before including your address, phone number, email address, or other personal identifying information in your comment, you should be aware that your entire comment — including your personal identifying information — may be made publicly available at any time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so.
Jean Sonneman,
Bureau of Land Management, Information Collection Clearance Officer.
I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …
Sulphur HMA
… and that are, reportedly, posing safety-concerns along Highway 21.
I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
REASONS CITED BY BLM FOR SPECIAL ROUNDUP
Overpopulation, Forage Limitations
BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.
The Proposed Action
BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830” (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.
The Issues
There are several important questions concerning the planned gather that BLM has not addressed.
What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21”? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?
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, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.
FENCE OFF HIGHWAY 21
Outsiders — Dealing with Roving Equids
Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.
Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.
Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?
And, most importantly, …
Why hasn’t Highway 21 been fenced off near the HMA?
BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.
Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses
Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.
I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.
Wildlife Underpasses — Historical Perspective
Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.
Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.
What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.
The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.
Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!
Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.
At the link below, you will find information and resources regarding the use of overpasses, underpasses, and crosswalks for mitigating collisions between wildlife and vehicles.
You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
FLAWED POPULATION ESTIMATES
Unlikely Birth-Rate
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.
718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).
This is improbable.
Population and Gather Reports — The Data
Per a review of the …
HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,
discrepancies are evident.
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015
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. The beginning-of-the-year figure for 2015 — the pre-gather estimate — is per the BLM’s 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%
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%
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
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%
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%
But that 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%
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.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 Current estimate = 718+144-30-2
2015 830 Public health and safety excuse used to justify removing 100 wild horses without an EA.
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.
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 in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.
Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
Mistakes Cost Wild Horses Their Freedom
The planned removals appear to have been hurriedly scheduled 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 faulty figures.
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 inadvertently portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER BLM METHODOLOGY
Projections per a Twenty-Percent Foal-Survival Rate
Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.
Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.
Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.
Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.
A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.
However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.
Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.
Bottom line: Every benefit-of-the-doubt has been given.
Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths
2008 — 190 — BLM’s population-estimate post-gather November 2008
Year Herd-size
January 1
2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.
2011 — 244 — Foal-crop: 49. PZP does not affect already-pregnant mares.
2012 — 293 — Foal-crop: 59. Even though PZP at maximum-effect.
2013 — 352 — Foal-crop: 70. Even though PZP still in effect.
2014 — 422 — Foal-crop: 84. But gather in Aug removed 30 horses.
2015 — 476 — including the 2014 foal-crop
2015 — 392 — excluding the 2014 foal-crop
It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.
Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …
Below minimum-viable population.
No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.
Planned Roundup Would Have a Devastating Impact on the Sulphur Herd
Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.
But it gets worse. Recent studies have shown BLM’s “20-percent-per-year” rule to be exaggerated by double.
TRUE HERD-GROWTH RATE, FOAL-TO-YEARLING SURVIVAL RATE = 10%
Longitudinal Study Demonstrates Growth-Rate of Five-to-Ten-Percent
The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.
Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …
No removals
No predators
No PZP
Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.
http://www.ispmb.org/Letter.html
The ISPMB study casts doubt on BLM’s standard “20-percent-per-year” rule for estimating herd-growth. Certainly, assumed growth-rates of 29 percent IN 2010 and, especially, the 87 percent growth-rate the BLM assumed for 2014, are implausible. Further, because subsequent estimates were based on false, inflated previous estimates, the errors compounded.
Independent Research Discloses a 10% Foal-to-Yearling Survival-Rate
A study of BLM roundup-records for a representative sample of four herd management areas was recently published (Gregg, LeBlanc, and Johnston, 2014).
The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER NEW RESEARCH-FINDINGS
Projections per a Ten-Percent Growth-and-Survival Rate
Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Sulphur HMA — Per 10% Growth — Modified by Removals, but NOT by PZP
2008 — 190 — BLM’s population-estimate post-gather Nov ’08
2011 — 200 — Foal-crop: 20. PZP does not affect already-pregnant mares.
2012 — 220 — Foal-crop: 22. Even though PZP at maximum-effect.
2013 — 242 — Foal-crop: 24. Even though PZP still in effect.
