BLM Press Release: President Proposes $1.3 Billion Budget for BLM in Fiscal Year 2017

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Protect Mustangs does not endorse any of this. Read about drastic changes proposed for America’s wild horses and burros resembling the Salazar Plan towards the bottom and let your elected officials know you don’t want America’s wild horses to lose their protections and  be put at risk of going slaughter by way of these “transfers”.. This change will put America’s wild horses and burros at great risk.

Request addresses critical priorities including sage-steppe restoration, modernizing the energy program, and investing in our National Conservation Lands
WASHINGTON – President Barack Obama today requested a Fiscal Year (FY) 2017 budget for the Bureau of Land Management (BLM) that further strengthens the Administration’s commitment to restoring and conserving the Nation’s sage-steppe ecosystem, supports the safe and effective management of the agency’s oil and gas program, makes historic investments in the BLM’s National Conservation Lands, and takes a proactive approach to better manage the unsustainable proliferation of wild horses and burros on Western public lands.

“The President’s budget gives the BLM the resources we need to manage the public lands on a landscape scale,” said BLM Director Neil Kornze. “This funding will help us continue to devise 21st century solutions to the challenges we face.”

The FY 2017 budget requests $1.3 billion for BLM operations and activities, more than $7 million above the BLM’s FY 2016 enacted budget, and positions the agency for success by restoring the health of the West’s 65 million acres of sage-steppe ecosystem and ensuring responsible development of energy resources on the public lands. It also invests in the agency’s National Conservation Lands — including many of the Nation’s most precious and wildest areas — and seeks new tools to address a rapidly growing and unsustainable wild horse and burro population.

Charged by Congress with a dual mandate of managing public lands for multiple use and sustained yield, the BLM carries out its mission of maintaining the health, diversity, and productivity of these lands in a fast-changing nation. The agency manages 245 million surface acres of public lands — the most of any Federal agency — primarily in 12 Western States, including Alaska, and 700 million acres of subsurface mineral estate nationwide. This equates to 13 percent of the Nation’s surface and roughly one-third of its subsurface mineral resources.

The FY 2017 budget proposes $1.2 billion for BLM operations, which is $2.1 million above the 2016 enacted level. The request includes $107 million for the Oregon and California Grant Lands appropriation and $1.1 billion for the Management of Lands and Resources appropriation. The change in total program resources relative to 2016 reflects the budget’s proposed offsetting user fees in the Rangeland Management and Oil and Gas Management programs, which together offset the total request by $64.5 million allowing support for additional priorities.

The FY 2017 budget includes the President’s continued focus on the following priorities:

Land and Water Conservation Fund: The Department of the Interior will submit a legislative proposal to authorize permanent annual funding, without further appropriation or fiscal year limitation, for the Land and Water Conservation Fund, the innovative, highly successful program that reinvests royalties from offshore oil and gas activities into public lands across the Nation. In 2017, the proposal includes $43.9 million in discretionary funding and $44.8 million in mandatory funding for the BLM’s land acquisition program.

Restoring the Sage-Steppe Ecosystem: In 2015, the BLM’s update of almost 70 land use plans in 10 Western States was integral to the U.S. Fish and Wildlife Service’s (FWS) decision in September 2015 to keep the Greater sage grouse off the Endangered Species Act list at this time. An unprecedented undertaking, the Greater sage-grouse conservation effort has significantly reduced threats to the rangeland bird across 90 percent of its breeding habitat, resulting from sustained collaboration among private stakeholders and local, State, and Federal partners. Moreover, the FWS determina­tion and the conservation mechanisms in place provide the regulatory certainty needed for sus­tainable economic development across millions of acres of Federal and private lands throughout the western United States. Success in sage-grouse conservation will demonstrate the value of planning for conservation and development at a landscape level through collaborative partnerships. The President has requested an additional $14.2 million in FY 2017 for sage-grouse conservation, bringing to $74.2 million the BLM’s total investment in protecting and restoring the sage grouse habitat, in addition to a complementary increase of $5 million for the BLM’s National Seed Strategy to appropriately restore priority sage steppe habitat. This strategy, which aims to ensure the right seeds are available in the right places at the right time, also guides efforts to make treated lands more resilient to fires, invasive species, and drought.

