While pretending to rely on the assumption that herds grow 20% a year, the Bureau of Land Management (BLM) posts numbers up to 8 times higher than that to justify roundups, which are pre-scheduled on a rotation-basis, seeming to target particular herds. For instance, the Agency recently claimed that the famous Kiger herd in Oregon grew from 21 horses to 156 horses in just four years — an increase of 643%, which equates to a yearly average increase of 160%, which is 8 times higher than the 20% BLM supposedly uses. [1] Such growth is biologically impossible. Kiger is not an isolated example, although it is the worst found so far. Here are some other phony figures on population-growth recently claimed by BLM to make it appear that gathers were necessary:
Blawn Wash (UT)
297.4 % increase in 3 years, averaging 99.1 % per year
Fish Creek (NV)
80% increase in one year
Green Mountain (WY)
281% increase in four years, averaging 70.3% per year
Stewart Creek (WY)
311% increase in four years, averaging 77.8% per year
But herd-growth is unlikely to reach even 20 percent a year. It is important to understand that the birth-rate is not the same as–and should not be equated to–the population growth-rate. Here’s why: Horses die. An independent study reviewed BLM roundup-records for a representative sample of four herd management areas composed 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. Further, adult wild horses also perish. They succumb to illness, injury, and predation. Their death-rate must be taken into consideration as well. But BLM ignores mortality–foal and adult–in its population-estimates. Given the 50% foal mortality-rate, and the 5% or higher average annual death-rate of adult wild horses, herd-growth could not increase 20% a year, and a herd-population could not double in 4 years–refuting yet another BLM myth.
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 how BLM creates the false impression of a population-explosion. 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.
BLM also fails to consider another factor limiting herd-growth–stochastic events–which are random catastrophes such as wildfires or contagious diseases that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.
Now BLM is distributing grant-money to universities and researchers to study more ways of dealing with the phantom overpopulation. All manner of sicko experiments are being carried out on the wild horses, such as treating them with endocrine disruptors and sterilizing them surgically. Why? Because BLM is a corrupt agency. It invented this counterfeit crisis to create a sense of urgency, which will pressure Congress to give the Agency extra money to “solve” a non-existent problem.
Contact your elected officials to make them aware of BLM’s fraudulent population claims to get funding for wild horse roundups and warehousing at great taxpayer expense: http://www.contactingthecongress.org
Visit www.ProtectMustangs.org for more information and click on the donate button help fight the injustice! You can make a difference.
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.
(Photo by BLM. Roundup paid for with your tax dollars.) Addendum:
[1] Using simple division to calculate the average increase is how most people would “do the math”–dividing the percentage increase (643%) by the number of years (4). Expressing the average that way is readily understandable. However, another way of calculating it is what is called the “compound annual growth rate” (CAGR). Per that method, herd-growth can be likened to compound interest that you earn on a savings account; except of course that horses do die, which complicates the computations. But for now, let’s assume that horses never die, because that’s the assumption that BLM makes.
Using the free, online CAGR tool linked below, you would enter Kiger’s beginning population–21–and its alleged ending population–156–and the number of years that had passed–4. Then press the “Calculate CAGR” button, and the tool will compute the compound annual growth rate. For the Kiger herd, the CAGR is 65%, which is “only” 3.25 times higher–instead of 8 times higher–than 20%.
Here are the other herds cited and their CAGRs. Fish Creek stays the same because its growth is just for one year.
Blawn Wash (UT)
38 = Population-estimate 2012
151 = Population-estimate 2014, including new foals
297.4 % = Percentage increase in three years
99.1 % = Simple average annual growth-rate
58.4 % = Compound annual growth-rate (CAGR)
Fish Creek (NV)
256 = Population-estimate 2013
461 = Population-estimate 2014, before foaling season (January)
80.1% = Percentage increase in one year
Green Mountain (WY)
258 = Population-estimate post-gather at the end of 2011
982 = Population-estimate in 2015 — including that year’s foals*
281.0 % = Percentage increase in four years
70.3 % = Simple average annual growth-rate
39.7 % = Compound annual growth-rate (CAGR)
Stewart Creek
124 = Population-estimate post-gather at the end of 2011
509 = Population-estimate in 2015 — including that year’s foals*
311.0 % = Percentage increase in four years
77.8 % = Simple average annual growth-rate
42.3 % = Compound annual growth-rate (CAGR)
* BLM’s population-modeling criteria said foals were not included in the AML. Evidently, they were.
Further Insight into Calculating Population-Growth
At the link below, you will find a discussion posted by the University of Oregon, providing a comparison between the simple average and the compound annual growth-rate methodologies for calculating annual percentage population-growth.
As will be readily apparent, the simple average approach is “straight-line” and … simple. Forgive yet another pun, but the average person can easily understand it and “do the math.”
The compound annual method, on the other hand, is extraordinarily complicated to compute, which is why the online tool is almost a necessity.
What is important is that both are legitimate ways of describing the data.
