Will There Be a Healthy Future for America’s Wild Horses and Burros IN THE WILD?

PM Helicopter Mustang Roundup

(Roundup to administer Pesticide PZP for experiments)

PZP or Reserve Design? You Decide

By Craig C. Downer, Wildlife Ecologist, Wild Horse and Burro Fund

September 24th, 2016

On September 7th, 2016, I participated in the National Wild Horse and Burro Advisory Board rangeland tour of the Antelope Valley Wild Horse Herd Management Area (HMA); and on September 8th, I again participated in this board’s official meeting at the historical Stockman’s Hotel in Elko, Nevada. Though both tour and meeting provided for some public input, these were “one slick operation” by BLM officials and certain members of the board. This event aimed to convince all board members as well as the public of a “wild horse overpopulation crisis” with a pre-meditated selection of sites to visit and points to make. And I can well understand why a person with little knowledge and background on wild horse and public lands issues or with a pre-existing selfish agenda could be easily stampeded into accepting the over-population myth.

Indeed, on Friday, September 9th, the board voted 8 to 1 to recommend disposal of ca. 44,000 wild horses and burros currently in holding throughout the United States. If accepted by the BLM, such a recommendation would result in the cruel killing of most of these national heritage animals.

Being all too aware of how wild horses and burros have been set up to fail, all too aware of how they have been used as scapegoats for ecological problems that overpopulated humans have basically caused, I was relieved that BLM officials did not – at least for now – accept their appointed board’s advice. I was also pleased to learn that BLM recently cancelled certain surgical sterilization experiments on over 200 captured wild mares in Oregon and others in Wyoming for which over $11 million dollars had been allocated.
The board’s recommendation would have been tantamount to murdering nearly all of the 44 thousand horses and burros in holding. This proposed bloodbath created an enormous national and international outcry, becoming a global bone of contention. And I find it heartening to see evidence that so many people care about the wild ones and their right to live freely and naturally.

Horses and their burro cousins are highly-evolved beings, fellow sojourners on planet Earth, companions who have lived and labored alongside us humans for many generations –even several millennia! What horses and humans have experienced together concerning Life’s unfolding story is truly awesome! Could this be why the cavalier disposal of the lives of so many horse souls rankles so deeply and with so many?

Today a great moral challenge stridently calls for us humans to more fairly and justly treat our fellow inhabitants of planet Earth. We must give these fellow conscious beings the life they deserve for a change! In the case at hand, horses present highly evolved beings present here on Earth for millions of years of free and natural living, often in wide-open spaces. In diverse ecosystems, they have developed intricate relationships with an astounding diversity of plants and animals and in a way that is truly splendid. As an ecologist, I realize that they are mutually complemental to the other species of fauna and flora. And that they are extraordinarily beautiful should give us some clue as to why they are pleasing to Heaven.

Such realizations occurred to those who established the Wild Free-Roaming Horses and Burros Act of 1971 (WFHBA). This was one of the first times Americans decided to do something major that was genuinely good for a fellow species. And it defied centuries, even millennia, of human self-absorption, thoughtlessness, cruelty and greed. For rather than merely continuing to take from, we humans actually chose to give back to horse kind something of true worth and excellence: their natural freedom to live on their rightful natural land, or home. In other words, to be themselves!

Along with the Wilderness and similar acts, the WFHBA was a “great forward leap for mankind.” Yet, an “all-points bulletin” today concerns our government’s emerging plans for America’s last remaining wild horses and burros. As a wildlife ecologist and even more as a human being who appreciates horses in the wild, I perceive their enemies not only among those traditionally opposed to them, but in our very government and even among people who claim to be wild horse advocates yet who are quick to overly compromise the future of these wild horses and burros as naturally living Earthlings! Why are the latter buckling under to the wild horses’ and burros’ traditional detractors and enemies? It seems that they are being duped into conceding to plans that will only ensure the decline of the wild herds? Many of us believe that this pusillanimous position must not pass! (No pasara! as we speakers of Spanish say.)

Core to what’s wrong are the so-called “Appropriate Management Levels” (AMLs) that have been assigned to the legal wild horse and wild burro herds on their legal lands throughout the West, both on BLM and US Forest Service lands. And along with these, the failure to fairly allocate natural resources for truly viable populations. These AMLs are simply much too low! They are genetically non-viable and would result in under-populated herds.

Any group of creatures that senses itself to be underpopulated usually “struggles to survive,” as Charles Darwin so aptly stated. Herd numbers as well as the locations and sizes of Herd Management Areas (HMAs) have been too arbitrarily set to fit the demands of cattle and sheep ranchers, big mining corporations, expansion-hooked land developers, ORV rippers up of the land, and the kill-focused hunting establishment. As is so typical, the root of the problem lies with that thoughtlessness and greed that infects too many humans today. The consequence has been many millions of acres of zeroed-out, though still legal, herd areas, and herd sizes and the sizes and habitat composition of HMAs (BLM) and Territories (US Forest Service) that are simply not adequate to the long-term survival needs of those wild horses and burros who still remain. To my very bones I feel that we humans must rise to the great moral challenge concerning the horses and burros and their right to live free. And this also has to do with our own success as a species, for it concerns obeying the laws of Higher Justice that govern the universe.

Truly realizing and living the noble intent of the WFHBA will make America great again, allow it to stand uprightly on solid moral ground. We shall learn to share the land and freedom with the wild ones, and this lesson shall be our salvation. We shall no longer restrict and exploit such “paragons of Nature” as the horses and their rightful lands in such a way that denies them their true place in the world we share with them as home. Today we have arrived at a crucial crossroad, a critical turning point:

Faulty PZP-type Choice for America’s Wild Horses and Burros

Shall we only continue to restrict and distort the true natures of the horses and burros and to ever greater degrees, as well as their proper habitats here on Earth? Shall we only continue to deny them genuine freedom here on Earth by condoning marginally productive, water-deprived, and un-whole habitats that have been carelessly and deviously assigned for them? Shall we be cornered into accepting the application of harmful, FDA-classified pesticides such as Porcine Zona Pelucida, or PZP, GonaCon, SpayVac, etc.?

