Via email: email@example.com
September 9, 2016
BLM Rock Springs Field Office
280 Highway 191 North
Rock Springs, WY 82901
Attn: Wild Horse and Burro Specialist
Subject: Checkerboard EA Comments
Project: Roundup-and-Removal — Announced
Document: Environmental Assessment ( EA )
NEPA ID: DOI-BLM-WY-D040-2016-0135-EA
This letter responds to your request for substantive comments and informed analysis that BoLM Rock Springs Field Office (RSFO) should consider regarding the subject EA. I submit my comments as an interested party in behalf of the wild horses of the Adobe Town (AT), Great Divide Basin (GDB), and Salt Wells Creek (SWC) Herd Management Areas (HMAs) who are deemed to have roamed into the “checkerboard lands” — those where Federal and private property sections alternate in a checkerboard-like pattern — in numbers that exceed the arbitrary levels established by the Consent Decree. Please note that in all instances where text has been emphasized, either through bold and/or italics, the emphasis was added by me.
For ease of reference, here are the links to the Dear Reader letter and to the Webpage where the EA is posted:
BoLM unwisely and unethically committed itself to reducing wild-horse numbers at harshly-low levels in the Checkerboard sections of three HMAs at issue. Per the Consent Decree, once it was determined — or projected — that more than 100 wild horses were present (or might be) at some point in time in GDB, and/or that more than a combined total of 200 wild horses were (or might be) present at some point in time in AT and SWC, then RSFO would have them all removed.
Here are the number of horses that, BLM alleges that, per April 2016 surveys, were present in the checkerboard area of the following herd management areas (HMAs):
25 Adobe Town
272 Great Divide Basin
187 Salt Wells Creek
RSFO proposes to remove not just the 484, but an additional 16, for an even 500. RSFO acknowledges that it would not be removing “excess” wild horses. RSFO further admits that the proposed removals would drop the population below the low-bound of the established arbitrary management level (AML).
Wild Horses Roam — Their Presence Is Fleeting, Their Numbers Are Fluid
Just because RSFO’s survey allegedly counted 484 wild horses in the Checkerboard does not mean that 484 are still there or were there the day after the census was conducted. Wild horses are constantly on the move. Just because they visit an area on certain days does not make them permanent residents.
Public Lands Commandeered by Private Interests
The Checkerboard area encompasses 2,427,220 acres, or 3,793 square miles. Public lands total 1,695,517 acres — 2,649 square miles — and privately-held lands total 731,703 acres –1,143 square miles. Thus, public lands constitute 70%, and private lands comprise 30%, of the Checkerboard.
Per the EA, the Rock Springs Grazing Association (RSGA) owns or “controls” the “majority” of the 30% of the privately-held Checkerboard area. The EA does not reveal how significant that majority is, but it would have to be 51% or more, by definition, to be a majority. If it were a “great” majority, then surely that point would have been made. Thus, the conservative inference would be around 51%. But to make the computations easier, and to give the benefit to the doubt, 60% will be used.
So, 60% x 30% = 18%. What results is a minor percentage of private-profiteers calling the shots for how public lands are managed. Unacceptable.
Wild-Horse Population-Density — Even If All 484 Were Only on Private Land
Let’s assume for the moment that 484 wild horses have established permanent residence in the 731,703 acres — 1,143 square miles — of privately-held checkerboard land. The resultant population-density would be:
1 wild horse per 1,512 acres = 1 wild horse per 2.4 square miles.
Public Corruption — Appearance of
According to the Website of the American Wild Horse Preservation Campaign, the Rock Springs Field Manager has stated publicly:
“For all intents and purposes, we consider all of the checkerboard private.”
If this direct quotation is accurate, then the Field Manager appears to be encouraging the private takeover of public lands. No wonder the Bundy brothers and company felt emboldened by such BoLM “dog whistles” to seize control of the Malheur Wildlife Refuge. Announcements like that suggest public corruption — abuse of public office to benefit private interests.
FRAUDULENT POPULATION ESTIMATES
Birth Rate versus Herd-Growth Rate
Before we examine BLM’s reported herd-growth rates of these HMAs, 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 of about 20% a year in wild-horse herds. But the herd growth rate is unlikely to be that high. Here’s why: Horses and burros die.
An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size of 5,859 wild horses. 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. It is wrong for RSFO to use 20% as the growth rates. It may be administratively convenient to equate the birth rate to the growth rate, but it is not valid.
Adult Wild-Horse-and-Burro Mortality Rates Must Be Factored
But it is not only foals that die. Adult wild horses also perish. They succumb to illness, injury, and predation. 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, a practice 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 birth rate. When BLM reports alleged herd-growth rates many times higher than 20% (horses) — that would necessarily mean birth rates substantially higher still. Such implausible rates are routinely found in BLM’s population data, including the year-to-year figures for the subject HMAs. Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — those are just some 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.
Imagine if such a catastrophe were to befall the subject herds. Note that the Saiga deaths involved antelope-mothers and their calves. What if these HMAs’ mares and their foals perished all of a sudden, leaving mainly stallions and sterile elderly mares? BLM must proactively manage the herds per IUCN 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 the subject HMAs. What is the MVP? According to the International Union for the Conservation of Nature: 2500 per equid species, which could easily be accommodated by the acreage composing each of the subject HMAs.
Fraudulent Population Figures
BLM-RSFO’s data reports that the herds-in-question grew at biologically-impossible reproduction-rates. Further, BLM-RSFO asserts that 484 of these imaginary horses were spotted in the checkerboard, thereby triggering their removal.
