Is the Concocted Wild Horse Crisis based on Fraud?

 

Photo by BLM in public domain

Read Marybeth Devlin’s opposition to the proposed Antelope and Triple B Roundup

Via email: blm_nv_eldowellshorsegathers@blm.gov

August 21, 2017

BLM Elko District Office
3900 Idaho Street
Elko, NV 89801

Attn: Marc Jackson, Wells Field Manager

 

Project: Antelope / Triple B Complexes

Document: Environmental Assessment ( EA )

Action: 2017 Gather Plan EA — Comments to

NEPA ID: DOI-BLM-NV-E030-2017-0010-EA

 

This letter responds to your request for substantive comments and informed analysis that BLM Elko and Ely District Offices should consider regarding the subject EA. I submit my remarks as an interested party in behalf of the wild horses of the Antelope and Triple B Complexes. BLM alleges that the herds’ respective populations exceed the arbitrary management levels (AMLs).

For ease of reference, here are the respective links to the Project Summary Webpage, where the EA and other documents are posted, and to the map of Nevada’s HMAs.

https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&projectId=84367&dctmId=0b0003e880df2fff

Please note that, in my comments, where text has been emphasized, either through bold and/or italics, the emphasis was added by me. Also, “page-number” means “screen-page” in the EA’s online version.

 

BACKGROUND

 

The Alternatives

BLM proffers four options in the EA, with Alternative A identified as BLM’s proposed action. Although not assigned a letter, the “No Action” Alternative is listed first in the EA, and it is the correct choice.

Alternative A — Cull to low-AML; PZP or GonaCon to mares; skew genders; geld 50% of studs.
Alternative B — Cull to low-AML; PZP or GonaCon to mares; skew genders.
Alternative C — Cull to low-AML.

For both Alternatives A, B, and C, the cull would drastically reduce the component herds per falsely-estimated population-levels. Page 18 of the EA states that 6,737 wild horses would be removed immediately, with the rest of the “excess” to be culled over a period of up to 10 years.

As if the cull were not bad enough, BLM would inject all released mares with pesticides — identified as either PZP-22 or GonaCon™ or “newly developed formulations.” The genders would be skewed 60:40 to favor stallions, but 50% of stallions would be gelded.

A careful review of the facts shows that the right option is the No Action Alternative. All proposed actions are contraindicated because fraud was the basis for the finding of “overpopulation.” BLM must not be rewarded for unethical, criminal behavior.

 

Wild Horses Roam — Their Presence Is Fleeting, Their Numbers Are Fluid

Just because a survey supposedly counts a particular number of wild horses in one of the Complexes on a certain day does not mean the same number are still there. Those horses may have been merely passing through per their normal free-roaming nature. They may have left the area the day after the census was conducted. Wild horses are constantly on the move. Roaming is “how they roll.” Visitor-horses are not permanent residents, but they likely get counted as such — and counted multiple times — in a census that does not take horse-movement into consideration. I refer you to my comments regarding the survey-method are why it is unsuitable for taking inventory of wild horses.

 

Not Reproduction, but Migration

BLM assumes that the Complex herds allegedly exceed the AMLs due to reproduction, and that, therefore, culling, sterilizing, and gelding must be conducted in order to save the “thriving natural ecological balance” from imminent destruction. But the EA fails to consider migration to and from nearby HMAs — such as Diamond, Diamond Hills North, Diamond Hills South, Fish Creek, Pancake, and Whistler Mountain.

 

Over-AML ≠ Over-Populated

BLM announces its intent to reduce the Complexes wild-horse herds because their numbers are — allegedly — over AML — that is, over the arbitrary management level (AML) for each herd. However, as is discussed elsewhere in my letter, the AMLs are invalid because they do not meet the minimum-viable population (MVP) as determined by the International Union for the Conservation of Nature for wild equids.

 

PRINCIPAL USE WITHIN MULTIPLE-USE APPROACH

 

Wild-Horse Habitat Must Be Managed Principally for Wild Horses

HAs and HMAs are wild-horse habitat-zones. Wild horses must enjoy principal use of their range. This requirement is stated plainly in the Wild and Free-Roaming Horses and Burros Act, which stipulates that their land is to be “devoted principally but not necessarily exclusively to their welfare ….” Thus, HAs and HMAs do not necessarily have to be managed exclusively for wild horses. However, HAs and HMAs must be managed principally for the welfare of our Federal horses.

On pages 32 and 34 of the EA, BLM disingenuously conflates “principal use” with “single use,” and claims to quote from a Senate Conference Report that single use was not intended. Who said it was? We are talking about principal use, not single use. Indeed, the WFRHBA was forward-looking for its time, anticipating the multiple-use concept while providing for principal use for wild-horses in their habitats.

Moreover, multiple-use does not mean every-conceivable-use. Incompatible uses should be excluded. Some examples of incompatible uses appear obvious — mining and off-road vehicles. HMAs should be designated “no surface occupancy” (NSO) areas — to preserve aesthetic and recreational values and to avoid disturbing the horses’ natural behavior. HMAs should also be declared “off-limits” to off-highway-vehicles (OHVs) — to protect the peace-and-quiet of the range and the cleanliness of the ambient air.

The Complexes are not being managed according to the Law because the wild horses are not allotted principal use of their habitat. The wild horses have been displaced by encroaching livestock.

This inversion must be righted, and BLM must employ the right mechanisms to do so. First, BLM needs to rescind this EA. Then, it must amend the Land-Use Plans (LUPs), Resource Management Plans (RMPs), Final Multiple-Use Decisions (FMUDs), and Herd Management Area Plans (HMAPs) to conform with the Law regarding principal use.

 

Disproportionate Allocation of Forage — Must Be Corrected

Of the 129,370 animal unit months (AUMs) — grazing slots — available in the Antelope Complex …

124,246 — AUMs — 96% — have been allotted to livestock

5,124 — AUMs — 4% — have been allotted to wild horses

Of the 93,070 animal unit months (AUMs) — grazing slots — available in the Triple B Complex …

87,406 — AUMs — 94% — have been allotted to livestock

5,664 — AUMs — 6% — have been allotted to wild horses

Question: What is wrong with that allocation? Answer: The allocation is inverted. By Law, wild horses must receive the majority of the grazing slots — the AUMs — within their HMAs in accordance with the legal requirement that they have principal use of their dedicated habitat.

 

Wild-Horses — Sparsely Populated, Widely Dispersed

The low-AML — 427 — restricts the wild-horse population-density in the 1,324,745 acres that constitute the Antelope Complex to …

1 wild horse per 3,102 acres — or about — 1 wild horse per 5 square miles.

The low-AML — 472 — restricts the wild-horse population-density in the 1,682,998 acres that constitute Triple B Complex to …

1 wild horse per 3,566 acres — or about — 1 wild horse per 5½ square miles.

Imagine if livestock were held to the same stocking-density. The sparse and widely-dispersed population imposed by the AML evidences bias. It also evidences violation of the Wild Free-Roaming Horses and Burros Act.

To grasp the enormity of the unfairness, we can see that, by converting the livestock AUMs to wild-horse equivalents, BLM allows …

Antelope Complex:

1 cow+calf pair per 128 acres — or about — 5 cow+calf pairs per 1 square mile

Triple B Complex:

1 cow+calf pair per 231 acres — or about — 3 cow+calf pairs per 1 square mile

 

Authorized v. Actual Livestock Use

BLM argues that actual livestock use is much lower than authorized or permitted use. Pages 58 through 62 feature charts that show the alleged 10-year average AUM uses by livestock in each Complex. It is curious that instead of providing recent use-figures that BLM went to the trouble of computing a 10-year average for each of the many allotments involved. What were you trying to hide?

BLM’s AUM-use charts for livestock showed 32.7% for the Antelope Complex and 46.7% for Triple B Complex. Lets assume for sake of argument that those figures are true. Then, obviously, the permittees don’t need all those authorized AUMs, and it is entirely appropriate to reassign them to whom they belong: wild horses.

But there’s more to this “use” issue. “Actual use” really means “billed use” — how many AUMs BLM billed permittees for having used. But because actual use is whatever the permit-holders self-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 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 “Actual 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.”

https://www.blm.gov/sites/blm.gov/files/uploads/Services_National-Operations-Center_Eforms_Rangeland-Resources_4130-005.pdf

http://www.gpo.gov/fdsys/pkg/FR-2014-08-22/html/2014-20049.htm

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 AUM-usage reported on Form 4130-5 is suspect.

 

Voluntary Non-Use of AUMs Reflects Price-Declines for Beef

BLM and its permit-holders protest that a lot of the livestock AUMs are in voluntary non-use. They complain loudly, blaming the seeming excess of wild horses — an illusion caused by BLM’s phony figures — for reducing their AUM-usage.

However, if permittees are not using 100% of their AUMs, it is likely because the market for their product is weak. Here is an excerpt from the most recent Cattle Report issued by Ag Center:

Cattle Futures. Price declines continued in the cattle futures market. Early week sales of cattle at lower prices discouraged any long buyers from entering the market. August, expected by some to rise to last week’s cash price, instead rolled over and continues to lead the cash market down.

http://www.agcenter.com/newcattlereport.aspx

 

Beef-Cattle Now Weigh More, So Fewer Needed — The AUM Needs to Be Reformed

In an August 2015 article titled “Cattle Weights Continue to Increase at Impressive Rates,” AgWatch Network reported:

The federally inspected steer dressed weight for the week of 8/15/15 was 900 pounds, according to USDA. This was 25 pounds heavier than a year ago, and well on track to set a new record in 2015 above the 906 pounds seen in October of 2014.

Looking back at steer dressed weights, on an annual average basis, weights increased by 0.5% per year since 1960 (they were 656 pounds in 1960). Using that percentage increase (0.5%) works through 2013, but does not capture the increased growth rate seen in 2014 and what is estimated for 2015. Looking back, 2014 experienced a 1% growth in steer dressed weights year-over-year, and 2015 is on track to be 2% higher than 2014’s.

The article goes on to predict that, because of the increase in cattle-weight, a decrease in cattle-numbers will likely ensue. It states: ” … if these weights continue to increase at a faster pace, the industry may not restock back to the previous inventory peak levels.”

The AUM was originally predicated on 1,000 pounds of live weight. However, the above article discusses the dressed weight — which is dead weight, excluding certain parts. Per Wikipedia …

Dressed weight (also known as dead weight or carcass weight) refers to the weight of an animal after being partially butchered, removing all the internal organs and oftentimes the head as well as inedible (or less desirable) portions of the tail and legs.

The new and increasing average dead weight is fast-approaching what used to be the average live weight.

The AUM for a wild horse presumes a mustang is the equivalent of a 1,000-pound saddle horse. But mustangs tend to be smaller and lighter, weighing 700 to 900 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 less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.

 

Sheep Production Continues Long Decline in the US

Not just cattle but sheep and even goats (as well as some domesticated horses) graze in the Complexes allotments. On pages 60 and 62 of the EA, BLM blames drought and “competition” with wild horses for forage causing a drop in actual-use livestock AUMs, which also include sheep. But BLM’s representation is not in accordance with the facts. Sheep-production has been in decline across the United States for decades, with herd-levels down 90% from their peak in the 1940s. [See article by Runyon in Harvest Public Media] The decline is reportedly due to a combination of factors not caused by wild horses.

Changing consumer-demand
Availability of synthetic fabrics
Competition from foreign imports
Competition from beef, chicken, pork
Scarce feed supplies for fattening
Harsh weather and drought
Price-volatility

 

Facilitation and Commensalism — Equids Enhance the Ecosystem

Some species thought to compete actually facilitate one another’s well-being. They interact positively and reduce physical stress. For instance, commensals are animals that eat “at the same table” but without competing.

BLM sees “competition” where there is really commensalism. For instance, in the EA, BLM implied that having fewer wild horses would reduce competition over not just forage but over water too. BLM alleges that wild horses drive off other creatures from watering holes. While that may happen, any such displacement lasts just minutes. Wild horses drink and leave. There is no ongoing blockade. Wild horses also expand water seeps, which is another benefit they provide.

Moreover, wild horses actually create little water-catchments. Sue McDonnell, PhD, a certified applied animal behaviorist and the founding head of the equine behavior program at the University of Pennsylvania’s School of Veterinary Medicine, explains how:

“A very interesting phenomenon in horses is the “creation” of dust bowls at the rolling sites. Repeated rolling in the same spot serves to eliminate the vegetation and erodes the surface, forming a shallow bowl. With time the bowl has a very compacted base lined with fine powdery soil. The bowl also becomes “oiled” with body residues. The drier and hotter it gets in summer, the more rolling occurs, and the deeper and more compact and oiled the bowl becomes. When it rains, these dust bowls gather water and become temporary watering sites.”