These drugs, vaccines, inhibitors of healthy horses – call them what you like – only distort and suppress the true health and well-being of vigorous wild horses and burros! And then do we expect the wild horses and burros so violated to fit into unfairly small and inadequate habitats that do not provide their long-term survival needs? No! Such marginal habitats, substandard population numbers, and biologically compromised individuals are simply unacceptable! They would not be genetically viable and would only set the horses and burros up for inbreeding suppression while at the same time preventing their filling their ecological niches in a harmoniously adapted way. And these animals already face enough survival challenges without having to deal with the violation of their most intimate parts!

Is PZP really a solution that works for the horses/burros?

I have participated in many wild horse and burro meetings and heard talks given by experts describing PZP and its actions on wild horses, including by PZP’s inventor Dr. Jay Kirkpatrick and by Dr. Daniel Rubenstein, a behavioral zoologist who has studied PZPed wild horses in nature. I have also perused many scientific and popular articles about the effects of PZP upon wild horses, both short- and long-term, and both upon individuals and their social groups.

Here are some of the major proven damages to wild horses caused by PZP:

(1) PZP weakens immune systems of individuals and their herds since it inhibits reproduction in horses with stronger immune systems. Horses with weaker immune systems are precisely those who reproduce in greater numbers in PZP-treated herds. Eventually, PZP weakens wild horse herds’ overall immune systems. (Reference: Gray, M.E. & Cameron, E.Z. 2010. Does contraceptive treatment in wildlife result in side effects? Reproduction 139: 45-55.)

(2) Increased stress is experienced by mares who have been successfully darted by PZP and by other members of their social bands. This is because of PZPed mares’ frustration in completing their natural reproductive cycle, which affects the other members of their bands. Ironically, it is precisely the mature and stable, more content and non-PZPed bands that do, in fact, cause a slowing of reproductive rates, as years of research by the International Society for the Protection of Mustangs and Burros (ISPMB) and others abundantly proves. (Reference: Sussman, Karen. 6/6/2015. Suspicious deaths with use of anti-fertility drugs. ISPMB Journal. www.ispmb.org/BirthControlDeaths.html.)

(3) PZP adversely affects mares’ hormonal systems and consequently the social groups to which they belong. PZPed mares become irritable, aggressive, and more masculine, causing disharmony in their bands. PZP lowers estrogen and increases testosterone in mares and also produces ovarian cysts. Cysts increase testosterone levels. (Reference: U.S. National Library of Medicine. National Institutes of Health. Ovarian overproduction of androgens. (Reference: https://www.nim.nih.gov/medicineplus/ency/article/001165.htm.)

(4) Auto-immune oophoritis, aka ovaritis or inflammation of ovaries, and also stillbirths result from PZP. Autoimmune oophoritis can lead to the development of other autoimmune diseases. (Reference: Kaur, K. & Prabha, V. 2014. Immunocontraceptives: New Approaches to Fertility Control. BioMed Research International, Vol. 2014, Article ID: 868196.)

(5) PZP-darted herds in Little Book Cliffs, McCullough Peaks, and Pryor Mountains wild horse legal herd management areas gave birth nearly year-round, i.e. 341 days, rather than in the normal spring season. This exposed PZPed wild mares and their offspring to extremes of temperature, and, consequently, to suffering and death. (Reference: Ransom, J.I. et al. 2013. Contraception Can Lead to Trophic Asynchrony between Birth Pulse and Resources. PLoS ONE 8(1): e54972. Doi: 10.1371/journal.pone.0054972.

(6) It is quite disturbing that PZP antibodies transfer to foals from the mare through the placenta while they are in the womb as well as through mare’s milk. These antibodies react with and bind to the zona pellucida of female newborns. Yet, BLM regularly administers PZP to pregnant and lactating mares in spite of these published scientific findings. (Reference: Sacco, A.G. et al. 1981. Passage of zona antibodies via placenta and milk following active immunization of female mice with porcine zonae pellucidae. Journal of Reproductive Immunology. 1981, December; Vol 3, Issue 6: pages 313-322.)

(7) Weakening of immune system subjects wild horses to mal-adaptiveness to unforeseen major changes such as are occurring due to Global Warming, or catastrophes such as epidemics or wildfires. (Reference: Gray & Cameron, 2010, op cit.)

(8) PZP causes the immune system to attack and destroy the ovaries and produces a large variety of adverse effects. (References: Gray & Cameron, 2010, op cit.; Kaur & Prabha, 2014, op. cit.)

(9) By extending the lifespans of PZPed mares, PZP creates abnormal numbers of aged, sterile mares. This disadvantages younger horses, who continue to be taken away by BLM roundups to reach arbitrary AMLs. This appeases livestock or other wild-horse-adverse interests on the public lands, rather than respecting the General Public, whose majority values wild horses and burros and wants them to be fairly treated. (Reference: Knight, C.M. & Rubenstein, D.I. 2014. The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus). Princeton University thesis, Dept. Ecology & Evolutionary Biology.)

(10) PZPed mares are no longer reproductively active in the wild horse population, thus diminishing the genetic viability of the herd. The resources they consume would otherwise contribute to reproducing adults and their offspring and maintain the vigor of the herd into ongoing future generations that adapt to ongoing environmental changes, thus assuring their long-term survival. (Reference: Ransom, J.I. et al. 2013, op. cit.)

(11) PZP is a safety hazard to humans, especially to females who administer it. (Reference: Devlin, M. and Protect Mustangs 2015. Fact Sheet: The Truth about PZP. http://protectmustangs.org/?p=8749.)