Name of HMA Population Population Percent
National OfcNational OfcIncrease
March 2015 March 2016
Adobe Town 602 1,030 71.0%
Great Divide Basin 199 670 236.7%
Salt Wells Creek 117 728 522.2%
BLM’s population-growth figures are fraudulent. They are biologically impossible. Even if the “data” represented only the birth rates, they would be as much as 100 times the normal birth rate. Moreover, the bogus birth rates have been conflated with herd-growth rates. The mortality rates were not factored. Consider how such errors will compound and magnify over time.
In light of these fictitious figures, no action is the appropriate alternative. BoLM-RSFO should be subjected to a forensic audit to determine who is behind the phony data. Those staffers must be held accountable.
But Is There a Mandate to Practice Scientific Integrity?
Yes. The Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states: “Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy.”
BLM-RSFO’s wild-horse population estimates are without merit.
Societal Impact of Inflated Population-Data
The population-estimates for the subject HMAs are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly state and 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.
Fraudulent Data Emboldens Scofflaw Ranchers, Costs Wild Horses Their Freedom
In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use. The notorious Cliven Bundy and permittees Kevin Borba and Dan Filippini blatantly defied BLM’s authority; yet they were pacified with non-enforcement and concessions. BLM enables and rewards such bad behavior by caving in to it. Meanwhile, poor LaVoy Finnicum lost his life because, per precedent BLM stand-downs, he concluded that BLM and FBI would not enforce the law.
There are likely permittees in Wyoming emulating Bundy, Borba, and Filippini. Certainly RSGA has no respect for the Act that was meant to protect America’s mustangs. Wild horses must not lose their freedom merely so that BLM can placate greedy and rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that elected officials and ranchers are building due to the false appearance created by fictitious herd-growth figures.
Voluntary Non-Use of AUMs Reflects Lowered Demand for Beef
BLM and its permit-holders protest that a lot of the livestock AUMs are in non-use, sometimes mandatorily, other times voluntarily. They complain loudly, pointing to the seeming excess of wild horses — an illusion caused by BLM’s phony figures.
Bloomberg News published an article recently concerning the state of the beef market. In the US, consumer-demand for beef is down to levels not seen in 40 years. The US cattle-herd population is at a 60-year low and is expected to drop further. The article explored why this situation exists.
Bloomberg noted that beef is a premium product, with a significantly higher price-point. US consumers are turning to lower-cost meats, such as pork and chicken. Further, the strength of the dollar makes US beef exports less competitive in the global marketplace. Thus, it does not make economic sense for a rancher to produce more beef, given current conditions. So, reduced demand and lowered cattle-population are important reasons why AUM-usage is down. It has nothing to do with wild horses.
Authorized v. Actual Livestock Use
BLM also argues 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.
USDA Reports Beef-Cattle Now Weigh More — AUM Calculations Need to Be Reformed
The same Bloomberg article noted that the average weight of a beef-cattle animal has increased to 1,385 pounds, up 32 pounds from just the previous year. Please note that the AUM was originally set per a weight of 1,000 pounds. But, in the meantime, what the industry refers to as “genetics” — technologically-advanced selective breeding — has increased average weight by 38½ percent, with better-than two percent of that increase coming in the past year alone. BLM needs to charge more AUMs for cattle — as well as charge more per AUM — in accordance with true market-rates.
On the other hand, the AUM for a horse presumes a 1,000-pound saddle horse. But mustangs tend to be smaller and lighter, weighing 700 to 800 pounds. Moreover, in contrast to cattle, wild horses are “easy-keepers” that thrive on poor-quality forage.
BLM needs to revisit and reform how it assesses forage-usage for cattle versus wild horses. Cattle need an AUM surcharge; wild horses need an AUM discount that reflects the less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.
HELICOPTERS — Inappropriate for Counting Wild Horses
Aerial Inventories Produce Gross Over-Counts
BLM likes to attribute impossibly-high estimates to “improved inventory methods.” But as has been pointed out to BLM previously, the “mark-resight” and the “simultaneous double-count” methods, conducted by helicopter, overcount the population. Indeed, as the report by the specialty-contractor who conducted the Red Desert Complex (also in 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. See pdf-pages 84-87 at the link below.
I note that the 2015 Checkerboard Census Report also mentioned that assumptions had been used but contended that an under-count was likely. That assumption is not only incorrect but opposite to the facts. When more horses are “seen” than could possibly exist, the method is faulty and likely fraudulent, given the “cooperation” of RGSA. Finally, I note the absence of photographs.
Both the Roundup-Contractor and BoLM Are Looking to “Make Their Numbers”
A glance at the map of the HMAs in question reveals that they are contiguous, and public lands are interspersed with private lands. How easy it would be for a profit-motivated helicopter-pilot to “poach” wild horses from strictly public lands by driving them into the target-area. What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?
In its response to this topic, which was raised during scoping, BoLM said that it would monitor the helicopter’s flight-path to keep this from happening. But BoLM’s purpose in conducting equid cleansing is to please the permittees. BoLM has committed to removing 500 wild horses to comply with the Consent Decree, and the roundup-contractor expects to earn the amount that corresponds to 500 captured wild horses. The helicopter-pilot is looking to “make his numbers” but so is BoLM. Thus, BoLM has a conflict of interest in needing the contractor to remove any 500 horses that he can find. The wild horses are fungible — one is as good as another — to make the pilot his money and to enable BoLM to fulfill its agreement with the arbitrary Consent Decree. Consequently, wild horses would lose their freedom for the private profit of RSGA and the helicopter-contractor, and for the administrative convenience of BoLM. Unacceptable.