Support for BLM’s National Conservation Lands: The President’s FY 2017 budget request includes a $13.7 million program increase for BLM’s National Conservation Lands, which contain some of the West’s most spectacular landscapes and receive about one-third of all visitors to BLM lands. The increase will bring funding for the program to a historic $50.6 million level, and helps solidify the importance of National Conservation Lands protection as the program embarks beyond its 15th anniversary. This investment will address high-priority on-the-ground needs in national monuments and national conservation areas, including developing management plans for recently designated units, and developing and implementing travel management plans for high-use areas.

Promoting Responsible Energy Development and Modernizing Regulations: The President’s FY 2017 budget request will enable the agency to continue strong support for the Administration’s energy goals. Many of the BLM’s oil and gas regulations date to the 1980s, soon after the BLM assumed responsibility for onshore leasing. The budget request includes a net increase of $19.9 million in program increases for several priorities, including:
Instituting new rules that establish procedures for how producers measure and account for oil and gas extracted from the public lands, which will ensure accurate royalties are paid;
Implementing stronger regulations to reduce the wasteful release of natural gas from oil and gas operations on public and American Indian lands, reducing harmful methane emissions and providing a fair return on public resources;
Implementing the hydraulic fracturing rule;
Modernizing the Automated Fluid Minerals Support System to increase efficiencies in the management of oil and gas operations;
Funding special pay for certain oil and gas program positions to improve recruitment and retention of these vital resources.
Addressing legacy wells on the Alaska North Slope.

Collaboratively Managing Wild Horses and Burros: With more than 100,000 horses in BLM’s care both on and off the range, the agency is redoubling its efforts to reduce the number of horses in holding facilities. The FY 2017 budget request supports new, innovative efforts to secure safe and cost-effective placement for unadopted animals, including proposed legislation to better facilitate the transfer of animals to other public entities at the local, state, and Federal levels. This proposal will work in tandem with other proactive efforts beginning in 2016 to better manage the nation’s large and growing population of wild horses and burros. Each animal placed into private care can save taxpayers almost $50,000.

The President’s FY2017 budget request of $13.4 billion for the Department of the Interior reflects his commitment to conserve vital national landscapes across the Nation, promote the responsible development of energy and mineral resources on public lands and meet Federal trust responsibilities to Native Americans. The Interior Budget in Brief is online: www.doi.gov/budget and www.doi.gov/budget/2017/Hilites/toc.html.

The BLM’s mission is to manage and conserve more than 245 million acres of public land­ for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. To download highlights of BLM’s FY 2017 budget, click this link.
The BLM 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’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2014, the BLM generated $5.2 billion in receipts from public lands.
–BLM–

From a BLM press release: http://www.blm.gov/wo/st/en/info/newsroom/2016/february/nr_02_09_2016.html

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





Complaint to the Office of the Inspector General regarding BLM killing 28 wild horses near Las Vegas

 

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)
  • What organizations were pushing for BLM to use PZP, a controversial EPA restricted use pesticide for “birth control”–made from slaughterhouse pig ovaries–that sterilizes after multiple use? http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf
  • Are the wild horses getting pushed out and killed as part of the New Energy Frontier–to put massive solar farms on fragile desert land and therefore impacting wildlife? https://eplanning.blm.gov/epl-front-office/projects/lup/2900/49868/54310/LV-RMP_Poster_Renewable_Energy.pdf
  • 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

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

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

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

Join the open forum: Using PZP on federally protected wild horses and burros, is it safe?

PM PZP Syringe Yearling Meme

 

The open forum on PZP for federally protected equids is held on Facebook here and everyone is welcome: https://www.facebook.com/groups/ForumPZPWildHorsesBurros/

Statement:

“If the good people of Nevada choose to use PZP to manage their wild horses on state land it’s up to them because that is a state issue. Americans across the country are concerned PZP isn’t safe and don’t want their wild horses and burros on federal land to be given the restricted-use pesticide hailed as “birth control” but known to sterilize after multiple use. If PZP advocates can prove PZP is 100% safe for native wild horse and burro herds, won’t sterilize them, ruin genetic variability or cause behavioral abnormalities then it could be considered as a management tool. Until then other holistic management tools must be examined. It’s time for a freeze on roundups, drugging and removals for scientific reevaluation. We need to get it right for our icons of American freedom.” ~ Anne Novak, Executive Director of Protect Mustangs

Controversy over PZP

nt B:W

 

Know this

Ken Salazar’s Wild Horse Plan Fuels Accusations That He’s In The Pocket Of Ranchers, Associated Press, 2010: http://www.huffingtonpost.com/2009/10/17/ken-salazars-wild-horse-p_n_324799.html

Wildlife ecologist Craig Downer of Nevada accused Salazar, a former rancher, of acting on behalf of those who view mustangs as taking scarce forage away from their cattle herds. Downer contends cattle are more destructive to the range because they concentrate in high numbers around water sources instead of grazing over a wider area as wild horses do.