Thus, wild horses contribute to, rather than compete for, the availability of water. They enhance the ecosystem.

 

Rangeland Health Monitored Using Method Considered Less Accurate

Per the EA, rangeland disturbance response groups (DRGs) were evaluated per the Key Forage Plant (KFP) Method. However, KFP is obsolete, having been replaced by a new method — Landscape Appearance (LA) Method in 1996. Both the KFP and LA methods are qualitative assessments known as “ocular estimates.” In other words, you “eyeball” the area to judge its appearance; hence “ocular.”

Technical Reference (TR) 1734-7, Ecological Site Inventory, notes that such ocular estimates — qualitative assessments — “may result in reduced accuracy, limiting use of the data.” It is apparent that BLM chose an easy method that could be manipulated to blame the wild horses for any and every range condition not meeting standard, even though a century of overgrazing by livestock was the real culprit.

 

Rangeland Health Monitoring Proceeded As If Only Wild Horses Impacted the Range

BLM did not evaluate the impacts of the many other species present in the Complexes — species many times more numerous and others that are known to consume a greater percentage of rangeland forage. Instead, BLM proceeded as if only livestock and/or wild horses used the rangeland’s resources, listing them as “primary” users. However, wild horses were the scapegoats. The rangeland monitoring was merely a “hatchet job” — a maliciously destructive critique — on the wild horses in order to make it seem as though culling, contracepting, and gelding the herd were justified when, in reality, such actions are contraindicated.

 

Lagomorphs

Although BLM alleges “competition” between mustangs and livestock over forage, one of the dominant herbivores on the range are lagomorphs — jackrabbits, hares, and cottontails. According to Appendix VII “Species List” to the EA, all-three species are found in the project area. However, BLM has neither determined nor factored in their impact on the range.

A recent study in Utah found that jackrabbits were consuming 34% of the forage on local grazing-allotments. Evidently, the creatures reproducing like rabbits were rabbits. Ranchers immediately called for an end to shooting coyotes, which prey on rabbits.

http://www.sltrib.com/news/2080640-155/usu-study-jackrabbits-are-a-bigger?fullpage=1

http://www.hcn.org/articles/bison-cows-rabbits-utah-ranching-henry-mountains

Instead of scapegoating wild horses for forage likely eaten by a different species, BLM needs to conduct a Ecological Site Inventory to determine actual use — including trespass use. The Inventory must pro-rate actual use by each animal-species present, including rodents and insects, and even including creatures such as lagomorphs.

 

Locusts

In normal times, locusts — grasshoppers and crickets — consume 20-to-25% of the forage in areas where they are present. However, in times of outbreaks, they can eat nearly all of the green biomass.

Grasshoppers thrive on the warming Wyoming range

Below is the link to the most recent USDA map, showing areas where there is grasshopper-and-cricket infestation. Nevada — including parts of the Complexes — appears to have been affected. As the map reflects, the creatures devouring the forage like locusts probably are locusts.

http://www.sidney.ars.usda.gov/grasshopper/Extras/2016GHwMC.htm

An Ecological Site Inventory would reveal the extent of forage-consumption by insects — such as locusts — in the project area. Again, you may be surprised to learn who is eating what and how much.

I note the omission of insects from Appendix VII’s Species List.

 

BIRTH RATE AND GROWTH RATE ARE DIFFERENT

 

Birth Rate ≠ Growth Rate

Before we examine BLM’s reported herd-growth rates for 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. The birth rate will necessarily be higher than the herd-growth rate. Here’s why: Horses die.

 

Foal Mortality Rate = 50%

An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records of four representative herd management areas with 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 before their first birthday. Thus, the 20% foaling rate is merely a temporary “blip” in the data. The effective foal-to-yearling survival rate is just 10%. By failing to adjust the population-estimates per expected foal mortality, BLM inflates the figures.

 

Other-than-Foal Mortality Rate = At Least 5%

Even when fed, watered, vaccinated, wormed, and protected, horses still die. BLM advises that about 5% of wild horses in short-term holding — and 8% of those in long-term holding — perish on a yearly basis. Adult horses in the wild also succumb to illness, injury, or predation. So, it is a reasonable and conservative estimate that at least 5% of wild horses other-than-foals perish annually out on the range. The actual number is probably much higher. By failing to factor in adult-wild-horse mortality, BLM further exaggerates the population-estimates.

 

Stochastic Events — Also Reduce Herd Growth

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

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

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

Imagine if such a catastrophe were to befall the 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, geldings, and sterile elderly mares? BLM must proactively manage the herds per IUCN guidelines, if only in case of stochastic events.

 

Normative Annual Herd-Growth = At Most, 5%

The surviving-foal rate (10%) minus the adult-mortality rate (5%) equals a normal herd-growth rate of 5%. If BLM wanted a handy — and valid — way of estimating herd-growth, using 5% per year would work. Please note: At that rate, it would take 14 years for a herd to double.

 

Maximum AML Set Below Minimum Viable Population

Approximately 83 percent of wild-horse herds are “managed” below MVP, including the subject Complexes of HMAs. What is the correct MVP for wild horses? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the acreage composing each HMA in the Complexes. However, the high-AMLs — even the combined Complexes’ high-AMLs — are set below MVP.

 

FRAUDULENT POPULATION DATA

 

Lies, More LIes, and Statistics

BLM has posted herd-growth rates that far exceed the normative rate of 5%. Here are charts showing the excessive growth rates, which are not credible. They appear to be falsified birth rates used as growth rates. Mortality was evidently ignored.

 

Antelope Complex Herds

Name of HMA: Antelope

Year Population Percent Compared to
Change 5% Norm

2013  344
2014  413  20%  4 times the norm
2015  669  62%  12 times the norm
2016  861  29%  6 times the norm
2017  1,271  48%  9 times the norm per official stats
2017ea 1,033  20%  4 times the norm per the EA
2017a  1,239  20%  4 times the norm against the EA figure

 

Name of HMA: Antelope Valley

Year Population Percent Compared to
Change 5% Norm

2013  662
2014  792  20%  4 times the norm
2015  1,013  28%  5 times the norm
2016  1,100  9%  2 times the norm
2017  1,320  20%  4 times the norm
2017a  1,584  20%  4 times the norm
2017b  1,488   96 removed in May

 

Name of HMA: Goshute

Year Population Percent Compared to
Change 5% Norm

2013  198
2014  523  164%  33 times the norm
2015  668  28%  5 times the norm
2016  904  35%  7 times the norm
2017  1,015  12%  2 times the norm
2017a  1,218  20%  4 times the norm

 

Name of HMA: Spruce-Pequop

Year Population Percent Compared to
Change 5% Norm

2013  380
2014  493  30%  6 times the norm
2015  789  60%  12 times the norm
2016  1,021  29%  6 times the norm
2017  1,170  15%  3 times the norm
2017a  1,404  20%  4 times the norm

 

Triple B Complex Herds

Name of HMA: Maverick-Medicine

Year Population Percent Compared to
Change 5% Norm

2013  586
2014  763  30%  6 times the norm
2015  910  19%  4 times the norm
2016  1,155  27%  5 times the norm
2017  1,309  13%  2 times the norm
2017a  1,571  20%  4 times the norm

 

Name of HMA: Triple B

Year Population Percent Compared to
Change 5% Norm

2013  498
2014  1,107  122% 24 times the norm
2015  1,460  32% 6 times the norm
2016  1,600  10% 2 times the norm
2017  1,702  6% 1 times the norm per official stats
2017ea  1,770  11% 2 times the norm per the EA
2017a  2,124  20% 4 times the norm against the EA figure

BLM’s population-growth figures are deemed invalid. Even if the “data” represented only the birth rates, they would, in many instances be higher than the normal birth rate.

Multiple over-counts, along with normal roaming behavior, migratory flux among HMAs, and erroneous assumptions, are likely factors to blame. Nevertheless, BLM knows the numbers have to be false. Therefore, by posting false and misleading information, and by proposing to manage per that false and misleading information, BLM is perpetuating a fraud.

In light of these fictitious figures, the No Action Alternative — is and must be the correct choice.

 

Unethical Manipulation

BLM staffers cannot claim ignorance. You are college-educated professionals with degrees in science and range management. You are well-aware that wild-horse herds cannot increase at exponential rates. Yet, you willfully continue to cite them, thereby inciting local ranchers and their elected officials. Worse yet, BLM proposes to conduct drastic culls based on those fraudulent figures.

 

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.

 

Fraud Is a Crime

BLM’s wild-horse population figures are without merit. They are false and misleading. Making false and misleading representations = fraud, which violates Title 18 USC 1001 of the Federal criminal code.

 

Fraudulent Data Emboldens Scofflaws, Costs Wild Horses Their Freedom

In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use. Conditions are egregious in Nevada, where the notorious Cliven Bundy and sons, 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.

BLM Leadership Coddles Hostile and Law Breaking Nevada Ranchers like Cliven Bundy

There are likely other permittees in Nevada emulating Bundy, Borba, and Filippini. 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.

No doubt, the local cattlemen are up in arms over BLM’s seeming tolerance for what has been portrayed — via fraudulent figures — as a huge overpopulation. BLM is, in part, to blame for inciting the the permittees with false and misleading information. However, the ranchers are also, in part, to blame. Certainly, being professional stockmen, they knows full well that horses are slow to reproduce. But they apparently go along with the farce because it advances their self-interest.

 

Societal Impact of Inflated Population-Data

The population-figures 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.

 

HELICOPTERS — INAPPROPRIATE FOR COUNTING WILD HORSES

 

But the Inventory Counted That Many Horses

When a count produces results that disagree with the known reproductive limitations of a species, the count must be deemed invalid. We know mares have a long gestation, and that they produce one foal per year. The normal annual herd-growth rate is 5% — not 122% or 164% — which are among the rates that your official data reported for herds in the Complexes. A 20% growth rate would be 4 times the norm.

 

Helicopter 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 census of the Red Desert Complex (in Wyoming) 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.

I note that the EA also mentioned that assumptions had been used, but contended that an under-count was likely. That assumption is incorrect and opposite to the facts. When more horses are “seen” than could possibly exist, the method is faulty and likely fraudulent. Finally, I note the absence of photographs taken from a Go-Pro camera mounted on the aircraft.

 

Both the Roundup-Contractor and BLM 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 target-areas. What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?

The helicopter-pilot is looking to “make his numbers” but so is BLM. Thus, BLM has a conflict of interest in needing the contractor to remove any 6,737 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 BLM to spend the budget. Consequently, wild horses would lose their freedom for the private profit of the helicopter-contractor and for the administrative, job-justifying convenience of BLM. 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 outside their HMAs 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.

Recommendations: In legitimate instances of straying, BLM 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 BLM wants them to use? What about siting mineral licks deep inside the HMAs, away from the outskirts? 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. BLM should specify preventive and reactive measures in this regard as part of its management approach. Return outsiders to the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from “outside” areas (aversive techniques).

 

HELICOPTERS — DANGEROUS TO HUMANS, HORSES,
AND THE ENVIRONMENT

 

The risks to humans, horses, and the environment posed by the use of helicopters to count and capture wild horses were fully discussed in comments I submitted to BLM-Nevada on Tuesday, June 27, 2017, when the Motorized Equipment Statewide Hearing was held. Therefore, I will not repeat them here but am linking them to these comments by reference.

 

POPULATION-CONTROL BY NATURE

 

Predators Prey on Ponies

Nature provides its own population-control for wild horses — by means of large predators. There can be no “thriving natural ecological balance” without apex predators. Mountain lions, bears, wolves, and coyotes effectively control wild-horse populations. Predators promote survival of the fittest, as Nature intends. Therefore, the best approach is for BLM to concentrate on conserving native predators to permit natural control of the wild-horse population on the range.

 

Mountain Lions Are Especially-Effective Population-Control Agents for Wild Horses

Many studies have established that mountain lions prey on wild horses more frequently than previously believed. Canadian biologists found that cougars tended to kill younger animals, especially when preying on feral horses. Nearly all of the cougars’ predation-events (86%) involved animals less than 2 years old.

http://sci-northern.ab.ca/wp-content/uploads/2010/12/CougarKillRateandPreyComposition.pdf

In an interview with the Billings Gazette, the above study’s lead researcher, Kyle Knopf, described observing a cougar that brought down a feral horse in less than 30 yards from where it attacked.

http://billingsgazette.com/lifestyles/recreation/article_d9cf046b-2c47-539f-a267-972e72e570b6.html

Other research confirms that mountain lions are quite capable, all by themselves, of keeping wild horse populations in check.