It should be kept in mind that population-growth estimates must consider births and deaths, not just births. That’s one reason why the Gregg et al. study was so important — it established, per BLM’s own documentation, a slightly-less than 20-percent birth-rate and a 50-percent foal mortality-rate. So, a wild-horse herd growth-rate of, for example, 65%, would have to mean a birth-rate that was much higher than 65% to offset foal deaths (50%) and adult deaths (5%).
We are updating this page so check back for more information as the scandal unfolds. Updates are being posted towards the bottom.
Save the young victims of the cruel experiment!
Wild foals captured from the Water Canyon portion of the Antelope Herd Management Area in eastern Nevada are up for adoption. They are the victims of a roundup to EXPERIMENT on wild horses with GONACON™. Nine weanlings and two yearlings are being held together at the National Wild Horse and Burro Center at Palomino Valley, north of Reno, Nevada. They need to be saved now and hopefully in pairs because this is so painful for them to have lost their families!
The wild horses are available for walk-up adoption from 8 a.m. to 4 p.m., Monday through Friday, and 8 a.m. to 2 p.m., Saturdays. All of the horses have received vaccinations and their bloodwork is completed. Brand inspections will be performed and health certificates issued on all adopted horses.
For more information, contact Jeremy Wilhelm, BLM public contact person, at (775) 475-2222.
The GONACON™ EXPERIMENT is being humane-washed by the Bureau of Land Management (BLM) and their partners. They are perpetrating the overpopulation myth when in truth America’s wild horses are underpopulated. In their experiment they are releasing only a fraction.
Nations says, “I wanted to mention also, that we did a quick online petition for about 6 days with American Wild Horse Preservation Campaign regarding this same proposal and we had over 19,000 people from all around the country and the world in favor of doing this pilot program.This just goes to show how badly people want a positive change in wild horse management!
Do people realize what they are signing and supporting when they sign petitions put out by the American Wild Horse Preservation Campaign? Are they reading the whole document or just reading the first paragraph and clicking quickly to add their name?
Why did the BLM take the Spin Dr.’s push for fertility control and turn it into an EXPERIMENT with GONACON™? It’s a slippery slope when “advocates” partner up with BLM for fertility control . . . American herds are becoming nonviable and will be wiped out.
GONACON™ like PZP is an EPA restricted use pesticide (see photo below). The BLM and their supporters are experimenting on America’s wild horses because the Feds see them as PESTS and want to dispose of them slowly . . . They hope the public won’t realize what’s happening.
Now it’s clear that some alleged “wild horse advocates” pushing fertility control, like PZP and GONACON™, are helping BLM not wild horses.
Update 5:27 pm PST: Why is the BLM’s Project Coordinator (volunteer) of the GONACON™ EXPERIMENT and BLM RAC member now raising money for her alleged Angels Acres Rescue to adopt the “Lucky 11” as she calls them? Yes she is calling the victims of this horrible GONACON™ EXPERIMENT and roundup “Lucky”.
Ask yourself if this:
Why didn’t the well funded wild horse preservation groups fight in court to stop the Water Canyon roundup?
Was this just another opportunity to get more donor data by sending out an online petition but do nothing to stop the roundup?
Is it because they are in with BLM, want more names on their email lists to push for fertility control?
November 08, 2015 5:45 am • LARRY HYSLOP A research project north of Ely will look at maintaining a stable wild horse population using a contraceptive. The goal is to treat mares with Gonacon, a commercial contraceptive, and then watch them over several years to make sure the project mares do not produce foals.
Jeanne Nations is a volunteer project coordinator who lives in the area, frequently visits the horses and knows most by sight. She will handle the on-site adoptions and help Ben Noyes, in charge of the project, and the Wild Horse Specialist in the BLM Ely District Office. Jeanne said if this research is successful, she hopes it could help other areas provide a more humane way to keep wild horse populations under control.
The Northeastern Nevada Resource Advisory Council recently visited the project site, after submitting a letter to the BLM’s Wild Horse and Burro Program supporting Jeanne’s project.
The research site is north of Ely, on a narrow strip of public land 12-15 miles long between U.S. Highway 93 and the Schell Creek Range. A fairly isolated group of 66 wild horses currently live in this part of the Antelope Herd Management Area, which has 803 wild horses with an Appropriate Management Level of 324. The nearest other wild horses to this project area are over the mountains to the east.
Trapping has begun and Ben has gathered 35 horses so far. All the rest of the area horses will be trapped this fall. Ben feels he can capture all the area horses using water and bait trapping but will use other techniques if needed.
While the last few members of the Council were visiting the trap site, seven horses came into the trap to eat hay and drink water, showing they are quite comfortable with the trap.
About 30 horses will be part of the project, with the rest removed from the area. It is hoped on-site adoptions will take most of the removed horses but any remaining will be taken to holding areas. People interested in adoption can email Jeanne at jnphotography@hughes.net.
The project horses kept on the site will consist of 15 stallions and 15 mares, having an assortment of ages. After capture, mares will be treated with Gonacon and freeze branded. DNA samples will be collected from all horses. The problem then is the mares must receive a booster 30 days later, so all mares and some of the stallions will be kept in holding pens. After the 30 days, the horses will be released back into their home range. Ben feels the horses should have no problem re-habituating to their open range after a month of daily hay and abundant water.