“Both the Forest Service and the Bureau of Land Management have the right to remove livestock to ensure viable, healthy populations of wild horses. But they refuse to exercise that,” Downer said. “Their master is primarily these traditional ranching interests.”

Opposition grows to Salazar’s plan to move wild horses to Midwest preserves, Associated Press 2009http://www.oregonlive.com/news/index.ssf/2009/12/opposition_grows_to_salazars_p.html

Horse defenders have stepped up their efforts in recent weeks, suing to block a proposed roundup of 2,700 horses in northern Nevada and lining up the support of celebrities such as Sheryl Crow, Lily Tomlin, Bill Maher and Ed Harris.

Crow took her concerns directly to Salazar in a telephone call this past week.

One of the first things he said was something must be done because the horses are starving. We (advocates) don’t believe it,” Crow said in an interview with The Associated Press.”

7 Preserves Envisioned to Manage Wild Horses, New York Times, 2009http://www.nytimes.com/2009/10/08/us/08horses.html?_r=0

“HELENA, Mont. — Interior Secretary Ken Salazar said Wednesday that he was proposing to create seven new wild-horse preserves, including one in the East and one in the Midwest, to address the problem of a growing population crowding the Western range.

The program, which also applies to wild burros, would expand the use of contraceptives and would geld more herds on public lands in the West, Mr. Salazar said.”

. . . ”

Yet the proposal quickly drew criticism from wild-horse advocates. Ginger Kathrens of Colorado Springs, a maker of documentary films who has chronicled the lives of a wild-horse herd in Montana, said that blocking reproduction could alter the animals’ behavior.

“It takes the wild out of wild-horse herds,” she said. “They’re families in sophisticated societies. Creating gelding herds and preventing them from reproducing is managing them toward extinction.”

But ranchers, who see wild horses as competing with cattle for grasses and water, welcomed the proposal. Jeff Eisenberg, executive director for the Public Lands Council, a group that works on public lands issues for ranchers, said Mr. Salazar’s proposal was a big step toward a solution.”

Sheryl Crow Slams Salazar’s Wild Horse Plan, Huffington Post 2010http://www.huffingtonpost.com/2009/11/22/sheryl-crow-slams-salazar_n_366809.html

With one voice we are insisting that our government stop managing these beautiful and important animals to extinction,” Crow said in a statement released by the Cloud Foundation, a Colorado Springs, Colo.-based horse advocacy group”. . .

It’s time for all of us to speak up for our wild horses and burros so we do not lose these living legends and inspiring symbols of our freedom in America,” she said.

Madeleine Pickens praises Salazar wild horse plan, Horsetalk, 2009http://www.horsetalk.co.nz/news/2009/10/077.shtml#axzz3HKN0uSuY

“Interior Secretary Ken Salazar announced wide-ranging proposals this week in which horses taken from the Western rangelands would be relocated to new preservation areas further east, utilising better quality grassland.

His plan includes the aggressive use of reproduction controls to manage numbers. Salazar hoped the new herd areas would provide tourism opportunities for nearby communities” . . .

Pickens said she would support Secretary Salazar’s efforts, and would gladly compete to offer the wild horse sanctuary that she has planned to the bureau as one of the facilities proposed by Secretary Salazar.”

 

MANAGEMENT OF WILD HORSES WITH PORCINEZONA PELLUCIDA: HISTORY, CONSEQUENCES, AND FUTURE STRATEGIES, Cassandra M.V. Nuñez, Princeton: http://bit.ly/1rJywKl

“However, recent research in other populations has revealed behavioral and physiological side effects of long-term PZP use.”

