Senate Appropriations maintains protections for wild horses

Despite crazy ideas pushed around to kill or slaughter America’s last wild horses, the United States Senate Appropriations Committee has upheld the law and we are grateful. We would like to thank Senator Udall for spearheading the moral path to honor the law.

We also want to thank you for taking action with phone calls, meetings and emails!

Please call the following Senators. Thank them for protecting America’s last wild horses and politely ask them for an independent head count.

Sen. Mitch McConnell: (202) 224-2541
Sen. Chuck Schumer: (202) 224-6542
Sen. Thad Cochran: (202) 224-5054
Sen. Patrcky Leahy: (202) 224-4242
Sen. John Hoeven: (202) 224-2551
Sen. Jeff Merkley: (202) 224-3753
Sen. Lisa Murkowski: (202)-224-6665
Sen. Tom Udall: (202) 224-6621

Join more than 46,000 people who have signed the Petition for a Head Count of Wild Horses and Burros: https://www.change.org/p/u-s-senate-investigate-the-wild-horse-burro-count-in-captivity-and-freedom It’s essential we find out how many are left.

The fight continues

Sadly the Bureau of Land Management and groups who lobby for population control experimentation, as well as permanent and semi-permanent sterilization will continue to fear monger the trusting public up through the end of the year. . . It’s now that the public can notice who is in the fight to protect the wild horses and who is playing the game for the research grants, long-term holding contracts and slick end of the year campaigns for fertility control–on a species threatened with extinction.

For the Wild Ones,

Anne Novak
Volunteer Executive Director
Protect Mustangs

Anne Novak interviewed at a protest outside Senator Feinstein’s office July 3, 2017

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



Conflict of interest, wild burros and pesticide PZP

-Wild-_Burros-credit-Rylee-Isitt-1

(Photo Credit Rylee Isitt/WikiCommons)

Deadline extended to August 22, 2016 so please get your comments in. Below is what Marybeth Devlin sent in. 

Postmarked or Received by:

August 15, 2016

To:

BLM-Arizona

State Office

Colorado River District Office

Kingman and Lake Havasu Field Offices

Copies to:

CEQ, DOI, and BLM National Office

with hard-copy via Priority Mail to:

Bureau of Land Management

Kingman Field Office

2755 Mission Boulevard

Kingman, AZ  86401

Subject: Black Mountain Wild Burros

Project: PZP Fertility-Management Pilot

Proposed by: Humane Society of the United States

Document: Environmental Assessment ( EA )

NEPA ID: DOI-BLM-AZ-C010-2016-0004-EA

This letter responds to the public-comment period currently underway regarding the management of the wild burros whose dedicated habitat is the Black Mountain Herd Management Area (HMA).  I submit these substantive comments — questioning the accuracy and integrity of BLM’s analysis — and new information relevant to the analysis that should have been considered but was not — as an interested party in behalf of the Black Mountain wild burros.  Please note that in all instances where text has been emphasized, either through bold and/or italics, the emphasis was added by me.  For ease of reference, below are the respective links to BLM’s press release and to the Webpage where the Dear Reader letter and the EA are posted.

http://www.blm.gov/az/st/en/info/newsroom/2016/july/blm_seeking_public.html

http://bit.ly/BLM-AZ-KFO-WildBurro

BACKGROUND

The Proposal

BLM received an unsolicited proposal from Humane Society of the United States (HSUS) to conduct a pilot study on the use of porcine zona pellucida (PZP), also known as ZonaStat-H, an EPA-registered pesticide that induces infertility, on as many as 165 wild jennies of the Black Mountain herd.  HSUS would endeavor to determine the effects of PZP on individual jennies and on herd-structure following treatments.  HSUS would particularly focus on whether remote “opportunistic” retreatment methods could work.  HSUS would collect and maintain data-sheets, and submit them as well as an annual progress report to BLM for review.

HSUS has requested $33,695 in funding from BLM over 3 years.  BLM reviewed the proposal and has now issued a preliminary EA, accepting public comments before issuing a decision.

Captured and Held — Injected and Re-Injected — Branded and Disfigured

The jennies would be captured via bait-trapping and then transported to a holding facility for injection with PZP.  They would be held captive for the next several weeks in order to administer a second “booster” injection of PZP.  Most (70 to 100) of the jenny-subjects would also be freeze-branded with three digits on both hips for HSUS and BLM’s convenience in identifying them.  Such permanent freeze-marks are typically 3½ or 4 inches high, and the letters are wide.  Following the injections and branding, the jennies would be transported back and released into the HMA.

Annual Roundups Probable

Although field-darting would be attempted for the annual retreatments, the EA acknowledges that it might be necessary to bait-trap the jennies again for that purpose as well as in order to freeze-brand them a second time or to allow veterinary treatment of abscesses at the injection-sites.  Thus, program funds would be spent for rounding up the test-subjects yearly, and the costs thereof would be over-and-above the grant for which HSUS has applied to conduct its study.

CONFLICTS OF INTEREST

HSUS — PZP’s Registrant

HSUS is a leading advocacy-organization for animal-welfare.  It provides leadership to advance the cause of humane treatment of animals.  In response to BLM’s abusive helicopter-roundups and scandals involving wild horses and burros being sold into slaughter, HSUS sought a compassionate way to manage the mustangs on the range.  It was a noble goal, and PZP was proffered as the answer.

PZP / ZonaStat-H was touted by its manufacturer as “so safe it is boring” [11] and its contraceptive effects, as reversible.  Relying on the manufacturer’s representations, HSUS applied to the Environmental Protection Administration (EPA) to have the product approved for use on wild horses and burros, which the EPA did — as a pesticide in cases where mustangs were deemed to have become a “nuisance.”  So highly respected was HSUS’ reputation, that EPA waived certain protocols that are normally required.  Unfortunately, HSUS failed to fully investigate the product beforehand, has not done so subsequently, and does not seem interested in knowing about any drawbacks to its use.  Consequently, HSUS is ignorant of the body of science weighing against PZP.

Now, HSUS is seeking to conduct a study of PZP on the subject herd of wild burros.  But because HSUS is the registrant of the pesticide PZP, a conflict of interest is apparent.  HSUS has a stake in the outcome of the proposed study, namely, to see it succeed and to ignore ill effects.  Lacking scientific impartiality, HSUS must be disqualified from studying its sponsored product and from using taxpayer money to experiment on America’s underpopulated wild burros.

BLM and HSUS — Rely on PZP’s Manufacturer for Safety Information

The EA relies heavily on reports issued by PZP’s manufacturer regarding product-safety and lack of adverse effects.  However, such data is suspect because the manufacturer has a stake in promoting its product.  Lacking scientific impartiality and having a financial interest in the outcome, the manufacturer has an apparent conflict of interest.  Therefore, independent studies should compose the majority of the references regarding the use of PZP; however, that is not the case.  Indeed, as will be addressed later in this letter, numerous independent studies have been conducted, and they revealed many adverse effects of PZP.

Mandate to Practice Scientific Integrity

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

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved.  Most importantly, it must be trustworthy. [36]

BLM and HSUS have ignored and BLM has suppressed independent scientific findings about PZP’s adverse effects and unintended consequences.  Instead, BLM and HSUS continue to rely almost exclusively on the manufacturer’s claims regarding PZP’s safety for use on burros and horses, and for handling by humans.  In fact, independent research — and even one study by the manufacturer — disclosed that PZP is hazardous to burros, horses, and humans.  BLM and HSUS are thus non-compliant with the Policy and malfeasant in their responsibilities to protect staff, volunteers, and the wild burros and horses.

FALSE PREMISES, FRAUDULENT NUMBERS

The rationale for using birth control on the Black Mountain burros is predicated on false assumptions — “virtually no natural predators” and “herd sizes can double nearly every four years” — and fraudulent figures — reported herd-growth numbers many times over the biologically plausible.  It is wrong to proceed when the premises-for-action are counterfactual and fraudulent.  In the EA, BLM attempts to separate the premises from the proposal; however, the two are inextricably linked.

False Premise #1 — Lack of Predators

Contrary to BLM’s assertion, burros do have natural predators: Mountain lions and coyotes.  Both species are present in Black Mountain HMA.  If BLM believes that inadequate numbers of these apex predators preventing them from fulfilling their population-control function, then BLM should take action to conserve them.  Collaborate with the Arizona Game & Fish Department (AGFD) to prohibit hunting of predators in the HMA, and negotiate with Wildlife Services, to stop that agency from killing them.  Put some healing balm on that “trigger itch” — as Aldo Leopold called it. [22]

Healthy Predators, Healthy Ecosystem

To achieve a “thriving natural ecological balance,” the Black Mountain HMA should be a safe-haven for predators.  Such an approach would help the burros by favoring survival-of-the-fittest and the best genetic adaptations, and by keep the herd-population in equilibrium with minimal human-interference, just as the Act envisioned.  Predators are the “no-cost” option.  Conservation Researcher Dr. Corey Bradshaw emphasizes just how important predators are to a healthy ecosystem:

Long story short – if your predators are not doing well, chances are the rest of the ecosystem is performing poorly.

Predators keep the ecosystem in balance.  Without them, prey species decline, as do the forage-production species on which the prey-animals feed.  Dr. Bradshaw warns: “Without predators, our feeble attempts to conserve ecosystems are doomed to fail.” [4]

Predator Reintroduction

Wolves also prey on burros.  However, Arizona’s wolves had been intentionally exterminated by the Federal and State governments to placate livestock-ranchers and to please trophy-hunters.  Both groups — ranchers and hunters — continue to oppose the wolves’ right-to-exist.  However, their reasons are self-serving.