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. However, removing horses that have wandered into the checkerboard area just creates a vacuum for other horses to fill. Thus, removing them is an ineffective population-control strategy. The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs. The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant. Thus, removal is not a true solution — it just perpetuates the situation and leads to the elimination of more mustangs than necessary. Moreover, the wanderers may be only temporary visitors or refugees, not permanent residents. Worse yet, they may have been driven into the checkerboard by the helicopter. RSFO acknowledges as much in the EA, but still pursues the removal-without-return alternative.
Recommendations: In legitimate instances of straying, RSFO should first encourage the wild horses to return to their proper place, then address those factors that caused the animals to leave home. Would palatable plantings draw the wild horses to the areas RSFO wants them to use? What about siting mineral licks deep inside the HMAs, away from the Checkerboard? Have guzzlers been installed to provide water sources deep within the boundaries? Aversive conditioning could also be employed to shoo the wild horses into the solid-block public lands. Certainly, positive reinforcement coupled with aversive conditioning would be an effective and cost-effective solution. RSFO should specify preventive and reactive measures in this regard as part of its management approach. Return outsiders to the solid-block public-lands areas of the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from the Checkerboard (aversive techniques).
HELICOPTERS — Dangerous to Humans
Scheduled Airliners — Safe; Helicopters — Crash-Prone
As cited in my scoping comments but reiterated here out of concern for staff-wellbeing, the American public considers travel-by-air to be safe, even routine. Crashes are rare, and fatalities, few. Thus, it is easy to assume that all flight is safe, which is not the case.
Helicopters are notorious for crashing. Please compare and contrast Wyoming’s aviation crash-records of scheduled air carriers versus helicopters during the 10-year period from January 1, 2006 to December 31, 2015 — per the National Transportation Safety Board (NTSB):
Scheduled Air Carriers (“Part 121”)
1 — Accidents (minor events excluded)
0 — Accidents that resulted in fatalities
13 — Accidents (minor events excluded)
1 — Accident that resulted in a fatality
1 — Number of persons that died in that accident
In Wyoming, for the period in question, there has been 1 accident involving a scheduled air carrier. Nobody died. Helicopters, in contrast, have had 13 accidents — 13 times more — including 1 that involved a fatality. At the link below, you can replicate the searches to verify these data.
Helicopter Census Method Puts BLM Personnel at Risk
BLM’s environmental assessments often allude to the use of “multiple experienced observers” (presumedly BLM staffers) to count and photograph wild horses — or what they think are wild horses — while being flown in grid patterns over the range.
Given the crash-proneness of helicopters, BoLM could face a tragedy — with the loss of key personnel, friends, and colleagues in an accident. Counting wild horses does not justify this risky method.
HELICOPTERS — Dangerous to Horses
Inhumane Roundup Method
BoLM’s use of helicopters to round up the wild horses is inhumane. The horses are terrified by the thunderous, high-intensity noise as they are pursued by the low-flying helicopter. They are blasted with sand, dirt, and gravel from the rotor wash. Panicked by the chaos, they stampede, injure themselves, and become separated from their babies and bandmates. Mares miscarry. Foals become orphans. Many horses die from stress, even more have to be euthanized. Helicopter-style roundups are abusive, especially to foals, older horses, and pregnant mares. This is unacceptable.
Recommendations: Helicopter-style roundups must be abolished. Roundups in extreme temperatures — either the summer heat or the winter cold — must end. Stampeding horses for countless miles — causing them to lather with sweat and then bringing them to an abrupt halt — must be prohibited. Forcing the horses to run long distances over rough terrain, thereby wrecking the delicate hooves of the newborns and resulting in lameness and even death — must never happen again.
BoLM should institute the kind approach to gathering wild horses. Roundups should be done slowly, quietly, and gently using the bait-and-water trapping approach. This method also tends to preserve family unity, which is essential to wild-horse social structure.
Abusive Behavior by Helicopter Pilots during Gathers
As has been documented on video, helicopter-pilots conducting roundups become frustrated by horses’ lack of cooperation. Impatient to get the animals moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the creatures 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 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
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 BoLM officials present did nothing to stop the abuse. What’s more, this cruelty took place in plain view of observers holding video cameras. Imagine what went on out of sight and off camera.
HELICOPTERS — Dangerous to the Environment
Possibility of a Post-Crash Fire’s Leading to a Wildfire
The crash of a roundup-helicopter could result in a fuel-spill. Especially in these times of drought, when there is an abundance of dry brush, a wildfire could be sparked. Thus, even the environment is at risk from the use of helicopters to round up wild horses. It bears repeating that, because herd management areas are typically in remote locations, it would be difficult to put out a post-crash fire and keep it from getting out of control.
1. RSFO should repudiate the arbitrary and corrupt Consent Decree.
2. RSFO’s Field Manager should stop making seditious announcements, leading rogue ranchers to believe that public lands are private and emboldening them to break the law, putting public safety at risk.