2014 — 266 — Foal-crop: 27. But gather in Aug removed 30 horses.
2015 — 263 — including 2014 foals
2015 — 236 — excluding 2014 foals
It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.
Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …
Below AML and
Below minimum-viable population.
It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.
Could There Really Be 100 Wild Horses Wandering onto the Highway?
Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.
Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.
Happy Tone, Ugly Reality
BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.
Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21”;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
ADOPTION … OR HIGHWAY TO HELL?
Sale to Slaughter for Sulphur HMA Captives
BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.
A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21” removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.
Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21” only to send them down a “highway to Hell”?
SULPHUR HERD’S AML WAS SET AT A GENETICALLY NON-VIABLE LEVEL
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP
BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.
A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:
BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Current
AML: 165 to 250 — Below minimum-viable population
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 1,063 – 1,610 — about 1⅔ to 2½ square miles per horse
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Recommended
AML: 2,500 to 5,000 — Meets minimum-viable population per IUCN
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 53 – 106 — about 6 to 12 horses per square mile
BLM’s National Authorized Livestock AUMs
But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?
BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.
Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.
157,000,000 acres of public lands on which BLM allows cattle
1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized
2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2
4,133,332 cows and calves = pairs x 2
38 acres per cow or calf
BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.
Actual Grazing Use Report — Form 4130-5
As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Annual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”
Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the reports is suspect.
Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use
In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.
Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.
What If There Is Not Enough Forage to Support 5,000 Horses?
Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that
… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.
Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.
Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.
The correct order is:
Sample first.
Sample complete — 100 percent.
Test samples.
Manage per test-results.
There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.
Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool
I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.
Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:
Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring
Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
A HELICOPTER-ROUNDUP IS ILL-ADVISED FOR SEVERAL REASONS
Helicopters Are Not Safe
BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.
Peculiar Way of Addressing Safety Concerns
Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.
Helicopter-Drive — an Inhumane Roundup Method
Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.
Abusive Behavior by Helicopter Pilots during Gathers
As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.
There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.
No Horse Left Behind
The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.
An Angry Contractor May Be Headed Your Way
In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.
Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.
Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.
Some Observers May Be Pumped-Up Too
Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.
The political weather is unstable. That is another good reason to call off the roundup.
Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs
A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.
How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.
Possible Collusion with Permit-Holders
Perhaps, as you read this, permit-holding ranchers are in the HMA, pushing wild horses toward the Highway.
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
1. Stop action. Cancel gather.
2. Complete environmental assessment.
3. Correct errors in the population-estimates.
4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.
5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.
6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.
7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).
8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.
9. Conduct a 100-percent evaluation of the Sulphur HMA herd’s genetic status.
Pine Nut wild horses between Carson City and Dayton, NV on 2/13/15
Only 332 Pine Nut wild horses left on more than 90,000 acres of public land set aside for their principal but not exclusive use and BLM still wants to decimate the herd.
Protect Mustangs went out on the Pine Nut range, near Carson City, last Friday after the judge’s ruling and found less wild horses than we hoped we would. This herd is probably the most famous herd in Nevada from the film The Misfits, starring Clark Gable and Marilyn Monroe.
We are grateful to have found the Pine Nut wild horses living in peace and harmony on their native land. For now they escaped the cruel roundup, forced drugging, removals and tearing apart of families forever. Thanks to Friends of Animals’ & Protect Mustangs’ Pine Nut lawsuit–currently active in federal court–these wild horses won’t be shipped off to sordid holding pens without shade or shelter from the elements. Those over 10-years-old won’t be shipped to slaughter while we continue to fight in court for what’s right.
Protect the Pine Nut Herd T-Shirts are still available here https://www.booster.com/protectpinenutwildhorses so you can show your support and wear the message when you visit your Congressional Representative to update them on the wild horse crisis in the West
Wild horses must never be forced to live in zoo-like settings with humans running a PZP-based breeding program–abolishing the survival of the fittest. This would manage them to extinction.
There is a lot of misinformation and fear mongering going around about our Pine Nut lawsuit. Some Spin Dr.s are making false claims to confuse the public and their followers about the PZP issue within our lawsuit.