Now that wiser minds have prevailed, initiatives to reintroduce wolves are ongoing. [22]  Mohave County does not yet appear to be participating in the Mexican Wolf Restoration Project.  However, again, if BLM believes there is a dearth of apex predators in the HMA, then reintroduction of Mexican Wolves is a logical solution.  Because the Federal government played a major role in the extermination of wolves, the moral imperative is for the Federal government — via BLM — to make restitution to the species.  The Black Mountain HMA could be designated a wolf-recovery area (WRA). [41]

False Premise #2 — High Reproductive Rate

First, some background facts.  Burros are a slow-growth species when it comes to reproduction. The gestation-period lasts an average of 12 months — although it can extend as long as 14 months.  A jennet produces just 1 foal, and she typically reproduces in alternate years.  Further, the conception-rate of jennies is lower than that of mares.  Thus, in contrast to wild-horse herds, wild-burro herds grow more slowly. [1, 31 and 46]

BLM uses a standard, assumed burro birth rate — 15% — as a proxy for the herd-growth rate.  However, for a herd-growth rate to be valid, the birth rate must be adjusted by the death rate.  To wit, …

Herd-growth rate Birth rate

Herd-growth rate = Birth rate Foal death rate Adult burro death rate

As is evident, BLM incorrectly equates births with herd growth.  BLM wrongly assumes that all foals survive and that all adult burros live forever.

BLM’s assumption regarding burro-foal survival has been falsified per a recent independent review of BLM records.  Gregg, LeBlanc, and Johnston (2014) found a high mortality rate for newborn burro-foals.  Their study concluded that, based on survival-data from birth-to-yearling status, the effective increase in a typical burro-population attributable to new foals is just 7%. [13]

However, adult mortality must also be taken into consideration when estimating herd-growth.  Adult wild burros succumb to illness, injury, and predation.  Others are shot and killed by unethical parties.  Still others perish from stochastic events — random catastrophes such as an epidemic or a wildfire.  Adult wild burros are believed to have a mortality rate of at least 5% a year.

So, what is a normal herd-growth rate among wild burros?  A good estimate would be about 2%, probably less.  Thus, a burro herd could not double in 4 years, debunking yet another false premise held by BLM.

Fraudulent Numbers

BLM’s press release starts off by announcing that there are 5,000 wild burros in Arizona.  The inescapable purpose of citing a state-level population instead of the subject herd’s population — which is the only one under analysis for the EA — is to prejudice the public against the burros, to “build a case” that the burros are seemingly “overpopulated.”  Such manipulation of the numbers evidences lack of scientific integrity on the part of BLM staff.

Figure 2 of the EA purports to show, in visual format, how “unchecked herds double in size every 4 years.”  Figure 2 is just another fraud perpetrated by BLM at the National level and now copied at the Field Office level.  It is disinformation — propaganda, not science.  Independent research and analyses have revealed that BLM falsifies its wild-horse-and-burro population-data.

Fraudulent Estimates

A review of BLM’s population-estimates for the Black Mountain herd disclosed biologically-dubious year-to-year growth data.  The figures reflect herd-growth way beyond the normative foal-survival rate, and adult mortality was evidently ignored. [40]

The chart below tracks BLM’s reported herd-growth estimates for the Black Mountain burros since 2013, which serves as the base, the starting point — assuming it is correct, which is probably not the case.  Deviations from three norms are calculated:

(1)  From BLM’s assumption of a herd-growth rate of 15%, which does not take mortality — either foal or adult — into account;

(2)  From the Gregg et al. study of BLM records, which found a 7% increase in burro herds attributable to new surviving foals but which did not take adult-mortality into account; and

(3)  From the Gregg et al. study’s finding of a 7% increase due to new surviving foals, but adjusted to take into account a conservative annual adult-mortality rate of 5%, which yields a net herd-growth rate of 2%.

    (1)     (2)     (3)

DeviationDeviationDeviation

from 15% from 7%             from 2%

per BLMper Studyper Study

without without with 5%

Foal orAdult Adult

PopulationGrowthAdult Mortality Mortality

Year Estimate Rate Mortality

2013   800   n/a    n/a    n/a    n/a

2014 1,000   25%   67% higher 257% higher 1,150% higher

2015 1,450   45% 200% higher 543% higher 2,150% higher

2016 1,551     7%   53% lower   0% equal   250% higher

Note that the implausible growth rates compound, as each successive year is calculated per those that preceded it.  The errors compound also, leading to population-figures that are biologically impossible, given the reproductive limitations of the burro species.

Arbitrary Management Level (AML)

The AML for the Black Mountain herd was set in 1996 at 382 to 478 wild burros.  Black Mountain HMA comprises 925,425 acres, or 1,446 square miles.  Thus, per the AML, BLM implies that each burro needs 1,936 to 2,423 acres, or about 3 to 4 square miles per burro.

That idea that every little burro would need 3 or 4 square miles of range is preposterous as well as unscientific.  Therefore, the AML is arbitrary and capricious.

Minimum Viable Population (MVP) — IUCN Says ~ 2,500

The AML must be reformed to set a baseline — a starting point — of at least 2,500 burros.  Where does this number — 2,500 — originate?  It is the recommendations of the International Union for Conservation of Nature (IUCN), the world’s oldest and largest global environmental organization.  The IUCN is a neutral forum for practical solutions to conservation challenges and a leading authority on the preservation of genetic diversity in wild equids, including horses and burros.  The IUCN notes that the selective pressures wild equids have endured in the wild are likely shaping them genetically to be hardy stock that could prove useful as a genetic resource. [8]

Note that 2,500 is not a maximum but a minimum size.  Higher numbers would be better.  Because neither the questioned population-estimate nor the present AML reaches the minimal threshold of 2,500 individuals, the herd is under-populated.  Therefore, the Black Mountain HMA needs to have its herd-size baseline expanded accordingly.

By increasing the AML, the HMA would be brought into compliance with scientific expertise concerning adequate herd size.  The properly-set AML would be foundational to BLM’s best management practices (BMPs) relative to protecting and preserving this wild burro herd.

Minimum Viable Population (MVP) — Meta-Analysis Says ~ 5,000

Just when you think the answer to MVP has been found, a newer study is published. Traill, Bradshaw, and Brook (2007) conducted a meta-analysis of the scientific literature spanning the preceding 30 years on the topic of MVP. [35]  The researchers filtered hundreds of studies and selected 141 sources covering 212 unique species whose distribution was skewed toward heavier animals, particularly mammals. The researchers found:

Across all species, the median MVP was 4,169.  The “bootstrapped 95% confidence bounds” MVP for all species ranged from 3,577 to 5,129.

With regard to mammals, the median MVP was 3,876.  The “bootstrapped 95% confidence bounds” MVP for mammals ranged from 2,261 to 5,095.

Their conclusions:  In general, conservation practioners should aim for an MVP of approximately 5,000.  Specifically, the authors state: “… we recommend the upper 95% confidence limit of MVP ….”  For all species and for mammals specifically, a round number — a numerical threshold — of approximately 5,000 can be used to inform conservation management practices.

A 2010 article in American Scientist discussed the meta-analysis’ findings and provided some additional information gleaned from an interview with the lead author. [5]

How Would the New Levels Look?

Here are some numbers to compare and contrast.

Black Mountain HMA

Size:  925,425  total acres

Current Maximum Management Level:   478  wild burros

Acres per burro:  1,936

Current Exaggerated Population Estimate: 1,551  wild burros

Acres per burro:     597

IUCN Minimum Herd Size: 2,500  wild burros

Acres per burro:     370

Meta-Analysis Minimum Level for Mammals: 5,000  wild burros

Acres per burro:     185

Genetic Health of the Black Mountain Burros

In order to make informed decisions and to manage responsibly, BLM must have specific genetic data on each member Black Mountain burro herd.  Therefore, BLM needs to conduct a 100-percent evaluation of the Black Mountain burro-herd’s genetic health.  This would be accomplished by taking DNA samples and sending them in a timely manner to the Equine Genetics Lab.  Per the test-results, and per guidance from Dr. Gus Cothran and other equine experts, BLM must then reform the AML and develop best management practices to restore and maintain gene-pool diversity via a robust population-level.

The AML must ensure an optimal burro-population — one that can easily self-sustain its diversity and viability, and that can bounce back from random catastrophic events.

The correct sampling approach and order are:

Sample current and continuing herd members.

Sample first, before considering any actions.

Sample large — 100 percent.

Test samples.

Manage per test-results and best-available science.

PZP — ADVERSE EFFECTS

PZP — The Pesticide

Porcine zona pellucida — PZP aka ZonaStat-H or Native PZP — is an EPA-registered pesticide derived from the ovaries of slaughtered pigs.  PZP is approved for use on wild horses “in areas where they have become a nuisance ….” [38]

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

PZP — an Anti-Vaccine

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

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

HSUS, the registrant of PZP advised the Environmental Protection Agency that, based on information from the pesticide’s researcher-manufacturer, PZP works by generating antibodies that “block sperm attachment.”  This representation of PZP as a sort of chemical condom was not fact but merely an untested hypothesis, postulated three decades ago. The old hypothesis was disproved by subsequent research.  PZP’s manufacturer knew, or should have known, this.  The manufacturer should also have been informed and up-to-date regarding the side effects and unintended consequences of PZP.  Yet, the manufacturer continued to cite the disproved hypothesis and to deny that PZP has any adverse effects. [11 and 19]  HSUS is remiss in not investigating PZP beyond the manufacturer’s claims before touting it as the solution to the non-existent burro-overpopulation “problem.”  BLM is irresponsible in ignoring research that has disclosed PZP’s risks.