The Montgomery Pass Wild Horse Territory, on the California/Nevada border, has had its ppopulation managed by cougars alone. An eleven-year study by Turner and Morrison (2001) concluded that the growth of this herd was limited by cougar predation. In fact, the population actually decreased over the course of the research.

http://www.jstor.org/discover/10.2307/3672527?uid=2129&uid=2&uid=70&uid=4&sid=21101018535373

The Nevada Wild Horse Range (current designation) averaged negative population growth due to cougar predation from 1989 to 1998 (Greger and Romney, 1999).

https://www.sciencebase.gov/catalog/item/5053f9e6e4b097cd4fcf8fd3

Per The Cloud Foundation, the Pryor Mountain herd averaged no population growth over a four-year period due to predation by mountain lions. Only when those lions were killed — so that BLM could continue practicing management of the herd with PZP — did the wild-horse population begin to grow.

 

Healthy Predators, Healthy Ecosystems

Minimum feasible management means letting natural selection do its job. Mountain lions, wolves, bears, and coyotes should be allowed to carry out their role of population-control agents. Predators will cull the weak, and a thriving natural ecological balance will ensue. Conservation Researcher Dr. Corey Bradshaw emphasizes “… just how important predators are for healthy ecosystems. Long story short – if your predators are not doing well, chances are the rest of the ecosystem is performing poorly.”

Due to pressure from livestock and hunting interests that mistakenly view predators as pests, it has been the Federal government’s practice to exterminate native predators outright or to allow them to be hunted on a massive scale. That policy is wrong. Predators function to keep the ecosystem in balance. Without them, prey species decline, as do the forage-production species on which the prey-animals feed. Dr. Bradshaw warns: “Without predators, our feeble attempts to conserve ecosystems are doomed to fail.” Here’s the link to his timely article:

Essential predators

 

Predator Protection

HMAs should be safe-havens for predators, which will serve as wild-horse population-control agents.

There can be no true “thriving natural ecological balance” without predators. Therefore, BLM should ensure the protection of native predators, instituting a prohibition on hunting them. Conservation measures will work to enable the right number of predators to establish themselves. Large carnivores will keep the wild-horse population in check. Such an approach would keep the herd-population in equilibrium with minimal human-interference, just as the Wild and Free-Roaming Horses and Burros Act envisioned. Predators are the “no-cost” option.

Recommendations: Puma-protection, bear-introduction, wolf-reintroduction, and coyote-protection programs should be implemented. BLM should collaborate with Nevada Department of Wildlife to prohibit hunting of predators in the HMAs. Concerned livestock operators and residents of the surrounding area can be advised to use guardian-dogs to protect their animals. There are several specialty-breeds that have been developed just for this purpose, and they are reportedly effective. Protecting one’s herd is just part of the cost of doing business. The timely article linked below provides information on livestock-guardian-dogs.

https://www.hcn.org/articles/searching-for-the-best-dog-to-save-livestock-and-wildlife

 

PZP — BLM PROPOSES TO DEPLOY IT AGAINST WILD MARES

 

PZP — The Pesticide

Porcine zona pellucida — PZP aka ZonaStat-H or Native PZP — is an EPA-registered pesticide derived from the ovaries of slaughtered pigs. PZP is approved for use on wild horses “in areas where they have become a nuisance ….”

Some persons argue that, because PZP does not kill the mare, it is not really a “pesticide.” Actually, PZP does kill. As will be documented herein, PZP’s use is associated with stillborn foals. PZP is further correlated with stolen foals and out-of-season foals, who perish as neonates. In the long term, PZP tends to weaken a herd immunologically, which could swiftly lead to its extinction. So, yes, PZP is a real pesticide.

 

PZP — an Anti-Vaccine

While touted as a “vaccine,” PZP is actually a perversion of what a true vaccine is supposed to be. Instead of preventing disease, PZP causes disease — auto-immune disease. Thus, PZP could be viewed as an anti-vaccine.

 

PZP’s Mode of Action as Stated in the Pesticide Registration Is a Disproved Hypothesis

HSUS, the registrant of PZP advised the Environmental Protection Agency that, based on information from the pesticide’s researcher-manufacturer, PZP works by generating antibodies that “block sperm attachment.” This representation of PZP as a sort of chemical condom was not fact but merely an untested hypothesis, postulated three decades ago. The old hypothesis was disproved by subsequent research. PZP’s manufacturer knew, or should have known, this. The manufacturer should also have been informed and up-to-date regarding the side effects and unintended consequences of PZP. Yet, the manufacturer continued to cite the disproved hypothesis and to deny that PZP has any adverse effects. [25 and 36] HSUS is remiss in not investigating PZP beyond the manufacturer’s claims before touting it as the solution to the non-existent wild-horse overpopulation “problem.” BLM is irresponsible in ignoring research that has disclosed PZP’s risks.

 

PZP’s True Mode-of-Action

So how does PZP really work? PZP tricks the immune system into waging immunological war on the ovaries. In a meta-analysis of ZP-type contraceptives, Kaur & Prabha (2014) reported that the infertility brought on by such products is ” … a consequence of ovarian dystrophy rather than inhibition of sperm-oocyte interaction.” Thus, PZP’s antibodies “work” not by blocking sperm attachment but by destroying the ovaries. Kaur & Prabha further disclosed that ” … histological examination of ovaries of immunized animals revealed the presence of atretic follicles with degenerating oocytes.” [Atretic follicles are ovarian follicles in an undeveloped state due to immaturity, poor nutrition or systemic disease; manifested by prolonged anestrus.]

Kaur & Prabha’s review concluded that PZP’s antibodies induce ovarian dystrophy, destruction of oocytes in all growing follicles, and depletion of resting follicles. The manufacturer of PZP as well as BoLM should have been aware of these and other findings about the pesticide. Yet they ignored or disregarded any information that was contrary to their personally-preferred but obsolete and false description of PZP’s mode-of-action.

Kaur & Prabha warned that “… long term studies showed that immunization with zona antigens might induce immunological attack on many eggs in the ovary which might lead to premature ovarian failure.”

Included as a reference to the EA? No.

 

Study Shows PZP Elicits Ovarian Pathologies

One of the references cited in the EA was a study by Curtis et al. (2001) on the comparative effects of GnRH and PZP on white-tailed deer. However, Curtis, along with most of the same colleagues issued a newer study (2007) on PZP alone.

Curtis, Richmond, Miller, and Quimby (2007) disclosed that 75% of PZP-treated white-tailed deer — and 50% of re-treated deer — suffered eosinophilic oophoritis (inflammation of the ovaries).

Further, the re-treated deer that did not develop oophoritis instead developed a different problem — significantly fewer normal secondary follicles than control females.

The study-authors concluded that PZP “elicited ovarian pathologies in deer similar to those observed in other species.”

Included as a reference to the EA? No.

 

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

In a telling study, Kirkpatrick, Liu, Turner, Naugle, and Keiper (1992a), the lead author and manufacturer of Native PZP, along with colleagues, reported that ” … three consecutive years of PZP treatment may interfere with normal ovarian function as shown by markedly depressed oestrogen secretion.” So, despite all the hype about PZP being non-hormonal, the manufacturer knew that ZonaStat-H has an adverse hormonal effect, causing significantly-lowered estrogen. Thus, PZP is an endocrine disruptor. [39] The plummeting estrogen-levels may also reflect the ovarian dystrophy and oophoritis now known to be caused by PZP. Despite personally discovering negative hormonal impacts 24 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and hid its endocrine-disruptor side-effects.

Included as a reference to the EA? Cannot tell. A 1992 study is listed twice, but not 1992a.

 

PZP Causes Ovarian Cysts

In their 2010 meta-analysis, Gray & Cameron cited a number of studies that found ” … alterations to ovarian function, oophoritis, and cyst formation with PZP treatment (Mahi-Brown et al.1988, Sehgal et al. 1989, Rhim et al. 1992, Stoops et al. 2006, Curtis et al. 2007).” These findings support those of Kaur & Prabha while introducing yet another adverse effect: ovarian cysts. Gray & Cameron’s review also noted that increased irritability, aggression, and masculine behavior had been observed in females following PZP-treatment.

Included as a reference to the EA? No.

 

PZP → Endocrine Disruptor → Elevated Testosterone → Masculinizing Effects

Recall that PZP has endocrine-disrupting effects that result in lowered estrogen. Per the observed masculine behavior of treated mares, PZP seems to have a testosterone-elevating effect too. A deficit of estrogen alone would not necessarily manifest in the masculinization of treated females, but an excess of testosterone would. So, it appears that PZP disrupts at least two hormones: estrogen — by substantially lowering it — and testosterone — by substantially elevating it. Adverse effect: Abnormal behavior.

 

PZP → Ovarian Cysts → Elevated Testosterone → Masculinizing Effects

As discussed above, PZP correlates with abnormal masculine behavior on the part of treated females, a side-effect likely due to elevated testosterone. But in addition to the endocrine-disruption caused by PZP, there could be a second way for testosterone levels to become elevated. Recall that PZP causes ovarian cysts. An Internet search on “ovarian cysts and testosterone” yielded results for polycystic ovary syndrome (PCOS) in women. Interestingly, one of the symptoms of PCOS is high testosterone levels. The connection between ovarian cysts and elevated testosterone suggests that the ovarian cysts caused by PZP could — either alone or in combination with PZP’s endocrine-disruptor effects — lead to high testosterone levels in treated females, as evidenced by their masculinized behavior.

 

PZP Causes Additional Adverse Effects

Gray & Cameron’s review also disclosed that, when PZP was administered to the females of a herd, males lost body condition while the oft-claimed improvement in female body condition did not hold up. Further, mares remained sexually active beyond the normal breeding season and had more estrus events.

 

PZP Selects for Weak Immune Function

Gray & Cameron’s analysis raised the possibility of PZP selecting for immuno-compromised individuals. Here’s why. 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 dam, 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. Thus, a herd being treated with PZP is undergoing selective breeding for weak immunity, which puts the population at risk for disease — and ultimately, for extinction.

 

PZP Confers Dubious “Benefit” of Increased Longevity

Gray & Cameron also cited a study that found that “… PZP treated feral horse mares lived longer, resulting in a new age class (>25 years) not present before treatment ….” Exceptionally-long life is an ironic effect of PZP treatments. PZP’s manufacturer actually boasted about it, as if the anomaly were a good thing. However, Gray & Cameron questioned the supposed benefit of mares living much longer than their normal life expectancy. Indeed, such mares take up scarce slots within size-restricted populations. The ultra-elderly mares continue to consume resources for many years, but they no longer contribute to the gene-pool. It is detrimental to a population’s genetic viability to carry significant numbers of sterile herd-members way-beyond their normal life-span.

 

Research on Wildlife Contraceptives Revealed Stillbirths and Auto-Immune Oophoritis from PZP

There was an even earlier, definitive meta-analysis on wildlife contraceptives. Nettles (1997) reviewed 75 studies available at that time on the subject. Among his findings regarding PZP-use across different species, including horses, were:

Stillbirths;
Altered ovarian structure and cyclicity;
Interference with normal ovarian function;
Permanent ovarian damage; and
Some cases of irreversible sterility due to auto-immune oophoritis, which suggested that PZP can be selective against a certain genotype in a population.

Many of these findings were confirmed by Kaur & Prabha as well as by Gray & Cameron. The focus now turns to certain of these key findings: Stillbirths, and auto-immune oophoritis. However, in discussing the correlation between stillborn foals and PZP-use, a related abnormality will be addressed: Stolen foals — abducted by barren mares treated with PZP.

Included as a reference to the EA? No.

 

Foals May Be Their Dam’s and/or Sire’s Only Offspring

In view of the fact that PZP eventually — if not immediately — causes sterility, any foal could be genetically rare and precious. In many cases, a foal may be the only offspring of a certain mare or stallion. By using PZP on the Sand Wash Basin mares en masse, BLM could endanger the herd’s genetic diversity.

 

Autoimmune Ovarian Disease — Known to Cause Premature Ovarian Failure — Induced by PZP

Tung, Agersborg, Bagavant, Garza, and Wei (2002) found that autoimmune oophoritis (ovarian inflammation) could be induced by injecting test-animals with ZP3 peptide. The researchers noted that autoimmune ovarian disease is a known cause of human premature ovarian failure. Here again, is causation of autoimmune disease by a ZP-type product. Humans and horses are both mammals. It is logical to conclude that ovarian failure also occurs in horses. This study confirms other research cited herein.

Included as a reference to the EA? No.

 

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

Varras, Anastasiadis, Panelos, Balassi, Demou, & Akrivis (2013) disclosed that, in humans, autoimmune oophoritis carries the risk of the patient developing other autoimmune diseases. The correlation between autoimmune oophoritis and subsequent other autoimmune disorders weighs against injecting the mares with PZP.