For these and related reasons, I believe that PZP will seriously harm and undermine the vigor of wild horse and burro populations that our nation’s laws mandate us to protect and preserve, as well as to manage. The restoration and maintenance of herd vigor is essential to the ongoing ecological adaptation and long-term survival of each herd. Healthy reproduction is key to healthy wild horse and burro individuals, bands and herds. Tampering with reproduction produces a variety of aberrations that lead to dysfunctional and disordered wild horses. This results in a decline of the herds.

I have heard from many people who closely observe and/or live near wild horses treated with PZP. They describe many still-born or defective foals produced by mares in whom the effects of PZP have worn off, permitting them to again try to reproduce. Also please consider that after a few to several years of yearly application, PZP generally produces total sterility in mares, depending upon the strength of their individual immune systems. This calls into serious question the proclaimed “reversibility of PZP” to enable mares to reproduce again! To reiterate: of great concern is the fact that PZP is less effective in those mares with weakened immune systems. Hence, the wide-spread use of PZP among America’s last wild horse/burro herds – nearly all below minimum viable population (MVP) level – will seriously undermine their long term survival.

But thankfully there exists an honorable alternative to PZP, and similar horse-disrespectful “quick fixes”. As a wildlife ecologist, I have formulated a sound alternative to PZP and similar invasive proposals. This Reserve Design strategy would restore long-term viable, ecologically well-adapted, and naturally self-stabilizing populations of wild horses and burros throughout the West. (References concerning Reserve Design: Peck, S. 1998. Reserve Design. In: Planning for Biodiversity: Issues and Examples. Island Press, Washington, D.C. Pages 89-114; Soule, M.E. & Terborgh, J. 1999. Continental Conservation: Scientific Foundations of Regional Reserve Networks. Island Press, Washington, D.C.; Downer, C.C. 2010. Proposal for wild horse/burro reserve design as a solution to present crisis. Natural Horse Volume 12, Issue 5, pages 26 to 27; Downer, C.C. 2014. The Wild Horse Conspiracy, www.amazon.com/dp/1461068983, look up “Reserve Design” in Index.)

Reserve Design: the Intelligent and Caring Choice for America’s Wild Horses and Burros

If followed correctly, the unanimously passed WFHBA would have set aside somewhere between 54 million and 90 million acres for the preservation of wild horses and burros in the wild. Lamentably, the rights of these animals—and their human supporters—have been undermined by wild horse and burro enemies, including officials charged with their protection. Current policies toward these “national heritage species” are thinly disguised plans for reducing the herds to cripplingly low, non-viable population numbers. These levels would be unable to sufficiently and adequately reproduce so as to survive into the long-term future. Too often the plan has been to simply eliminate them from their legal areas, i.e. “zero-out”. Indeed, anywhere from 22 million to 40 or more million legal acres have been declared officially empty and “not for” the wild horses and burros or simply ignored at the onset of the WFHBA in the early years of this act (see Downer, C.C. 2014. The Wild Horse Conspiracy).

Some wild horse advocates and observers say there are only 33,000 wild horses and burros remaining on America’s public lands as independently estimated for mid-2016 (Louise, Katia, wild horse documentary filmmaker, pers. comm.). Even if the official BLM figure of 67,027 wild horse and burros remain on the public lands (55,311 horses & 11,716 burros [BLM report of March 1, 2016]), either level would be out of step with the amount of ecologically appropriate habitat where these animals have a legal right to live. The small number of horses and burros our government intends to leave on each of the ca. 179 remaining BLM-designated areas is a sure prescription for the over-fragmentation and isolation of wild horse/burro populations. This would only jeopardize their long-term survival, compromising their true vigor in the wild.

The nationwide population of wild horses and burros that our government plans to allow as the high end Appropriate Management Level is only 26,715. This would be composed of only 1,676 individual wild horses and/or burros in Arizona; 2,200 in California, 812 in Colorado, 617 in Idaho, 120 in Montana, 12,811 in Nevada, 83 in New Mexico, 2,715 in Oregon, 1,956 in Utah, and 3,725 in Wyoming. (Source: Herd Area and Herd Management Area Statistics as of March 1, 2016. BLM, Washington, D.C.) These assigned population levels are very unfair and cater to wild horse and burro detractors while largely disregarding the General Public that are strongly support this Quality of Life issue.

Our government’s current goal of and plans for drastically reducing small and genetically vulnerable wild herds include the partial—and very possibly total—sterilization of mares through PZP injection. These plans also include the unnatural skewing of sex ratios to establish excess males, even in the naturally harem social structure of naturally living horses in which females are usually more numerous. And even more invasive measures have been planned in the past and are likely to crop up again, including painful—often lethal castration of stallions and the ovariectomies (removal of ovaries) of mares (thankfully recently cancelled in Oregon and Wyoming), as well as the individually deranging and socially disruptive injection of sterilization drugs or vaccines, such as PZP.

Clearly, our wild horses and burros are in a very critical situation today. I judge them to be more imperiled than they were in 1971 just before the passage of the WFHBA when they were “fast disappearing from the American scene”—and I used to work with Wild Horse Annie. We must quickly respond with a well-conceived plan for reforms that will restore the true rights of wild horses and burros upon our public lands. These lands belong to all Americans, not just to resource exploiters, whether officials of corporations or private individuals. As a wildlife ecologist and deeply rooted native Nevadan personally familiar with many of the West’s wild horse and burro herds, I strongly urge the restoration of these deeply rooted North American native species. Their return to North America should be as genetically viable and naturally self-stabilizing herds that are allowed too adapt ecologically to each specific region where they have legal right. This can be accomplished by following the sound principles of Reserve Design. Such a plan would end cruel, disruptive roundups and reproductive manipulations – practices that mock the true intent of the 1971 WFHBA by causing untold suffering and death to these beautiful and highly evolved, sensitive, wise, and freedom-loving creatures.