PZP’s True Mode-of-Action

So how does PZP really work?  PZP tricks the immune system into waging immunological war on the ovaries.  In a meta-analysis of ZP-type contraceptives, Kaur & Prabha (2014) reported that the infertility brought on by such products is ” … a consequence of ovarian dystrophy rather than inhibition of sperm-oocyte interaction.”  Thus, PZP’s antibodies “work” not by blocking sperm attachment but by destroying the ovaries.  Kaur & Prabha further disclosed that ” … histological examination of ovaries of immunized animals revealed the presence of atretic follicles with degenerating oocytes.” [16]  [Atretic follicles are ovarian follicles in an undeveloped state due to immaturity, poor nutrition or systemic disease; manifested by prolonged anestrus.]

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

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

Included as a reference to the EA?  No.

EA Lists Older PZP Study, but not Newer One by Same Scientists Showing Ovarian Pathologies

One of the references cited in the EA was a study by Curtis, Pooler, Richmond, Miller, Matfield, and Quimby (2002) on the comparative effects of GnRH and PZP on white-tailed deer.  However, the HSUS proposal would only examine PZP, not GnRH; so the Curtis et al. (2002) study would not be the most appropriate reference to use, especially in view of the fact that lead-researcher Curtis, along with most of the same colleagues — Richmond, Miller, and Quimby — issued a newer study (2007) on PZP alone.

The Curtis et al. (2007) study disclosed that 75% of PZP-treated white-tailed deer — and 50% of re-treated deer — suffered eosinophilic oophoritis (inflammation of the ovaries).  Further, the re-treated deer that did not develop oophoritis had a different problem — significantly fewer normal secondary follicles than control females.  The study-authors concluded that PZP “elicited ovarian pathologies in deer similar to those observed in other species.” [7]

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

In a telling study, Kirkpatrick, Liu, Turner, Naugle, and Keiper (1992a), the lead author and manufacturer of Native PZP, along with colleagues, reported that ” … three consecutive years of PZP treatment may interfere with normal ovarian function as shown by markedly depressed oestrogen secretion.” [17]  So, despite all the hype about PZP being non-hormonal, the manufacturer knew that ZonaStat-H has an adverse hormonal effect, causing significantly-lowered estrogen.  Thus, PZP is an endocrine disruptor. [39]  The plummeting estrogen-levels may also reflect the ovarian dystrophy and oophoritis now known to be caused by PZP.  Despite personally discovering negative hormonal impacts 24 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and hid its endocrine-disruptor side-effects.

Included as a reference to the EA?  No.

PZP Causes Ovarian Cysts

In their 2010 meta-analysis, Gray & Cameron cited a number of studies that found ” … alterations to ovarian function, oophoritis, and cyst formation with PZP treatment (Mahi-Brown et al.1988, Sehgal et al. 1989, Rhim et al. 1992, Stoops et al. 2006, Curtis et al. 2007).” [12]  These findings support those of Kaur & Prabha while introducing yet another adverse effect: ovarian cysts.  Gray & Cameron’s review also noted that increased irritability, aggression, and masculine behavior had been observed in females following PZP-treatment.

Included as a reference to the EA?  No.

PZP    Endocrine Disruptor    Elevated Testosterone    Masculinizing Effects   

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

PZP    Ovarian Cysts    Elevated Testosterone    Masculinizing Effects

As discussed above, PZP correlates with abnormal masculine behavior on the part of treated females, a side-effect likely due to elevated testosterone.  But in addition to the endocrine-disruption caused by PZP, there could be a second way for testosterone levels to become elevated.  Recall that PZP causes ovarian cysts.  An Internet search on “ovarian cysts and testosterone” yielded results for polycystic ovary syndrome (PCOS) in women.  Interestingly, one of the symptoms of PCOS is high testosterone levels. [26 and 42]  The connection between ovarian cysts and elevated testosterone suggests that the ovarian cysts caused by PZP could — either alone or in combination with PZP’s endocrine-disruptor effects — lead to high testosterone levels in treated females, as evidenced by their masculinized behavior.

PZP Causes Additional Adverse Effects

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

PZP Selects for Weak Immune Function

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

PZP Confers Dubious “Benefit” of Increased Longevity

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

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

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

Stillbirths;

Altered ovarian structure and cyclicity;

Interference with normal ovarian function;

Permanent ovarian damage; and

Some cases of irreversible sterility due to auto-immune oophoritis, which suggested that PZP can be selective against a certain genotype in a population. [23]

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

Included as a reference to the EA?  No.

Stillborn Foals — Recent Stillbirths Correlated with PZP

There is recent evidence confirming Nettles’ finding of a correlation between PZP treatments and subsequent stillbirths.  In June 2015, Karen Sussman, President of the International Society for the Protection of Mustangs and Burros (ISPMB), reported that 7 mares previously treated with PZP at ISPMB, when taken off PZP, were able to get pregnant.  However, 6 of those 7 mares — that is, 86 percent — produced foals that were stillborn.  All other ISPMB mares that had not been injected with PZP successfully birthed healthy foals.  Thus, given that environmental and other conditions were identical, the only variable was PZP.  The dead foals have been sent to a university pathology department for autopsy. [33]

Included as a reference to the EA?  No.

Stolen Foals — Dominant Mares Treated with PZP Steal Foals from Young Mares

Ms. Sussman of ISPMB further reported that several mares that are barren due to PZP treatments have stolen — and continue to steal — foals from first-time-mother mares. [34]  Although the kidnappers do care for the foals tenderly, they have no milk.  Consequently, the foals starve unless ISPMB discovers the “crime” and can intervene in time to save them.  However, when such stealing occurs on public lands, there is no one to rescue the foals. So, it is likely that PZP kills foals indirectly — by their being kidnapped by barren PZP-treated mares, further confirming its status as a pesticide.  We can also infer that PZP’s population-reduction effect is probably due, in part, to foal deaths.

Included as a reference to the EA?  No.

Why Do PZP-Treated Mares Steal Foals?

Ms. Sussman has observed that the PZP-treated mares appear to suffer psychologically from their barrenness.  They seem unhappy and frustrated that they don’t have foals of their own.  So, they steal foals to fulfill that unmet maternal need.

Foal-stealing is yet another behavioral abnormality associated with PZP-use.  Thus, PZP wreaks havoc beyond just the individual mares treated with it, disrupting the life of non-treated mares and threatening the life of innocent new foals. It is likely that the apparent “contraceptive” effect of PZP is due, in part, to the death of stolen foals on the range, where no one is there to save them.

Foal-Stealing — Hormonal Hypothesis

In the literature, it is noted that foal-stealing is not as common among horses as in some other species.  However, when foal-stealing does occur, Waring (2003) [44] — citing Crowell-Davis and Houpt (1986) [6] — reported that foal-stealing typically correlates with a mare …

Who is close to giving birth or

Who is separated from her own neonate or

Whose foal has recently died.

Sue McDonnell, PhD, a certified applied animal behaviorist and the founding head of the equine behavior program at the University of Pennsylvania’s School of Veterinary Medicine, states:

The explanation proposed (but not known for sure) for this in a mare just before she foals is that her hormones might be a bit misaligned, such that the hormones of bonding prevail a bit earlier than they should and maternal interest and bonding occur prematurely. [21]

However, the kidnapper-mares in question are neither pregnant, nor separated from a neonate, nor grieving the death of a foal.  If the unusual behavior is hormonally-induced, then it would seem that PZP has another endocrine-disrupting effect — and additional unintended consequences — causing social disruption and foal deaths.

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

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

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

Tung, Agersborg, Bagavant, Garza, and Wei (2002) found that autoimmune oophoritis (ovarian inflammation) could be induced by injecting test-animals with ZP3 peptide. [36]  The researchers noted that autoimmune ovarian disease is a known cause of human premature ovarian failure.  Here again, is causation of autoimmune disease by a ZP-type product.  Humans and horses are both mammals.  It is logical to conclude that ovarian failure also occurs in horses.  This study confirms other research cited herein.

Included as a reference to the EA?  No.

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

Varras, Anastasiadis, Panelos, Balassi, Demou, & Akrivis (2013) disclosed that, in humans, autoimmune oophoritis carries the risk of the patient developing other autoimmune diseases. [43]  The correlation between autoimmune oophoritis and subsequent other autoimmune disorders weighs against injecting 165 jennies with PZP.

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

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

A prolonged breeding season and

Unusually-late parturition dates.  (Parturition is the formal term for “giving birth.”)

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

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

A longitudinal study by Ransom, Hobbs, Bruemmer (2013) of three herds currently being managed by PZP — Little Book Cliffs, McCullough Peaks, and Pryor Mountain — found a prolonged parturition-season — it lasted 341 days. [29]  Ransom et al.’s finding of a nearly year-round birthing season supports the earlier finding by Nettles (1997).  Thus, during its period of potential reversibility, PZP’s effects wear off unpredictably.  Out-of-season births put the life of both the mare and the foal in jeopardy.  Nature designed the equine birthing-season to occur in Spring, not year-round, and certainly not in the dead of Winter.

Included as a reference to the EA?  No.

Prolonged Delay in Recovery of Fertility

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

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

As if the above scenario were not bad enough, PZP’s manufacturer conceded that it could take up to 8 years to recover fertility after just 3 consecutive PZP treatments. [27]

Ransom Advises Proceeding with Caution regarding PZP

The Ransom et al. study warned:

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

Because BLM keeps over 80 percent of the herds — including the Black Mountain burros — at levels below minimum-viable population (MVP) per the IUCN, most herds qualify as “small refugia.”

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

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

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

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

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

BLM Was Fully-Aware of the Ransom et al. (2013) Study but Suppressed the Findings

In their report, the authors of the Ransom et al. study gave a shout-out to BLM “for administrative and technical support throughout this project.”  Thus, BLM was fully aware of the multi-year study while it was in progress and even lent support to it administratively and technically.  Yet, in the case of the Pryor Mountain herd, BLM omitted this important report as a reference for the 2015 Environmental Assessment, which proposed intensifying the PZP “prescription.”  Thus, BLM pretended that there was no such report and unethicallly suppressed it.  Consequently, the public could not comment knowledgeably and appropriately on the continued use of — let alone the accelerated application of — PZP.