Here are the facts: PZP doesn’t stop roundups. The BLM would need to roundup the herd with helicopters to give them the EPA approved pesticide–made from slaughterhouse pig ovaries–known as PZP. Then they would use that as an excuse to rip 200 wild horses from their native land–never to return. Today the herd is underpopulated on the range. When nature’s balance is disrupted and there aren’t enough left to help eat the grass, then catastrophic wildfires will occur. The BLM’s chosen management number for the Pine Nut wild horses is outrageously low.
What the Spin Dr.s really don’t want you to know is that PZP sterilizes after multiple use. You might want to read the truth about the lawsuit, directly from the court and government documents below:
We are so grateful justice is unfolding in court but the wild ones need your help.
The Pine Nut wild horses are very, very happy they have been spared for now. It’s essential to get technical services for court evidence to keep them free and safe in the wild. If you would like to take direct action to help these wild horses continue to live in freedom, please make your tax-deductible donation today right here: http://www.gofundme.com/lqsy50 and please share this post widely. Thank you, because it takes a village.
Anne Novak, Executive Director, Protect Mustangs; 415.531.8454; anne@protectmustangs.org
Jenni Barnes, staff attorney, FoA’s Wildlife Law Program 720.949.7791; jenniferbarnes@friendsofanimals.org
Mike Harris, Director, Wildlife Law Program; 720.949.7791; michaelharris@friendsofanimals.org
BREAKING NEWS: Judge temporarily blocks the roundup and forced drugging of beloved Nevada herd known from THE MISFITS
Government cannot rely on a five-year-old environmental analysis that ignores allegations of pesticide dangers
RENO, NV (February 11, 2015)—U.S. District Judge Larry Hicks has granted Protect Mustangs and Friends of Animals a motion for a preliminary injunction to stop the Bureau of Land Management’s (BLM) roundup and permanent removal of 200 wild horses in the Pine Nut Herd Management Area (HMA) and the roundup of another 132 wild horses so that an estimated 66 mares can be given the drug PZP, an EPA approved pesticide, as a form of birth control. These wild horses belong to the most famous horse herd in NV–the one featured in The Misfits starring Clark Gable and Marilyn Monroe–which helped pave the way for the Wild Horse & Burro Act of 1971. This herd now faces possible obliteration, despite the Act and advocates are fighting to stop a travesty with attorneys Michael Harris and Jennifer Barnes from Friends of Animals Wildlife Law program and attorney Jennifer Spencer from Cavanaugh-Bill Law Offices in Elko, Nevada
“Today is a milestone for America’s wild horses who have been scapegoated for range damage and forcibly drugged with PZP in experiments for decades,” states Anne Novak, executive director of Protect Mustangs based in San Francisco. “They should never live in zoo-like settings on public land. That’s not freedom. Wild horses are a native species who contribute to the ecosystem. They belong here.”
Hicks said that with the proposed Pine Nut roundup, which was slated to begin Feb. 20, 2015, the BLM has failed to satisfy the National Environmental Protection Act (NEPA) and other federal laws that are applicable.
“Accordingly, the court finds that the public interest will be best served by enjoining the BLM’s proposed gather, at least until the court has an opportunity to fully consider the merits of plaintiffs’ claims,” Hicks said.
“We are delighted that the Court agreed with Friends of Animals and Protect Mustangs that BLM is obligated to fully evaluate under NEPA each and every proposed round-up,” said Michael Harris, director of Friends of Animals’ (FoA’s) Wildlife Law Program. “In relying upon a stale Environmental Assessment from 2010, BLM has not met its duty to fully inform the public about the impacts associated with its plan to permanently remove more than 200 wild horses from the Pine Nut Range, and to dose dozens of mares with the fertility drug PZP. It is time for BLM to evaluate the harsh reality that PZP has long-term detrimental effects on wild horses.”
“I would say this is a major victory for wild horses and reflects rising concerns about rounding up and drugging wild horses with PZP,” added Jennifer Barnes, staff attorney with FoA’s Wildlife Law Program.
“I’m grateful that the wild herd I’ve been studying for 50 years has received justice in federal court today.” Craig Downer, director of ecology and conservation at Protect Mustangs. “This is an opportunity to prove our case to restore the herds.”
www.ProtectMustangs.org
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.