 

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

Nettles’ (1997) previously-mentioned meta-analysis on PZP disclosed additional adverse effects:

A prolonged breeding season and
Unusually-late parturition dates. (Parturition is the formal term for “giving birth.”)

These findings have recently been confirmed, as is discussed below.

 

Parturition-Season Extends to Nearly Year-Round When a Herd Is Treated with PZP

A longitudinal study by Ransom, Hobbs, and Bruemmer (2013) of three herds currently being managed by PZP — Little Book Cliffs (Colorado), McCullough Peaks (Wyoming), and Pryor Mountain (Montana) — found a prolonged parturition-season — it lasted 341 days. Ransom et al.’s finding of a nearly year-round birthing season supports the earlier finding by Nettles (1997). Thus, during its period of potential reversibility, PZP’s effects wear off unpredictably. Out-of-season births put the life of both the mare and the foal in jeopardy. Nature designed the equine birthing-season to occur in Spring, not year-round, and certainly not in the dead of Winter.

Included as a reference to the EA? Yes, but EA is dismissive of its findings.

 

Prolonged Delay in Recovery of Fertility

The same longitudinal study by Ransom et al. found that, after suspension of PZP, there was a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recovered their fertility. What this means is that it takes that long, on average, for the ovaries to heal, to clear out all those cysts, and to regain some degree of normal hormonal function.

The question is: How is the delay in recovery-of-fertility addressed by BLM management practices? Answer: BLM ignores it. For instance, BLM currently administers PZP to Pryor Mountain’s fillies and mares starting at age 1½ — whom BLM artfully described in the Environmental Assessment as fillies “becoming two year olds” — through age four. Thus, these fillies and mares receive intentional treatments for four consecutive years before being allowed the privilege of reproductive potentiality. Per Ransom et al.’s study, the Pryor Mountain fillies and mares would be expected to need 1,645.2 days (4.51 years) to regain reproductive capacity. But BLM gives the Pryor Mountain mares only 5 years off PZP before they are put back on it again — for the rest of their life. Thus, these fillies and mares might have just a 6-month window — at best — in which to conceive. Due to the unpredictable timing of PZP’s wearing off, for some mares that window of fertility will close before they get a chance to produce a foal. Those mares’ genetic contribution will be zero.

As if the above scenario were not bad enough, PZP’s manufacturer conceded that it could take up to 8 years to recover fertility after just 3 consecutive PZP treatments.

 

Ransom Advises Proceeding with Caution regarding PZP

The Ransom et al. study warned:

Humans are increasingly attempting to manage the planet’s wildlife and habitats with new tools that are often not fully understood. The transient nature of the immunocontraceptive PZP can manifest into extraordinary persistence of infertility with repeated vaccinations, and ultimately can alter birth phenology in horses. This persistence may be of benefit for managing overabundant wildlife, but also suggests caution for use in small refugia or breeding facilities maintained for repatriation of rare species.

Because BLM keeps virtually all of the herds — including those of the Antelope and Triple B Complexes — at levels below minimum-viable population (MVP) per the IUCN, these herds qualify as “small refugia.”

 

Ransom’s Exclusion of Seven Mares Evidences PZP’s Non-Effect on Immunocompromised Mares

In the “Data Collection” methodology section of the Ransom et al. report, the authors advised:

We omitted data for one female from the Little Book Cliffs and six females from McCullough Peaks because they produced offspring in every treatment year and thus were never effectively contracepted.

This fact is important because it evidences PZP’s lack-of-efficacy on immunocompromised fillies and mares.

To review: Because PZP activates the immune system, mares with naturally-low or depressed immune function do not “respond” to the treatment. It’s as if they had been injected with saline — their immune system is so weak that it does not react to the PZP by producing antibodies. The good news is such mares’ ovaries are saved from PZP’s destructive effects. The bad news is that these mares continue to become pregnant year after year, producing foals that will also tend to inherit low immune-function. Over time, the herd will become populated with more such low-immune horses because those with strong immunity get sterilized. Thus, PZP selects for horses with low immune function, which is bad for a herd in the long term. Even a routine infection could spread quickly and wipe out a population of horses or burros with weak immune-function. If the goal is to preserve a herd, the use of PZP constitutes a worst management-practice.

 

Three PZP Injections Can Trigger Sterility in Mares, or Just One Shot in Fillies Before Puberty

Disturbingly, another recent study on PZP (Knight & Rubenstein, 2014) found that ” … three or more consecutive years of treatment or administration of the first dose before sexual maturity may have triggered infertility in some mares.

These findings are particularly troubling. They suggest that, actually, only two consecutive PZP-treatments may be reversible. Except, that is, in the case of fillies who have not yet reached puberty — they could be sterilized by just one injection. For instance, the Pryor Mountain fillies’ PZP treatments begin when they are just 1½ years old. They may not have reached puberty when they are initially treated. And as we shall see later in this report, that first shot of PZP may not be their first shot of PZP.

Included as a reference to the EA? No.

 

Researchers Again Express Concerns about the Abnormal Life-Spans of Sterilized Mares

Returning to the subject Knight & Rubenstein study, the researchers warned:

Inducing sterility, while relieving the mares from the energetic costs of lactation and reducing the stress from harem switching, may have unintended consequences on population dynamics by increasing longevity and eliminating the mares’ ability to contribute genetically.

Knight & Rubenstein’s concerns support those of Gray & Cameron, who also questioned the supposed benefit of sterile mares’ extended life-spans. The abnormal numbers of aged, sterile mares count for census-purposes; but their presence disadvantages the younger horses, who become targeted for removal in order for BoLM to achieve arbitrary management levels. Further, such mares no longer belong to the viable gene-pool.

 

PZP’s Destructive Antibodies Are Transmitted via the Placenta and Mother’s Milk

It gets worse. Sacco, Subramanian, Yurewicz (1981) reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques.

These findings were disclosed in 1981 — 35 years ago. PZP’s manufacturer must have known about this dangerous effect, and certainly BLM should have investigated on its own whether there was any risk to the unborn or the nursing foal. Yet, the manufacturer continued to insist that there was no danger to the foal, whether born or unborn. Indeed, the EA recites the manufacturer’s claim in that regard. And in fact, BLM regularly administers PZP to lactating mares, who transfer the destructive antibodies to their foal via mother’s milk.

Fillies whose dams were injected with PZP while nursing will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when those same fillies are injected later, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized while nursing, the treatment having been received prior to puberty, about which Knight & Rubenstein warned.

Likewise, if the Antelope and Triple B mares were to be injected while nursing, their filly-foals would have PZP antibodies inflaming their little ovaries. Subsequent injections could easily sterilize them in one shot, especially if given prior to puberty.

Included as a reference to the EA? Yes, but findings discounted.

 

PZP Continues the Use of Roundups and Removals

If the promise of PZP were true — if PZP really did eliminate the need to roundup and remove “excess” wild horses from the range — gathers and removals would have ended long ago in the Pryor Mountain Wild Horse Range, where PZP has been in use for approximately two decades. Yet removals are scheduled there with regularity every 3 years, the latest one in 2015.

But evidently every 3 years, in BLM’s mind, wasn’t often-enough. BLM announced plans to conduct removals every year in the Pryor Mountains despite recently-intensified PZP-treatments. Friends of Animals, a renowned animal-advocacy organization that opposes PZP, sued to prevent BLM from initiating the accelerated schedule of gathers. Friends of Animals prevailed, and the annual removals were blocked. The Court directed BLM to fulfill its commitments to reevaluate the Pryor Mountain AML. [25 and 32]

As the EA proposes, the Antelope and Triple B Complexes’ herd would be rounded up in order to inject / re-inject the mares. Roundups are stressful on wild horses and costly to taxpayers. The better and no-cost population-control method is predation by mountain lions, bears, coyotes, and perhaps even reintroduced wolves.

Risks to Humans Who Administer PZP Injections

For BLM staff, contractors, and volunteers who inject wild horses with PZP, EPA’s Pesticide Fact Sheet 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.

However, EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …

Pregnant women of the reason why it is so important that they strictly avoid PZP — because PZP’s antibodies cross the placenta and cross-react with and bind to an unborn female child’s own little zonae pellucidae. The baby-girl could be “anti-vaccinated” with PZP and even sterilized before birth;

EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …

Lactating women to avoid PZP and why — because PZP’s destructive antibodies would be passed along to a nursing female child via mother’s milk. The baby-girl could be “anti-vaccinated” with PZP and possibly sterilized simply from nursing.

EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …

All women of the reason why to avoid PZP — due to the risk of ovarian dystrophy, oophoritis, ovarian cysts, depressed estrogen and elevated testosterone-levels — in addition to infertility and, potentially, sterility — from unintentional self-injection.

EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures further fail to emphasize the magnitude of the risk — the PZP-in-question is a dose meant for a horse.

 

Mandate to Practice Scientific Integrity

Let us return to the Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct, which 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.

In the EA, BoLM has omitted independent scientific findings about PZP’s adverse effects and unintended consequences. Instead, BLM continues to rely almost exclusively on the manufacturer’s claims regarding PZP’s safety for use on horses or burros and for handling by humans. BLM is thus non-compliant with the Policy and malfeasant in its responsibilities to protect staff, contractors, volunteers, and the wild horses.

 

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

The manufacturer of PZP — a partner to BLM, but since deceased — misrepresented the pesticide as safe for use on animals by humans. The manufacturer knew or should have known that the former hypothesis regarding PZP’s mode-of-action had been disproved, and that PZP has dangerous side effects, safety-issues, and unintended consequences. Yet he hid and denied that information and failed to warn about PZP’s adverse effects. The manufacturer cited his own research as if it were definitive, and aggressively criticized wild-horse-and-burro advocacy groups that oppose PZP, such as Friends of Animals and Protect Mustangs, and independent researchers whose findings did not fully support his claims. Indeed, he submitted an Op-ed to The Salt Lake Tribune wherein he accused Friends of Animals and Protect Mustangs of citing “dubious and distorted” data about PZP. He belittled the research of fellow scientists whose studies on PZP yielded results somewhat different from his own. His accusations were so unreasonable that the scientists felt it necessary to submit an Op-ed in response to defend the integrity and validity of their work. The manufacturer also disparaged members of the public — one of whom was appointed to the Pennsylvania Game Commission — that expressed concerns about PZP. He dismissively accused them of “an attempt to mislead,” of “hyperbole,” of “knowingly manipulating information,” of “attempts to frighten people,” and of indulging in an “anti-intellectual approach to debates.” [35] By these actions, the manufacturer violated the DOI Code of Scientific and Scholarly Conduct.

 

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

BoLM and HSUS staff and volunteers receive their training from PZP’s manufacturer in how to handle and administer the pesticide. BoLM and HSUS are remiss in delegating the training to the manufacturer without verifying the adequacy of the instruction and the truthfulness of it. Two comments recorded recently in the media suggest that PZP’s manufacturer misled not just the public-at-large but those who received training therefrom in how to administer PZP.

Recall that the manufacturer claimed PZP is “so safe it is boring.” Independent research shows otherwise — that PZP is a powerful hormone disruptor that could sterilize a female with just one injection. If trainees believe that PZP is boringly safe, they will be less likely to protect themselves adequately from this dangerous pesticide. Indeed, many of the trainees are women and, therefore, particularly at risk. It is worrisome that the volunteers may be conducting their darting under the impression that it is perfectly safe. As evidence that such is the case, in a photograph that accompanied a recent article on PZP, a volunteer-darter is shown not wearing the required protective garb.

Another PZP supporter, who self-identified at the time as a recent completer of the PZP-darting training program conducted by the manufacturer, said in a comment posted to a news article:

I just received my FDA certification to handle and administer Native PZP. Would you be so kind to provide a link to the study you keep referencing? To my knowledge, and those teaching the Native PZP certification class, there are no side effects of the PZP produced by Dr. Kirkpatrick and his team, which is Native PZP.”

Key words: “no side effects.” It is disturbing that a person who was, no doubt, motivated by a desire to help the wild horses and burros has been disinformed regarding PZP’s safety-hazards to humans as well as to horses and burros.

Likewise, wild-horse-and-burro advocates are lulled into complacency, trusting that PZP is harmless. Of course, that is not true.

 

PZP — Conclusions about

PZP is appropriately categorized as a pesticide by the EPA. PZP “works” by tricking the immune system into attacking and destroying the ovaries. PZP has many adverse effects as well as unintended consequences. PZP presents safety-hazards to humans who handle it. PZP is a dangerous pesticide whose use is antithetical to the spirit and intent of the Wild and Free-Roaming Horses and Burros Act.