I note that the Black Mountain EA also omitted the Ransom et al. (2013) study as a reference but did include an earlier study by Ransom, Cade, and Hobbs (2010) on PZP’s influence on issues of lesser importance: Time budgets, social behavior, and body condition.  The 2013 study is certainly more relevant in terms of PZP’s potential impact to the very existence of the Black Mountain burros than was the 2010 report.  The 2013 study’s important scientific findings should inform the decision-making process, but were left out.  Thus, BLM did not use the best-available research.

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

Disturbingly, another recent study on PZP (Knight & Rubenstein, 2014) found that ” … three or more consecutive years of treatment or administration of the first dose before sexual maturity may have triggered infertility in some mares. [20]

These findings are particularly troubling.  They suggest that, actually, only two consecutive PZP-treatments may be reversible.  Except, that is, in the case of fillies who have not yet reached puberty — they could be sterilized by just one injection.  Recall the Pryor Mountain fillies, whose PZP treatments begin when they are just 1½ years old.  They may not have reached puberty when they are initially treated. [9]  And as we shall see later in this report, that first shot of PZP may not be their first shot of PZP.

Included as a reference to the EA?  Yes, but the EA said: “However, Knight and Rubenstein (2014) speculated that three consecutive years may trigger infertility in some mares.” (pdf-page 35)

Black Mountain’s EA Lifted Passages Wholesale from Another Fertility-Control EA

When I read the sentence referenced immediately above — that Knight and Rubenstein had “speculated” about PZP triggering infertility in as few as 3 years — it had a déjà vu quality.  I knew I had encountered just that same dismissive-to-science word-choice before.  Indeed I had.  The 2015 Pryor Mountain Wild Horse Range Fertility Control Environmental Assessment DOI-BLM-MT-0010-2015-0006-EA contained that same sentence, word-for-word, on pdf-page 14. [3]  In fact, the entire paragraph that ends in that sentence was lifted directly from the Pryor Mountain EA.  What’s more, most of the paragraph preceding that one was taken directly from the Pryor Mountain EA.  Continuing on, I found example after example of such copying, with minor additions and modifications here and there referencing jacks and jennies instead of stallions and mares.

Questions as to scientific integrity: The fact that the team of 9 BLM-Arizona staffers who prepared the EA copied extensively and word-for-word from another EA suggests that no true analysis was conducted.  I wonder: Did they even read the studies they cited?  Probably not.

More questions as to scientific integrity:  Pdf-page 48 of the Black Mountain EA identifies the BLM National Office staff who reviewed it.  One of the reviewers is the former Wild Horse Specialist for the Pryor Mountain Wild Horse Range, and held that position at the time that the 2015 fertility-control EA was issued.  Did the W. O. Senior Wild Horse and Burro Representative supply his old EA for the convenience of BLM-Arizona staff?  Did he essentially approve his own EA, modified slightly to reference Black Mountain wild burros instead of Pryor Mountain wild horses?

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

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

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

Knight & Rubenstein’s concerns support those of Gray & Cameron, who also questioned the supposed benefit of sterile mares’ extended life-spans.  The abnormal numbers of aged, sterile mares count for census-purposes; but their presence disadvantages the younger horses, who become tageted for removal in order for BLM to achieve arbitrary management levels.  Further, such mares no longer belong to the viable gene-pool.  The same concern should be taken seriously with regard to jennies, especially in light of their lower fertility and alternating-year breeding cycle.

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

It gets worse.  Sacco, Subramanian, Yurewicz (1981) reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk.  The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. [30]

These findings were disclosed in 1981 — 35 years ago.  PZP’s manufacturer must have known about this dangerous effect, and certainly BLM should have investigated on its own whether there was any risk to the unborn or the nursing foal.  Yet, the manufacturer continued to insist that there was no danger to the foal, whether born or unborn. [19]  And in fact, BLM regularly administers PZP to pregnant and lactating mares, who transfer the destructive antibodies to their fetus, via the placenta, and to their foal, via mother’s milk.

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

Likewise, if the Black Mountain jennies were injected while pregnant and / or nursing, their filly-foals would have PZP antibodies inflaming their little ovaries.  Subsequent injections could easily sterilize them in one shot, especially if given prior to puberty.

Included as a reference to the EA?  No.

PZP Weakens Herd-Immunity, Posing Risk of Stochastic Events Leading to Herd-Extinction

To be self-sustaining, a herd needs to possess good immunity to withstand random catastrophes — known as stochastic events — such as contagious infections.  There was such an event recently in Kazakhstan, where 120,000 endangered Saiga antelope — half the world’s population — died off suddenly and inexplicably within a two-week period.  Scientists think a common bacterial infection was the cause of this mass-mortality event, but are unsure why the antelope were unable to fight off the disease immunologically. [28]

Imagine if such a catastrophe were to befall the Black Mountain burros, whose herd-immunity would be eroded by PZP.  Note that the Saiga deaths involved antelope-mothers and their calves.  If Black Mountain’s few fertile jennies and their foals perished all of a sudden, that would leave just jacks and sterile old jennies.  The herd would be composed of the living dead, reproductively speaking, its rare alleles extinguished.  BLM would be failing to proactively manage the Black Mountain herd with stochastic events taken into consideration.  That would constitute malfeasance.  PZP is a tool of immunological destruction, not of proper management.

PZP Continues the Use of Roundups and Removals

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

But evidently every 3 years, in BLM’s mind, wasn’t often-enough.  BLM announced plans to conduct removals every year in the Pryor Mountains despite recently-intensified PZP-treatments.  Friends of Animals, a reknowned animal-advocacy organization that opposes PZP, sued to prevent BLM from initiating the accelerated schedule of gathers.  Friends of Animals prevailed, and the annual removals were blocked.  The Court directed BLM to fulfill its commitments to reevaluate the Pryor Mountain AML. [11 and 15]

As the EA acknowledges, the Black Mountain herd would likely also be subject to annual roundups in order to re-inject the jennies, to re-brand them, and to render veterinary treatment of injection-site abscesses.  What the EA refers to as “opportunistic” field-darting would probably not be adequate to “re-booster” enough of the test-subjects.  Roundups are stressful on burros and costly to taxpayers.  The better and no-cost population-control method is predation by mountain lions, coyotes, and perhaps even reintroduced wolves.

  

Risks to Humans Who Administer PZP Injections

For BLM and HSUS staff and volunteers who inject wild horses with PZP, EPA’s Pesticide Fact Sheet advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure.  EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility. [38]

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

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

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

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

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

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

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

Mandate to Practice Scientific Integrity

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

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved.  Most importantly, it must be trustworthy. [37]

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

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

The manufacturer of PZP — a partner to BLM — misrepresented the pesticide as safe for use on animals by humans.  The manufacturer knew or should have known that the former hypothesis regarding PZP’s mode-of-action had been disproved, and that PZP has dangerous side effects, safety-issues, and unintended consequences. Yet he hid and denied that information and failed to warn about PZP’s adverse effects.  The manufacturer cited his own research as if it were definitive, and aggressively criticized wild-horse-and-burro advocacy groups that oppose PZP, such as Friends of Animals and Protect Mustangs, and independent researchers whose findings did not fully support his claims.  Indeed, he submitted an Op-ed to The Salt Lake Tribune wherein he accused Friends of Animals and Protect Mustangs of citing “dubious and distorted” data about PZP.  He belittled the research of fellow scientists whose studies on PZP yielded results somewhat different from his own. [19]  His accusations were so unreasonable that the scientists felt it necessary to submit an Op-ed in response to defend the integrity and validity of their work. [24]  The manufacturer also disparaged members of the public — one of whom was appointed to the Pennsylvania Game Commission — that expressed concerns about PZP.  He dismissively accused them of “an attempt to mislead,” of “hyperbole,” of “knowingly manipulating information,” of “attempts to frighten people,” and of indulging in an “anti-intellectual approach to debates.” [18]  By these actions, the manufacturer violated the DOI Code of Scientific and Scholarly Conduct.

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

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

Recall that the manufacturer claimed PZP is “so safe it is boring.” [11]  Independent research shows otherwise — that PZP is a powerful hormone disruptor that could sterilize a female with just one injection.  If trainees believe that PZP is boringly safe, they will be less likely to protect themselves adequately from this dangerous pesticide.  Indeed, many of the trainees are women and, therefore, particularly at risk.  Likewise, wild-horse-and-burro advocates are lulled into complacency, trusting that PZP is harmless.  Of course, none of that is true.

Second, a PZP supporter, who self-identified as a recent completer of the PZP-darting training program conducted by the manufacturer, said in a comment posted to a news article: “I just received my FDA certification to handle and administer Native PZP.  Would you be so kind to provide a link to the study you keep referencing?  To my knowledge, and those teaching the Native PZP certification class, there are no side effects of the PZP produced by Dr. Kirkpatrick and his team, which is Native PZP.” [10]  Key words: “no side effects.”  It is disturbing that a person who was, no doubt, motivated by a desire to help the wild horses and burros has been disinformed regarding PZP’s safety-hazards to humans as well as to horses and burros.

PZP — Conclusions about

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

ADDITIONAL CONCERNS AND INFORMATION

EA Includes a Reference that Cannot Be Verified and that Perpetrates a Fraud

The APA Publication Manual “contains the complete guidelines on how to cite research in text as well as formatting of material for publication.  It is a set of style rules that codifies the components of scientific writing in order to deliver concise and bias free information to the reader.” [2]

One of the references BLM cited in the EA is listed thusly:

Cothran.  2010.  Personal Communication.  Conversation regarding genetics and related testing.

