Is the Concocted Wild Horse Crisis based on Fraud?

 

Photo by BLM in public domain

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

Via email: blm_nv_eldowellshorsegathers@blm.gov

August 21, 2017

BLM Elko District Office
3900 Idaho Street
Elko, NV 89801

Attn: Marc Jackson, Wells Field Manager

 

Project: Antelope / Triple B Complexes

Document: Environmental Assessment ( EA )

Action: 2017 Gather Plan EA — Comments to

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

 

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

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

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

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

 

BACKGROUND

 

The Alternatives

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

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

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

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

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

 

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

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

 

Not Reproduction, but Migration

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

 

Over-AML ≠ Over-Populated

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

 

PRINCIPAL USE WITHIN MULTIPLE-USE APPROACH

 

Wild-Horse Habitat Must Be Managed Principally for Wild Horses

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

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

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

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

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

 

Disproportionate Allocation of Forage — Must Be Corrected

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

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

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

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

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

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

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

 

Wild-Horses — Sparsely Populated, Widely Dispersed

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

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

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

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

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

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

Antelope Complex:

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

Triple B Complex:

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

 

Authorized v. Actual Livestock Use

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

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

But there’s more to this “use” issue. “Actual use” really means “billed use” — how many AUMs BLM billed permittees for having used. But because actual use is whatever the permit-holders self-report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not — see Bundy, Cliven — the actual-use number is unverified and likely under-reported.

 

Actual Grazing Use Report — Form 4130-5

As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Actual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”

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

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

Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the AUM-usage reported on Form 4130-5 is suspect.

 

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

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

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

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

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

 

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

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

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

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

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

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

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

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

The AUM for a wild horse presumes a mustang is the equivalent of a 1,000-pound saddle horse. But mustangs tend to be smaller and lighter, weighing 700 to 900 pounds. Moreover, in contrast to cattle, wild horses are “easy-keepers” that thrive on poor-quality forage.

BLM needs to revisit and reform how it assesses forage-usage for cattle versus wild horses. Cattle need an AUM surcharge; wild horses need an AUM discount that reflects less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.

 

Sheep Production Continues Long Decline in the US

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

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

 

Facilitation and Commensalism — Equids Enhance the Ecosystem

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

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

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

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

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

 

Rangeland Health Monitored Using Method Considered Less Accurate

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

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

 

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

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

 

Lagomorphs

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

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

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

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

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

 

Locusts

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

Grasshoppers thrive on the warming Wyoming range

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

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

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

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

 

BIRTH RATE AND GROWTH RATE ARE DIFFERENT

 

Birth Rate ≠ Growth Rate

Before we examine BLM’s reported herd-growth rates for these HMAs, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. The birth rate will necessarily be higher than the herd-growth rate. Here’s why: Horses die.

 

Foal Mortality Rate = 50%

An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records of four representative herd management areas with a robust sample-size of 5,859 wild horses. While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish before their first birthday. Thus, the 20% foaling rate is merely a temporary “blip” in the data. The effective foal-to-yearling survival rate is just 10%. By failing to adjust the population-estimates per expected foal mortality, BLM inflates the figures.

 

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

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

 

Stochastic Events — Also Reduce Herd Growth

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

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

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

Imagine if such a catastrophe were to befall the subject herds. Note that the Saiga deaths involved antelope-mothers and their calves. What if these HMAs’ mares and their foals perished all of a sudden, leaving mainly stallions, geldings, and sterile elderly mares? BLM must proactively manage the herds per IUCN guidelines, if only in case of stochastic events.

 

Normative Annual Herd-Growth = At Most, 5%

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

 

Maximum AML Set Below Minimum Viable Population

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

 

FRAUDULENT POPULATION DATA

 

Lies, More LIes, and Statistics

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

 

Antelope Complex Herds

Name of HMA: Antelope

Year Population Percent Compared to
Change 5% Norm

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

 

Name of HMA: Antelope Valley

Year Population Percent Compared to
Change 5% Norm

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

 

Name of HMA: Goshute

Year Population Percent Compared to
Change 5% Norm

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

 

Name of HMA: Spruce-Pequop

Year Population Percent Compared to
Change 5% Norm

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

 

Triple B Complex Herds

Name of HMA: Maverick-Medicine

Year Population Percent Compared to
Change 5% Norm

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

 

Name of HMA: Triple B

Year Population Percent Compared to
Change 5% Norm

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

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

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

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

 

Unethical Manipulation

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

 

Is There a Mandate to Practice Scientific Integrity?

Yes. The Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states:

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy.

 

Fraud Is a Crime

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

 

Fraudulent Data Emboldens Scofflaws, Costs Wild Horses Their Freedom

In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use. Conditions are egregious in Nevada, where the notorious Cliven Bundy and sons, and permittees Kevin Borba and Dan Filippini, blatantly defied BLM’s authority. Yet, they were pacified with non-enforcement and concessions. BLM enables and rewards such bad behavior by caving in to it. Meanwhile, poor LaVoy Finnicum lost his life because, per precedent BLM stand-downs, he concluded that BLM and FBI would not enforce the law.

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

There are likely other permittees in Nevada emulating Bundy, Borba, and Filippini. Wild horses must not lose their freedom merely so that BLM can placate greedy and rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that elected officials and ranchers are building due to the false appearance created by fictitious herd-growth figures.

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

 

Societal Impact of Inflated Population-Data

The population-figures for the subject HMAs are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly state and local elected officials and permittees — in an uproar over a false “overpopulation” that BLM’s faulty figures portray. BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must stop this phony-story-gone-viral of a wild-horse population-explosion.