 

GONACON™ — BLM CONSIDERS DEPLOYING IT AGAINST THE HERDS

 

Gonacon™ — Yet Another Immuno-Pesticide

GonaCon™ is an EPA-registered, immuno-contraceptive pesticide. Its classification is “restricted-use” due to “non-target injection hazard.” EPA warns that “pregnant women should not be involved in handling or injecting GonaCon and that all women should be aware that accidental self-injection may cause infertility.” Children are not allowed in areas where the product is used. Please keep in mind that the GonaCon™ dose-in-question is meant for a horse.

 

GonaCon™ — Mechanism of Action

GonaCon™ causes an auto-immune disorder. Behaving like a perverted vaccine, GonaCon™ tricks the immune system into producing antibodies that destroy a female’s gonadotropin-releasing hormone (GnRH). Without GnRH, a female does not produce sex hormones, does not come into estrus, and is thus infertile. Behaviorally, courtship-rituals cease. Thus, GonaCon™ is a hormone-disruptor.

 

Gonacon™ — Link to PZP

Wild-horse-and-burro advocates who oppose the other immuno-contraceptive — PZP — will be disturbed to learn the following from the USDA-APHIS “Questions and Answers” sheet regarding GonaCon™:

After evaluating GonaCon™, the Food and Drug Administration (FDA) … approved the slaughter of pigs vaccinated with GonaCon™. Similar injectable hormone-altering products are used routinely in livestock applications.

Good grief. So, the slaughterhouse pig ovaries used to manufacture PZP may very well come from animals who were previously injected with GonaCon™ to destroy their GnRH hormone — without which the ovaries cannot produce estrogen. Those poor pigs may also have been “routinely” injected with other similar “hormone-altering products.” Then our wild horses and burros are injected with PZP, which itself causes a marked drop in estrogen after just three treatments. Surely, these hormonal atrocities constitute animal abuse.

 

Gonacon™ — Causes Long-Term Infertility

GonaCon™ is long-acting. The treatment-protocol, consisting of two injections administered 30 to 60 days apart, can cause infertility for as long as four-to-five years without the need for booster shots. However, mares would still need to be rounded up and held captive for those 30 to 60 days to administer the injections properly. If all females in a small herd were treated per the multi-year plan, it could result in an unintended consequence — a huge gap in the herd’s age-structure, because very few if any foals would have been born during that period.

 

Gonacon™ — Adverse Side-Effects, Chance of Sterilization

Although the pesticide’s effectiveness was expected to diminish over time, a 3-year study of GonaCon-treated elk revealed that the percentage of infertile females actually increased each year, finally reaching 100%. It was also noted that every one of the treated elk suffered an abscess at the injection-site. [1]

Because GonaCon™ stimulates the immune-system, it will elicit the greatest reaction — the greatest output of destructive antibodies — if a mare is blessed with healthy immune-function. Such a mare will react strongly and be contracepted quickly. But she could just as easily be sterilized. In fact, GonaCon’s™ “application instructions” warn of the chance of sterilization.

On the other hand, GonaCon™ may not work at all if a mare suffers from weak immune-function. That mare’s immune system will fail to react to GonaCon™, and she will get pregnant in spite of it. Thus, over time, there is the risk of another unintended consequence ؅— selection for immuno-compromised horses.

Jenny Powers, a National Park Service wildlife veterinarian and one of three lead scientists who participated in the elk research referenced above commented:

“Some things are meant to be wild,” Powers says. “At some point, do we not want to treat them like domestic animals and be handling them? I think it’s important to point out that this is no silver bullet so that we don’t have to kill wild animals. Any time we’re manipulative with wild animals, we’re messing with natural selection.

 

GELDING — BLM WANTS TO STERILIZE HALF OF THE STALLIONS

 

Geldings Are Not Normal in Nature

Surgical sterilization would effect a permanent change in character for a wild horse. That is not natural or normal. But BLM is itching to geld, even though the EA admits that the study it cites — by Garrott and Siniff — says “not effective” unless 85% of the males are castrated, and even then, within 2 years, a new crop of males is born.

 

Gelding Would Severely Impact Genetic Diversity

No problem, BLM says. The agency would solve that by trucking in new stallions, mares, or both. Don’t be ridiculous. Herds are, by Law, to be self-sustaining, free from BLM-meddling.

 

CONCLUSIONS

 

1. BLM must make the right decision by choosing the No Action Alternative.

2. BLM must post scientific, truthful data regarding wild horses’ herd-growth rates.

3. BLM must take responsibility to provide water-sources — guzzlers — for the herds.

4. BLM needs to conduct Ecological Site Inventories to determine actual use by species.

5. BLM must conserve predators in the HMAs for a thriving, natural, ecological balance.

 

———————————————-

Sincerely,

Marybeth Devlin

———————————————-

 

REFERENCES

 

Bradshaw, Corey J.A. (2012, November 21) Essential Predators. ConservationBytes.com. Retrieved from http://conservationbytes.com/2012/11/21/essential-predators/#more-8024

Branson, David H. (no date) Current Research. USDA Agricultural Research Service Sidney, MT. Retrieved from http://www.ars.usda.gov/pandp/people/people.htm?personid=601

Bunge, Jacob. (2016, August 28) “They Shoot Horses (With Birth-Control Darts), Don’t They?” Wall Street Journal. Retrieved from http://www.wsj.com/articles/they-shoot-horses-with-birth-control-darts-dont-they-1472415126

Clabby, Catherine. (2010, January-February) A Magic Number? American Scientist. Retrieved from http://www.americanscientist.org/issues/pub/a-magic-number/

Curtis PD, Richmond ME, Miller LA, Quimby FW. (2007) Pathophysiology of white-tailed deer vaccinated with porcine zona pellucida immunocontraceptive. Vaccine. 2007 Jun 6;25(23):4623-30. Epub 2007 Apr 11. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/17475371

Dayton, Kelsey. (2016, March 18) Grasshoppers thrive on the warming Wyoming range. WyoFile. Retrieved from http://www.wyofile.com/column/grasshoppers-thrive-warming-wyoming-range/?utm_source=newsletter&utm_medium=email&utm_campaign=weeklynewsletter

Duncan, Patrick (Editor). 1992. Zebras, Asses, and Horses: An Action Plan for the Conservation of Wild Equids. International Union for the Conservation of Nature and Natural Resources. Retrieved from http://data.iucn.org/dbtw-wpd/edocs/1992-043.pdf

EquiMed staff. (2010, March 13) Equine Reproductive Maturity in Mares and Stallions. Puberty in Equines. Retrieved from http://equimed.com/health-centers/reproductive-care/articles/equine-reproductive-maturity-in-mares-and-stallions

EWCS. (2015, November 10). Re: “Contraceptive could reduce taxpayer costs for wild horses.” Retrieved from http://wyomingpublicmedia.org/post/contraceptive-could-reduce-taxpayer-costs-wild-horses#comment-2352628323

Federal Register Volume 79, Number 163 (Friday, August 22, 2014). Notices. Pages 49802-49803. Renewal of Approved Information Collection. AGENCY: Bureau of Land Management, Interior. Concerning a number of data-collection documents, including Form 4130-5, Actual Grazing Use Report. OMB Control Number: 1004-0041. Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2014-08-22/html/2014-20049.htm

Ferguson, Mike. (2015, June 4) “Police called as group protests wild horse contraceptives.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/montana/police-called-as-group-protests-wild-horse-contraceptives/article_81462303-e128-5ee8-a7ef-2c8b098450f6.html

Goldfarb, Ben. (2015, April 23) Searching for the best dog to save livestock — and wildlife. High Country News. Retrieved from https://www.hcn.org/articles/searching-for-the-best-dog-to-save-livestock-and-wildlife

Gray, M.E. and Cameron, E.Z. (2010) Does contraceptive treatment in wildlife result in side effects? A review of quantitative and anecdotal evidence. Reproduction 139, 45-55. Online publication date: 1-Jan-2010. Retrieved from http://www.reproduction-online.org/content/139/1/45.full

Gregg, Kathleen, LeBlanc, Lisa, and Johnston, Jesica. (2014) Wild Horse Population Growth. Retrieved from http://protectmustangs.org/wp-content/uploads/2014/04/PM-Population-Growth-4.25.14-FINAL.pdf

Hanselka CW, Lyons R, and Teague R. (2002, October) Patch Grazing and Sustainable Rangeland Production. AgriLIfe Communications and Marketing, Texas A&M University System. Retrieved from http://www1.foragebeef.ca/$Foragebeef/frgebeef.nsf/all/frg30/$FILE/rangedistributionpatch.pdf

Information Quality Act. Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106-554, H.R. 5658). 44 USC § 3504 (d-h) and § 3516 (a-b). Retrieved from http://www.archives.gov/about/laws/fed-information-policy.html#admin — and from — http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title44-section3516&num=0&edition=prelim

Johnson, Clair. (2016, August 4) “Judge rules for wild horse advocacy group in BLM suit.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/judge-rules-for-wild-horse-advocacy-group-in-blm-suit/article_08c938df-2723-5d87-8d40-8ef4814a6be8.html

Kaur, Kiranjeet and Prabha, Vijay. (2014) “Immunocontraceptives: New Approaches to Fertility Control,” BioMed Research International, vol. 2014, Article ID 868196, 15 pages, 2014. doi:10.1155/2014/868196. Retrieved from http://downloads.hindawi.com/journals/bmri/2014/868196.pdf

Keller, Larry. (2011, May 17) To shoot, or not to shoot, at Rocky Mountain NP. High Country News. Retrieved from http://www.hcn.org/blogs/range/to-shoot-or-not-to-shoot-at-rocky-mountain-np

Kirkpatrick, J. F., I. K. M. Liu, J. W. Turner, Jr., R. Naugle, and R. Keiper. 1992a. Long-term effects of porcine zonae pellucidae immunocontraception on ovarian function of feral horses (Equus caballus). J. Reprod. Fert. 94:437-444. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/1317449

Kirkpatrick, Jay. 2007. “Response to PA [Pennsylvania] Game Commission.” Posted on PNC’s Wildlife Forever Home Page. Retrieved from http://www.pzpinfo.org/home.html

Kirkpatrick, Jay F. (2015, May 16). Op-ed: Wild-horse contraceptives are based on sound science. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2517266-155/op-ed-wild-horse-contraceptives-are-based-on?fullpage=1

Knight, Colleen M., Rubenstein, Daniel I. 2014. The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus). Princeton University Thesis, Ecology and Evolutionary Biology. Retrieved from http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p

McDonnell, Sue. (No date) “Rolling Along. Why Do Horses Roll?” Havemeyer Equine Behavior Lab, Penn Vet / New Bolton Center, School of Veterinary Medicine, University of Pennsylvania. Retrieved from http://research.vet.upenn.edu/HavemeyerEquineBehaviorLabHomePage/HavemeyerEquineBehaviorClinic/FrequentlyAskedBehaviorQuestions/WhydoHorsesRoll/tabid/2988/Default.aspx

McGrath, Matt. (2011, September 1) “Deer ‘pill’ curbs aggressive mating.” BBC News. Retrieved from http://www.bbc.com/news/science-environment-14744811

McNamee, Gregory. 2015. “Wolves in Arizona: The Return of El Lobo Southwestern Wolves Make Their Troubled Way Home.” DesertUSA. Retrieved from http://www.desertusa.com/desert-arizona/wolf-arizona.html

Nettles, Victor F. (1997) Potential consequences and problems with wildlife contraceptives. Reproduction, Fertility and Development 9(1) 137 – 144. Accessed full pdf text via purchase of a copy from Csiro Publishing. Retrieved from http://www.publish.csiro.au/paper/R96054.htm

Nuñez, Cassandra, Jim Adelman and Dan Rubenstein. (2015, July 3). Op-ed: Wild horse contraception not without unintended consequences. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2653298-155/op-ed-wild-horse-contraception-not-without

PCOS Foundation. (2015) What Causes PCOS? Retrieved from http://www.pcosfoundation.org/what-is-pcos

PNC, Inc. (Pity Not Cruelty). PZP FAQs. (2006) “Frequently Asked Questions on Immunocontraception.” (Special thanks to Jay Kirkpatrick and Rick Naugle for additions and corrections). Retrieved from http://www.pzpinfo.org/pzp_faqs.html

Prettyman, Brett. (2015, January 26) “Jackrabbits are a bigger problem for cattle than bison in Utah’s Henry Mountains, USU study says.” The Salt Lake Tribune. Retrieved from http://www.sltrib.com/news/2080640-155/usu-study-jackrabbits-are-a-bigger?fullpage=1

Raab. Lauren. (2015, May 31) “120,000 endangered saiga antelopes die mysteriously in Kazakhstan.” Los Angeles Times. Retrieved from http://www.latimes.com/science/sciencenow/la-sci-sn-saiga-antelope-die-off-20150531-story.html