Ben and Jeanne will keep an eye on the mares and watch them for pregnancies. The mares will need to be gathered again in two years to receive another booster.
There is a good chance the project mares are now pregnant and will produce foals the first year. However, these treatments should keep the mares from becoming pregnant again during the length of the project. After the project ends, it is hoped the mares will then become pregnant. Other horses may cross the mountains to join this group but they will not throw off the research since only the branded mares will be watched.
We are sharing this anonymous tip in hopes legal action or rescue will follow to save the thousands of horses who are still alive.
#TakeAction to demand horse slaughter stop now!
Email Secretary Sally Jewell ( Secretary_jewell@ios.doi.gov ). The Secretary of Interior oversees the Bureau of Indian Affairs. You can also write her a letter. Here is her address:
The Honorable Sally Jewell Secretary of the Interior
Join the movement to Protect Mustangs by liking the Facebook page: www.Facebook.com/ProtectMustangs Check the page daily and invite your friends to join the movement to protect mustangs!
We are working for the wild horses on Twitter too so Join up at www.Twitter.com/ProtectMustangs You can also join our Founder and Executive Director, Anne Novak, on Twitter at www.Twitter.com/theAnneNovak There is a lot we can do together to Protect Mustangs!
Please share this video so people will learn what is going on. Then they can demand change and legal action to stop the slaughter of thousands of wild horses!
Video Copyright Protect Mustangs, 2015, all rights reserved. Photo copyright Christina Lynn Williams Photography
We are against experimenting on wild horses, harassment and animal cruelty, period. We believe the 1971 protection act should protect mustangs from forcing ovarian ligation on them. This underpopulated species is in crisis and ovarian ligation is a risky procedure that should never be done on America’s icons of freedom.
Proposal of Ovarian Ligation
By Sandee Force on Monday, August 24, 2015
From: Members of Wild Horses, BLM and Logical Solutions
To: U.S. Wild Horse and Burro Advisory Council
Re: Population Management of wild herds on HMAs
The members of the Wild Horses,BLM and Logical Solutions have spent time considering potential solutions to the ever increasing number of horses and burros needing to be removed from the range held in both Long Term Holding and Short Term Holding. We feel that a two pronged program would both greatly decrease the number of animals needing to maintained in this manner and allow older mares to live out their lives on the range.
We would like to suggest that ovarian ligation be put into an immediate test program in at least 2 and preferably 3 herds using herds that are widely watched and recorded by regional photographers. Our suggestion would allow for mares that are old enough to have had at least 4-5 foals accessed at gathering and removed to the closest holding facility to do ovarian ligation by a veterinarian who has experience in this procedure. We would suggest that working with the state veterinary school located closest to each facility would be the optimal way to get young vets trained on this procedure and to potentially hire vets specifically for the program from this pool of trained professionals. We realize that standard policy would normally be to spend a number of years doing in pen trials with horses thatwould be scheduled to go to LTH. We feel that this can be bypassed by using herds that are currently being observed and by training the photographers to record information on these mares that would give accurate information about how they assimilate back into the herds. We would like to suggest that along with the ovarian ligation all fillies 3 and under be given PZP and allowed to be more mature at first foaling.
To summarize our proposal as accurately as possible, allowing for changes needed by region or herd.
1. Two to three test herds be chosen that mares will be brought in and those 3 and under be given the correct dosage of PZP for their age and mares that are of an age to have 4-5 foals on the ground have the ovarian ligation procedure done to at the holding facility. Those mares that are operated on can be held for an appropriate period for recovery at the facility to document reaction and to ensure proper healing of all incisions before being returned to the area that they were captured. Any foals that are under weaning age should stay with the mare in the holding facility and be release with her. Use a
small hip brand to designate ovarian ligation for observation purposes.
2. Any mare that shows a major genetic defect or has thrown multiple foals with genetic disorders should automatically be put into the ovarian ligation program no matter what the age.
3. Train photographers and volunteers to work with the USGS and Universities to properly document range interaction of both the mares who have been given ovarian ligation and those fillies given PZP. Video and photographic documentation of herd/band interaction would be ideal. It is imperative to have USGS and at least one University involved in both
documentation and study of the effect of ovarian ligation on herd dynamics and the health and well being of both, mares and foals as well as the local bands that they belong to.
4. Document the short and long term consequences of ovarian ligation on the mares, i.e. heath, longevity, and acceptance/position within the band. Note if the mares are removed from the bands and act like bachelor stallion bands.
5. Within 3 years if the results of the test herds are good expand to other BLM managed herds with the goal to cut down on required gathers to once every 6-8 years.
6. Look into the possibility of darting with PZP every 2 years to expand the time young mares have a chance to mature before starting to foal.
The goal of this plan is to decrease the rate of population growth on the range.