In response to a lawsuit filed Jan.26 by Friends of Animals (FoA) and Protect Mustangs against the U.S. Bureau of Land Management (BLM), the roundup of wild horses and forced drugging of mares planned by the government agency in the Pine Nut Herd Management Area (HMA) of Nevada has been halted at least until Feb. 17. The court has set Feb. 9 as the hearing date for FoA and Protect Mustangs to make their preliminary injunction motion.
Jenni Barnes, staff attorney, FoA’s Wildlife Law Program 720.949.7791; jenniferbarnes@friendsofanimals.org
Mike Harris, Director, Wildlife Law Program; 720.949.7791; michaelharris@friendsofanimals.org
Anne Novak, Executive Director, Protect Mustangs; 415.531.8454; anne@protectmustangs.org
Protect Mustangs & Friends of Animals file lawsuit to stop Pine Nut Mountains roundup
Advocates push for NEPA to be upheld when BLM snubs public comment
Reno, NV (Jan. 26, 2015)—Protect Mustangs and Friends of Animals (FoA) have filed a lawsuit against the Bureau of Land Management (BLM) to stop the round-up and permanent removal of 200 wild horses in the Pine Nut Herd Management Area (HMA) and the round-up of another 132 wild horses so that an estimated 66 mares would be forcibly drugged with the pesticide known as PZP for fertility control. In addition, the groups plan to file a temporary restraining order—asking the judge for an emergency ruling so that the BLM can’t round up any horses or administer PZP until the court has time to hear FoA’s and Protect Mustangs’ case. The roundup is expected to last for 10 days and is slated for late January/early February.
“The BLM abruptly made a decision in December of 2014 to round-up, permanently remove and forcibly administer fertility control drugs on our wild horses. This decision has long-lasting implications for wild horses,” said Jenni Barnes, attorney for FoA’s wildlife law program. “BLM violated the law by excluding the public from this decision and completely failing to consider its impacts. FoA and Protect Mustangs have filed this lawsuit to ensure that BLM does not destroy Nevada’s last remaining wild horses.”
“The American public is outraged elected officials aren’t doing anything to stop cruel roundups and sterilization experiments on our native wild horses,” said Anne Novak, executive director of Protect Mustangs. “It’s disgusting and shameful. Risky drugs like PZP and other forms of sterilization are a sham at this point because there aren’t any ‘excess’ wild horses on millions of acres of public land.”
“When wild horses don’t seem useful to the BLM, they’re resented. Rounded up. Sterilized. Killed or otherwise displaced,”said Priscilla Feral, FoA’s president. “In contrast, cows and sheep owned by large corporations and hobby ranchers are seen as having a dollar value, so ranchers are relieved from having to compete over water and grasslands with horses. Since horses are not hamburgers, Nevada and the BLM want them gone. People don’t want this madness anymore.”
The lawsuit states that the defendants did not prepare an Environmental Assessment for the proposed roundup and instead relied on the 2010 environmental assessment for the Clan Alpine, Pilot Mountain and Pine Nut HMA Gather Plan, which does not take into consideration science that shows the negative side effects associated with PZP. Furthermore, the BLM did not solicit public comments. In fact, FoA employees traveled to Nevada on Jan. 22 to participate in a BLM public meeting regarding the Carson City Resource Management Plan, which includes the Pine Nut HMA, but the BLM denied the public the ability to comment. When Edita Birnkrant, FoA’s campaigns director, got up and spoke at the microphone anyways, she was silenced—BLM shut off the microphone and ejected her from the meeting, just like BLM removes wild horses from public land.
“I was infuriated that the BLM dared to hold a ‘public’ meeting yet forbid the public from speaking,” said Edita Birnkrant, FoA’s campaign director. “BLM employees specifically said there would be no discussion of the Pine Nut roundup during the intro to the meeting. After the intro, I took over the microphone to call out the sham of a BLM public meeting that shut out the public. I said that FoA was there to oppose the BLM’s extinction plan for wild horses in Nevada.”