Reserve Design combines ecological, biological, social, and political considerations in order to achieve desired results. Basically, it involves setting aside areas of complete year-round habitat where human intervention is buffered against and where natural processes are allowed to reestablish natural checks and balances. Reserve Design will achieve internal harmony for the diverse, yet interrelated, species living within each wild horse/burro-containing ecosystem.

Critical steps for realizing Reserve Design in wild horse and wild burro habitats are as follows:

[1] Properly identify the long-term survival requirements for viable equid population levels to be accommodated in each reserve. Our chief focus would be to promote wild horse/burro-containing ecosystems of adequate size and condition to sustain viable equid populations and where plant and animal species are allowed to adapt naturally over the generations and in inter-balanced fashion. The level of 2,500 individual has been recommended for the viability of an equid population by the IUCN SSC Equid Survival Group (Equid Action Plan, IUCN SSC ESG, 1992).

[2] Conscientiously identify appropriate ecological areas suitable for the implementation of wild horse/burro-containing reserves. This would involve travel to, on-ground inspection of, flights over, and GIS analysis of a wide variety of places throughout the West. This would also entail setting up Cooperative Agreements under Sections 4 and 6 of the WFHBA in order to achieve complete habitats around the federally designated wild equid lands and involving both private and other government lands such as state and local.

[3] Wherever possible, wisely incorporate natural equid predators (such as puma, bear, and wolf) that would both limit and tone/strengthen, wild horse and burro populations.

[4] Wherever possible, wisely incorporate natural barriers that would limit the ingress and/or the egress of certain species, including the wild horses and burros. This would avoid conflicts and set up conditions for the natural self-regulation of populations.

[5] Identify where buffer zones, artificial barriers, or other means of impeding movements in and out of a reserve should be established in order to keep the species in question from coming into conflict with humans. Buffer zones possibly involving non-injurious means of “adverse conditioning” could be employed as well as “positive reinforcement” as a means of encouraging the wild equids to stay within the reserve, as for example, by providing all of their habitat needs. Also, “semi-permeable barriers” that do not restrict most species but do prevent equids from passing out of the reserve may be used. These means would be described in practical detail and as tailored to fit each specific reserve area.

[6] Identify the presence and abundance of necessary food, water, shelter, mineral procurement sites, elevation gradients for seasonal migrations, etc., that will accommodate the long-term habitat needs of long-term viable wild equid populations. Such will also allow the natural rest-rotation of foraging between the natural subdivisions of the reserve. Fences within the reserve that impede the free-roaming lifestyle of the wild equids will be located and their removal accomplished. The intrinsic Carrying Capacity of the land in question will also be estimated as closely as possible. Such will be based upon the Productivity of forage adequate to at least a minimally viable population of wild horses/burros. Besides food, this determination will take into account other survival factors such as water, minerals, shelter, breeding and nurturing habitat, seasonal migrations, and needed protection from existing threats to the wild equids.

[7] Identify geographical regions whose human inhabitants are benignly disposed toward the creation and long-term implementation of extensive, ecologically balanced wild horse/burro-containing reserves. This would involve traveling to different areas and setting up meetings with pertinent individuals, town and government officials, etc. This also relates to the setting up of Cooperative Agreements under Sections 4 and 6 of the WFHBA, as mentioned above.

[8] Identify ways of and benefits from implementing Reserve Design that result in win-win relationships centered on the presence of wild horses and burros. Ecotourism is one major possibility here, and wild horse/burro viewing tours have already proven to be successful in several states, including Craig London’s tours to the Montgomery Pass wild horses of eastern California. Restoring native ecosystems, including soils and native species, would be a major ecological benefit. The reduction of flammable vegetation through equid grazing and the restoration of hydrographic basins through the enrichment of soils, would be other major, positive contributions by wild horses and burros. Another major benefit concerns the prevention of catastrophic wildfires that over-burn vegetation, sterilize soils and denature their stored seed banks. Such fires can set the life community back to very primitive evolutionary stages. Indeed, it can be strongly argued that the restoration of wild equids in North America is crucial to combating life-disrupting Global Warming itself.

[9] Of key importance is informing the public concerning the many ways that horses and burros, as ecological “climax” species, self-limit their own populations once their respective ecological niches are filled in any given bounded area. This knowledge is key to realizing a humane relationship with these animals, a relationship that does justice to and demonstrates respect for them. And it is this respect and appreciation on the part of us humans that is key to allowing the horses and burros to fulfill their important natural roles within the life community.

Whom to Contact to Help Wild Horses and Burros:

Please contact your Senators and Representatives, the President, the Secretary of Interior and its Bureau of Land Management; and the Secretary of Agriculture and its US Forest Service. Both of these agencies are mandated by the WFHBA to preserve and protect as well as to manage the wild horses and burros and their legal lands and resources for the benefit of the former.

Also contact your state governor and state, county, and municipal officials concerned with wildlife and natural resources. Get in touch with the media: newspapers, magazines, TV and radio stations. Make all of the above aware of what is needed to stop the over-reduction or zeroing-out of the herds and the cruel abuse of wild horses and burros, whether through drugging, vaccines, surgeries, or other unnatural and invasive methods. Rather, persist in the restoration of the wild horse and burro herds and their habitats to viable levels, healthy conditions and sizes. This will be to restore the pure intent of the law.

A key committee to contact right away is the U.S. House of Representatives’ Appropriations Committee, particularly its Interior, Environment & Related Agencies Subcommittee. The telephone number of the latter is (202) 225-3081. Emails of staff to contact are betsy.bina@mail.house.gov and Kristin.richmond@mail.house.gov. This subcommittee is now deciding which direction to take in regards to the wild horses and burros. It has been hearing too exclusively from traditional wild horse and burro enemies.

Those of us who value and appreciate the wild horses and burros and their rightful place in the world of nature must set the record straight for these wonderful and ancient presences on Earth. We must not allow their enemies or those ignorant of their worthiness prevail!

The spirited and intelligent horses and burros are depending on you and I!