In conjunction it would allow these older mares to stay on the range without adding to population growth until their deaths and not have to be gathered and shipped to Long Term Holding Facilities for their senior years. Between the ovarian ligation and using PZP on the fillies the herd’s rate of growth could be reduced by 50% per year. This would substantially help both the range and the cost of gathering and housing the horses and burros while keeping more horses on the range. By hip branding the mares that have had ovarian ligation you would be able to gate cut those mares back onto the range at any subsequent gather and not have to haul them off the range.
Some of the herds suggested for this procedure are South Steens, Oregon; Sand Wash Basin, Colorado; Twin Peaks, California; and/or BLM HMA around the Reno/Carson area of Nevada. These are herds that have been previously documented and in the case of both Sand Wash Basin and South Steens there is photographic documentation of the herds for 5-7 years that would be available to work within this project.
Respectfully
Submitted,
Sandra Force – Junction City, Oregon
AJ Sutton- Lawndale,Ca.
Kari Masoner – Tuson, Arizona
Ana Andrick – Wellington, Colorado
Nancy Warrick Kerson – Napa, California
Kathleen T. Granzow – Genoa City, Wisconsin
Thomas P. Brunshilde – Hammond, Wisconsin
Karen Goodroad – Pleasant Hill, Oregon
Lea Erwood – Rosedale, IN.
Kathryn Shirley – Holly Springs, North Carolina
Margaret Rothauge (Maggie) Creswell, Oregon
Angela Robey – Witch Well, AZ
Tom Hool – Casper, Wyoming
Debbra Dotson Christensen – Coquille, Oregon
Stephanie Jones – Eugene, Oregon
Jamie M. Adkins – Casper, Wyoming
Lisa Sink-Sheridan, Oregon
Beverly Shaffer – Burns, Oregon
Ramona Bishop – Burns, Oregon
Shyla Creasey – Oregon
Stacey Harnew –
Andi Harmon – Burns, Oregon
Keelyn Fawcett – Salem, OR
Kimberly Omnes
Mark Omnes
Angela “Angel” Rakestraw – Dinwiddie, Va
Jennifer Gregton – Midvale, Idaho
Iris Benson – Corvallis, Oregon
Karen Landis – Centralia, WA
Candy Nichols – Poolville, TX
Christina Picchi
Bree Alsman – Sandy, Oregon
JoAnna Lamb – Boardman, Oregon
Tracey Westbury – Bellingham, Washington
Cathy Smith – Pleasant Hill, Oregon
Rhonda Chayer – Barton, Vermont
Debbie Jackson – Ellensburg, Washington
Jes Sothern – Oregon
Rex Moore – Denton, Texas
Rose Howe – Monument, Oregon
Kerry O’Brien – Van Nuys, CA.
Susan Clogson – Woodinville, Washington
Nancy Willard – Eugene, Oregon
Loretta M. Jones – Redmond, Oregon
Jennie Kreutzer – Arlington, Washington
Monica Shifflet – New Haven, PA
Crystal Cooke – Clovis, New Mexico
Christie Brown – Daphne, Alabama
Pat Garcia – Burnet, Texas
Carrie Marie Fuesler – Brownsville, Oregon
Jackie Mousseau – Clinton Township MI
Betty Forman
Kathy Tellechea – Lexington, OR
Jim Bishop – Hines, Oregon
Angela Huston – St Louis, Missouri
Mike Huston – St Louis, Missouri
Kay Hamilton – Phoenix, OR
Richelle Wilson – Hillsboro, OR
Suzanne Ganazzi – Point Reyes Station, California
Tina Smith – Sommers, Conn
Andrea Walker – Fort Worth, Texas
Jeni Adler Snyder, Oklahoma
Ash Michael – Madison, South Dakota
Ashley Lawler
Brigid Piccaro – Acton, California
Kathryn Meyer – Orion, MI
Nancy Kohl – Surprise, Arizona
Jeni Adler – Snyder, Oklahoma
Kate Bogel – Howell, New Jersey
Lara Mogensen – Ellensburg, Washington
Carol Davis – Selma, Oregon
Susan Humphrey – Hot Springs, South Dakota
Gini Everts – Eugene, Oregon 72
To the Office of the Inspector General at the United States Department of Interior
Dear Sirs,
We officially request a full investigation into the management of wild horses and land use planning 6 years before the roundup, the roundup itself, feeding, veterinary care and killing of the 28 Cold Creek wild horses who had become skinny.
Why didn’t the BLM help these federally protected wild horses get the forage they needed earlier?
Why didn’t the BLM move the native wild horses up to areas with more forage?
What happened to their forage?
What about the livestock grazing permits? (see attached)
Why aren’t the Cold Creek wild horses getting their fair share of the land that is for their principal but not exclusive use according to the 1971 Free Roaming Wild Horse & Burro Protection Act?
Why is the agency appointed “appropriate management level” (AML) for wild horses so low when a genetically viable herd needs more members?
Why is the BLM limiting access to the public to bare witness to this cruel roundup?
Was euthanasia chosen for convenience and the bottom line, pure and simple?