3. RSFO should select either Alternative A — No Action, or Alternative C — Removal-and-Return.
6880 SW 27th ST
Miami, FL 33155-2916
§ 1334. Private maintenance; numerical approximation; strays on private lands; removal; destruction by agents THE WILD FREE-ROAMING HORSES AND BURROS ACT OF 1971 (PUBLIC LAW 92-195) Retrieved from
18 U.S. Code § 2383 – Rebellion or insurrection. Cornell University Law School. Retrieved from https://www.law.cornell.edu/uscode/text/18/2383
18 U.S. Code § 2384 – Seditious conspiracy. Cornell University Law School. Retrieved from https://www.law.cornell.edu/uscode/text/18/2384
American Wild Horse Preservation Campaign. (2016, August-September) BLM Wyoming Wild Horse Wipeout Continues – Action Needed Today! Retrieved from http://act.wildhorsepreservation.org/p/dia/action3/common/public/?action_KEY=23543
Public corruption. Definition. Cornell University Law School. Retrieved from https://www.law.cornell.edu/wex/public_corruption
Romboy, Dennis. (2015, December 18) “Judge sentences San Juan Commissioner Phil Lyman to 10 days in jail, 3 years of probation.” Deseret News. Deseret Digital Media. Retrieved from http://www.deseretnews.com/article/865643995/Judge-sentences-San-Juan-Commissioner-Phil-Lyman-to-10-days-jail-3-years-of-probation.html?pg=all
Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.
Protect Mustangs, a 501c3 nonprofit organization calls for protests against the Bureau of Land Management’s (BoLM) Wild Horse Advisory Board’s decision today to euthanize all the allegedly “unadoptable” wild horses in long-term holding. They also voted to push more wild horses through advertised adoption events to strike them out quicker! Under former Secretary Salazar, the BoLM has irresponsibly rounded up more wild horses than they could ever adopt out at once. Is it because Salazar is a fifth generation rancher paying back a promise to the Cattlemen’s lobby? Since then the federal agency has been hoarding America’s wild horses in captivity at huge tax-payer expense without correcting the failed adoption program. Now they want to kill the mustangs they call “unadoptable” and sterilize all the wild horses living in freedom on the range. Protect Mustangs is calling for the Bureau of Land Management to #PutThemBack on the 1971 herd areas in the West and stop sterilization. More than one-third of the herd areas have been zeroed out.
“We will fight this outrageous plan to kill and sterilize America’s icons of freedom and we will win,” states Anne Novak, executive director of Protect Mustangs. “The public is not going to tolerate this. The Bureau of Land Management is a rogue agency and their advisory board is made up of people favoring the livestock industry except for one person. The bogus board of mustang haters needs to be dismantled and recreated with wild horse and burro experts–not cattlemen with a huge conflict of interest. It’s time to put America’s wild horses and burros back on public land where they belong.”
Who are the wild horses in long-term holding? Are they mostly 3-Strike mustangs from the BoLM’s failed adoption program with rotten customer service? Others are over 10 years old and should have been left out on the range to live their lives out in peace.
Check back here for updates and donate to Protect Mustangs for legal fees to fight with the law by clicking here www.PayPal.me/ProtectMustangs or go here to donate on the crowd-funding site: https://www.gofundme.com/FightwithLaw
The fight is on!
Update on Cleo April 2012: We found an adopter for Cleo but the BoLM had already shipped her out. When we told the Nevada BLM that the adopter was willing to go to long-term holding (Midwest) to get her they said that was impossible. They said they would only sell 100 horses at a time out of long term holding. The adopter could only take Cleo. The BLM said it was impossible.
Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.
Made with slaughterhouse pig ovaries PZP is dangerous to herd health
To: Jacob Bunge, Wall Street Journal
Dear Mr. Bunge: Regarding your article — They Shoot Horses (With Birth-Control Darts), Don’t They? — here are facts to correct the lies and disinformation you have been told.
Sting of the dart: If it were only a sting! Fact: Many wild horses develop an abscess at the dart-injection site.
Bogus ballooning population: Wild horses are a slow-growth species when it comes to reproduction. The gestation period lasts 11 months, and a mare produces just 1 foal. While an independent study of BLM’s records confirmed an almost 20% birth rate, that study also found that 50% of foals perish before their first birthday. Thus, the effective increase in population from new foals is just 10%. But adult mustangs also die. They succumb to illness, injury, and predation at a rate of at least 5% a year. So, what is a normal herd-growth rate? About 5%, probably less.
Fraudulent figures: The Big Lie of “overpopulation” is the pretext for BLM’s war against the wild horses, and the wild horses are prisoners of that war. It’s BLM’s version of the “Shock Doctrine,” wherein BLM concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People. There is no overpopulation except on BLM’s falsified spreadsheets. Reviews of BLM’s population-estimates reveal biologically-impossible herd-growth rates. For instance, in Utah, BLM claimed that the Conger herd grew from 156 horses to 285 horses in one year, an 82.7% increase, to which BLM tacked on another 20% by counting the unborn foals — the fetuses. In Wyoming, BLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase. BLM’s “data” is chock-full of such preposterous growth-estimates. So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that BLM has falsified the data.
Wild horses are underpopulated: Per the guidelines of BLM’s own geneticist, 83% of the herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP). Low AMLs enable BLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP. So being “over AML” is meaningless as well as misleading. But the low AMLs, combined with falsified, biologically-impossible herd-growth estimates, give BLM an excuse to scapegoat those few wild horses for the range-damage done by the millions of livestock that overgraze the public lands.
Whose grass? In fact, it is the livestock who are eating the wild horses’ grass. Some background — the dedicated wild-horse habitats cover only 11% of BLM land. Cattle are allowed to graze about 5 times that much, including within all but 4 of the wild-horse herd areas. Yet in those official wild-horse habitats where livestock are given allotments, the mustangs are restricted to 18% of the forage while the cattle get 82%.