 

HELICOPTERS — INAPPROPRIATE FOR COUNTING WILD HORSES

 

But the Inventory Counted That Many Horses

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

 

Helicopter Inventories Produce Gross Over-Counts

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

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

 

Both the Roundup-Contractor and BLM Are Looking to “Make Their Numbers”

A glance at the map of the HMAs in question reveals that they are contiguous, and public lands are interspersed with private lands. How easy it would be for a profit-motivated helicopter-pilot to “poach” wild horses from strictly public lands by driving them into target-areas. What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?

The helicopter-pilot is looking to “make his numbers” but so is BLM. Thus, BLM has a conflict of interest in needing the contractor to remove any 6,737 horses that he can find. The wild horses are fungible — one is as good as another — to make the pilot his money and to enable BLM to spend the budget. Consequently, wild horses would lose their freedom for the private profit of the helicopter-contractor and for the administrative, job-justifying convenience of BLM. Unacceptable.

 

Dealing with Roving Equids

Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. However, removing horses that have wandered outside their HMAs just creates a vacuum for other horses to fill. Thus, removing them is an ineffective population-control strategy. The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs. The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant. Thus, removal is not a true solution — it just perpetuates the situation and leads to the elimination of more mustangs than necessary. Moreover, the wanderers may be only temporary visitors or refugees, not permanent residents. Worse yet, they may have been driven into the checkerboard by the helicopter.

Recommendations: In legitimate instances of straying, BLM should first encourage the wild horses to return to their proper place, then address those factors that caused the animals to leave home. Would palatable plantings draw the wild horses to the areas BLM wants them to use? What about siting mineral licks deep inside the HMAs, away from the outskirts? Have guzzlers been installed to provide water sources deep within the boundaries? Aversive conditioning could also be employed to shoo the wild horses into the solid-block public lands. Certainly, positive reinforcement coupled with aversive conditioning would be an effective and cost-effective solution. BLM should specify preventive and reactive measures in this regard as part of its management approach. Return outsiders to the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from “outside” areas (aversive techniques).

 

HELICOPTERS — DANGEROUS TO HUMANS, HORSES,
AND THE ENVIRONMENT

 

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

 

POPULATION-CONTROL BY NATURE

 

Predators Prey on Ponies

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

 

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

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

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

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

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

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

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

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

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

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

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

 

Healthy Predators, Healthy Ecosystems

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

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

Essential predators

 

Predator Protection

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

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

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

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

 

PZP — BLM PROPOSES TO DEPLOY IT AGAINST WILD MARES

 

PZP — The Pesticide

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

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

 

PZP — an Anti-Vaccine

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

 

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

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

 

PZP’s True Mode-of-Action

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

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

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

Included as a reference to the EA? No.

 

Study Shows PZP Elicits Ovarian Pathologies

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

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

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

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

Included as a reference to the EA? No.

 

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

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

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

 

PZP Causes Ovarian Cysts

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

Included as a reference to the EA? No.

 

PZP → Endocrine Disruptor → Elevated Testosterone → Masculinizing Effects

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

 

PZP → Ovarian Cysts → Elevated Testosterone → Masculinizing Effects

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

 

PZP Causes Additional Adverse Effects

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

 

PZP Selects for Weak Immune Function

Gray & Cameron’s analysis raised the possibility of PZP selecting for immuno-compromised individuals. Here’s why. Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function. Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries. But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed. Those mares fail to respond to PZP. They keep getting pregnant and producing foals who, like their dam, suffer from weak immune-function. So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised. Thus, a herd being treated with PZP is undergoing selective breeding for weak immunity, which puts the population at risk for disease — and ultimately, for extinction.

 

PZP Confers Dubious “Benefit” of Increased Longevity

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

 

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

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

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

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

Included as a reference to the EA? No.

 

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

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

 

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

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

Included as a reference to the EA? No.

 

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

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

 

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

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

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

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

 

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

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

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

 

Prolonged Delay in Recovery of Fertility

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

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

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

 

Ransom Advises Proceeding with Caution regarding PZP

The Ransom et al. study warned:

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

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

 

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

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

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

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

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

 

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

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

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

Included as a reference to the EA? No.

 

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

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

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

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

 

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

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

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

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

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

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

 

PZP Continues the Use of Roundups and Removals

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

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

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

Risks to Humans Who Administer PZP Injections

For BLM staff, contractors, and volunteers who inject wild horses with PZP, EPA’s Pesticide Fact Sheet advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility.

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

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

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

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

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

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

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

 

Mandate to Practice Scientific Integrity

Let us return to the Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct, which applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states:

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy.

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

 

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

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

 

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

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

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

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

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

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

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

 

PZP — Conclusions about

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

 

GONACON™ — BLM CONSIDERS DEPLOYING IT AGAINST THE HERDS

 

Gonacon™ — Yet Another Immuno-Pesticide

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

 

GonaCon™ — Mechanism of Action

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

 

Gonacon™ — Link to PZP

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

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

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

 

Gonacon™ — Causes Long-Term Infertility

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

 

Gonacon™ — Adverse Side-Effects, Chance of Sterilization

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

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

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

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

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

 

GELDING — BLM WANTS TO STERILIZE HALF OF THE STALLIONS

 

Geldings Are Not Normal in Nature

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

 

Gelding Would Severely Impact Genetic Diversity

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

 

CONCLUSIONS

 

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

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

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

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

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

 

———————————————-

Sincerely,

Marybeth Devlin

———————————————-

 

REFERENCES

 

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



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

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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.”

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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