Did they look at the feed and labor involved vs adoptability and take the cheap and easy way out?
Rescues and members of the public would have helped bring the Cold Creek wild horses back to health if manpower was an issue. Adoption would have been simple once they healed because people know about them and cherish them.
Tourists from around the world, visiting Las Vegas, love the wild horses of the American West.
The BLM continues to roundup more beloved Cold Creek wild horses and we pray they will not kill any more but nurse them back to health.
The public is outraged.
We thank you for investigating into the wrongdoings surrounding the management, roundup and killing of 28 Cold Creek wild horses, provide transparency and shine the light of truth.
Sincerely,
Anne Novak
Anne Novak
Executive Director
Protect Mustangs
Tel./Text: 415.531.8454
Anne@ProtectMustangs.org
Dave Duquette (Horse Slaughter Pusher) hugs Sharon Stone on the set of RUNNING WILD Produced by Forrest Lucas from PROTECT THE HARVEST the 501c4 organization lobbying to open HORSE SLAUGHTER plants in the USA and pushing for WILD & DOMESTIC HORSE SLAUGHTER
According to Variety, Running Wild tells the tale of a widow, Stella Davis, who saves her ranch by working with convicts to rehabilitate a herd of wild horses that have wandered onto her property. Sons of Anarchy star Tommy Flanagan has been recruited to play Ponytail John, the alpha male of the group of convicts, while Dorian Brown has been cast to play Stella. Sharon Stone will play Meredith, the movie’s main villain.
Do these actors starring in the film RUNNING WILD know that wild horses are underpopulated in the wild? Do they understand how cruel and inhumane horse slaughter is?
Have they seen this?
Do these Hollywood actors realize they are being used by HORSE-SLAUGHTER Pushers like Dave Duquette and ESX Entertainment’s producer Forrest Lucas who are behind Protect the Harvest. That’s the HORSE SLAUGHTER non profit working to set up horse slaughter plants in the USA for domestic and wild horses.
Dave Duquette (Horse-Slaughter Pusher) with Tommy Flanagan (Sons of Anarchy) on the set of RUNNING WILD Produced by Forrest Lucas from PROTECT THE HARVEST the 501c4 organization lobbying to open HORSE SLAUGHTER plants in the USA and pushing for WILD & DOMESTIC HORSE SLAUGHTER
Dave Duquette (Horse-Slaughter Pusher) with Tommy Flanagan (Sons of Anarchy) on the set of RUNNING WILD Produced by Forrest Lucas from PROTECT THE HARVEST the 501c4 organization (Super PAC) lobbying to open HORSE SLAUGHTER plants in the USA and pushing for HORSE SLAUGHTER
Dave Duquette (Horse-Slaughter Pusher with PROTECT THE HARVEST) with Dorian Brown (left) starring in RUNNING WILD Produced by Forrest Lucas CEO of ESX and PROTECT THE HARVEST the 501c4 organization (Super PAC) lobbying to open HORSE SLAUGHTER plants in the USA with the writer of RUNNING WILD Christine Moore (right)
Dorian Brown riding lesson for RUNNING WILD Produced by Forrest Lucas from PROTECT THE HARVEST the 501c4 organization (Super PAC) lobbying to open HORSE SLAUGHTER plants in the USA and pushing for WILD & DOMESTIC HORSE SLAUGHTER
Protect the Harvest, the Horse Slaughter Super PAC, have their logo on the back of the crew’s T-Shirts (see below) to advertise their organization pushing for HORSE SLAUGHTER to come back to the USA
Members of the crew are wearing t-shirts with the Super PAC logo on it “Protect the Harvest”.
Looking at the Wikipedia description of the film, “…widow Stella Davis, fighting to save her ranch from a herd of wild horses by working with convicts…” these actors must know what they are doing.
Sharon Stone will star in the drama “Running Wild” for Forrest Lucas and Ali Afshar’s newly launched ESX Entertainment.
Alex Ranarivelo (“The Wrong Side of Right”) is directing the film from a script by Christina Moore and Brian Rudnick.
Stone will portray the villain in “Running Wild,” which centers on a widow who saves her ranch by working with convicts to rehabilitate a herd of wild horses that wandered onto her property. The role of the widow will be cast shortly.
“Running Wild” is financed and being produced by ESX Entertainment, with Lucas and Afshar serving as producers. Christina Moore is co-producer.
Protect the Harvest, the Super PAC made a video filled with untruths, skewed statistics and an old dying horse allegedly starving yet with grass around her — to push for opening horse slaughter plants in the USA. Cattle activists are featured.
Lucas’s television production company is making a documentary about abandoned horses starving to death on public lands in the U.S. He wants to reintroduce horse slaughter plants in the United States to allow a better end of life for abandoned, old and unused horses.