This citation does not comply with APA standards for a proper scientific reference because a conversation is not “findable” or “retrievable” or “recoverable.” [2]  Thus, the above personal communication cannot be verified.  It should have been mentioned only in text, not in References.  It was also odd that, in the intervening 6 years, a better reference was not secured.

Evidently, the citation was intended in support of the following sentence, found on pdf-page 38.

Extended length between generations provides for lengthening generation time and slows the rate of genetic loss (Cothran, personal communication 2010).

But this sentence, too, had a déjà vu feeling to it.  Sure enough, it was taken directly, word-for-word, from pdf-page 16 of the 2015 Pryor Mountain Fertility Control EA.  In fact, the entire paragraph that contains the above sentence was lifted from the 2015 EA.

What is more troubling is that the reader is led to believe that someone from BLM-Arizona actually had a personal communication with Dr. Cothran back 6 years ago.  Surely, no such conversation happened.  Thus, a fraud is being perpetrated against the reader in violation of scholarly-integrity principles.

Bighorn Sheep — Study Shows No True Competition from Burros

Black Mountain is home to bighorn sheep, prized trophy-targets for hunters.  Extraordinary efforts have been made to translocate sheep into suitable habitat in the state and to augment their numbers.  On pdf-page 25 of the EA, BLM implies that burros compete with bighorn:

Over the very long-term (20 years or longer), if the results of the project are found to be effective in reducing jenny fertility rates (through extrapolation), there could be the potential for a reduction in competition for forage resources between ungulates (desert bighorn sheep, cattle, and burros).

BLM assumes — incorrectly — that burros disadvantage bighorn (and cattle).  That false assumption has been debunked.  Wehausen (1998) concluded that “a negative influence of burros on bighorn sheep demography has not been shown as support for true competition.” [45]  As to the alleged competition with cattle, that false assumption has been debunked too.

Facilitation and Commensalism — Equids Enhance Livestock Production

Some species thought to compete actually facilitate one another’s well-being.  They interact positively and reduce physical stress. [32]  For instance, commensals are animals that eat “at the same table” but without competing.  Such is the case for burros and bovids.  Counter-intuitive but true, research has shown that cattle gain more weight when grazed with donkeys. [25]

BLM neds to stop the range-war, pitting burros against bovids.  Forage-grazing is not a zero-sum game.

Symbiosis — Burros Graze Old Growth — Cattle Prefer New Growth

Wild burros utilize coarse, old-growth forage.  They are like lawn mowers.  They take off the top growth — the dry, unpalatable layer.  This grazing method enables the plants to put down deeper roots, and it prevents weeds from maturing to produce seeds.  Grasses are encouraged by the burros’ frequent “mowing.”  In addition, the fuel-load is reduced, helping to prevent wildfires.

Livestock, in contrast, prefer tender new growth.  They will even return to patches previously grazed — not rested — to get at that new growth. [14]  Thus, by consuming the old growth and making available the new growth, wild burros make conditions better for the range and better for livestock.  Arizona needs more burros, not fewer.

ESTHETICS UGLIFIED VISITOR-EXPERIENCE RUINED

Scarlet Letters

BLM procedures would call for the 165 jennies treated with PZP to be freeze-marked with three letters on both sides of their hips — left and right.  Each of the letters would be 3½-4 inches in size.  The purpose of these huge brands is to make it easy for HSUS researchers to spot and dart the jennies from a distance.

First, please note that the Act prohibits the branding of wild horses and burros.  The Act provides no exemption for BLM or HSUS.  The disfigurement of burros is unacceptable.  Surely, no jennies uglified with such blemishes would ever be adopted.  Their marred appearance would also spoil the wilderness experience of eco-tourists who come to see the lovely burros in their natural habitat.  Like Hester Prynne, the Black Mountain jennies would wear their prominent “scarlet letters” to announce their shameful status for the rest of their life, their only “sin” being their fertility, for which they would be punished.

With regard to tracking and locating wild horses, BLM should employ inconspicuous electronic devices, such as tracking tags.  The use of disfiguring freeze-marks must be prohibited.  It should be noted that electronic tracking can also provide a record of each burro’s personal data for longitudinal studies.  It is time for BLM to use modern methods instead of destroying the jennies’ beauty.

Recreation and Wild Burro Viewing

As it is, most wildlife-tour visitors have to search long and hard to find any wild burros to view in the Black Mountain HMA.  So, with 165 of the jennies injected with PZP, there would be fewer families, and especially, fewer darling “babies” frolicking on the range.  The presence of foals delights recreational visitors; the absence of foals disappoints them.  Forelorn, childless jennies disfigured with huge freeze brands on their rumps would be repulsive, and not what the public wants to see.  Esthetics count, and recreation is fast-becoming the predominant use of our public lands.  Please don’t ruin it for us.

Sincerely,

Marybeth Devlin


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




REFERENCES

  1.  Alberta Agriculture and Forestry.  (2016, July 5 — Last Reviewed/Revised)  The Donkey.  Retrieved from http://www1.agric.gov.ab.ca/$department/deptdocs.nsf/all/agdex598

  2.  APA 6th Edition Publication Manual.  (2015 — Last Udate)  Alliant Library.  Retrieved from http://alliant.libguides.com/content.php?pid=268617&sid=2216572  and  2956230

  3.  BLM, Billings Field Office (March 2015) Environmental Assessment, Final. Pryor Mountain Wild Horse Range Fertility Control.  DOI-BLM-MT-0010-2015-006-EA.  Retrieved from http://www.blm.gov/style/medialib/blm/mt/field_offices/billings/horseeas/2015.Par.28280.File.dat/PMWHR%20fertility%20EA%202015.pdf

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

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

  6.  Crowell-Davis, S.L. and K.A. Houpt.  1986.  Maternal behavior.  Vet. Clin. No. Amer.: Equine Pract. 2:557–571.  Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/3492245

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

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

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

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

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

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

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

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

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

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

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

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

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

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

21.  McDonnell, Sue.  (2010, September 1)  “Foal ‘Stealing’.”  The Horse.  Retrieved from http://www.thehorse.com/articles/27692/foal-stealing

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

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

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

25.  Odadi W, Jain M, Van Wieren S, Prins H, Rubenstein D.  (2011)  Facilitation between bovids and equids on an African savanna.  Evolutionary Ecology Research, 2011, 13: 237–252.  Retrieved from https://www.princeton.edu/~dir/pdf_dir/2011OdadiCowdonk.pdf

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

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

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

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

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

31.  San Diego Zoo.  (2009)  Domestic Donkey & Wild Ass Fact Sheet.  Retrieved from http://library.sandiegozoo.org/factsheets/donkey/donkey.htm#repro

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

33.  Sussman, Karen.  (2015 June 6)  “Suspicious Deaths with Use of Anti-Fertility Drugs.”  International Society for the Protection of Mustangs and Burros.  Retrieved from http://www.ispmb.org/BirthControlDeaths.html

34.  Sussman, Karen.  (2014 October)  “A Beautiful Story But Sad for the Kidnapper.”  International Society for the Protection of Mustangs and Burros.  Retrieved from http://www.ispmb.org/sheldon_wipeout.html

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

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

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

38.  United States Environmental Protection Agency.  Office of Chemical Safety and Pollution Prevention.  Pesticide Fact Sheet.  Porcine Zona Pellucida (PZP).  New Chemical.  Nonfood Use.  January 2012.  Retrieved from

http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

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

40.  U.S. Department of the Interior.  Bureau of Land Management.  Wild Horse and Burro Program Data.  Retrieved from   http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html

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

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

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

44.  Waring, George H.  2003.  Horse Behavior. 2nd Ed.  Noyes Publications / William Andrew Publishing.  Norwich, NY. Retrieved from http://www2.univet.hu/users/knagy/books/Waring_Horse_Behavior.pdf

45.  Wehausen, John D.  (1998)  Nelson Bighorn Sheep.  White Mountain Research Station.  Retrieved from http://www.blm.gov/ca/pdfs/cdd_pdfs/Bighorn1.PDF

46.  World Atlas.  (2016, February 12 — Last modified)  Burro Facts: Animals of North America.  Retrieved from http://www.worldatlas.com/articles/burro-facts-animals-of-north-america.html

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




#Pesticide PZP is dangerous for the last American herds of wild horses and burros

PM PZP Injection

The old hypothesis — that PZP merely blocks sperm attachment — has been disproved.

Kaur & Prabha (2014) found that the infertility brought on by PZP is ” … a consequence of ovarian dystrophy rather than inhibition of sperm-oocyte interaction.” They reported that PZP’s antibodies induce ovarian dystrophy, oophoritis (inflammation of the ovaries), destruction of oocytes in all growing follicles, and depletion of resting follicles.

Despite all the hype about PZP being non-hormonal, the manufacturer himself knew that it had an adverse hormonal effect — significantly-lowered estrogen. In 1992, he reported that ” … three consecutive years of PZP treatment may interfere with normal ovarian function as shown by markedly depressed oestrogen secretion.” Thus, PZP is an endocrine disruptor.

Worse yet, Sacco et al. (1981) found that 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. This is bad news because BLM regularly administers PZP to pregnant and lactating mares, who transfer the destructive antibodies to their filly-foals. Thus, the fillies get their first treatment with PZP in utero, while nursing, or both.

Nettles (1997) found an association between PZP and stillbirths. In 2015, the International Society for the Protection of Mustangs and Burros reported that 7 mares previously treated with PZP, when taken off it, were able to get pregnant. However, 6 of those 7 mares — that is, 86 percent — produced foals that were stillborn. All other ISPMB mares that had not been previously injected with PZP successfully birthed healthy foals. Environmental and other conditions were identical. The only variable was PZP. Meanwhile, over on the East Coast, the Corolla herd, long-managed with PZP, has recently experienced birth defects among its newborns.