Bogus billion: The wild horses being held in captivity are the “legacy” of former Secretary Salazar’s equid cleansing era, during which he had thousands of wild horses removed from the range. However, the mortality rate of captive wild horses is about 8% a year. So, obviously, since they are not reproducing, their numbers will steadily drop, showing that BLM’s billion-dollar figure for their care is just another Lie. The Wild Horse and Burro program, if run per the minimum-feasible management-model specified by Law, would not cost much at all. BLM does not lack for resources. There are 22 million acres of legally-designated wild-horse herd areas — which BLM previously took away for expediency — that can be reopened as habitat. The horses now held captive can be released to those areas, where the cost of their upkeep will be $0.
Adoptions: Have not declined. It’s just that BLM used to count sales-for-slaughter as “adoptions.” Now, only “forever-family” placements qualify. However, wild horses are not homeless horses. They have a home — where they belong — on the range.
Persecuted predators: Contrary to BLM’s disinformation campaign, wild horses do have natural predators — mountain lions, bears, wolves, and coyotes. But those predators are persecuted mercilessly. The government exterminates what the hunters don’t shoot. However, the International Society for the Protection of Mustangs and Burros — Wild Horse Annie’s foundation — notes that even without predators, wild-horse herds self-regulate their numbers, with population-growth in the single digits.
Science and Conservation Center: Is the manufacturer and distributor of PZP / ZonaStat-H. Thus, its information is not impartial. PZP is a registered pesticide that was approved by the EPA for use on wild horses and burros “where they have become a nuisance.” However, PZP was registered without the standard testing requirements. There is currently a lawsuit challenging the legitimacy of the registration, especially in light of studies that have disclosed PZP’s many adverse side-effects.
Shooting wild horses: PZP is a potent weapon in BLM’s arsenal — for its biological warfare against the wild horses. But birth control for wild horses is unnecessary because there is no overpopulation. Why would we contracept herds whose population is inadequate for genetic viability? Why would we contracept herds based on falsified figures? Logically we wouldn’t and ethically we shouldn’t. Further, if PZP were going to stop the roundups, it would have done so long ago for the Pryor Mountain herd, which has been darted with PZP for nearly two decades. Yet roundups have been scheduled there like clockwork every 3 years and, in spite of intensifying the PZP treatments recently, BLM tried to implement yearly roundups until stopped by a Friends of Animals lawsuit.
PZP — the anti-vaccine: PZP causes auto-immune disease. PZP “works” by tricking the immune system into producing antibodies that target and attack the ovaries. The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. The mare’s estrogen-levels drop markedly as PZP destroys her ovaries. Ultimately, PZP sterilizes her. Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function. Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries. But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed. Those mares fail to respond to PZP. They keep getting pregnant and producing foals who, like their dams, suffer from weak immune-function. So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised. Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.
Health-risks to volunteers: As for the well-meaning volunteers who dart wild horses, EPA’s Pesticide Fact Sheet for PZP advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility. Unfortunately, PZP’s manufacturer has misrepresented PZP as “so safe it is boring.” But research shows that PZP is a powerful hormone disruptor. Further, consider the magnitude of the risk — the PZP-in-question is a horse-size dose. If volunteers think PZP is safe, they will be less likely to protect themselves from this dangerous pesticide. Indeed, please note that in the photo accompanying your article, Ms. Bolbol is not in compliance with EPA’s safety-precautions. She is not wearing the required protective gear.
Mengelian experiments: Now, BLM wants to perform diabolical sterilization experiments on these equine POWs to develop a Final Solution to the “problem”. BLM is handing out $11 million for sterilization-studies. The grant money is surely intended to buy loyalty and silence potential criticism from academia. Plus, BLM, a corrupt agency, gets to cloak itself in respectability by affiliating with prestigious universities.
The ugly side of PZP is humane-washed by feel-good features that describe it with humor, sweetness and light. However, the true story of PZP is one of scandal, whose deceit and danger — to both horses and humans — must be exposed. That is the story that needs to be reported.
By Marybeth Devlin
It is good to know that the US Forest Service is promoting adoptions of wild horses. However, no roundup should occur.
Inadequate Population of Wild Horses in Devil’s Garden
The International Union for the Conservation of Nature recommends a minimum-viable population (MVP) of at least 2,500 for a wild-horse herd. The arbitrary management level (AML) for the wild horses of The Garden — 206 to 402 — is way-below MVP. The AML implies that each wild horse needs 578 to 1,129 acres. But how many acres does BLM estimate each cow or calf needs? Answer: 38 acres. So, absolutely, The Garden’s 232,500 acres could support 2,500 horses at 93 acres per horse. I further note that it was USFS who split the horses’ habitat into 2 sections and, in so doing, took away 25,500 acres, which were then given over to commercial livestock, which already had many more grazing slots than the horses. Indeed, USFS allows nearly 4,000 cattle to graze in The Garden, where the horses are supposed to, by law, have principal use.
Costs and Method
Spending $600,000 on a helicopter roundup is a waste of taxpayer money, especially because there is a better way. Modoc National Forest Office declared that it had all the necessary equipment on hand to conduct bait-trapping operations in a humane manner. Therefore, the bait-trapping method should be used — when the herd substantially exceeds the IUCN guidelines for MVP. Bait-trapping is the cost-effective and humane technique.
Helicopters, in contrast, pose risks to both humans and horses. Their crash-record is high, with numerous fatalities. Using helicopters to chase wild horses is inhumane, especially in The Garden, where the landscape has been described as “… brutal for gathering. Dense stands of Western Juniper and many rocky outcropping make this landscape one of the most difficult places in the country to gather wild horses.”