 

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/

“Abnormal dart trauma included cases where the dart hit bone or the needle broke off. We found strong evidence (odds ratio = 5.023, P = 0.001) for a higher probability of occurrence of swelling when darts were delivered by blowgun. We found some evidence (odds ratio = 8.729, P = 0.07) that abnormal dart trauma led to a higher frequency of nodule formation. Nodules were the most common reactions observed and often persisted for a year or more, but in our observations they did not appear to change any animal’s range of movement or locomotor patterns and in most cases did not appear to differ in magnitude from naturally occurring injuries or scars. We were unable to perform histological examinations of these nodules, but they may be similar to granulomas reported by other investigators following administration of Freund’s adjuvant.”

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

Why end natural selection in the Pryors? Should humans run a wild horse breeding program or does nature know best? http://protectmustangs.org/?p=4941

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 2014

Animal Advocates Sue Bureau of Land Management Over Wild Horses and Withheld Public Records

 

James Anaquad Kleinert

James Anaquad Kleinert

Roundups of Wild Horses on Public Lands Stir Controversy, Feature in Documentary Exposé

WASHINGTON, D.C. — A Freedom of Information Act (FOIA) lawsuit was filed this month against the federal Bureau of Land Management (BLM) for withholding public records from filmmaker James Kleinert. The BLM has been investigating Kleinert and his film company, presumably in retaliation for making documentary films Wild Horses & Renegades, Saving the American Wild Horse, and Wild Horse Spirit, which expose the BLM’s cruel roundups of wild horses on public land and allege corruption within the Department of the Interior. “Roundups” involve herding horses into corrals using helicopters and separating them from their families. The national non-profit Animal Legal Defense Fund (ALDF) has reason to believe that wild horses corralled by the BLM end up for sale for slaughter in Mexico and Canada. The federal lawsuit was filed September 3, 2014 in the U.S. District Court for the District of Columbia. ALDF is providing consulting assistance to Kleinert’s attorney, Daniel J. Stotter.

The lawsuit, Kleinert v. Bureau of Land Management, alleges that the BLM violated its duty under FOIA to provide records documenting the BLM’s investigation of Kleinert and his film company as he filmed roundups over the last decade. The BLM was required to provide all records and respond to this FOIA request within 20 working days of receiving it. The BLM now has 30 days to file a response to Kleinert’s lawsuit.

“Rounding up wild horses from public lands for the sake of private ranchers who want to graze cattle and sheep is outrageous,” said Stephen Wells, executive director of the Animal Legal Defense Fund. “The Bureau of Land Management should be protecting wild horses, not virtually guaranteeing their slaughter or targeting filmmakers who expose what’s going on.”

 

BLM Sets Meeting of National Wild Horse and Burro Advisory Board for April 14-15 in Sacramento

BLM press release:

SACRAMENTO, CA: The Bureau of Land Management’s National Wild Horse and Burro Advisory Board will meet for two days in April in Sacramento, California, to discuss issues relating to the management and protection of wild horses and burros on Western public rangelands.  The meeting will take place on Monday, April 14, 2014, from 8:00 a.m. to 5:00 p.m. (Pacific Time), and on Tuesday, April 15, 2014, from 8:00 a.m. to 5:00 p.m. (Pacific Time).

The upcoming Advisory Board meeting will be held at the Courtyard by Marriott Sacramento Cal Expo, 1782 Tribute Road, Sacramento, California 95815 (hotel phone number: 916-929-7900).  The agenda of the meeting can be found in the Friday, March 21, 2014, Federal Register (at www.federalregister.gov or https://www.federalregister.gov/articles/2014/03/21/2014-06186/wild-horse-and-burro-advisory-board-meeting).

Contacts: Tom Gorey (BLM) , 202-912-7420

The Advisory Board provides input and advice to the BLM as it carries out its responsibilities under the 1971 Wild Free-Roaming Horses and Burros Act.  The law mandates the protection and management of these free-roaming animals in a manner that ensures healthy herds at levels consistent with the land’s capacity to support them.  According to the BLM’s latest official estimate, approximately 40,600 wild horses and burros roam on BLM-managed rangelands in 10 Western states.

The BLM recently announced it is seeking research proposals to develop new or improve existing ways of controlling the population growth of wild horses and burros that roam public lands in the West.  The agency has issued a Request for Applications to alert veterinarians, scientists, universities, pharmaceutical companies, and other researchers of the BLM’s need to develop new, innovative techniques and protocols for implementing population growth-suppression methods.  The submission deadline for applications is May 7, 2014.