In addition to contacting the above, be sure to contact the President of the United States and the White House staff at (202) 456-1111 (TTY/TTD: (202) 456-6213). Switchboard (202) 456-1414. You can also do this by email at http://www.whitehourse.gov/contact or president@whitehouse.gov.

You may contact your Senators and Congressmen/State Representatives (federal and state) by linking on internet with “Elected Officials / USA Gov”. This will provide you with the contacts you require for federal, state, and local offices. The link is: https://www.usa.gov/elected-officials.

And in closing I urge you to contact the natural resource and public lands committee and subcommittee in the U.S. Senate.

On behalf of our wonderful wild horses and burros, I sincerely thank all of you for your caring and for your effective action.

Craig Downer

 

Wildlife Ecologist. A.B. UCB; M.S. UNR; Ph.D. Cand. U. Durham UK. Link to his article The Horse and Burro as Positively Contributed Returned Natives in North America is http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12 Website to check out is www.thewildhorseconspiracy.org in which the links to the article and how to order his book are present.

Also please consider signing this important petition to stop this massacre of the wild horses and burros from happening: The link to this petition is: http://www.thepetitionsite.com/907/592/301/demand-nokill-45000-wild-horses-burros-in-holding/

Fraudulent figures, sterilization and underpopulation

PM Burros Wild 2 © Carl Mrozek

To:  Heather van Blokland at KJZZ

Rio Salado College and Maricopa Community College, Arizona

I am emailing you directly because comments cannot be posted to your article.

http://kjzz.org/content/360434/feds-look-solution-wild-horse-burro-overpopulation

First, let me commend you for correctly identifying PZP as a “sterilization drug.” The Bureau of Land Management (BoLM) and the Humane Society of the United States (HSUS) both like to refer to it as “birth control,” but PZP is actually a sterilant.  More on that later.  The reason for my email is to alert you that BoLM has given you false information regarding the wild horses and burros.

While a reporter or any member of the public should be able to secure accurate data from government agencies, BoLM’s data is fraudulent as concerns wild horses and burros.  BoLM is aggressively pursuing a disinformation campaign against the mustangs, concocting a crisis that does not exist, and using scare-tactics to secure increased funding for itself.  Let me now address certain points cited in your article.

Herd-growth rates:  Equids are slow-growth species when it comes to reproduction. The gestation period for horses lasts 11 months, and a mare produces just 1 foal.  The gestation period for burros lasts 12 to 14 months, and a jenny is less fertile than a mare.  While an independent study of BoLM’s records did confirm an almost 20% birth rate for wild-horse herds, and an almost 15% birth rate for wild-burro herds, the study also found that 50% of foals perish before their first birthday.  Thus, the effective increase in population from new foals is just 10% for wild horses and 7% for wild burros.  Adult mustangs also die.  They succumb to illness, injury, and predation at a rate of at least 5% a year. So, what is a normal herd-growth rate?  Around5% for wild horses and about 2% for wild burros, probably less in each case.  Thus, a herd could not double every four years — that’s just BoLM propaganda.

Fraudulent figures:  There is no overpopulation except on BoLM’s falsified spreadsheets.  Reviews of the agency’s population-estimates reveal biologically-impossible herd-growth rates.  For instance, in Arizona, BoLM reported that the Big Sandy herd grew from 250 burros to 754 burros in one year, a 202% increase.  In Nevada, BoLM would have us believe that the Lava Beds herd grew from 40 burros to 350 burros in one year, a 775% increase.  In Wyoming, BoLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase.  The agency’s “data” is chock-full of such preposterous growth-estimates.  So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that the numbers have been falsified.

Wild horses and burros are underpopulated:  Per the guidelines of BoLM’s own geneticist, 83% of the wild-horse herds and 90% of the wild-burro herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP).  Low AMLs enable BoLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP.  For instance, the AML for Arizona’s Black Mountain herd was set at 382 to 478 wild burros.  The Black Mountain Herd Management Area comprises 925,425 acres, or 1,446 square miles.  Thus, per the AML, BoLM implies that each burro needs 1,936 to 2,423 acres, or about 3 to 4 square miles per burro.  If BoLM projects there to be 2 burros per 3 square miles, the agency declares an “overpopulation” because there is “double the number” that the AML allows.  As you can see, being “over AML” is meaningless as well as misleading.  But the low AMLs, combined with falsified, biologically-impossible herd-growth estimates, give BoLM an excuse to scapegoat those few wild horses and burros for the range-damage done by the millions of livestock that overgraze the public lands.

Adoptions:  Have not declined — let alone “disappeared” — contrary to what BoLM led you to believe.  It’s just that BoLM used to count the thousands of sales-for-slaughter as “adoptions.”  Now that only true adoptions — “forever-family” placements — qualify, it just seems as if the number has declined.  However, wild horses are not homeless horses.  They have a home — where they belong — on the range.

HSUS:  Is the registrant of PZP / ZonaStat-H with the Environmental Protection Agency.  Thus, HSUS’ information is not impartial because the organization has its reputation to protect.  Further, HSUS has submitted a proposal for a multi-year project in which BoLM would pay for HSUS staff to experiment on Arizona’s burros via “opportunistic” darting with PZP.

Pesticide:  PZP is not just a sterilant but also a registered pesticide that was approved by the EPA for use on wild horses and burros “where they have become a nuisance.”   However, PZP was registered without the standard testing requirements.  There is currently a lawsuit challenging the legitimacy of the registration, especially in light of new studies that have disclosed PZP’s many adverse side-effects.

Sterilizing mustangs:  PZP is a potent weapon in BoLM’s arsenal — for its biological warfare against the wild horses.  But population control for wild horses is unnecessary because there is no overpopulation.  Why would we contracept herds whose population is inadequate for genetic viability?  Why would we contracept herds based on falsified figures?  Logically we wouldn’t and ethically we shouldn’t.  Further, if PZP were going to stop the roundups, it would have done so long ago for the famous Pryor Mountain herd, home to Cloud, the stallion who was the subject of a number of documentaries that aired on PBS.  The Pryor Mountain mares have been darted with PZP for nearly two decades.  Yet roundups have been scheduled there like clockwork every 3 years and, in spite of intensifying the PZP treatments recently, BoLM tried to implement yearly roundups until stopped by a Friends of Animals lawsuit.