Dealing with Roving Equids
Horses will roam. It is their nature. Surely, that’s why the Law is known as the Wild and Free-Roaming Horses and Burros Act. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered into onto private and Tribal lands just creates a vacuum for other horses to fill. Thus, removing them is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs. The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant. Thus, removal is not a true solution. Instead, it perpetuates the problem and leads to the removal of more mustangs, a costly and unnecessary recurring action. More unfairly, the wandering equids may be only temporary visitors, not permanent residents. Worse yet, they may be driven out of their habitat by a profit-motivated helicopter pilot eager to “make his numbers.”
USFS and BLM should implement preventive measures to keep wild horses home in their habitat. Fence The Garden’s perimeters — after correcting all boundary-line discrepancies, making sure migration corridors are open, and restoring any herd-area land previously taken away. Next, address those factors that allowed the animals to leave home. For instance: Do fences need repair? It would be more effective for USFS and BLM to pay for new fences than to pay for a helicopter-gather. Removing wild horses will not mend fences.
Protect Mustangs is an organization who protects and preserves native and wild horses.
Today The Economist published an article titled America is set to spend billions on taming its growing wild-horse population with fake projected costs in the multi-billions for shock value and pro-kill, pro-slaughter, pro-sterilization undertones. It’s clear the media piece goes beyond yellow journalism and was placed in the economist by a PR firm paid for by public land-grabbers who hate wild horses. Otherwise, how could such an article, filled with outrageous errors and lack of facts, get into the publication?
This “article” is trying to put pressure on Congress to kill or sterilize America’s beloved wild horses. The motives are clear.
Marybeth Devlin, Protect Mustangs Advisory Board member and member of the Alliance for Wild Horses and Burros wrote the following in the comment section. Let’s hope people will read the facts:
“The Big Lie of “overpopulation” is the pretext for BLM’s war against the wild horses. It’s BLM’s version of the “Shock Doctrine,” wherein BLM concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People.
In fact, horses are a slow-growth species when it comes to reproduction. The gestation-period lasts over 11 months, and a mare produces just 1 foal. While an independent study of BLM’s records did confirm a nearly 20% birth rate, that study also found that 50% of foals perish before their first birthday. Thus, the effective increase in population from new foals is just 10%. However, adult mortality must also be taken into consideration. Adult mustangs succumb at a rate of at least 5% a year. So, what is a normal herd-growth rate? Around 5%, probably less. Thus, a herd could not double in 4 or 5 years, debunking another BLM falsehood. But BLM stealthily inserts herd-growth rates far higher than 20% in its reports — biologically-impossible herd-growth rates. For instance, in Wyoming, BLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase. BLM’s “data” is chock-full of preposterous growth-estimates. So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that BLM has falsified the data. You should also know that the National Academy of Sciences was required by the terms of its grant to draw conclusions per BLM’s figures — the falsified figures. The NAS was not allowed to collect data independently. Thus, BLM wired the results to confirm its lies.
Wild horses are underpopulated. Per the guidelines of BLM’s own geneticist, more than 80% of the herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP). Low AMLs enable BLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP. So being “over AML” is meaningless as well as misleading. But those low AMLs, combined with fraudulent, biologically-impossible herd-growth estimates, give BLM an excuse to scapegoat those few wild horses for the range-damage done by the millions of livestock that overgraze the public lands.
PZP is a potent weapon in BLM’s arsenal — for its biological warfare against the wild horses. PZP is a registered pesticide. Its mechanism-of-action is to cause auto-immune disease — tricking the immune system into producing antibodies that target and attack the ovaries. The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. The mare’s estrogen-levels drop markedly as PZP destroys her ovaries. Ultimately, PZP sterilizes her. A recent study — which included the McCullough Peaks herd — found that PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.
As for the wild horses held in captivity, they are the “legacy” of former Secretary Salazar’s equid cleansing era, during which he had tens of thousands of wild horses removed from the range. However, the mortality rate of captive wild horses is about 8% a year. So, obviously, since they are not reproducing, their numbers will steadily drop, showing that BLM’s billion-dollar figure for their care was bogus — it was just another Lie. But that Lie has ballooned. BLM has taken the $1 billion figure that it originally announced, multiplied it by 230%, and then multiplied that number by another 200%, amplifying the fraud. When BLM lies, it lies Big.
The Wild Horse and Burro program, if administered per the minimum-feasible management-model specified by Law, would not cost much at all. BLM does not lack for resources. There are 22 million acres of legally-designated wild-horse herd areas — which BLM previously took away for political expediency — that can be reopened as habitat. The horses now held captive can be released to those areas, where the cost of their upkeep will be $0.
Contrary to BLM’s disinformation campaign, wild horses do have natural predators — mountain lions, bears, wolves, and coyotes. But those predators are persecuted mercilessly. The government exterminates what the hunters don’t shoot. However, the International Society for the Protection of Mustangs and Burros — Wild Horse Annie’s foundation — notes that even without predators, their wild-horse herds self-regulate their numbers, with population-growth in the single digits.
Finally, adoptions have not declined. It’s just that BLM used to count sales-for-slaughter as “adoptions.” Now, only “forever-family” placements qualify. However, mustangs are not homeless horses. They are wild horses whose home is on the range.”
Protect Mustangs is an organization who protects and preserves native and wild horses.
See the list of sterilization activists who are asking for sterilization experiments on wild mares below
A group of Pro-Experiment activists on a Bureau of Land Management (BoLM) support Facebook page called Wild Horses, BLM and Logical Solutions (https://www.facebook.com/groups/1446611602254365/) , have asked the BoLM to experiment on wild horses. They wrote a letter calling for the Oregon sterilization experiments. They also asked for PZP to be used on the more tame herds. Pro-Experiment activists in their group signed it. Pro-Slaughter activists signed it too.