The public may address the Advisory Board on Monday, April 14, from 3:00 p.m. to 4:30 p.m., local time.  Individuals who want to make a statement at Monday’s meeting should register in person with the BLM by 2:00 p.m., local time, on that same day at the meeting site.  Depending on the number of speakers, the Board may limit the length of presentations, set at three minutes for previous meetings.

Speakers should submit a written copy of their statement to the BLM at the addresses below or bring a copy to the meeting.  There may be a Webcam present during the entire meeting and individual comments may be recorded.  Those who would like to comment but are unable to attend may submit a written statement to: National Wild Horse and Burro Program, WO-260, Attention: Ramona DeLorme, 1340 Financial Boulevard, Reno, Nevada, 89502-7147.  Comments may also be e-mailed to the BLM (at wildhorse@blm.gov); please include “Advisory Board Comment” in the subject line of the e-mail.

For additional information regarding the meeting, please contact Ramona DeLorme, Wild Horse and Burro Administrative Assistant, at 775-861-6583.  Individuals who use a telecommunications device for the deaf (TDD) may reach Ms. DeLorme during normal business hours by calling the Federal Information Relay Service at 1-800-877-8339.

The Advisory Board meets at least once a year and the BLM Director may call additional meetings when necessary.  Members serve without salary, but are reimbursed for travel and per diem expenses according to government travel regulations.

The BLM 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’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2013, the BLM generated $4.7 billion in receipts from public lands.
–BLM–

BLM announces 12 million in budget for helicopter roundups. Share the petition to stop cruel roundups!

 

Protect Mustangs.org (Photo © Cat Kindsfather)

Protect Mustangs.org (Photo © Cat Kindsfather)

 

Watch what a roundup looks like:

Please sign and share the petition to defund the roundups: http://www.change.org/petitions/defund-and-stop-the-wild-horse-burro-roundups

It reads:

According to a press release from National Academy of Sciences 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.

We request an immediate moratorium on roundups for scientific population studies.

Wild horses are a returned-native species to America. Rounding up federally protected wild horses and burros has been documented as cruel. Warehousing them for decades is fiscally irresponsible. Clearing mustangs and burros off public land–for industrialization, fracking, grazing and the water grab–goes against the 1971 Free Roaming Wild Horse and Burro Act put in place to protect the living legends of the American West. They must never go to slaughter.

We request you defund and stop the roundups immediatly.

There is no accurate census and the BLM figures do not add up. We request population studies for each herd management area (HMA) and each herd area (HA) because we are gravely concerned there are less than 18,000 wild horses and burros in the 10 western states combined. More roundups or fertility control/sterilizations will wipe them out because the majority are no longer genticaly viable herds.

Wild horses are not overpopulating despite spin from the forces that want to perform heinous sterilizations in the field. Humane fertility control could be looked at as an option only after scientific population studies have been conducted for each HMA and each HA. Right now it’s premature.

Field observers have noticed a worrisome decline in wild horse and burro population since the BLM’s rampant roundups from 2009 to this day.

Kindly allow returned-native wild horses and the burros to reverse desertification, reduce the fuel for wildfires and create biodiversity on public land–while living with their families in freedom.

Study shows wild horse herds with functional social structures contribute to low herd growth compared to BLM managed herds

© Novak

 

International Society for the Protection of Mustangs and Burros (ISPMB)

As we complete our thirteenth year in studying the White Sands and Gila herds, two isolated herds, which live in similar habitat but represent two different horse cultures, have demonstrated much lower reproductive rates than BLM managed herds.  Maintaining the “herd integrity” with a hands off management strategy (“minimal feasible management”) and no removals in 13 years has shown us that functional herds demonstrating strong social bonds and leadership of elder animals is key to the behavioral management of population growth.

ISPMB’s president, Karen Sussman, who has monitored and studied The Society’s four wild herds all these years explains, “We would ascertain from our data that due to BLM’s constant roundups causing the continual disruption of the very intricate social structures of the harem bands has allowed younger stallions to take over losing the mentorship of the older wiser stallions.

In simplistic terms Sussman makes the analogy that over time Harvard professors (elder wiser stallions) have been replaced by errant teenagers (younger bachelor stallions).  We know that generally teenagers do not make good parents because they are children themselves.