FoA and Protect Mustangs oppose all roundups of wild horses and the use of PZP, which destroy family structure within the herds, and believe the Appropriate Management Levels set for the Herd Management Areas in all states are too low, outdated and do not accurately reflect the number of wild horses that are needed to maintain genetic viability to prevent extinction and to create a thriving ecological balance.
The groups are adamant the BLM looks beyond data about PZP provided by the Humane Society of the United States, which has a vested interest in PZP as it is the registrant of the pesticide, and Jay Kirkpatrick, the director of the Science and Conservation Center, which produces the active ingredient in PZP. FoA believes the public needs to know there is a conflict of interest when it comes to PZP and it questions the motives of an animal charity pushing a harmful pesticide on wildlife rather than embracing holistic ways to manage public lands.
Novak pointed out that according to the National Academy of Sciences’ 2013 report, there is “no evidence” of overpopulation.
Ranchers scapegoat wild horses because they don’t want to share the public land they lease to graze their livestock. So they bully the Bureau of Land Management to remove wild horses. In Beaver and Iron County, Utah, where wild horses are scapegoated, data shows cows and sheep outnumber wild horses 10.6:1; in Oregon it’s 33:1. And prior to a massive roundup in Wyoming last summer, there were 356,222 cattle, 45,206 sheep, and only 1,912 wild horses. It seems that it’s easier for the BLM to accommodate ranchers and manage wild horses to extinction, than to consider holistic ways to manage our public lands.
“Wild horses need to be protected in Nevada,” said plaintiff Craig Downer, a wildlife ecologist who has studied the Pine Nut herd for decades and author of The Wild Horse Conspiracy. “They restore the ecosystem as a deeply rooted native in North America with a unique niche that helps the other species thrive.”
In his book, Downer, also the director of ecology and conservation for Protect Mustangs, advocates for reserve design , which involves utilizing natural and/or artificial barriers, natural predators, as well as community-involving buffer zones as a better way for BLM to manage public lands. Once available habitat is filled, wild horses, as climax species, would limit their own population as density-dependent controls are triggered.
“The bottom line is the BLM is ignoring the public’s right to be heard about a heinous roundup paid for with tax dollars on public land,” explains Novak. “And that’s just unAmerican.”
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses. www.ProtectMustangs.org
BLM refused to hear public comments at “public” meeting
MINDEN, NV (January 22, 2015)—Edita Birnkrant, Campaigns Director for Friends of Animals (FoA) flew out from New York City with FoA correspondent Nicole Rivard to give public comments at the Bureau of Land Management (BLM) public meeting about the Carson City District Draft Resource Management Plan which calls to zero out 6 treasured herds of wild horses. After being denied her rights at the public meeting, held at the Carson Valley Inn in Minden, Nevada this afternoon, Birnkrant took over the microphone at the BLM meeting and held up yellow crime scene tape while Rivard filmed the protest against censorship and managing wild horses to extinction. Birnkrant was threatened with arrest by Nevada Sheriffs while holding up her banner. The hotel manager made Rivard stop filming and told the advocates they were being thrown out of the hotel, even though they had booked rooms there that night.
Statement from Edita Birnkrant:
“While we were waiting to go into the meeting a man told a BLM staffer “I wanna open up a horse butcher shop”. Then a few other guys started making jokes about how tender horse meat is. The BLM guy just chuckled but didn’t tell them it was inappropriate.
I was outraged that the BLM dared to hold a “public ” meeting and forbid the public from speaking. I took over the microphone to call out the sham of a BLM meeting, that shut out the public, and I said that Friends of Animals was there tonight to oppose the BLM’s extinction plan for wild horses in Nevada. I said the BLM is managing wild horses to extinction through roundups and PZP and we are outraged and demand it stop. I held our banner that said “Stop the BLM’s Criminal Reign of Terror. Protect Wild Horses Under the Endangered Species Act” The sheriffs were surrounding me at that point threatening to arrest me unless I left. I still had the banner and was shouting “the BLM is charged with crimes against wild horses”.
Then the hotel manager at the Carson Valley Inn in Minden, Nevada—Phil Dohrn–started bullying us and got in Nicole’s face. He pushed against her—blocking the camera and told her she had to shut her video off and we were getting thrown out.