If you have “joined” their group–just to watch what this treacherous group of Pro-Slaughter, Pro-Experiment, Pro-Livestock, Pro-Pesticide PZP activists, BoLM employees and supporters, etc. are up to–know that they count all their group members as people supporting their agenda for sterilization experiments on wild pregnant mares in Oregon and elsewhere.
Recently one of their admins boasted, “We have 2,000 members . . . “.
We were very shocked to see The Cloud Foundation board member, Linda Gresham Hanick, vocal in the Wild Horses, BLM and Logical Solutions group but since this group not only pushes for sterilization experiments on pregnant mares but also pushes for Pesticide PZP–like the Cloud Foundation who calls and partners with BLM for Pesticide PZP–we understand why their board member might be there. (http://www.blm.gov/style/medialib/blm/mt/main_story.Par.31432.File.dat/TopStoryHorse.pdf)
Hanick seems to have been also a vocal member of a group Facebook shut down for Harassment and Hate Speech targeting our volunteer executive director, Anne Novak who created the Forum on PZP for Wild Horses & Burros on Federal Land (https://www.facebook.com/groups/ForumPZPWildHorsesBurros) educating thousands of people on Pesticide PZP. Novak is against experimenting on wild horses, against horse slaughter and a strong advocate for wild horse freedom often quoted in the news.
Many of the signors of the Ovarian Ligation and PZP letter were active members of a public group Facebook shut down for Harassment and Hate Speech targeting Anne Novak. Keep in mind Novak and other members of the Alliance for Wild Horses and Burros have been speaking out against the experiments since they announced them.
We have evidence of members of the Hate Group engaging in stalking, harassment, hate speech, etc. plotting to interfere with Anne Novak’s work, Protect Mustangs‘ mission as we as the mission of The American Wild Horse Institute, care of the wild horses rescued back from the slaughterhouse known as the Wyoming 14™ (WY14™) plus others and evidence of their plot to smear Novak’s good reputation and more.
Below are the names of the members of Logical Solutions who signed the letter calling for sterilization experiments on pregnant mares:
Proposal of Ovarian Ligation
By Sandee Force on Monday, August 24, 2015
From: Members of Wild Horses, BLM and Logical Solutions
To: U.S. Wild Horse and Burro Advisory Council
Re: Population Management of wild herds on HMAs
The members of the Wild Horses, BLM and Logical Solutions have spent time considering potential solutions to the ever increasing number of horses and burros needing to be removed from the range held in both Long Term Holding and Short Term Holding. We feel that a two pronged program would both greatly decrease the number of animals needing to maintained in this manner and allow older mares to live out their lives on the range.
We would like to suggest that ovarian ligation be put into an immediate test program in at least 2 and preferably 3 herds using herds that are widely watched and recorded by regional photographers. Our suggestion would allow for mares that are old enough to have had at least 4-5 foals accessed at gathering and removed to the closest holding facility to do ovarian ligation by a veterinarian who has experience in this procedure. We would suggest that working with the state veterinary school located closest to each facility would be the optimal way to get young vets trained on this procedure and to potentially hire vets specifically for the program from this pool of trained professionals.We realize that standard policy would normally be to spend a number of years doing in pen trials with horses that would be scheduled to go to LTH. We feel that this can be bypassed by using herds that are currently being observed and by training the photographers to record information on these mares that would give accurate information about how they assimilate back into the herds. We would like to suggest that along with the ovarian ligation all fillies 3 and under be given PZP and allowed to be more mature at first foaling.
To summarize our proposal as accurately as possible, allowing for changes needed by region or herd.
1. Two to three test herds be chosen that mares will be brought in and those 3 and under be given the correct dosage of PZP for their age and mares that are of an age to have 4-5 foals on the ground have the ovarian ligation procedure done to at the holding
facility. Those mares that are operated on can be held for an appropriate period for recovery at the facility to document reaction and to ensure proper healing of all incisions before being returned to the area that they were captured. Any foals that are under weaning age should stay with the mare in the holding facility and be release with her. Use a
small hip brand to designate ovarian ligation for observation purposes.
2. Any mare that shows a major genetic defect or has thrown multiple foals with genetic disorders should automatically be put into the ovarian ligation program no matter what the age.
3. Train photographers and volunteers to work with the USGS and Universities to properly document range interaction of both the mares who have been given ovarian ligation and those fillies given PZP. Video and photographic documentation of herd/band interaction would be ideal. It is imperative to have USGS and at least one University involved in both
documentation and study of the effect of ovarian ligation on herd dynamics and the health and well being of both, mares and foals as well as the local bands that they belong to.
4. Document the short and long term consequences of ovarian ligation on the mares, i.e. heath, longevity, and acceptance/position within the band. Note if the mares are removed from the bands and act like bachelor stallion bands.
5. Within 3 years if the results of the test herds are good expand to other BLM managed herds with the goal to cut down on required gathers to once every 6-8 years.
6. Look into the possibility of darting with PZP every 2 years to expand the time young mares have a chance to mature before starting to foal.
The goal of this plan is to decrease the rate of population growth on the range.