Production
On July 29, 2015, it was announced that Alex Ranarivelo would direct the Horse drama film Running Wild based on the script by Brian Rudnick.Forrest Lucas and Ali Afshar would produce the film through ESX Entertainment, and the banner would also finance the film.On August 18, 2015, Sharon Stone signed on to play the main villain role in the film as Meredith, while the script was done by Christina Moore and Rudnick, and Moore would also co-produce the film.On August 19, 2015, Dorian Brown and Tommy Flanagan joined the film, Brown to play the lead role of a widow Stella Davis, fighting to save her ranch from a herd of wild horses by working with convicts, while Flanagan to play the leader of the convicts. On August 20, 2015, Jason Lewis joined the cast to play the male lead.
Helicopter roundups will increase to administer PZP
95% of the herds can’t be shot with darts in the field
Does the Humane Society of the United States (HSUS) want to take over the Wild Horse and Burro Program, pushing forced drugging with PZP (pesticide made from slaughterhouse pig ovaries http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf) for management on underpopulated herds? PZP is a “tool” to manage wild horses to extinction. Science proves PZP (native, 22, etc.) sterilizes after multiple use.
Isn’t the American Wild Horse Preservation Campaign (AWHPC) the wild horse mouthpiece for HSUS? Doesn’t their pledge to “keep them in the wild” written up in the Huffington Post include forced drugging with PZP as their cornerstone management tool? Does HSUS want to create zoo-like settings to “keep them in the wild”? HSUS endorsed the former Secretary of Interior’s Plan, aka the Salazar Plan, in 2009. Now the plan is entering the final wipe-out phase with the help of PZP pushers.
For decades native wild horses have been used by the pharmaceutical industry as lab rats for birth control “research” at huge taxpayer expense. This involves killing wild horses to research drug damage on ovaries and other organs. PZP = Roundups = Cruel Animal Experiments
Roundups occur to PZP the wild mares with a pesticide for birth control!
Send in your public comments and be a voice for America’s wild horses and burros! Ask for management levels to rise for genetically viable herds to survive and for holistic management for all Herd Management Areas. Speak for the voiceless today.
Proposed Collection of Information on Wild Horses and Burros; Request for
Comments.
AGENCY: Bureau of Land Management, Interior.
ACTION: 60-day notice and request for comments.
SUMMARY: In compliance with the Paperwork Reduction Act, the Bureau of Land
Management (BLM) will ask the Office of Management and Budget (OMB) to approve
the information collection (IC) described below, and invites public comments on the
proposed IC.
DATES: Please submit comments on the proposed information collection by May 11, 2015.
ADDRESSES: Comments may be submitted by mail, fax, or electronic mail.
Mail: U.S. Department of the Interior, Bureau of Land Management, 1849 C Street, NW,
Room 2134LM, Attention: Jean Sonneman, Washington, D.C. 20240.
Fax: to Jean Sonneman at 202-245-0050.
Electronic mail: Jean_Sonneman@blm.gov.
Please indicate “Attn: 1004-NEW” regardless of the form of your comments.
FOR FURTHER INFORMATION CONTACT: Sarah Bohl at (202) 912-7263.
Persons who use a telecommunication device for the deaf may call the Federal
Information Relay Service on 1-800-877-8339, to contact Ms. Bohl. You may contact Ms. Bohl to obtain a copy, at no cost, of the draft discussion guides for the focus groups and in-depth interviews described in this 60-day notice. You may also contact Ms. Bohl to obtain a copy, at no cost, of the regulations that authorize this collection of information.
SUPPLEMENTARY INFORMATION:
I. Proposed Information Collection
Title: Knowledge and Values Study Regarding the Management of Wild Horses and Burros.
OMB Control Number: 1004-NEW.
Frequency: On occasion.
Respondents’ obligation: Voluntary.
Abstract: The BLM protects and manages wild horses and burros that roam Western public rangelands, under the authority of the Wild Free-Roaming Horses and Burros Act (Act), 16 U.S.C. 1331-1340. The Act requires that wild horses and burros be managed in a manner that is designed to achieve and maintain a thriving natural ecological balance on the public lands. 16 U.S.C. 1333(a). Stakeholders and the general public hold a variety of views on how wild horses and burros should be managed. The BLM has determined that conducting focus groups, in-depth interviews, and a national survey will lead to a better understanding of public perceptions, values, and preferences regarding the management of wild horses and burros on public rangelands.
After reviewing public comments and making appropriate revisions, the BLM will include the discussion guides in a request for OMB approval. Upon receiving OMB approval, the BLM will conduct the focus groups and in-depth interviews. The results of focus groups and in-depth interviews will be used to help design a national survey, which will be the second and final phase of the research.
The BLM will prepare a draft of the national survey and publish a second 60-day notice and invite public comments on the draft national survey. After reviewing public comments and making appropriate revisions, the BLM will include the national survey in a request for OMB approval. Upon receiving OMB approval, the BLM will conduct the national survey.