Gray & Cameron (2010) questioned the supposed benefit of PZP-sterilized mares living much longer than their normal life expectancy, and and Knight & Rubenstein (2014) warned of unintended consequences of PZP’s ironic effect of extended longevity. Ultra-elderly mares take up scarce slots within AML-restricted herds. They consume resources but no longer contribute to the gene-pool. It is detrimental to a population’s genetic viability to carry significant numbers of sterile herd-members way-beyond their normal life-span. Meanwhile, those few foals that are born have to be removed to achieve AML because they’re more adoptable.

Ransom et al. (2013) conducted a longitudinal study of three herds currently being managed by PZP — Little Book Cliffs, McCullough Peaks, and Pryor Mountain. They found that the the birthing season lasted 341 days — nearly year-round — which puts the life of mares and foals in jeopardy. Nature designed the equine birthing-season to occur in Spring, not year-round, and certainly not in the dead of Winter.

Ransom et al. also found that, after suspension of PZP, there was a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recovered their fertility. They warned: “Humans are increasingly attempting to manage the planet’s wildlife and habitats with new tools that are often not fully understood. The transient nature of the immunocontraceptive PZP can manifest into extraordinary persistence of infertility with repeated vaccinations, and ultimately can alter birth phenology in horses. This persistence may be of benefit for managing overabundant wildlife, but also suggests caution for use in small refugia or breeding facilities maintained for repatriation of rare species.”

PZP’s manufacturer conceded that it could take up to eight years to recover fertility after just three consecutive PZP treatments.

The study on PZP by Knight & Rubenstein (2014) found that ” … three or more consecutive years of treatment or administration of the first dose before sexual maturity may have triggered infertility in some mares.” These findings are particularly troubling. They suggest that, actually, only two consecutive PZP-treatments may be reversible. Except, that is, in the case of fillies who have not yet reached puberty — they could be sterilized by just one injection.

PZP’s manufacturer was quoted describing PZP as “so safe it is boring.” Independent research shows otherwise — that PZP is a powerful hormone disruptor that could sterilize a female with just one injection. If staff and volunteers believe that PZP is boringly safe, they will be less likely to protect themselves adequately from this dangerous pesticide. Indeed, many of the volunteers are women and, therefore, at risk. Accidental self-injection with PZP could cause them to suffer diseased ovaries and depressed estrogen-levels — in addition to infertility and, potentially, sterility. Consider the magnitude of the risk — the PZP-in-question is a horse-size dose.

~ Marybeth Devlin, Wild Horse Advocate

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




Wild horses rescued from slaughterhouse are stalked, harassed by pro-slaughter & pro-sterilization advocates

Retaliation scheme against Protect Mustangs for speaking out against sterilization and slaughter

The pro-slaughter, pro-experiment on pregnant mares, pro-sterilization, pro-pzp advocates are posing as horse advocates in the “Sinister Solutions” group on Facebook. They broadcast the BLM agenda on their Facebook page sprinkled with BLM employees. It’s like an endless biased talk show. They bash and lie about real advocates championing the rights of America’s wild horses and Facebook lets them do it.

Several members of Sinister Solutions started a new group to lead the smear against us, the WY14™ and Protect Mustangs™. They are spreading lies, bashing, bullying and harassing us. They want to hurt the March pasture board fundraiser for the Wyoming 14™ (WY14™) https://www.gofundme.com/MustangPasture3-16 and they want to hurt the wild horses.

The sinister group launched a Facebook page to find the WY14™ in their private location so they would lose their safety. Now their location has been disclosed to many pro-slaughter people. What is the real motive of the group run by BLM supporters?

Several haters and jealous people also joined the Facebook group to be part of the hate-fest. Their goal is to hurt donations for the WY14™ so the orphans of slaughter can’t pay their pasture board for March. They are trying to put them at-risk.

These online bullies are not only hoping for neglect but they are interfering in our program and work. It seems they are also threatening to cause harm. The pro-slaughter, pro-sterilization advocates are plotting to “swoop in to take them”. . . But we aren’t going to let that happen.

We have contacted the authorities. Protect Mustangs has enlisted an armed security guard for an additional $1000. per month after receiving screenshots of the stalkers plotting in the Facebook group. The WY14™ board is $2,500. Security is now $1000. and then GoFundMe/WP takes 10% combined for processing. That makes the total $3,850. per month until we can move them to a new location. I pray that’s very soon so the WY14™ can know peace again. Please donate here: https://www.gofundme.com/MustangPasture3-16

If you are hearing lies about missing horses or anything else, please call me and ask any questions. My number is 415-531-8454. You can also email us at Contact@ProtectMustangs.org All the members of the herd known as the WY14™ (14 + 2 foals) are fine and well cared for on a daily basis. Craig Downer, wildlife ecologist, will attest to that. You can read his report here.

You will remember that I spoke about the one mustang who escaped during loading from the layover sanctuary last August. His name is White Socks and he was invited to stay at Dreamcatcher for the winter. The haters and pro-slaughter people have been spreading lies to create hysteria that he was missing when we had already told supporters he was there. They even went as far as to violate copyright laws to harass and bully us. This is vicious, illegal and there’s more to it.

The WY14™ are sad that their peaceful eco-pasture has been ruined by stalkers with telephoto cameras posting smears on Facebook, spewing jealously, hatred and bad energy. The WY14™ were starting to get better after all the trauma from the BLM roundup where everyone over the age of 2 was killed at slaughter for human consumption. Now they are being persecuted again. . .

Keep in mind all this is happening when a few members of the WY14™ are going to contribute foals. These fertility-haters are spying on the pregnant mares, making false claims to animal welfare agencies and then rushing off on Facebook to spread gloom and doom about their pregnancies, calling them “rank”, “inbred”, and “ugly”, etc. This is so  wrong.

Right now the WY14™ need your help to share and donate for their March pasture rent. Please help them here: https://www.gofundme.com/MustangPasture3-16 Please share often so others can help donate too. This makes a big difference.

Please keep the WY14™ in your prayers and PRAY we find the land for their permanent Eco-Sanctuary in California ASAP. This is an emergency now!

With love,
Anne

Anne Novak
Volunteer Executive Director
www.ProtectMustangs.org

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


Below Susan Humphrey shares her view on wild horses–calling them feral and pests. http://magicvalley.com/news/local/utah-wildlife-board-urges-blm-to-remove-some-wild-horses/article_9721b046-d207-11e3-964d-001a4bcf887a.htmlBelow Susan Humphrey is speaking about Anne Novak, Executive Director of Protect Mustangs in a public Facebook group.

 

Does PZP result in wild herds with lower immune systems and potential for die-offs?

PM Tule Elk Males FIghting by austlee

PZP is an immunocontraceptive and pesticide which causes an immune reaction to reject fertilization, while the females still come into estrus. Besides wrecking havoc on the immune system, injecting herds with PZP results in more fighting between males and many other behavior abnormalities.

Tule elk in Pt. Ryes National Seashore (Marin County, California) were part of a PZP (Porcine Zona Pellucida) experiment. Several years later there was a strange die-off.

Wildlife groups blamed park service management for leaving the elk fenced in during a drought–claiming that was the reason for the die-off.

Park service officials said the tule elk had water during the die-off.

“Some wildlife advocates have termed the situation a “die-off” and accuse the park service of allowing the elk to perish behind the fence that prevents them from finding enough food and water. Park service officials have a different view of what caused the population drop, and are hoping that new data will help address these concerns, especially as visitor interest peaks during the fall rutting season.” from: https://baynature.org/articles/on-the-fence/

Listen to Wildlife Ecologist Dave Press Discusses Tomales Point Elk and mention “there was water in the pond up there . . .” at 2:18.

 

It’s time to connect the dots and ask the obvious question: Did PZP lower the herds’ immune system and genetic diversity to the point of making them vulnerable to a die-off?

With suspect data regarding the long-term use of PZP on wild herds, more questions and answers are needed to prevent a similar die-off in America’s wild horses & burros.

With regards to wild horses, keep in mind what Marybeth Devlin wrote about PZP:

“PZP is a registered pesticide whose mechanism-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that target and attack the ovaries. PZP’s antibodies cause the mare to suffer ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. Not surprisingly, estrogen levels drop markedly as the ovaries are slowly destroyed. But PZP’s adverse effects are not limited to the individual animal. As a recent study — which included the Little Book Cliffs, Colorado herd and the McCullough Peaks, Wyoming herd — found, PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Further, the same study disclosed that the pesticide causes a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recover their fertility after suspension of PZP. However, some mares never recover — they are left permanently sterile, and quickly too. Indeed, yet another study found that sterility could occur in some mares from just three years of PZP injections or from just one treatment if the pesticide were given to a filly before she reached puberty. Because PZP messes with the immune system, it ironically works “best” — sterilizes faster — if the mare has a strong immune system. But, conversely, PZP may not work at all in mares whose immune function is weak or depressed. So, the pesticide discriminates against the very horses that Nature has best equipped for survival against disease while favoring and selecting for the immuno-compromised. Worse yet, tests performed via radioimmunoassay indicated that 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.”  [From: http://protectmustangs.org/?p=8529]

 

Pm PZP Darts

Links of interest™:

Immunocontraception (Wikipedia): https://en.wikipedia.org/wiki/Immunocontraception

“Whenever an immune response is provoked, there is some risk of autoimmunity. Therefore immunocontraception trials typically check for signs of autoimmune disease.[17] One concern with zona pellucida vaccination, in particular, is that in certain cases it appears to be correlated with ovarian pathogenesis.[2] However, ovarian disease has not been observed in every trial of zona pellucida vaccination, and when observed, has not always been irreversible.[18]”

 

Autoimmune disease (Wikipedia): https://en.wikipedia.org/wiki/Autoimmune_disease 

“Autoimmune diseases arise from an abnormal immune response of the body against substances and tissues normally present in the body (autoimmunity). . .”