PZP — the anti-vaccine:  PZP causes disease — auto-immune disease.  PZP “works” by tricking the immune system into producing antibodies that target and attack the ovaries.  The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles.  The mare’s estrogen-levels drop markedly as PZP destroys her ovaries.  Ultimately, PZP sterilizes her.  Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function.  Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries.  But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed.  Those mares fail to respond to PZP.  They keep getting pregnant and producing foals who, like their dams, suffer from weak immune-function.  So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised.  Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.

Health-risks to volunteers:  As for the well-meaning volunteers who dart wild horses, EPA’s Pesticide Fact Sheet for PZP advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure.  EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility.  Unfortunately, PZP’s manufacturer misrepresented PZP as “so safe it is boring.”   But research shows that PZP is a powerful hormone disruptor.  Further, consider the magnitude of the risk — the PZP-in-question is a horse-sized dose.  If volunteers think PZP is safe, they will be less likely to protect themselves from this dangerous pesticide.

Mengelian experiments:  The Big Lie of “overpopulation” is the pretext for BoLM’s war against the wild horses, and the wild horses are prisoners of that war.  It’s BoLM’s version of the “Shock Doctrine,” wherein the agency concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People.  Now, BoLM is funding surgical-sterilization studies on the equine POWs to develop a Final Solution to the “problem” — handing out $11 million for these diabolical experiments.  The grant money is surely intended to buy loyalty and silence potential criticism from academia.  Plus, BoLM, a corrupt, rogue agency, gets to cloak itself in respectability by affiliating with prestigious universities.

Should you wish to learn more about how BoLM is mismanaging Arizona’s wild burros, I would be happy to send you a copy of comments recently submitted.  Just let me know.

Sincerely,

Marybeth Devlin

Miami, FL

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.




Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Email: blm_ut_sulphur@blm.gov

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

Document: Environmental Assessment — Preliminary

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

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

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

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

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

News Release — 2015 EA

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

News Release — 2015 Public-Safety Removals

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

Sulphur Gather Environmental Assessment — Preliminary

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Let’s do the math.

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

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

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

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

Discrepancies were evident per a review of the …

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

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

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

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

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

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

125 %
131 %
153 %
157 %
249 %

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

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

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

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

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

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

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

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

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

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

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

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

Here are excerpts from a news report:

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

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

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

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

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

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

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

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

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

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

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

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

The EA states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Marybeth Devlin





Protect Mustangs comments against spaying wild mares in Wyoming


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

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

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

January 14, 2016

Dear Public Servants at the BLM:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

PM Checkerboard ROundup Sept 20 2014

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

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

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

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

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

Sincerely,
Anne Novak

.Anne Novak
Executive Director
Protect Mustangs

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

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

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





Protect Mustangs & Friends of Animals take action in court to stop roundups

 

PM WY WIld Horses Running

For Immediate Release

Jenni Barnes, staff attorney, FoA’s Wildlife Law Program 720.949.7791; jenniferbarnes@friendsofanimals.org
Mike Harris, Director, Wildlife Law Program; 720.949.7791; michaelharris@friendsofanimals.org
Anne Novak, Executive Director, Protect Mustangs; 415.531.8454; anne@protectmustangs.org

Protect Mustangs & Friends of Animals intervene after Wyoming sues feds to reduce number of wild horses

Underpopulated national treasures at risk of being wiped out.

Cheyenne, WY (December 17, 2014)—Protect Mustangs based in California and Friends of Animals (FoA) based in Connecticut have filed a motion to intervene in a lawsuit filed by the State of Wyoming against the United States Department of Interior and the United States Bureau of Land Management (BLM) to get even more wild horses removed from the state. The State of Wyoming alleges that the federal respondents have failed to take action on the state’s request to remove “excess” wild horses from the range in Wyoming.

“We feel compelled to intervene because the BLM isn’t protecting America’s wild horses and burros the way they should,” says Anne Novak, executive director of Protect Mustangs. “BLM’s new wipe-out plan is to complain their hands are tied and then invite states and other land-grabbers to sue them to roundup wild horses—under false claims of overpopulation. This subterfuge must be stopped.”

“In September, BLM proceeded to remove 1,263 wild horses from the Wyoming range, which reduced populations in the affected areas to below their Appropriate Management Levels (AMLs),” said Jenni Barnes, staff attorney for FoA’s Wildlife Law Program. “I am appalled at Wyoming’s attempt to remove even more wild horses from our public lands. We all have a right to be involved in decisions about our public lands, yet it appears that Wyoming is trying to bypass this process and make a side deal with BLM to eradicate wild horses. Friends of Animals will not just stand by while this happens and we are intervening to protect the freedom of the last remaining wild horses in the state.”

FoA and Protect Mustangs, both non-profit animal advocacy organizations, and their members, have long-standing involvement in conserving wild horses in the western United States generally, and have specific conservation, academic, educational and recreational interests in wild horses in Wyoming.

The organizations are concerned that the BLM has shown a willingness to settle actions seeking to force the removal of wild horses in Wyoming. For instance, this past summer, when Rock Springs Grazing Association filed a lawsuit against the BLM to force it to remove all wild horses from the Checkerboard area, a mix of federal and private land that runs along an old railroad route across southern Wyoming, BLM did not advocate for wild horse conservation. Instead BLM entered a consent decree with the plaintiffs in which BLM agreed to remove all wild horses from the Checkerboard area.