Three extremely hostile sheriffs and the Carson Valley Inn manager escorted us to our rooms and waited outside while we packed our bags. They pounded on the door to hurry us or they’d arrest us. They called additional sheriffs to the hotel during all this. We left the hotel shocked that the Carson Valley Inn treats paying guests who exercise their First Amendment rights in their meeting room like this.”
The federal plan for public land in the Reno/Carson area is of interest to all Americans from coast to coast. Citizens care about public land and want federally protected wild horses protected by the law that allows them to roam freely without harassment.
Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org
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Friends of Animals’ public comments that advocates were not allowed to read and were given to Collen Sievers the BLM BLM Project Manager for Carson City District at the public hearing on the draft resource management plan for Carson City District
Edita Birnkrant, FoA’s campaigns director 917-940-2725
The opinion of the American public, as declared through Congress is clear: “wild free-roaming horses and burros are living symbols of the historic and pioneer spirit of the West; they contribute to the diversity of life forms within the Nation and enrich the lives of the American people.” BLM has an obligation to consider wild horses as an integral part of the natural system of public lands.
It appears from the Carson City’s Draft Resource Management Plan (RMP) and Environmental Impact Statement that the BLM failed to take into consideration critical information about wild horses and failed to consider any alternatives that promote a free and viable wild horse population.
Friends of Animal is here to urge BLM to reevaluate its Resource Management Plan.
We ask that BLM consider an alternative that: (1) maintains all wild horse herd management areas; (2) prohibits conflicting uses on herd management areas; and (3) prohibits efforts to eradicate wild horses, such as round-ups, fertility control and sterilization. BLM must take into consideration the small population of wild horses and the potential that they will be listed as a threatened or endangered species under the Federal Endangered Species Act. From a scientific perspective, wild horses on our public lands are at risk of extinction if BLM does not change its management plans.
BLM does not provide adequate area for wild horses. Under the current RMP, approximately 4.8 million acres of public lands covered by the plan are open for private ranchers to graze cattle and sheep while only 1.2 million acres are reserved for wild horses. In the preferred alternative the ratio or area available for cattle and sheep grazing is also more than 4 times that available for wild horses.
Moreover, under no alternative, are cattle and sheep prohibited from grazing on wild horse herd management areas. BLM must consider an alternative that provides contiguous habitat for wild horses to roam freely.
Second, all alternatives for the proposed Resource Management Plan allows BLM to continue managing horses at artificially low populations, or appropriate management levels. This results in expensive, and cruel round-ups that tear the wild horses from their homes and families and place them in tax funded holding facilities. This is one of the largest threat to wild horses on U.S. lands. Experts have warned that the “majority of wild equid populations managed by the BLM are kept at population sizes that are small enough for the loss of genetic variation to be a real concern.”
The Equid Specialist Group of IUCN Species Survival Commission recommends minimum populations of 2,500 individuals for the conservation of genetic diversity. Others have warned that populations managed with a target size of fewer than 500 horses are at some risk of losing more than 90 percent of selective neutral genetic variation over a period of 200 years.
There are no herds that have a large enough population to meet the recommendation of the IUCN Species Survival Commission – 2,500 animals—and only 1 out of 17 of the herd management areas in this planning area has an appropriate management level set to 500 or more. Limiting horses to an artificially low number is short-sighted and ineffective because it could prompt short-term population growth.
Finally, Friends of Animals submitted a petition to the US Fish and Wildlife Service asking it to recognize wild horses as threatened or endangered. The Endangered Species Act requires the government to make final determination on the petition within 12 months – which would be this June. The BLM should not undermine this legal process by allowing BLM to round-up and remove wild horses from Carson City herd management areas. Not only would such actions undermine the Endangered Species Act, but they would also put the viability of the horses here at risk. Instead the plan should recommend BLM halt all efforts to remove wild horses, and allow Fish and Wildlife Service to review the law and facts in regards to wild horses. Nicole Rivard, correspondent, FoA 203-910-1217
As my colleague just pointed out, all but one of the 17 herd management areas in the Carson City District has an appropriate management level set to 500 or more. Everywhere else the loss of genetic viability is a real concern. So additional roundups, which destroy social structure that can lead to population spikes, as well as consideration of administering fertility control, should be removed from this Carson City District Plan immediately if not sooner.