Need and Proposed Use: The proposed research was recommended by the National Research Council of the National Academy of Sciences in a 2013 report, Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward. Conducting the focus groups and in-depth interviews will enable the researchers to characterize the range of preferences that exist for wild horse and burro management. The national survey will then assess the distribution of these preferences across the larger population. The research results will assist the BLM to more effectively manage wild horses and burros by providing information to:
Help evaluate the benefits and costs of competing rangeland uses and variousmanagement options;
Help identify areas of common ground and opportunities for collaboration with stakeholder groups; and
Communicate more effectively with the public and with stakeholder groups.Description of Respondents: The BLM intends to survey a variety of respondents for this project by conducting focus groups, in-depth interviews, and a nationally representative survey. For the focus groups and in-depth interviews, the primary respondents will be individuals belonging to a variety of organizations that have previously lobbied, commented on program policy or activities, or have otherwise sought influence with the BLM in regard to its wild horse and burro program. Representatives of wild horse and burro advocacy groups, domestic horse owners, wild horse adopters, the Western livestock grazing community, environmental conservationists, hunters, and public land managers will be included. Nine focus groups across three locations around the country and up to 12 in-depth interviews will be conducted with individuals from these groups. Focus group participants will be recruited by BLM’s research contractor through a variety of approaches tailored to the communities participating in the discussions. In addition, four focus groups (spread across two locations) will be conducted with the general public to explore public understanding of various terms and issues involved in wild horse and burro management so that the questionnaire for the national survey can effectively communicate the relevant topics.
II. Estimated Reporting and Recordkeeping Burden
The estimated reporting burden for this collection is 142 responses and 272 hours. There will be no non-hour burdens. The following table details the individual components and estimated hour burdens of this collection.
Activity
Estimated
number of respondents
Estimated number of responses per respondent
Completion time per response
Total burden hours
Focus Groups
130 (13 groups)
1
120 mins
15,600 mins/260 hrs
In-depth Interviews
12
1
60 mins
720 mins/12 hrs
Activity
Estimated
number of respondents
Estimated number of responses per respondent
Completion time per response
Total burden hours
Totals
142
272 hrs
III. Request for Comments
OMB regulations at 5 CFR 1320, which implement provisions of the Paperwork Reduction Act (44 U.S.C. 3501-3521), require that interested members of the public and affected agencies be provided an opportunity to comment on information collection and recordkeeping activities (see 5 CFR 1320.8(d) and 1320.12(a)). The BLM will request that the OMB approve this information collection activity for a 3-year term.
Comments are invited on: (1) the need for the collection of information for the performance of the functions of the agency; (2) the accuracy of the agency’s burden estimates; (3) ways to enhance the quality, utility and clarity of the information collection; and (4) ways to minimize the information collection burden on respondents, such as use of automated means of collection of the information. A summary of the public comments will accompany the BLM’s submission of the information collection requests to OMB.
Before including your address, phone number, email address, or other personal identifying information in your comment, you should be aware that your entire comment — including your personal identifying information — may be made publicly available at any time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so.
Jean Sonneman,
Bureau of Land Management, Information Collection Clearance Officer.
I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …
Sulphur HMA
… and that are, reportedly, posing safety-concerns along Highway 21.
I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
REASONS CITED BY BLM FOR SPECIAL ROUNDUP
Overpopulation, Forage Limitations
BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.
The Proposed Action
BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830” (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.
The Issues
There are several important questions concerning the planned gather that BLM has not addressed.
What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21”? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?
A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed
Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.
FENCE OFF HIGHWAY 21
Outsiders — Dealing with Roving Equids
Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.
Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.
Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?
And, most importantly, …
Why hasn’t Highway 21 been fenced off near the HMA?
BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.
Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses
Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.
I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.
Wildlife Underpasses — Historical Perspective
Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.
Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.
What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.
The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.
Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!
Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.
At the link below, you will find information and resources regarding the use of overpasses, underpasses, and crosswalks for mitigating collisions between wildlife and vehicles.
You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
FLAWED POPULATION ESTIMATES
Unlikely Birth-Rate
According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.
718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).
This is improbable.
Population and Gather Reports — The Data
Per a review of the …
HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,
discrepancies are evident.
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015
The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made. The beginning-of-the-year figure for 2015 — the pre-gather estimate — is per the BLM’s News Release.
Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
—— —– ———– ————– —————————————————
2008 250 435 + 87 BLM estimated foal-crop @ 20%
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
——
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
—–
267 Post-gather estimate = 38+22+207
2011 267 + 53 BLM estimated foal-crop @ 20%
PZP would not have affected mares
—– already pregnant when inoculated.
320 End-of-year estimate = 267+53
2012 320 + 64 BLM estimated foal-crop @ 20%
But that estimate was wrong.
PZP was at maximum effect and
—– would have reduced the foal-crop.
384 End-of-year estimate = 320+64
2013 384 +334 BLM estimated foal-crop @ 87%
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal- crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 Current estimate = 718+144-30-2
2015 830 Public health and safety excuse used to justify removing 100 wild horses without an EA.
The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.
Societal Impact of Inflated Population-Data
The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.
Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
Mistakes Cost Wild Horses Their Freedom
The planned removals appear to have been hurriedly scheduled to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by faulty figures.
Not the First Time Population-Estimates Were Found to Be Flawed
In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …
125 %
131 %
153 %
157 %
249 %
Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.
Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it inadvertently portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER BLM METHODOLOGY
Projections per a Twenty-Percent Foal-Survival Rate
Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.
Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.
Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.
Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.
A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.
However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.
Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.
Bottom line: Every benefit-of-the-doubt has been given.
Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths
2008 — 190 — BLM’s population-estimate post-gather November 2008
Year Herd-size
January 1
2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.
2011 — 244 — Foal-crop: 49. PZP does not affect already-pregnant mares.
2012 — 293 — Foal-crop: 59. Even though PZP at maximum-effect.
2013 — 352 — Foal-crop: 70. Even though PZP still in effect.
2014 — 422 — Foal-crop: 84. But gather in Aug removed 30 horses.
2015 — 476 — including the 2014 foal-crop
2015 — 392 — excluding the 2014 foal-crop
It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.
Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …
Below minimum-viable population.
No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.
Planned Roundup Would Have a Devastating Impact on the Sulphur Herd
Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.
But it gets worse. Recent studies have shown BLM’s “20-percent-per-year” rule to be exaggerated by double.
TRUE HERD-GROWTH RATE, FOAL-TO-YEARLING SURVIVAL RATE = 10%
Longitudinal Study Demonstrates Growth-Rate of Five-to-Ten-Percent
The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.
Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …
No removals
No predators
No PZP
Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.
http://www.ispmb.org/Letter.html
The ISPMB study casts doubt on BLM’s standard “20-percent-per-year” rule for estimating herd-growth. Certainly, assumed growth-rates of 29 percent IN 2010 and, especially, the 87 percent growth-rate the BLM assumed for 2014, are implausible. Further, because subsequent estimates were based on false, inflated previous estimates, the errors compounded.
Independent Research Discloses a 10% Foal-to-Yearling Survival-Rate
A study of BLM roundup-records for a representative sample of four herd management areas was recently published (Gregg, LeBlanc, and Johnston, 2014).
The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER NEW RESEARCH-FINDINGS
Projections per a Ten-Percent Growth-and-Survival Rate
Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Sulphur HMA — Per 10% Growth — Modified by Removals, but NOT by PZP
2008 — 190 — BLM’s population-estimate post-gather Nov ’08
2011 — 200 — Foal-crop: 20. PZP does not affect already-pregnant mares.
2012 — 220 — Foal-crop: 22. Even though PZP at maximum-effect.
2013 — 242 — Foal-crop: 24. Even though PZP still in effect.
2014 — 266 — Foal-crop: 27. But gather in Aug removed 30 horses.
2015 — 263 — including 2014 foals
2015 — 236 — excluding 2014 foals
It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.
Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …
Below AML and
Below minimum-viable population.
It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.
Could There Really Be 100 Wild Horses Wandering onto the Highway?
Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.
Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.
Happy Tone, Ugly Reality
BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.
Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21”;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
ADOPTION … OR HIGHWAY TO HELL?
Sale to Slaughter for Sulphur HMA Captives
BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.
A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21” removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.
Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21” only to send them down a “highway to Hell”?
SULPHUR HERD’S AML WAS SET AT A GENETICALLY NON-VIABLE LEVEL
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP
BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.
A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:
BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Current
AML: 165 to 250 — Below minimum-viable population
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 1,063 – 1,610 — about 1⅔ to 2½ square miles per horse
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Recommended
AML: 2,500 to 5,000 — Meets minimum-viable population per IUCN
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 53 – 106 — about 6 to 12 horses per square mile
BLM’s National Authorized Livestock AUMs
But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?
BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.
Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.
157,000,000 acres of public lands on which BLM allows cattle
1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized
2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2
4,133,332 cows and calves = pairs x 2
38 acres per cow or calf
BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.
Actual Grazing Use Report — Form 4130-5
As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Annual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”
Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the reports is suspect.
Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use
In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.
Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.
What If There Is Not Enough Forage to Support 5,000 Horses?
Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that
… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.
Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.
Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.
The correct order is:
Sample first.
Sample complete — 100 percent.
Test samples.
Manage per test-results.
There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.
Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool
I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.
Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:
Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring
Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
A HELICOPTER-ROUNDUP IS ILL-ADVISED FOR SEVERAL REASONS
Helicopters Are Not Safe
BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.
Peculiar Way of Addressing Safety Concerns
Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.
Helicopter-Drive — an Inhumane Roundup Method
Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.
Abusive Behavior by Helicopter Pilots during Gathers
As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.
There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.
No Horse Left Behind
The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.
An Angry Contractor May Be Headed Your Way
In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.
Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.
Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.
Some Observers May Be Pumped-Up Too
Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.
The political weather is unstable. That is another good reason to call off the roundup.
Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs
A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.
How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.
Possible Collusion with Permit-Holders
Perhaps, as you read this, permit-holding ranchers are in the HMA, pushing wild horses toward the Highway.
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
1. Stop action. Cancel gather.
2. Complete environmental assessment.
3. Correct errors in the population-estimates.
4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.
5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.
6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.
7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).
8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.
9. Conduct a 100-percent evaluation of the Sulphur HMA herd’s genetic status.