In conjunction it would allow these older mares to stay on the range without adding to population growth until their deaths and not have to be gathered and shipped to Long Term Holding Facilities for their senior years. Between the ovarian ligation and using PZP on the fillies the herd’s rate of growth could be reduced by 50% per year. This would substantially help both the range and the cost of gathering and housing the horses and burros while keeping more horses on the range. By hip branding the mares that have had ovarian ligation you would be able to gate cut those mares back onto the range at any subsequent gather and not have to haul them off the range.
Some of the herds suggested for this procedure are South Steens, Oregon; Sand Wash Basin, Colorado; Twin Peaks, California; and/or BLM HMA around the Reno/Carson area of Nevada. These are herds that have been previously documented and in the case of both Sand Wash Basin and South Steens there is photographic documentation of the herds for 5-7 years that would be available to work within this project.
Sandra Force – Junction City, Oregon
AJ Sutton- Lawndale,Ca.
Kari Masoner – Tuson, Arizona
Ana Andrick – Wellington, Colorado
Nancy Warrick Kerson – Napa, California
Kathleen T. Granzow – Genoa City, Wisconsin
Thomas P. Brunshilde – Hammond, Wisconsin
Karen Goodroad – Pleasant Hill, Oregon
Lea Erwood – Rosedale, IN.
Kathryn Shirley – Holly Springs, North Carolina
Margaret Rothauge (Maggie) Creswell, Oregon
Angela Robey – Witch Well, AZ
Tom Hool – Casper, Wyoming
Debbra Dotson Christensen – Coquille, Oregon
Stephanie Jones – Eugene, Oregon
Jamie M. Adkins – Casper, Wyoming
Lisa Sink-Sheridan, Oregon
Beverly Shaffer – Burns, Oregon
Ramona Bishop – Burns, Oregon
Shyla Creasey – Oregon
Stacey Harnew –
Andi Harmon – Burns, Oregon
Keelyn Fawcett – Salem, OR
Angela “Angel” Rakestraw – Dinwiddie, Va
Jennifer Gregton – Midvale, Idaho
Iris Benson – Corvallis, Oregon
Karen Landis – Centralia, WA
Candy Nichols – Poolville, TX
Bree Alsman – Sandy, Oregon
JoAnna Lamb – Boardman, Oregon
Tracey Westbury – Bellingham, Washington
Cathy Smith – Pleasant Hill, Oregon
Rhonda Chayer – Barton, Vermont
Debbie Jackson – Ellensburg, Washington
Jes Sothern – Oregon
Rex Moore – Denton, Texas
Rose Howe – Monument, Oregon
Kerry O’Brien – Van Nuys, CA.
Susan Clogson – Woodinville, Washington
Nancy Willard – Eugene, Oregon
Loretta M. Jones – Redmond, Oregon
Jennie Kreutzer – Arlington, Washington
Monica Shifflet – New Haven, PA
Crystal Cooke – Clovis, New Mexico
Christie Brown – Daphne, Alabama
Pat Garcia – Burnet, Texas
Carrie Marie Fuesler – Brownsville, Oregon
Jackie Mousseau – Clinton Township MI
Kathy Tellechea – Lexington, OR
Jim Bishop – Hines, Oregon
Angela Huston – St Louis, Missouri
Mike Huston – St Louis, Missouri
Kay Hamilton – Phoenix, OR
Richelle Wilson – Hillsboro, OR
Suzanne Ganazzi – Point Reyes Station, California
Tina Smith – Sommers, Conn
Andrea Walker – Fort Worth, Texas
Jeni Adler Snyder, Oklahoma
Ash Michael – Madison, South Dakota
Brigid Piccaro – Acton, California
Kathryn Meyer – Orion, MI
Nancy Kohl – Surprise, Arizona
Jeni Adler – Snyder, Oklahoma
Kate Bogel – Howell, New Jersey
Lara Mogensen – Ellensburg, Washington
Carol Davis – Selma, Oregon
Susan Humphrey – Hot Springs, South Dakota
Gini Everts – Eugene, Oregon
Protect Mustangs is an organization who protects and preserves native and wild horses.
Help the 3-Strike wild horses and burros who have lost their protections get to safe homes away from Kill Buyers!
Dear Friends of Wild Horses & Burros,
All of these wild horses and burros known as the #Nevada79 have received 3-Strikes and are now considered Sale Eligible thus losing their protections. 12 are located at the Palomino Valley Center outside Reno, Nevada and 67 are located at the facility in Fallon, Nevada known as Indian Lakes.
Let’s make sure none of them go to kill buyers signing on the dotted line and lying to BLM.
Here is the list: PM AWHI PVC Fallon Sale Eligible WOF53WOF56asof0 7 08 16
Most of these wild horses and burros will be put on the Internet Adoption for Sale starting next week here: www.blm.gov/adoptahorse
Let’s get them into loving homes in pairs. Let’s get all of them to safety!
Protect Mustangs is an organization who protects and preserves native and wild horses.
What is BLM hiding?
The Alliance for Wild Horses and Burros, made up of dedicated wild horse advocates and organizations, is working to place BLM’s 3-Strike wild horses in private care to end the drain on the budget.
When Anne Novak from Protect Mustangs, asked which wild horses and burros were 3-strikers at Palomino Valley Center, BLM staff tells her to file a FOIA to get the basic information that should be made readily available to the public. After all there are only 260 wild equids left at the facility.
Has the BLM made a special multi-million dollar deal with the Mustang Heritage Foundation (MHF) paying them to take the 3-Strikers and if so why are they hiding it?
Just for a point of reference, keep these figures in mind: 2000 wild horses x $2000 each if paid to the Mustang Heritage Foundation to take them = $4 million
Protect Mustangs is an organization who protects and preserves native and wild horses.