Ranglack, Dustin H., Durham, Susan, du Toit, Johan T. (April 2015) Competition on the range: science vs. perception in a bison–cattle conflict in the western USA. Journal of Applied Ecology. Retrieved from http://onlinelibrary.wiley.com/doi/10.1111/1365-2664.12386/full

Ransom JI, Hobbs NT, Bruemmer J (2013) Contraception Can Lead to Trophic Asynchrony between Birth Pulse and Resources. PLoS ONE 8(1): e54972. doi:10.1371/journal.pone.0054972. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/23383018

Runyon, Luke. (2013, October 8) The long, slow decline of the U.S. sheep industry. Harvest Public Media. Retrieved from http://harvestpublicmedia.org/article/long-slow-decline-us-sheep-industry

Sacco AG, Subramanian MG, Yurewicz EC. (1981) Passage of zona antibodies via placenta and milk following active immunization of female mice with porcine zonae pellucidae. J Reprod Immunol. 1981 Dec;3(6):313-22. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/7328557

Stachowicz, John J. (2001) Mutualism, Facilitation, and the Structure of Ecological Communities. BioScience (2001) 51 (3): 235-246. doi: 10.1641/0006-3568(2001)051[0235:MFATSO]2.0.CO;2. Retrieved from http://bioscience.oxfordjournals.org/content/51/3/235.full

Traill LW, Bradshaw CJA, Brook BW. (2007) Minimum viable population size: A meta-analysis of 30 years of published estimates. Elsevier Ltd. Retrieved from https://coreybradshaw.files.wordpress.com/2011/03/traill-et-al-2007-biol-conserv.pdf

Tung K, Agersborg S, Bagavant H, Garza K, Wei K. (2002) Autoimmune ovarian disease induced by immunization with zona pellucida (ZP3) peptide. Curr Protoc Immunol. 2002 Aug;Chapter 15:Unit 15.17. doi:10.1002/0471142735.im1517s49. Retrieved from http://www.ncbi.nlm.nih.gove/pubmed/18432873

United States Department of Agriculture. 2016 Rangeland Grasshopper Hazard. Map. Retrieved from http://www.sidney.ars.usda.gov/grasshopper/Extras/map16.htm

United States Department of Agriculture. 2016 Rangeland Grasshopper Hazard with Mormon Cricket Presence. Map. Retrieved from http://www.sidney.ars.usda.gov/grasshopper/Extras/2016GHwMC.htm

USDA-APHIS. (2007, February). “GonaCon™—Birth Control for Deer: Questions and Answers.” Retrieved from https://www.aphis.usda.gov/wildlife_damage/nwrc/downloads/faq_gonacon_07.pdf

United States Department of the Interior. Bureau of Land Management. Actual Grazing Use Report. Form 4130-5. OMB NO.1004-0041. Expires October 31, 2017. Retrieved from http://www.blm.gov/style/medialib/blm/noc/business/eforms.Par.2064.File.dat/4130-005.pdf

United States Department of the Interior. Bureau of Land Management. Technical Reference TR 1734-03. Utilization Studies and Residual Measurements. Retrieved from http://www.ntc.blm.gov/krc/viewresource.php?courseID=286

United States Department of the Interior. Bureau of Land Management. Technical Reference TR 1734-7, Ecological Site Inventory. Retrieved from http://www.blm.gov/nstc/library/1734-7direct.html

U.S. Department of the Interior. Bureau of Land Management. Wild Horse and Burro Program Data. Retrieved from https://www.blm.gov/programs/wild-horse-and-burro

United States Department of the Interior. Data Quality Guidelines. Originally retrieved from this link, which has either been moved or been taken down. http://www.blm.gov/style/medialib/blm/national/national_page.Par.7549.File.dat/guidelines.pdf

United States Department of the Interior. Integrity of Scientific and Scholarly Activities Policy. Code of Conduct. Retrieved from https://www.doi.gov/scientificintegrity

United States Department of the Interior. (2015) Review of Ungulate Fertility Control in the National Park Service. Retrieved from https://www.nature.nps.gov/biology/wildlifehealth/Documents/Ungulate%20Fertility%20Report_09242015.pdf — and then —
https://www.nps.gov/orgs/1103/upload/Ungulate-Fertility-Report_09242015.pdf

United States Environmental Protection Agency. (2009) Pesticide Fact Sheet. Mammalian Gonadotropin Releasing Hormone (GnRH). Retrieved from http://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-116800_01-Sep-09.pdf

United States Environmental Protection Agency. Office of Chemical Safety and Pollution Prevention. Pesticide Fact Sheet. Porcine Zona Pellucida (PZP). New Chemical. Nonfood Use. January 2012. Retrieved from
http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

U.S. Department of Health and Human Services. National Institutes of Health. Endocrine Disruptors. Retrieved from http://www.niehs.nih.gov/health/topics/agents/endocrine/

U. S. Fish & Wildlife Service. Ecological Services, Southwest Region. The Mexican Wolf Recovery Program. Retrieved from https://www.fws.gov/southwest/es/mexicanwolf/BRWRP_home.cfm

U.S. National Library of Medicine. National Institutes of Health. Ovarian overproduction of androgens. Retrieved from https://www.nlm.nih.gov/medlineplus/ency/article/001165.htm

Varras M, Anastasiadis A, Panelos J, Balassi E, Demou A, Akrivis CH. (2013) Autoimmune oophoritis: Clinical presentation of an unusual clinical entity. OA Case Reports 2013 Jan 31;2(1):7. Retrieved from http://www.oapublishinglondon.com/article/369#

 

Protect Mustangs is a 501(c)3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org



Perverted Darting with Pesticide PZP

10 things you need to know about Pesticide PZP

1. PZP — The Pesticide: PZP is an EPA-registered pesticide manufactured from the ovaries of slaughtered pigs. Some persons argue that, because PZP does not kill the mare, it is not really a “pesticide.” Actually, PZP does kill. Stillbirths are associated with the pesticide’s use, meaning that some of its supposed contraceptive effects are actually feticidal.. In addition, over the long term, PZP weakens a herd immunologically, putting it at risk for eventual or even sudden extinction.

2. PZP — The Disproved Hypothesis: PZP’s manufacturer promoted the product as generating antibodies that “block sperm attachment.” But that marketing-hype was merely an untested hypothesis postulated three decades ago. Independent researchers found that PZP has a different effect, and many adverse effects.

3. PZP — The Actual Mode-of-Action: Behaving like a perverted vaccine, PZP tricks the mare’s immune system into making antibodies that cause ovarian dystrophy, autoimmune oophoritis, ovarian cysts, and premature ovarian failure. PZP quickly sterilizes mares that have a strong immune system but has no effect on those suffering from weak immunity. Thus, PZP both works and doesn’t work but, in the long run, selects for poor immune function. Weak immunity = weak resistance to infection, which could quickly wipe out a herd. PZP also affects the foals. If a mare is pregnant or nursing when darted, PZP antibodies are transferred to her offspring via the placenta and her milk. So, inadvertently, unborn and newborn foals receive a dose or two of the pesticide when their dams are injected.

4. PZP — The Danger to Humans: PZP is a powerful endocrine-disruptor. It causes a sharp drop in estrogen levels. Unfortunately, because the manufacturer misrepresented PZP as “so safe it is boring,” volunteer-darters have become lax in following safety-precautions. Accidental self-injection could result in severe adverse effects because the dose-in-question is sized for a horse.

5. PZP — The Year-Round Birthing-Season: A longitudinal study (Ransom et al. 2013) of three herds currently under treatment with PZP found that the the birthing-season lasts virtually year-round (341 days). Out-of-season births put the life of mares and their foals in jeopardy. Nature designed foals to be born in Spring, not year-round, and certainly not in Winter.

6. PZP — Prolonged Delay in Recovery of Fertility: Ransom et al. also found that, after suspension of PZP, it takes more than a year per each year-of-treatment before mares recover their fertility. PZP’s manufacturer conceded that it could take up to 8 years to recover fertility after just 3 consecutive years of PZP treatment.

7. PZP — Scientists Say Proceed with Caution: Ransom et al. warned: “The transient nature of … PZP can manifest into extraordinary persistence of infertility with repeated vaccinations, and ultimately can alter birth phenology in horses. This persistence … suggests caution for use in small refugia ….”

8. PZP — Contraindicated for Tiny, Isolated Herds: Several years ago, BLM convened a meeting of scientists on the topic of minimum herd-size for genetic fitness. Conclusion: “Smaller, isolated populations (<200 total census size) are particularly vulnerable ….” And that’s without PZP in the mix.

9. Slow Herd-Growth: Per independent research, wild-horse herds increase at a rate of only 5% a year; and wild-burro herds, just 2%. Such slow growth does not warrant pesticide treatments administered en masse every year. Eventual sterilization is inevitable, with extinction of the herd over the long term.

10. Predators: The right way to right-size the wild-horse population is Nature’s way — predators. But those predators — mountain lions, bears, wolves, and coyotes — are persecuted mercilessly. Wildlife Services exterminates what trophy-hunters don’t shoot. Predators help the herds by favoring survival-of-the-fittest and the best genetic adaptations. Predators are the “no-cost” solution.

by Marybeth Devlin
Wild Horse Advocate

This mare waits in the alley before being led into the chute where her age and body condition will be checked. After being treated with the PZP fertility control agent, this mare will be released back to the Owyhee HMA.

Protect Mustangs is a 501(c)3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org



Expose BLM’s backdoor to slaughter!

How many are left?

When I first heard about wild horses in the Pryor Mountains being brutally rounded up in 2009, Nevada was home to 80% of America’s federally protected wild horses. Wyoming was the next state who had the most wild horses and California only had a few herds left.

Today Nevada has only about 50% of America’s wild horses and I believe California now has the second largest population. In Wyoming, the feds are proposing to remove another 1,029 wild horses. One of their former congresswomen even wanted to kill them!

The Department of Interior is giving away grants for university students in Wyoming to cruelly collar mares from the Adobe Town herd. They want to find out where they hide in the desert. Then the agency in charge of protecting them can find them and wipe out the ancient Adobe Town mustangs too.

Invasive cruelty against America’s wild horses must stop. The law states they are to be left alone and not be abused. How dare they collar wild horses! This harassment will cause deaths and these deaths will be hidden. . . Hidden like the others.

The deception continues. People who once spoke out against mustang cruelty back in 2009 are now mute because they are playing a political game to get what they want. I’m disgusted and will never sell out. Never.

In 8 years of roundups, experiments, removals, pesticides for “birth control”, 3-Strikes to sell truckloads for slaughter and taxpayer-funded propaganda campaigns, the Bureau of Land Management (BLM) has decimated America’s wild herds on public land. Now wild horses are in danger of dying out because they lack genetic diversity, population and strength. Natural selection is being ruined by the “one foal” on the range breeding programs run by Pesticide PZP darters in partnership with BLM. Remember Pesticide PZP sterilizes wild horses after multiple use. Yes sterilizes. The public is fooled by those trusted to manage the last American wild horses and their nonprofit partners peddling for donations to “help” them.

Overpopulation is a lie. Population control is based on a false premise that wild horses are “pests”. Follow the money behind population control experiments and the donation cash cow for the nonprofit who claims they solved the wild horse “problem”.

Know the truth: Wild horses are native wildlife, period. Cattle and sheep are not.

Right now we are witnessing a wild horse and burro underpopulation crisis in the West. This is our last chance to help America’s wild horses and burros survive the ugly greed wiping out our herds. It’s time to expose the overpopulation lies. It’s time to expose all the trucks sneaking wild stallions to slaughter over the borders. . . expose the lies that there are “too many” wild horses on public land. Count them.

The truth must be exposed by your elected officials now before it’s too late.

I urge you to sign and share the petition to investigate the wild horse and burro count in captivity and freedom: https://www.change.org/p/u-s-senate-investigate-the-wild-horse-burro-count-in-captivity-and-freedom Join us to double the numbers on the petition in the next 7 days!

America won’t be the same without our iconic wild symbols of liberty running freely on public land . . . The wild herds are to be protected by the law–but because of the greed for resources (oil, gas, livestock grazing, etc.) the law is being twisted, lies are spread in the media and spoon-fed to your elected officials acting on your behalf.

It’s time to know how many wild horses and burros are really left so we can all stand up to protect them.

Prayers and miracles are needed right now. Please contact me if you can help with a lawsuit to save America’s last wild horses and burros.