Sussman’s observations of her two stable herds show that there is tremendous respect commanded amongst the harems.  Bachelor stallions learn that respect from their natal harems.  Bachelors usually don’t take their own harems until they are ten years of age.  Sussman has observed that stallions mature emotionally at much slower rates than mares and at age ten they appear ready to assume the awesome responsibility of becoming a harem stallion.

Also observed in these herds is the length of time that fillies remain with their natal bands.  The fillies leave when they are bred by an outside stallion at the age of four or five years.  Often as first time mothers, they do quite well with their foals but foal mortality is higher than with seasoned mothers.

Sussman has also observed in her Gila herd where the harems work together for the good of the entire herd.  “Seeing this cooperative effort is quite exciting,” states Sussman.

ISPMB’s third herd, the Catnips, coming from the Sheldon Wildlife Range where efforts are underway to eliminate all horses on the refuge, demonstrate exactly the reverse of the organization’s two stable herds.

The first year of their arrival (2004) their fertility rates were 30% the following first and second years. They have loose band formations and some mares are without any harem stallions.  Stallions are observed breeding fillies as young as one year of age.  Foal mortality is very high in this herd.  Generally there is a lack of leadership and wisdom noted in the stallions as most of them were not older than ten years of age when they arrived.  In 2007, a decision to use PZP on this herd, a contraceptive, was employed by ISPMB.  This herd remains a very interesting herd to study over time according to Sussman.   “The question is, can a dysfunctional herd become functional,” says Sussman who speculates that the Catnips emulate many of the public lands herds.

In 1992 when Sussman and her colleague, Mary Ann Simonds, served on the National Wild Horse and Burro Advisory Board, they believed that BLM’s management should change and recommended that selective removals should begin by turning back all the older and wiser animals to retain the herd wisdom.  Sussman realizes that the missing ingredient was to stop the destruction of the harem bands caused by helicopter roundups where stallions are separated from their mares.  “Instead, bait and water trapping, band by band, needed to be instituted immediately,” says Sussman.  Had this been done for the past twenty years, we would have functionally healthy horses who have stable reproductive rates and we wouldn’t have had 52,000 wild horses in holding pastures today.   BLM’s selective removal policy was to return all horses over the age of five.  When the stallions and mares were released back to their herd management areas by the BLM, younger stallions under the age of ten fought for the mares and took mares from the older wiser stallions.  This occurs when there is chaos happening in a herd such as roundups cause.

Sussman also believes that when roundups happen often the younger stallions aged 6-9 are ones that evade capture.  This again contributes to younger stallions taking the place of older wiser stallions that remain with their mares and do not evade capture.  She is advocating that the BLM carry out two studies: determining the age of fillies who are pregnant and determining age structures of stallions after removals.

Currently Sussman is developing criteria to determine whether bands are behaviorally healthy or not.  This could be instituted easily in observation of public lands horses.

Taken from BLM’s website:  “Because of federal protection and a lack of natural predators, wild horse and burro herds can double in size about every four years.”

White Sands Herd Growth: 1999-2013 – 165 animals.

BLM’s assertion herds double every four years means there should be 980 horses or more than five times the growth of ISPMB’s White Sands herd.

Gila Herd Growth:1999-2013- 100 animals.

BLM’s assertion herds double every four years means there should be 434 horses or nearly four times the growth of ISPMB’s Gila herd.

Sussman says that BLM’s assertion as to why horse herds double every four years is incorrect. The two reasons given are federal protection of wild horse herds and lack of natural predators. ISPMB herds are also protected and also have no natural predators, but they do not reproduce exponentially. She adds that exponential wild horse population growth on BLM lands must have another cause, and the most likely cause is lack of management and understanding of wild horses as wildlife species.  Instead BLM manages horses like livestock. “According to the Wild Horse and Burro Act of 1971, all management of wild horse populations was to be at the ‘minimal feasible level’,” Sussman says. “When the BLM’s heavy-handed disruption and destruction of wild horse social structures is the chief contributing factor in creating population growth five times greater than normal, than the BLM interference can hardly be at a ‘minimal feasible level.’”

Sussman concludes that ISPMB herds are given the greatest opportunity for survival, compared to the BLM’s herds which are not monitored throughout the year.  “One would assume,” Sussman says, “herds that are well taken care of and monitored closely would have a greater survival rate.  Yet, even under the optimum conditions of ISPMB herds, they still did not increase nearly 500% like BLM herds.”