 

ZonaStat-H is the EPA restricted-use pesticide–PZP–for wild horses and burros the registrant calls “pests”: http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

 

Tule elk: http://www.nps.gov/pore/learn/nature/tule_elk.htm

 

Tule elks at Pt. Reyes National Seashore (National Park Service): http://www.nps.gov/pore/getinvolved/supportyourpark/upload/volunteer_docent_info_tule_elk_elkmanagement_v5.0_1.pdf

 

Challenges face tule elk management in Point Reyes National Seashore  http://www.mercurynews.com/pets-animals/ci_28311296/challenges-face-tule-elk-management-point-reyes-national

“Earlier this year park service officials revealed that more than 250 tule elk died inside the fenced area over a two-year period, in part because pools that the herds rely on for water had gone dry. Meanwhile, ranchers are complaining about the free-range elk getting on their land and eating grass and drinking water intended for their dairy cattle and other agricultural operations.”

 

Paratuberculosis or Johne’s disease (Wikipedia): https://en.wikipedia.org/wiki/Paratuberculosis

 

Testing for Mycobacterium avium subsp. paratuberculosis infection in asymptomatic free-ranging tule elk from an infected herd.  http://www.ncbi.nlm.nih.gov/pubmed/12910759

“Forty-five adult tule elk (Cervus elaphus nannodes) in good physical condition were translocated from a population located at Point Reyes National Seashore, Marin County (California, USA), to a holding pen 6 mo prior to release in an unfenced region of the park. Because infection with Mycobacterium avium subsp. paratuberculosis (Mptb) had been reported in the source population, the translocated elk underwent extensive ante-mortem testing using three Johne’s disease assays: enzyme linked immunosorbent assay (ELISA); agar gel immunodiffusion assay (AGID), and fecal culture. Isolation of Mptb was made from fecal samples in six of 45 elk (13%). All AGID results were negative while ELISA results for 18 elk (40%) were considered elevated. Elevated ELISA results or Mptb isolation from fecal samples were obtained for 22 of 45 elk (49%); these elk were euthanized and necropsied. Mycobacterium avium subsp. paratuberculosis was isolated from tissue in 10 of 22 euthanized elk (45%); of these 10 cases of confirmed infection, eight had elevated ELISA results (80%) and four were fecal culture positive (40%). One of 10 cases had histopathologic lesions consistent with Mptb infection. Mycobacterium avium subsp. paratuberculosis was also isolated from tissue from one of eight fetuses sampled. The number of tule elk found to be infected was unexpected, both because of the continued overall health of the source herd and the normal clinical status of all study animals.”

 

Mycobacterium avium subspecies paratuberculosis and Mycobacterium avium subsp. avium infections in a tule elk (Cervus elaphus nannodes) herd. 2006. http://www.ncbi.nlm.nih.gov/pubmed/17255437 

Abstract
“Between 2 August and 22 September 2000, 37 hunter-killed tule elk (Cervus elaphus nannodes) were evaluated at the Grizzly Island Wildlife Area, California, USA, for evidence of paratuberculosis. Elk were examined post-mortem, and tissue and fecal samples were submitted for radiometric mycobacterial culture. Acid-fast isolates were identified by a multiplex polymerase chain reaction (PCR) that discriminates among members of the Mycobacterium avium complex (MAC). Histopathologic evaluations were completed, and animals were tested for antibodies using a Johne’s enzyme-linked immunosorbent assay (ELISA) and agar gel immunodiffusion. In addition, 104 fecal samples from tule elk remaining in the herd were collected from the ground and submitted for radiometric mycobacterial culture. No gross lesions were detected in any of the hunter-killed animals. Mycobacterium avium subsp. paratuberculosis (MAP) was cultured once from ileocecal tissue of one adult elk and was determined to be a strain (A18) found commonly in infected cattle. One or more isolates of Mycobacterium avium subsp. avium (MAA) were isolated from tissues of five additional adult elk. Gastrointestinal tract and lymph node tissues from 17 of the 37 elk (46%) examined had histopathologic lesions commonly seen with mycobacterial infection; however, acid-fast bacteria were not observed. All MAC infections were detected from adult elk (P = 0.023). In adult elk, a statistically significant association was found between MAA infection and ELISA sample-to-positive ratio (S/P) > or = 0.25 (P=0.021); four of five MAA culture-positive elk tested positive by ELISA. Sensitivity and specificity of ELISA S/P > or = 0.25 for detection of MAA in adult elk were 50% and 93%, respectively. No significant associations were found between MAC infection and sex or histopathologic lesions. Bacteriologic culture confirmed infection with MAP and MAA in this asymptomatic tule elk herd. The Johne’s ELISA was useful in signaling mycobacterial infection on a population basis but could not discriminate between MAA and MAP antibodies. The multiplex PCR was useful in discriminating among the closely related species belonging to MAC.
Between 2 August and 22 September 2000, 37 hunter-killed tule elk (Cervus elaphus nannodes) were evaluated at the Grizzly Island Wildlife Area, California, USA, for evidence of paratuberculosis. Elk were examined post-mortem, and tissue and fecal samples were submitted for radiometric mycobacterial culture. Acid-fast isolates were identified by a multiplex polymerase chain reaction (PCR) that discriminates among members of the Mycobacterium avium complex (MAC). Histopathologic evaluations were completed, and animals were tested for antibodies using a Johne’s enzyme-linked immunosorbent assay (ELISA) and agar gel immunodiffusion. In addition, 104 fecal samples from tule elk remaining in the herd were collected from the ground and submitted for radiometric mycobacterial culture. No gross lesions were detected in any of the hunter-killed animals. Mycobacterium avium subsp. paratuberculosis (MAP) was cultured once from ileocecal tissue of one adult elk and was determined to be a strain (A18) found commonly in infected cattle. One or more isolates of Mycobacterium avium subsp. avium (MAA) were isolated from tissues of five additional adult elk. Gastrointestinal tract and lymph node tissues from 17 of the 37 elk (46%) examined had histopathologic lesions commonly seen with mycobacterial infection; however, acid-fast bacteria were not observed. All MAC infections were detected from adult elk (P = 0.023). In adult elk, a statistically significant association was found between MAA infection and ELISA sample-to-positive ratio (S/P) > or = 0.25 (P=0.021); four of five MAA culture-positive elk tested positive by ELISA. Sensitivity and specificity of ELISA S/P > or = 0.25 for detection of MAA in adult elk were 50% and 93%, respectively. No significant associations were found between MAC infection and sex or histopathologic lesions. Bacteriologic culture confirmed infection with MAP and MAA in this asymptomatic tule elk herd. The Johne’s ELISA was useful in signaling mycobacterial infection on a population basis but could not discriminate between MAA and MAP antibodies. The multiplex PCR was useful in discriminating among the closely related species belonging to MAC.”

 

Epizootic of paratuberculosis in farmed elk http://www.johnes.org/handouts/files/Elk_outbreak.pdf

 

TESTING FOR MYCOBACTERIUM AVIUM SUBSP. PARATUBERCULOSIS INFECTION IN ASYMPTOMATIC FREE-RANGING TULE ELK FROM AN INFECTED HERD (Journal of Wildlife Diseases, : http://www.bioone.org/doi/pdf/10.7589/0090-3558-39.2.323

 

Immuno-Contraception Research for Managing Tule Elk Population – Phase I Scheduled to Begin on August 6, 1997 http://www.nps.gov/pore/learn/news/newsreleases_19970805_elkimmunocontraception97.htm

“. . . Funding for tule elk projects has come from a variety of sources. To date, monetary support and in-kind services for the tule elk project has been received from the Rocky Mountain Elk Foundation, Point Reyes National Seashore Association, Committee for the Preservation of Tule Elk, California Department of Fish and Game, The Humane Society of the United States (HSUS), University of California at Davis, the National Park Service Natural Resource Preservation Program and In Defense of Animals.” [Evidently Suzanne Roy, currently the Director of the American Wild Horse Preservation Campaign–who pushes PZP based management–was working for IDA at the time.]

 

Immuno-Contraception Research for Managing Tule Elk Population – Phase II Scheduled to Begin on June 15, 1998  http://www.nps.gov/pore/learn/news/newsreleases_19980615_elkimmunocontraception98.htm

“. . . During the second phase of the contraceptive research project, the first vaccine will be administered by direct syringe injection. To administer the injection, 30 elk will be captured from a helicopter and hobbled by ground crews. Scientists will gather data on the individual elk and place a radio collar on each of the elk. The collar will allow scientists to follow the individual elk to determine the effectiveness of the contraceptive. After several weeks, a booster shot will be remotely administered, from ranges of 30 to 150 feet, by means of self-injecting darts. The darts are brightly colored and easily retrieved. A single annual booster inoculation will be administered to continue contraceptive effects for successive breeding seasons.”