“BLM’s ridiculously biased ‘appropriate management level’ always favors commercial livestock grazing and the extractive industry over wild horses and burros on public land,” explains Novak. “The State of Wyoming and the BLM are trying to blow away the 1971 Protection Act wherein wild horses and burros should receive primary but not exclusive use of designated areas on public land. Just follow the money to understand why they don’t like wild horses.”

Priscilla Feral, President of Friends of Animals states, “When wild horses don’t seem useful to the BLM, they’re resented. Rounded up. Sterilized. Killed or otherwise displaced. In contrast, cows and sheep owned by large corporations and hobby ranchers are seen as having a dollar value, so ranchers are relieved from having to compete over water and grasslands with horses. Since horses are not hamburgers, Wyoming and the BLM want them gone. People don’t want this madness anymore.”

FoA and Protect Mustangs oppose all removals of wild horses and believe the AMLs set for the Herd Management Areas in Wyoming are too low, outdated and do not accurately reflect the number of wild horses that are needed to maintain genetic viability to prevent extinction and to create a thriving natural ecological balance in the state.

“The American public is outraged because elected officials aren’t doing anything to stop cruel roundups and sterilization experiments on our native wild horses,” says Novak. “It’s disgusting and shameful. Risky drugs like PZP and other forms of sterilization are a sham at this point because there aren’t enough wild horses left on millions of acres of public land.”

Novak pointed out that according to the National Academy of Sciences’ 2013 report, there is “no evidence” of overpopulation.

“Wild horses must be protected in Wyoming,” states Craig Downer, wildlife biologist based in Nevada, author and member of Protect Mustangs. “They restore the ecosystem as a deeply rooted native in North America with a unique niche that helps other species thrive.”

###

Links of interest™:

Friends of Animals & Protect Mustangs’ Motion to Intervene http://protectmustangs.org/wp-content/uploads/2014/12/PM-WY-Motion-to-Intervene_WY-wild-horses_vfinal.pdf

Wyoming sues feds claiming too many horses (AP) http://www.sfgate.com/news/science/article/Wyoming-sues-feds-claiming-too-many-wild-horses-5943755.php

Appropriate Management Level (National Academy of Sciences) http://www.nap.edu/openbook.php?record_id=13511&page=195

Feds’ cruel roundups https://www.youtube.com/watch?v=yF49csCB9qM

Livestock grazing (Center for Biological Diversity) http://www.biologicaldiversity.org/programs/public_lands/grazing/

Genetic viability (Wikipedia) http://en.wikipedia.org/wiki/Genetic_viability

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

Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org

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

PZP advocates put wild horses at risk of sterilization after roundup

Stop the Roundups!

Protect Mustangs calls for a freeze on roundups for scientific reevaluation

Tonopah, NV (October 31, 2014)–The Battle Mountain District, Tonopah Field Office is rounding up about 120 wild horses from within the Reveille Allotment and Herd Management Area (HMA) located approximately 50 miles east of Tonopah, NV to remove alleged excess wild horses on 600,000 acres of public land.

“The BLM is wiping out America’s wild horses and taxpayers are paying for the abuse,” states Anne Novak, executive director of Protect Mustangs. “We need to stop the roundups and protect our native wild horses.”

The roundup will stampede native wild horse families by helicopter over a fragile ecosystem and possible sage grouse habitat in the Great Basin Desert. Often wild horses are injured and die in roundups. The treacherous roundup is paid for with tax dollars, and began October 30, 2014. Most herds need to be rounded up before given PZP.

After the roundup, approximately 70 wild horses will be permanently removed, 60 wild horses will be sent to holding facilities in Ridgecrest, California and about 10 horses will be offered for adoption after the roundup in Tonopah, NV on November 8. The remaining 50 wild horses will be released back into the HMA for a post roundup population of 98 wild horses, putting the survivors at risk. The minimum number for genetic variability is 150 wild horses.

Often the BLM returns wild horses with conformation defects to the range, instead of placing them in adoptive homes or long-term holding where they will not breed. Apparently the agency doesn’t realize that by returning wild horses with defects they will ruin the breeding pool. The BLM claims mares selected to maintain herd characteristics will be released back to the HMA. The public must watchdog the agency to ensure wild horses with defects are pulled from the breeding pool and rehomed. Euthanizing them is not an option supported by the American public.

The informed public is outraged over an EPA approved restricted use pesticide called PZP, made from pigs ovaries, to be used on native wild horses. PZP advocates campaign rigorously to treat mares with the Porcine Zona Pellucidae (PZP-22) in order to temporarily sterilize mares. PZP advocates hail the use of PZP in spite of the fact that wild horses are underpopulated on millions of acres of public land.

Experimental research on ovary damage in mares given the immunocontraceptive PZP is used to hone the drug for eventual human use. This could be where the “follow the money” piece fits in. Wild horse advocates are furious America’s herds are being used as lab rats. Science has proven the drug sterilizes wild horses after multiple use. PZP advocates are pushing for BLM to manage wild horses “in the wild” using these risky drugs.

The devastation of wild horses in the Reveille Allotment appears to be subject to a 1987 District Court Order and two orders issued by the Interior Board of Land Appeals (IBLA) in 2001 and 2002, requiring BLM conduct an annual inventory of wild horses in the Reveille Allotment and initiate a roundup to remove alleged excess native horses from the Allotment when the inventory shows that population numbers exceed the out of date Appropriate Management Level (AML) of 138 horses.

Current AML does not represent healthy herd populations and lacks scientific merit. AML must be updated to ensure healthy herds remain on public land. The herd census must never fall below 150 wild horses to maintain genetic variability.

The current estimated population, based on previous inventory flights is 168 wild horses, according to BLM. This is the low end of the genetic viability scale. The orders need to be challenged based on scientific reevaluation of wild horses benefiting the ecosystem as a native species, livestock causing range damage and the minimum number of wild horses needed for genetic variability.

“We must ensure native wild horses can survive upcoming environmental changes,” states Anne Novak, executive director of Protect Mustangs. “The minimum population for a genetically variable herd is 150. Why are PZP advocates and the BLM allowing wild horse herds to fall below safe numbers?”