For the Wild Ones,
Anne Novak
Volunteer Executive Director
Protect Mustangs

Contact@ProtectMustangs.org

Protect Mustangs is a 501(c)3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org



Wild horses impacted in BoLM’s landscape project (Carson district)

PM Photo WY © Stephaie Thomson

Please comment to help the wild horses stay on public land and stop the BoLM from using herbicides

From a BoLM press release:

Carson City, Nev. – The Bureau of Land Management (BoLM), Carson City District, Stillwater Field Office, has completed an Environmental Assessment (EA) for the Cow Canyon, Clan Alpine, and Dixie Valley Allotments Landscape Project. The BoLM is also seeking public input under Section 106 of the National Historic Preservation Act for the Project. This includes seeking information and identifying historic properties in our near the Project area. Public comments will be accepted through September 26, 2016.

The EA analyzes seven alternatives that include proposals for livestock grazing permit renewals, range improvements, wild horse management, community mineral material pit designation, invasive, nonnative and noxious weed treatments, interim visual resource management class establishment and adaptive management.  The alternatives include changes in season of use proposals, reductions in livestock numbers proposals, no grazing and the no action alternative (status quo).

The EA and associated documents are available on the Project webpage at: http://bit.ly/2blRZFp  during the 30-day comment period.  Please send written comments to Linda Appel, Project Lead at the address in the letterhead, via fax at (775) 885-6147 or via email to: blm_nv_ccdgrazingea@blm.gov. Comments should include “CCD Landscape Project EA” in the subject line. If you have any questions, please contact Linda Appel or Angelica Rose at 775-885-6000 or at the above address.  For input or questions regarding historic properties please contact Jason Wright at 775-885-6015 or the address in the letterhead above.

-BLM-

 

#URGENT: File a complaint against Nazi-like population control experiments on America’s wild horses!

The clock is ticking. Oregon State University isn’t stopping. They are going ahead with their Nazi-like population control experiments on wild mares and a lot of them are pregnant! The experiments were encouraged by a bunch of sick pro-slaughter, pro-cattle activists that work in darkness to bring the “final solutions” to America’s underpopulated wild horses and burros. These people have no soul. They have no empathy for the suffering these horrible experiments will inflict on WILD horses . . . wild animals . . . wildlife . . . that the law was supposed to protect.

Take action right now and fill out this Animal Welfare Complaint: https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/complaint-form. Mention that the procedures used to sterilize wild horses in the experiments at Oregon State University and elsewhere are cruel. Let them know that wild horses are underpopulated and the basis for these heinous experiments is false. Underpopulated wild horses and burros in America don’t need population control or birth control.

America’s wild horses and burros need your help to live and survive on public land set aside for them in 1971–the public sanctuary that is open 24/7 at no charge. The wild ones need YOU to go to your elected officials’ home offices and push for their protection.

Please also send an email to your congressman/woman and your 2 senators. Their contact information is here: http://www.contactingthecongress.org/ Short handwritten letters have the most impact as elected officials see them representing the opinion of 1000 voters.

Ignore anyone who says birth control is a tool in the stupid toolbox. Who’s toolbox are they talking about?

Ignore the spin doctors claiming they are overpopulated. It’s a lie.

The Bureau of Land Management’s (BoLM) claim there are 67,000 wild horses and burros combined in all western states is based on no more than an inflated guess. The BoLM have no headcount and no evidence according to the National Academy of Sciences. Even if there were 67,000 wild horses and burros left in the wild that would be too few to survive serious changes in climate, disease and environmental disaster. Do you want to see our majestic symbols of freedom and the American spirit become extinct forever? No you don’t, so take action. Your voice counts.

Don’t get distracted from the facts:

America’s wild horses and burros are being wiped off public land because greedy people and corporations with no conscious want to exploit the wild ones’ territory for profit–big profit. These people who are out for big money need to find the win-win, respect the environment and learn to work with–not annihilate–the last free roaming wild horses and burros. After all, wild horses prevent wildfires that could hurt their money making projects (oil and gas wells, solar energy zones, mining, etc.) These people should realize cattle will never roam like wild horses do and therefore cannot replace the wild herds for fire prevention.

Stop BLM from EXPERIMENTING on wild mares!

Tell your friends, family, co-workers and neighbors what’s going on and tune into our website daily for updates on the fight to save America’s wild horses! www.ProtectMustangs.org There are a lot of ways you can help by using your voice right from your computer. If we all don’t do something now then hundreds of wild horses will be cruelly carved up in Nazi-like population control experiments to rid the land of wild horses. Our beloved wild ones have been wrongfully labelled “pests” in the Pesticide PZP EPA application. Also based on the overpopulation lie, thousands of wild horses could end up at slaughter soon if they are not all accounted for and placed in safe homes.

Your elected officials need to be contacted regularly by email, handwritten letters and in meetings to stop the abuse against wild horses and keep them living in real freedom. . . in the wild.

It’s time to send an email requesting an appointment to get your elected officials involved in protecting America’s iconic wild horses and burros. Yes really protect them–not forcibly drug them with Pesticide PZP or sterilize them.

Do you realize YOUR voices in government have been fed a bunch of lies based on a false premise from other elected officials, lobbyists and traitor “advocates” as well? Follow the money . . . Then move beyond that to real “solutions” to protect real freedom. Make your voice heard.

From the Team at Protect Mustangs
www.ProtectMustangs.org

a member for the Alliance for Wild Horses and Burros

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




Help fund NATIVE WILD HORSES™ the documentary

 

Native Wild Horses™

Please help support the documentary NATIVE WILD HORSES™, a film by Anne Novak, to educate and inspire people to stand up for America’s vanishing icons of freedom. Right now we need your help to film in Wyoming before the Bureau of Land Management roundup wipes out the Divide Basin, Adobe Town and Salt Wells herds.

Buying someone else’s Wyoming footage would be too expensive, not have our point of view and often filmmakers want to keep their footage for their exclusive use–so it’s not even an option.

You can go to our homepage at www.ProtectMustangs.org to make a donation to the documentary NATIVE WILD HORSES™ and make a difference for these magnificent wild creatures who deserve to remain forever wild and free.

We also have a tax-deductible fundraiser here http://www.gofundme.com/ejjcwo for the Wyoming leg of the shoot. Everyone who donates $200 and up will be thanked in the credits because we are so grateful for your support of the documentary.

America’s wild horses deserve to be seen and protected forever.

 

Petition to grant a 10-year moratorium on wild horse roundups for recovery and studies

OLYMPUS DIGITAL CAMERA

Wyoming, March 2014: BLM’s stealth roundup of 41 American wild horses

The issue

Science must start guiding the management policy of Americas wild horses and burros on public land.

It’s time for real science for real solutions.

We need scientific studies on population, migration, holistic land management and more before the government continues to roundup or tamper with America’s equine herds using permanent/temporary sterilization or kill them. We support wild horse and burro recovery on public land.

Right now the feds are managing our indigenous wild horses and burros to extinction. They want to aggressively sterilize the herds. There is “no evidence” of overpopulation according to the National Academy of Sciences 2013 report.

Together we can turn this around.

The Petition

To:
Sally Jewell, Secretary of Interior
President of the United States
U.S. Senate
U.S. House of Representatives
Rep. Tom Rooney, Florida-17
Sen. Tom Harkin, Iowa
Sen. Dick Durbin, Illinois
Sen. Mary Landrieu, Louisiana
Sen. Barbara Mikulski, Maryland
Sen. Barbara Boxer, California
Rep. Nancy Pelosi, California-12
Rep. Barbara Lee, California-13
Sen. Mark Kirk, Illinois
Rep. Raul Grijalva, Arizona-03
Sen. Dianne Feinstein, California
Rep. Debbie Wasserman Schultz, Florida-23
Rep. John Garamendi, California-03
Science must start guiding the management policy of America’s wild horses and burros on public land.

It’s time for real science for real solutions.

We need scientific studies on population, migration, holistic land management and more before the government continues to roundup or tamper with America’s equine herds using permanent/temporary sterilization or kill them.

Right now the feds are managing our indigenous wild horses and burros to extinction. They want to aggressively sterilize the herds. There is “no evidence” of overpopulation according to the National Academy of Sciences 2013 report.

We support wild horse and burro recovery on public land and request your help.

Sincerely,
[Your name]

Please sign and share the petition now. Here is the link: https://www.change.org/p/sally-jewell-urgent-grant-a-10-year-moratorium-on-wild-horse-roundups-for-recovery-and-studies

Wild Horses as Native North American Wildlife

Wild Horses @ Peace (Photo ©Anne Novak, all rights reserved.)

Wild Horses @ Peace (Photo ©Anne Novak, all rights reserved.)

by Jay F. Kirkpatrick, Ph.D. and Patricia M. Fazio, Ph.D. (Revised January 2010)

© 2003‐2010, Drs. Jay F. Kirkpatrick and Patricia M. Fazio. All Rights Reserved.

Are wild horses truly “wild,” as an indigenous species in North America, or are they “feral weeds” – barnyard escapees, far removed genetically from their prehistoric ancestors? The question at hand is, therefore, whether or not modern horses, Equus caballus, should be considered native wildlife.

The question is legitimate, and the answer important. In North America, the wild horse is often labeled as a non‐native, or even an exotic species, by most federal or state agencies dealing with wildlife management, such as the National Park Service, U.S. Fish and Wildlife Service, and the Bureau of Land Management. The legal mandate for many of these agencies is to protect native wildlife and prevent non‐native species from causing harmful effects on the general ecology of the land. Thus, management is often directed at total eradication, or at least minimal numbers. If the idea that wild horses were, indeed, native wildlife, a great many current management approaches might be compromised. Thus, the rationale for examining this proposition, that the horse is a native or non-native species, is significant.

The genus Equus, which includes modern horses, zebras, and asses, is the only surviving genus in a once diverse family of horses that included 27 genera. The precise date of origin for the genus Equus is unknown, but evidence documents the dispersal of Equus from North America to Eurasia approximately 2‐3 million years ago and a possible origin at about 3.4‐3.9 million years ago. Following this original emigration, several extinctions occurred in North America, with additional migrations to Asia (presumably across the Bering Land Bridge), and return migrations back to North America, over time. The last North American extinction probably occurred between 13,000 and 11,000 years ago (Fazio 1995), although more recent extinctions for horses have been suggested. Dr. Ross MacPhee, Curator of Mammalogy at the American Museum of Natural History, and colleagues, have dated the existence of woolly mammoths and horses in North America to as recent as 7,600 years ago. Had it not been for previous westward migration, over the 2 Bering Land Bridge, into northwestern Russia (Siberia) and Asia, the horse would have faced complete extinction. However, Equus survived and spread to all continents of the globe, except Australia and Antarctica.

In 1493, on Columbus’ second voyage to the Americas, Spanish horses, representing E. caballus, were brought back to North America, first in the Virgin Islands, and, in 1519, they were reintroduced on the continent, in modern‐day Mexico, from where they radiated throughout the American Great Plains, after escape from their owners or by pilfering (Fazio 1995).

Critics of the idea that the North American wild horse is a native animal, using only selected paleontological data, assert that the species, E. caballus (or the caballoid horse), which was introduced in 1519, was a different species from that which disappeared between 13,000‐11,000 years before. Herein lies the crux of the debate. However, neither paleontological opinion nor modern molecular genetics support the contention that the modern horse in North America is non‐native.

Equus, a monophyletic taxon, is first represented in the North American fossil record about four million years ago by E. simplicidens, and this species is directly ancestral to later Blancan species about three million years ago (Azaroli and Voorhies 1990). Azzaroli (1992) believed, again on the basis of fossil records, that E. simplicidensgave rise to the late Pliocene E. Idahoensis, and that species, in turn, gave rise to the first caballoid horses two million years ago in North America. Some migrated to Asia about one million years ago, while others, such as E. niobrarensis, remained in North America.

In North America, the divergence of E. caballus into various ecomorphotypes (breeds) included E. caballus mexicanus, or the American Periglacial Horse (also known as E. caballus laurentius Hay, or midlandensis Quinn) (Hibbard 1955). Today, we would recognize these latter two horses as breeds, but in the realm of wildlife, the term used is subspecies. By ecomorphotype, we refer to differing phenotypic or physical characteristics within the same species, caused by genetic isolation in discrete habitats. In North America, isolated lower molar teeth and a mandible from sites of the Irvingtonian age appear to be E. caballus, morphologically. Through most of the Pleistocene Epoch in North America, the commonest species of Equus were not caballines but other lineages (species) resembling zebras, hemiones, and possibly asses (McGrew 1944; Quinn, 1957). 3 Initially rare in North America, caballoid horses were associated with stenoid horses (perhaps ancestral forerunners but certainly distinct species), but between one million and 500,000 years ago, the caballoid horses replaced the stenoid horses because of climatic preferences and changes in ecological niches (Forstén 1988). By the late Pleistocene, the North American taxa that can definitely be assigned to E. caballus are E. caballus alaskae (Azzaroli 1995) and E. caballus mexicanus (Winans 1989 – using the name laurentius). Both subspecies were thought to have been derived from E. niobrarensis (Azzaroli 1995).