Karen Sussman has been riding horses since the age of four.  She has spent the last thirty-two years working with wild horses and burros and has been involved in every aspect of the BLM’s Wild Horse and Burro program including: assisting in the development of a consistent training program for the prison training program, development of a volunteer compliance program for adopted wild horses and burros, a catalyst for the increasing fines from $2,000 to $100,000 for the death of wild horses or burros, monitoring fee-waivered animals in Montana.  Sussman received the prestigious Health of the Land Award serving on the BLM’s Black Mountain Eco-team developing a gold-standard model for managing wild burros.  She served on the National Wild Horse and Advisory Board in 1990-92

BLM sets meeting of national wild horse and burro advisory board

Release Date: 08/09/13
Contacts: Tom Gorey  202-912-7420

[Note: Meeting will be live-streamed]

The Bureau of Land Management’s National Wild Horse and Burro Advisory Board will meet for three days in September in Arlington, Virginia, to discuss issues relating to the management, protection, and control of wild horses and burros on Western public rangelands. The meeting, which will focus on the June 2013 report by the National Academy of Sciences (titled “Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward”), will take place on Monday, September 9, 2013, from 1:00 p.m. to 5:00 p.m., on Tuesday, September 10, from 8:00 a.m. to 5:00 p.m., and Wednesday, September 11, from 8:00 a.m. to 12:00 p.m. local time.

The NAS report, which was commissioned by the BLM, called for several management actions, including the more widespread use of a fertility-control vaccine known as PZP (porcine zona pellucida) on mares. Contrary to some reports, the study did not call for an end to gathers of wild horses and burros from overpopulated herds, nor did the report urge the BLM to “let nature cull any excess herds.” The report’s recommendations are under review by the BLM.
The upcoming Advisory Board meeting will be held at the Key Bridge Marriott, 1401 Lee Highway, Arlington, Virginia 22209, telephone number 703-524-6400. The agenda of the meeting can be found in the August 1, 2013, Federal Register (at http://www.gpo.gov/fdsys/pkg/FR-2013-08-01/pdf/2013-18571.pdf).
The Advisory Board provides input and advice to the BLM as it carries out its responsibilities under the 1971 Wild Free-Roaming Horses and Burros Act. The law mandates the protection, management, and control of these free-roaming animals in a manner that ensures healthy herds at levels consistent with the land’s capacity to support them.  According to the BLM’s latest official estimate, approximately 40,600 wild horses and burros roam on BLM-managed rangelands in 10 Western states.
The public may address the Advisory Board on Tuesday, September 10, at 3:00 p.m., local time. Individuals who want to make a statement at Tuesday’s meeting should register in person with the BLM by 2:00 p.m., local time, on that same day at the meeting site.  Depending on the number of speakers, the Board may limit the length of presentations, set at three minutes for previous meetings.
Speakers should submit a written copy of their statement to the BLM at the addresses below or bring a copy to the meeting.  There may be a Webcam present during the entire meeting and individual comments may be recorded.  Those who would like to comment but are unable to attend may submit a written statement to: National Wild Horse and Burro Program, WO-260, Attention: Ramona DeLorme, 1340 Financial Boulevard, Reno, Nevada, 89502-7147. Comments may also be e-mailed to the BLM (atwildhorse@blm.gov); please include “Advisory Board Comment” in the subject line of the e-mail.
For additional information regarding the meeting, please contact Ramona DeLorme, Wild Horse and Burro Administrative Assistant, at 775-861-6583.  Individuals who use a telecommunications device for the deaf (TDD) may reach Ms. DeLorme during normal business hours by calling the Federal Information Relay Service at 1-800-877-8339.
The Advisory Board meets at least once a year and the BLM Director may call additional meetings when necessary.  Members serve without salary, but are reimbursed for travel and per diem expenses according to government travel regulations.
The BLM 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’s multiple-use mission is to sustain the health, diversity, and productivity of the public lands for the use and enjoyment of present and future generations. In Fiscal Year 2012, activities on public lands generated $4.6 billion in revenue, much of which was shared with the States where the activities occurred. In addition, public lands contributed more than $112 billion to the U.S. economy and helped support more than 500,000 jobs.
–BLM–