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

The NAS report states there is “no evidence” of overpopulation. Only tobacco science and spin backs up BLM’s population claim to justify roundups and fertility control/sterilizations. PZP advocates lobbied NAS to have fertility control recommended even though the herds are underpopulated.

Roundup activities within the Reveille HMA were analyzed in the 2010 Reveille HMA Wild Horse Gather Plan and Environmental Assessment (EA) and the 2014 Reveille Wild Horse Gather Determination of NEPA Adequacy (DNA). The EA, DNA, and Decision Record can be accessed on the Reveille Wild Horse Gather website: http://on.doi.gov/10qLBlh.

Members of the public are encouraged to witness the helicopter stampede and document America’s icons losing their freedom to spread awareness that cruel roundups must stop. Observation protocols and visitor information are available at http://on.doi.gov/1xAMeTp. The BLM will post updates, photos and other information about the roundup on the Reveille website and on the hotline at 775-861-6700 throughout the course of the roundup.

The BLM is wiping out wild horses for the extractive industry and New Energy Frontier in the West. The agency manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM focuses on their mandate of multiple-use and sustained yield. In Fiscal Year 2013, the BLM generated $4.7 billion in receipts from public lands.

BLM’s roundups disturb the thriving natural ecological balance by disturbing habitat dynamics. This crime against nature causes abnormally high birthrate and puts native wild horses at risk of inbreeding.

“We are calling for an immediate freeze on roundups and removals for scientific reevaluation,” states Novak. “Right now native wild horses are at risk of being ruined by bad policy.”

Protect Mustangs is a nonprofit organization dedicated to the conservation of native and wild horses. The group is against using PZP in the wild. Today most wild herds are threatened with low numbers and a lack of genetic variability. Using PZP in a sanctuary setting where acreage is limited is a different situation. Wild horses must not be managed in the wild as if they were a zoo exhibit.

# # #

Links of interest™:

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

Princeton study on the pros and cons of adoption and immunocontraception: http://www.equinewelfarealliance.org/uploads/IEC.Rubenstein.pdf Not sure about EWA’s position on PZP now they might have embraced it like some others have.

Jamie Jackson’s piece on PZP: http://protectmustangs.org/wp-content/uploads/2013/06/PM-Jamie-Jackson-Using_Science_to_Improve_the_BLM_Wild_Horse_and_Burro_Program.pdf

Management of Wild Horses with Porcinezona Pellucida Pellucide: History, Consequences and Future Strategies, Cassandra M.V. Nuñez, Princeton: http://bit.ly/1rJywKl

Restricted use pesticide info: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-de info: Jan-12.pdf

Injection-Site Reactions in Wild Horses (Equus caballus) Receiving an Immunocontraceptive Vaccine, By James E. Roelle and Jason I. Ransom, http://pubs.usgs.gov/sir/2009/5038/

Pilot project to treat wild horses in Fish Springs communityhttp://www.blm.gov/nv/st/en/info/newsroom/2014/april/blm_approves_pilot.html

and http://www.wildhorsepreservation.org/media/pzp-pilot-project-treat-wild-horses-fish-springs-community

BLM Nevada Advisory Council Endorses Fertility Control Plan (Oct. 20, 2014) http://www.returntofreedom.org/blm-nevada-advisory-council-endorses-fertility-control-plan-october20-2014/

BLM partners with The Cloud Foundation in the Pryorshttp://www.blm.gov/pgdata/etc/medialib/blm/mt/main_story.Par.31432.File.dat/TopStoryHorse.pdf

Why end natural selection in the Pryors? http://protectmustangs.org/?p=4941

Are wild horses at risk of being sterilized due to an advocacy campaign? http://protectmustangs.org/?p=6356

Ecologist Craig Downer speaks out against using PZP in the Pryorshttp://protectmustangs.org/?p=4178

Horse contraceptive study raises concerns  Horsetalk, NZ: http://www.horsetalk.co.nz/news/2010/10/220.shtml#ixzz3Hti8ioCv

Appeal to stop the wild horse wipe outhttp://protectmustangs.org/?p=6527

The Horse and Burro as Positively Contributing Returned Natives in North America by Craig Downer PhD candidate: http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12

Wild Horse Conspiracy by Craig Downer:  www.amazon.com/dp/1461068983

Conformation defectshttp://www.thehorse.com/articles/10115/conformation-in-horses

Genetic viabilityhttp://en.wikipedia.org/wiki/Genetic_viability

Genetic variabilityhttp://en.wikipedia.org/wiki/Genetic_variability

J. Kirkpatrick team get $100K for wild horse fertility control drug PZPhttp://tuesdayshorse.wordpress.com/2012/04/17/jay-kirkpatrick-team-get-100k-for-wild-horse-fertility-control-drug-pzp/

Making PZP at The Science and Conservation Centerhttp://www.sccpzp.org

Native wild horseshttp://protectmustangs.org/?page_id=562

Petition for shelter and shade for captive wild horses and burroshttp://www.change.org/p/bring-emergency-shelter-and-shade-to-captive-wild-horses-and-burros

Petition for 10 year moratorium on wild horse roundups for recovery and studieshttps://www.change.org/p/sally-jewell-urgent-grant-a-10-year-moratorium-on-wild-horse-roundups-for-recovery-and-studies

Petition to defund and stop the wild horse roundupshttp://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups

Join the Walking Billboard Campaign to STOP THE ROUNDUPS in Nevadahttps://www.booster.com/protect-mustangs-nevada

Sample of viral news clippings: https://newsle.com/AnneNovak

Anne Novak on Twitter: https://twitter.com/TheAnneNovak

Protect Mustangs on Twitter: https://twitter.com/ProtectMustangs

Facebook: https://www.facebook.com/ProtectMustangs

www.ProtectMustangs.org