While some wild horse advocates may claim fertility control drugs, such as PZP, is the lesser of two evils, we at FoA believe birth control is equally harmful and inhumane as roundups. In most cases—even the BLM admits this—wild horses would still have to be captured to be treated with the pesticide before being released.
The widespread use of PZP is really very contrary to the true core intent of the Wild Horse and Burro Act of 1971, which was to restore wild horses as naturally, integrated, harmonious components of the public land ecosystem who are not overly tampered with. Deciding which animal should give birth or not is a very invasive, unacceptable thing to do to these wild animals.
Studies have revealed adverse effects of PZP— that it sterilizes wild horses after multiple uses and results in risky foal birth out of season and significant behavioral changes that can affect the health of the herd.
BLM’s discussion regarding a population control program in the EIS is inaccurate and unsupported. They claim fertility control limits the stress of pregnancy on mares, and helps stallions as they will not be exerting extra energy fighting to control mares or raising foals.
What about the stress on mares of not being able to get pregnant as nature intended!
We urge the BLM to look beyond data provided by the Humane Society of the United States, which has a vested interest in PZP as it is the registrant of the pesticide, and Jay Kirkpatrick, the director of the Science and Conservation Center, which produces the active ingredient in PZP. For instance a 2009 Princeton University study of the horses on Shackleford Banks in North Carolina, who began getting PZP in 2000, showed that prolonged infertility has significant consequences on social behavior.
Researchers found that females who were receiving contraception were much more likely to change groups. Normally bands are really very stable, said researcher Cassandra Nunez, and mares will stay with males much if not all of their lives. That stability is really important for the health of the group members. Foal mortality increases when there are a bunch of different changes, and parasite load of animals in the group can go up because they are getting more stressed.
In a later study in 2010, Nunez found that recipients of PZP also extend the receptive breeding period into what is normally the non-breeding season, resulting in foal birth out of season.
Normally the winter is spent eating as much as they can, and everyone is more relaxed. Males tend to let females roam farther, which is good because food is patchier. So all of this is changing because of extended cycling.
Nunez also noted it’s taking a while for the contracepted mares, who were taken off PZP in 2009, to respond physiologically. So that flexibility that you think you have with PZP…it’s not really that flexible.”
It is imperative that BLM reduce the number of cattle and sheep allowed to graze on public lands, as well as consider holistic resource management plan, such as reserve design, which is described in detail in Craig Downer’s Book the Wild Horse Conspiracy. Both options would adequately protect these majestic animals so that they can persist for future generations.
Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org
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BLM Nevada News CARSON CITY DISTRICT OFFICE NO. CCDO 2015-11 FOR RELEASE: November 28, 2014
CONTACT: Lisa Ross, 775-885-6107, lross@blm.gov
Draft Resource Management Plan Environmental Impact Statement Available for
BLM Carson City District
Carson City, Nev. – The Bureau of Land Management (BLM) is asking the public to review and comment on a Draft Resource Management Plan (RMP) and Environmental Impact Statement (EIS) for the Carson City District. The draft plan will affect approximately 4.8 million acres of public land. The comment period opened with the publication of a notice of availability in the Federal Register on November 28, 2014. Comments will be accepted during a 120-day period which closes March 27, 2015.
Public meetings to review and comment on the draft EIS will be announced at least 15 days in advance in local newspapers and on the BLM website.
The plan will address: Areas of Critical Environmental Concern, lands and realty, utility corridors, wind energy, travel management, recreation, fish and wildlife, minerals, wild and scenic rivers, public health and safety, and visual resource management.