Thus, based on a great deal of paleontological data, the origin of E. caballus is thought to be about two million years ago, and it originated in North America. However, the determination of species divergence based on phenotype is at least modestly subjective and often fails to account for the differing ecomorphotypes within a species, described above. Purely taxonomic methodologies looked at physical form for classifying animals and plants, relying on visual observations of physical characteristics. While earlier taxonomists tried to deal with the subjectivity of choosing characters they felt would adequately describe, and thus group, genera and species, these observations were lacking in precision. Nevertheless, the more subjective paleontological data strongly suggests the origin of E. caballus somewhere between one and two million years ago.

Reclassifications are now taking place, based on the power and objectivity of molecular biology. If one considers primate evolution, for example, the molecular biologists have provided us with a completely different evolutionary pathway for humans, and they have described entirely different relationships with other primates. None of this would have been possible prior to the methodologies now available through mitochondrial‐DNA analysis.

A series of genetic analyses, carried out at the San Diego Zoo’s Center for Reproduction in Endangered Species, and based on chromosome differences (Benirschke et al. 1965) and mitochondrial genes (George and Ryder 1986) both indicate significant genetic divergence among several forms of wild E. caballus as early as 200,000‐300,000 years ago. These studies do not speak to the origins of E. caballus per se, but they do point to a great deal of genetic divergence among members of E. caballus by 200,000 to 300,000 years ago. Thus, the origin had to be earlier, but, at the very least, well before the disappearance of the horse in North America between 13,000‐11,000 years ago. 4 The relatively new (30‐year‐old) field of molecular biology, using mitochondrial‐DNA analysis, has recently revealed that the modern or caballine horse, E. caballus, is genetically equivalent to E. lambei, a horse, according to fossil records, that represented the most recent Equus species in North America prior to extinction. Not only is E. caballus genetically equivalent to E. lambei, but no evidence exists for the origin of E. caballus anywhere except North America (Forstén 1992).

According to the work of researchers from Uppsala University of the Department of Evolutionary Biology (Forstén 1992), the date of origin, based on mutation rates for mitochondrial‐DNA, for E. caballus, is set at approximately 1.7 million years ago in North America. This, of course, is very close, geologically speaking, to the 1‐2 million‐year figure presented by the interpretation of the fossil record.

Carles Vilà, also of the Department of Evolutionary Biology at Uppsala University, has corroborated Forstén’s work. Vilà et al. (2001) have shown that the origin of domestic horse lineages was extremely widespread, over time and geography, and supports the existence of the caballoid horse in North American before its disappearance, corroborating the work of Benirschke et al. (1965), George and Ryder (1995), and Hibbard (1955).

A study conducted at the Ancient Biomolecules Centre of Oxford University (Weinstock et al. 2005) also corroborates the conclusions of Forstén (1992). Despite a great deal of variability in the size of the Pleistocene equids from differing locations (mostly ecomorphotypes), the DNA evidence strongly suggests that all of the large and small caballine samples belonged to the same species. The author states, “The presence of a morphologically variable caballine species widely distributed both north and south of the North American ice sheets raises the tantalizing possibility that, in spite of many taxa named on morphological grounds, most or even all North American caballines were members of the same species.”

In another study, Kruger et al. (2005), using microsatellite data, confirms the work of Forstén (1992) but gives a wider range for the emergence of the caballoid horse, of 0.86 to 2.3 million years ago. At the latest, however, that still places the caballoid horse in North America 860,000 years ago. 5 The work of Hofreiter et al. (2001), examining the genetics of the so-called E. lambei from the permafrost of Alaska, found that the variation was within that of modern horses, which translates into E. lambeiactually being E. caballus, genetically. The molecular biology evidence is incontrovertible and indisputable, but it is also supported by the interpretation of the fossil record, as well.

Finally, very recent work (Orlando et al. 2009) that examined the evolutionary history of a variety of non‐caballine equids across four continents, found evidence for taxonomic “oversplitting” from species to generic levels. This overspitting was based primarily on late‐Pleistocene fossil remains without the benefit of molecular data. A co‐author of this study, Dr. Alan Cooper, of the Australian Centre for Ancient DNA, stated, “Overall, the new genetic results suggest that we have underestimated how much a single species can vary over time and space, and mistakenly assumed more diversity among extinct species of megafauna.”

The fact that horses were domesticated before they were reintroduced matters little from a biological viewpoint. They are the same species that originated here, and whether or not they were domesticated is quite irrelevant. Domestication altered little biology, and we can see that in the phenomenon called “going wild,” where wild horses revert to ancient behavioral patterns. Feist and McCullough (1976) dubbed this “social conservation” in his paper on behavior patterns and communication in the Pryor Mountain wild horses. The reemergence of primitive behaviors, resembling those of the plains zebra, indicated to him the shallowness of domestication in horses.

The issue of feralization and the use of the word “feral” is a human construct that has little biological meaning except in transitory behavior, usually forced on the animal in some manner. Consider this parallel. E. Przewalskii (Mongolian wild horse) disappeared from Mongolia a hundred years ago. It has survived since then in zoos. That is not domestication in the classic sense, but it is captivity, with keepers providing food and veterinarians providing health care. Then they were released during the 1990s and now repopulate their native range in Mongolia. Are they a reintroduced native species or not? And what is the difference between them and E. caballus in North America, except for the time frame and degree of captivity?

The key element in describing an animal as a native species is (1) where it originated; and (2) whether or not it co‐evolved with its habitat. Clearly, E. caballus did both, here in North American. There might be arguments about “breeds,” but there are no scientific grounds for arguments about “species.”

The non‐native, feral, and exotic designations given by agencies are not merely reflections of their failure to understand modern science but also a reflection of their desire to preserve old ways of thinking to keep alive the conflict between a species (wild horses), with no economic value anymore (by law), and the economic value of commercial livestock.

Native status for wild horses would place these animals, under law, within a new category for management considerations. As a form of wildlife, embedded with wildness, ancient behavioral patterns, and the morphology and biology of a sensitive prey species, they may finally be released from the “livestock‐gone‐loose” appellation.

Please cite as: Kirkpatrick, J.F., and P.M. Fazio. Revised January 2010. Wild Horses as Native North American Wildlife. The Science and Conservation Center, ZooMontana, Billings. 8 pages.

 

LITERATURE CITED

 

Azzaroli, A. 1990. The genus Equus in Europe. pp. 339‐356 in: European Neogene mammal chronology (E.H. Lindsay, V. Fahlbuech, and P. Mein, eds.). Plenum Press, New York.

 

Azzaroli, A. 1992. Ascent and decline of monodactyl equids: A case for prehistoric overkill. Annales Zoologica Fennici 28:151‐163.

 

Azzaroli, A. 1995. A synopsis of the Quaternary species of Equus in North America. Bollttino della Societa Paleontologica Italiana. 34:205‐221.

 

Azzaroli, A., and M.R. Voorhies. 1990. The genus Equus in North America: The Blancan species. Paleontologica Italiana 80:175‐198.

 

Benirschke K., N. Malouf, R.J. Low, and H. Heck. 1965. Chromosome compliment: Difference between Equus caballus and Equus przewalskii Polliakoff. Science 148:382‐383.

 

Fazio, P.M. 1995. ʺThe Fight to Save a Memory: Creation of the Pryor Mountain Wild Horse Range (1968) and Evolving Federal Wild Horse Protection through 7 1971,ʺ doctoral dissertation, Texas A&M University, College Station, p. 21.

 

Feist, J.D., and D.R. McCullough, Behavior Patterns and Communication in Feral Horses, Z. Tierpsychol. 41:337‐371.

 

Forstén, A. 1988. Middle Pleistocene replacement of stenoid horses by caballoid horses ecological implications. Paleogeography, Paleoclimatology, Paleoecology 65:23‐33.

 

Forstén, A. 1992. Mitochondrial‐DNA timetable and the evolution of Equus: Comparison of molecular and paleontological evidence. Ann. Zool. Fennici 28: 301‐309.

 

George, Jr., M., and O.A. Ryder. 1986. Mitochondrial DNA evolution in the genusEquus. Mol. Biol. Evol. 3:535‐546.

 

Hibbard C.W. 1955. Pleistocene vertebrates from the upper Becarra (Becarra Superior) Formation, Valley of Tequixquiac, Mexico, with notes on other Pleistocene forms. Contributions from the Museum of Paleontology, University of Michigan, 12:47‐96.

 

Hofreiter, M., Serre, D. Poinar, H.N. Kuch, M., Pääbo, S. 2001. Ancient DNA. Nature Reviews Genetics. 2(5), 353‐359.

 

Kruger et al. 2005. Phylogenetic analysis and species allocation of individual equids using microsatellite data. J. Anim. Breed. Genet. 122 (Suppl. 1):78‐86.

 

McGrew, P.O. 1944. An early Pleistocene (Blancan) fauna from Nebraska. Field Museum of Natural History, Geology Series, 9:33‐66.

 

Orlando, L. et al. 2009. Revising the recent evolutionary history of equids using ancient DNA. Proc. Nat. Acad. Sci. www.pnas.org/cai/doi/10.1073/pnas.0903672106

 

Quinn, J.H. 1957. Pleistocene Equidae of Texas. University of Texas, Bureau of Economic Geology, Report of Investigations 33:1‐51.

 

Vilà, C., J.A. Leonard, A. Götherström, S. Marklund, K. Sandberg, K. Lidén, R. K. Wayne, H. Ellegren. 2001. Widespread origins of domestic horse lineages. Science 291: 474‐477. 8 Weinstock, J.E., A. Sher Willerslev, W. Tong, S.Y.W. Ho, D. Rubnestein, J. Storer, J. Burns, L. Martin, C. Bravi, A. Prieto, D. Froese, E. Scott, L. Xulong, A. Cooper. 2005. Evolution, systematics, and the phylogeography of Pleistocene horses in the New World: a molecular perspective. PLoS Biology 3:1‐7.

 

Winans M.C. 1989. A quantitative study of North American fossil species of the genusEquus. pp. 262‐297, in: The Evolution of Perissodactyles (D.R. Prothero and R.M. Schoch, eds.). Oxford University Press, New York, NY.

 

Ω

 

Jay F. Kirkpatrick, Director, The Science and Conservation Center, ZooMontana, Billings, holds a Ph.D. in reproductive physiology from the College of Veterinary Medicine at Cornell University.

 

~

 

Patricia M. Fazio, Research Fellow, The Science and Conservation Center, ZooMontana, Billings, holds a B.S. in agriculture (animal husbandry/biology) from Cornell University, and M.S. and Ph.D. degrees in environmental history from the University of Wyoming and Texas A&M University, College Station, respectively. Her dissertation was a creation history of the Pryor Mountain Wild Horse Range, Montana/Wyoming.

 

Please note: This document is the sole intellectual property of Drs. Jay F. Kirkpatrick and Patricia M. Fazio. As such, altering of content, in any manner, is strictly prohibited. However, this article may be copied and distributed freely in hardcopy, electronic, or Website form, for educational purposes only.

 

Help Wyoming wild horses find homes away from slaughter

PM Steve Mantle

Adopt from Mantle Ranch. If you can’t adopt then share this to help the mustangs.

Steve Mantle was mentored by Brian Neubert who was mentored by Bill and Tom Dorrance.  Steve works with wild horses using natural horsemanship methods.

Steve’s ranch has a contract with BLM to adopt out wild horses. He has taken in many Wyoming horses to help them get homes. Recently he accepted many from the Rock Springs Corral that was being cleared out for the Adobe Town/Salt Wells roundup.

We recommend getting an untamed or halter-gentled wild horse from Steve and his sons.

When no one came forward to adopt Tibet, he went to Mantle Ranch where we picked him up. We had a positive experience with Steve and recommend him. Steve is a good horseman with vast knowledge who genuinely cares about the horses.

People like Steve Mantle help keep wild horses out of the slaughter pipeline but they need our help. If you or your friends can adopt one or two horses from Steve then he can help more wild horses.

Contact Mantle Ranch by email: Mantle9@WyomingWireless.com and by phone: 307-322-5799

Meet Steve and his sons:

 

 

 

Links of interest™:

Tom Dorrance: http://tomdorrance.com/

Bill Dorrance: http://www.billdorrance.com/

Ray Hunt: http://www.rayhunt.com/

Brian Neubert: http://www.bryanneubert.com/

Mantle Ranch: http://www.mantleswildhorses.com/

Remember sharing is caring.