Public meetings on the Draft RMP/Draft EIS are currently scheduled for 5:00 to 7:00 p.m.; on January 13, at the John Ascuaga’s Nugget (1100 Nugget Ave.) in Sparks, Nev.; on January 15, at the Fallon Convention Center (100 Campus Way) in Fallon, Nev.; on January 20, at the Mineral County Library (First & A Street) in Hawthorne, Nev.; on January 22, at the Carson Valley Inn (1627 US Hwy 395 N) in Minden, Nev.; and on January 29, at the Yerington Elementary School (112 N. California St.) in Yerington, Nev. An additional public meeting will be held from 2:00 to 4:00 p.m., on January 24, at the Carson City Plaza Hotel and Event Center (801 South Carson Street) in Carson City, Nev. Additional public meetings are anticipated in coordination with local County Commissions and Boards of Supervisors.
Written comments related to the Carson City District Draft RMP/Draft EIS may be submitted by any of the following methods:
• Website: http://on.doi.gov/1uYBNGT• E-mail: BLM_NV_CCDO_RMP@blm.gov
• Fax: 775-885-6147
• Mail: BLM Carson City District, Attn: CCD RMP, 5665 Morgan Mill Rd., Carson City, NV 89701.
Copies of the Carson City District Draft RMP/Draft EIS are available in the Carson City District Office at the above address or on the following website: http://on.doi.gov/1uYBNGT
Now the BLM and the PZP Advocates want to roundup the Pine Nut Herd and give them the EPA restricted-use pesticide known as PZP-22 which sterilizes after multiple us. Protect Mustangs is against PZP and roundups. America’s wild horses deserve to be forever wild and free.
BLM to Host Tour of Pine Nut Herd Management Area Gather
Carson City, Nev. – The Carson City District, Sierra Front Field Office is holding a public pre-gather tour on Friday, January 23, 2015. The public will meet at the Dayton Valley Dog Park (located at Old Como and Dayton Valley Road) in Dayton, Nevada, at 10:00 a.m. The tour is expected to last approximately three hours. Because of road conditions a four wheel-drive high clearance vehicle is required. Visitors must RSVP by calling the Gather Information Hotline at 775-861-6700, option 2 and leave a message, or call Lisa Ross, Public Affairs Specialist, at 775-885-6107, email lross@blm.gov.
“This pre-gather tour is being offered to provide an opportunity for the interested public to obtain information about the Pine Nut Gather, by interacting with BLM staff as they provide an overview of gather operations,” said Sierra Front Field Manager Leon Thomas.
The BLM will gather approximately 332 wild horses and remove approximately 200 excess wild horses within and outside the Pine Nut Herd Management Area (HMA). As many as 132 wild horses will be released back to the range following the gather. The gather area is located south of Dayton and east of Carson City and Gardnerville, Nevada within Lyon, Douglas, and Carson City Counties. The gather is scheduled to begin late January 2015.
A population inventory completed in August 2014 documented 332 wild horses. The Appropriate Management Level (AML) for the HMA is 119-179 wild horses. Based on the inventory, and monitoring data showing impacts from an over-population of the HMA, BLM has determined that removal of the excess wild horses is necessary to achieve a thriving natural ecological balance. Protect Mustangs is against the BLM’s false comment here: Excessive grazing from wild horses has not only degraded the sage-grouse habitat, but has also reduced the availability of native forage grasses within the HMA, thereby decreasing the number of wild horses that can be supported by current range conditions. Wild horses are not the source of habitat degradation but off road vehicles are. It’s time for the BLM to tell the truth.
Of the approximately 132 wild horses released back to the range, an estimated 66 mares will receive a 22-month Porcine Zona Pellucida (PZP-22) immunocontraceptive vaccine treatment prior to release. This vaccine will extend the time between gathers, and reduce the number of excess wild horses that would need to be removed in the future. The sex ratio of the released animals will be dependent on the sex ratio of the gathered wild horses. [PZP is an EPA approved restricted-use pesticide as seen here: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf For more information, facts and public discussion about PZP visit the PZP Forum on Facebook here: https://www.facebook.com/groups/ForumPZPWildHorsesBurros]
For more information contact Lisa Ross at 775-885-6107.
The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2013, the BLM generated $4.7 billion in receipts from public lands.
–BLM–
Carson City District 5665 Morgan Mill Road Carson City, NV 89703 http://www.blm.gov/nv/st/en/info/newsroom/2015/january/blm_to_host_tour_of.html