 

Use of porcine zona pellucida (PZP) vaccine as a contraceptive agent in free-ranging tule elk (Cervus elaphus nannodes). published 2002: http://www.ncbi.nlm.nih.gov/pubmed/12220156 

Abstract (note only a 5 year study. Why aren’t they studying the truly long-term effects?)
The potential for the application of porcine zona pellucida (PZP) immunocontraception in wildlife population management has been tested over a 15 year period and promises to provide a useful wildlife management tool. These studies have provided evidence indicating that the use of PZP immunocontraception in wildlife: (i) is effective at both the physiological and population level (Liu et al., 1989; Kirkpatrick et al., 1996; Turner et al., this supplement); (ii) is deliverable by remote means (Kirkpatrick et al., 1990; Shideler, 2000); (iii) is safe in pregnant animals (Kirkpatrick and Turner, this supplement); (iv) is reversible (Kirkpatrick et al., 1991; Kirkpatrick and Turner, this supplement); (v) results in no long-term debilitating health problems (Kirkpatrick et al., 1995; Turner and Kirkpatrick, this supplement); (vi) has no implications for passage through the food chain (Harlow and Lane, 1988); and (vii) is reasonably inexpensive (J. F. Kirkpatrick, personal communication). This report presents the results of a 5 year study in tule elk (Cervus elaphus nannodes), 3 years of which were on the application of PZP immunocontraception to an expanding elk population living in a wilderness area of Point Reyes National Seashore in Marin County, CA…”

 

Copyright Protect Mustangs.org 2016





Feds want to use 11 million tax dollars to experiment on American Wild Horses and Burros

Note from Protect Mustangs: If you don’t like this then: 1.) Go see your congressional representative this week and ask them to intervene to stop these horrible experiments on America’s wild horses who are being managed to extinction. 2.) Sign and share this petition and email it to everyone you know: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups Groups like The Cloud Foundation and the coalition led by The American Wild Horse Preservation Campaign seem to be misleading the public because they have chosen pushing PZP (controlled by The Humane Society of the United States) over championing wild horse freedom on public land. They slip appeals for PZP in the bottom of their online petitions hoping the public won’t notice what they are signing. That was the beginning of this slippery slope towards experimentation and extinction. Why? Follow the money, fear mongering and the seduction to campaign for drugging wild horses and burros with a risky pesticide made from slaughterhouse pig ovaries to block fertility. . . 3.) It’s time to join Protect Mustangs to protect our national treasures. Go to www.ProtectMustangs.org to sign up. 4.) You can donate to the Wild Horse Legal Fund also. The crowd funding link is here: https://www.gofundme.com/MustangLaw2016 or donate by www.PayPal.com to Contact@ProtectMustangs.org and please mark your donation is for the “Legal Fund”. Thank you for taking action today! Together we can turn this around.





The Bureau of Land Management (BLM) wants to use American tax dollars in several cruel experiments to develop methods of wild horse and burro population control–despite the fact that there is no overpopulation of wild horses or burros. The BLM anticipates the total cost of the experiments to be $11 million over 5 years.The research is being conducted by university scientists as well as scientists from the U.S. Geological Survey.

Research with Universities results in experimenting on wild horses and burros

In its 2013 report to the BLM, the National Academy of Sciences (NAS) found that no highly effective, easily delivered and affordable fertility-control methods were currently available for use on wild horses and burros. The most promising birth control, PZP, made from slaughterhouse pig ovaries, is limited in the duration of its effectiveness (1-2 years). At the same time, after multiple applications or if applied to young fillies it permanently sterilizes native wild horses.

The BLM released a solicitation for experimentation to develop new or improve existing population growth suppression methods for wild horses. (http://www.blm.gov/wo/st/en/info/newsroom/2015/july/nr_07_07_2015.html)  The following seven research projects were reviewed and recommended by an NAS panel of experts and are consistent with recommendations made to the BLM by its Wild Horse and Burro Advisory Board who is biased against wild horses and prefers livestock use public land for cheap grazing.

Wild Horse & Burro Advisory Board Meeting in 2013

 

© EquineClinic.comn shared for educational purposes

© EquineClinic.comn shared for educational purposes

1. Evaluation of minimally invasive methods of contraception in wild horse and burro mares: tubal ligation and hysteroscopically-guided oviduct papilla laser ablation. This was pushed by pro-slaughter advocates who want the horses free of fertility control drugs so they can go to slaughter eventually.

Recipient: Oregon State University
Summary: A one-year experiment that will aim to develop a minimally invasive surgical sterilization method for wild horse mares that requires no incisions.
Details: In an effort to develop minimally invasive, low-risk techniques for contraception and population control in female wild horses and burros, the experiment will evaluate two procedures, tubal ligation and hysteroscopically-guided laser ablation of the oviduct papilla in standing sedated females. For tubal ligation, the research team hypothesizes that a flexible endoscope inserted through a small incision in the vaginal vault will allow visualization of each oviduct in mares. Use of a diode laser or cautery instrument will allow effective fulguration followed by bloodless sectioning of the oviduct. This procedure should allow successful sterilization of up to 100% of female wild horses and burros gathered in any particular location as a single event. For the hysteroscopic procedure, the recipients expect to endoscopically visualize each oviduct papilla in standing, sedated, non-pregnant mares. A diode laser will be used to seal the opening between the oviduct and each uterine horn, thus preventing subsequent fertilization. The proposed procedures do not involve major surgery, are expected to have minimal complications while approaching 100% effectiveness, and when applied, are expected to result in a static to decreasing population level. Additionally, tubal ligation is a technique commonly performed in humans. The development of an acceptable sterilization technique will help control the population levels of wild horses and burros.


2. Tubo-ovarian ligation via colpotomy as a method for sterilization in mares

Recipient: University of Kentucky
Summary: A two-year experiment to develop different surgical approaches for tubal ligation in mares.
Details: The overall goal of this experiment is to develop methodology for the safe, economical and effective sterilizationof mares via colpotomy (vaginal incision) to achieve: 1) ovarian necrosis / atrophy via application of a ligature to the ovarian pedicle and 2) simultaneous sterilization via tubal ligation (i.e., tubo-ovarian ligation). The project will help determine the effectiveness of a custom-designed instrument for placement of a polyamide (nylon) cable tie around the ovarian pedicle and oviduct of mares via colpotomy for tubo-ovarian ligation. The procedure, conducted in the standing animal under sedation and local anesthesia, is expected to induce permanent sterilization of treated mares. The researchers will assess any post-operative complications of the procedure in mares and the effects on the health of mares to determine long-term effects on the reproductive tract, the overall health of mares and the fertility of mares undergoing the procedure, and the feasibility of these procedures in pregnant mares.

PM Sick Filly PVC March 25 2014
3. Functional assessment of ovariectomy (spaying) via colpotomy of wild mares as an acceptable method of contraception and wild horse population control

Recipient: Oregon State University
Summary: A six-month experiment that will determine whether an existing accepted surgical sterilization procedure commonly used for domestic mares can be safely conducted on wild horses.
Details: This experiment proposes to conduct a large-scope investigation of the safety and practicality of spaying mares as a tool for wild horse population control. Specifically, the researchers will help determine whether ovariectomy via vaginal colpotomy can be safely and effectively performed on wild mares that have been selected for non-breeding status. Non-breeding horses could then be returned to the range to live out their natural lives without individually contributing to population growth. The proposed research effort is based on recent pilot studies that have suggested the potential for surgery-related health complications from ovariectomy in adult female horses is low (near 1%). When evaluating options for field techniques, spaying (ovariectomizing) mares as a population control method is not recommended unless it can be performed in a safe, practical, and effective manner. The results of this study will provide standardized, baseline outcomes for this surgical procedure which can be directly compared to other less invasive procedures being conducted and evaluated by the same research team.

PM WC11 Lucky 11 Map

Map of Western United States showing 12 current field research/pilot projects.

4. Re-immunization of Free-Ranging Horses with GonaCon Immunological Vaccine: Effects on Reproduction, Safety, and Population Performance

Recipient: Colorado State University
Summary: A two-year experiment will focus on further study of Gonocon, an approved and labeled contraceptive vaccine for equids.

PM PZP Injection
Details: This experiment will focus on the effectiveness of GonaCon as an immunological vaccine, with five objectives: 1) to begin to determine the optimum and most effective re-vaccination schedule with GonaCon vaccine for suppressing reproductive rates in free-ranging horses, the duration of effectiveness, and the return to fertility following treatment; 2) to determine the safety and physiological side-effects (if any) in feral horses following re-vaccination with GonaCon including visual assessment of general health, body condition, injection site reactions, effects on current pregnancy, and neonatal health and survival; 3) to determine the effects of GonaCon vaccination on the behavioral side-effects (if any) in free-ranging horses including quantitative assessment of the effects on daily activity patterns and social interactions; 4) to develop and test a safe and effective dart configuration and injection system for remotely administering GonaCon vaccine to free-ranging horses by means of a syringe dart; and 5) to develop a Bayesian model to forecast the consequences of different GonaCon vaccine treatments on feral horse population dynamics at THRO. [Teddy Roosevelt National Park].


5. The Effect of Immunization against Oocyte Specific Growth Factors in Mares

Recipient: Colorado State University
Summary: A two-year experiment to develop a new, permanent contraceptive vaccine for wild horse mares.
Details: This experiment will focus on vaccination against two key proteins in wild horse and burro females, either alone or in combination, which may result in permanent sterility through premature oocyte depletion. The depletion of oocytes may occur by simply causing them all to become atretic prematurely and/or accelerating the process so that after a single season the mares and jennies have depleted their oocyte reserves. To test this hypothesis, the researchers will vaccinate mares against the proteins and track their sexual behavior, follicular growth, hormonal profile and ultimately total oocyte count over a two-year period. The long-term goal is to develop a vaccine that can cause permanent sterility after a single dose.

PM Burros Wild 2 © Carl Mrozek

Cruel way to drag foal by pulling bailing twine around their neck (Photo © Bo Rodriguez)

Cruel way to drag foal by pulling bailing twine around their neck (Photo © Bo Rodriguez)

6. Electrospun delivery to enhance the effectiveness of immunocontraception strategies in equids

Recipient: Ohio State University
Summary: A four-year experiment that will attempt to develop a new delivery vehicle for porcine zona pellucida (PZP) – a temporary contraceptive currently used in some wild horse herds – that would increase the duration of the vaccine’s effectiveness.
Details: To reduce population on public lands, horse immunocontraception has largely focused on the use of PZP in free-roaming wild populations. The vaccine appears to act by stimulating anti-PZP antibodies that bind to the surface of the ovulated egg, preventing sperm attachment. While performance has been satisfactory, recent results have been associated with contraceptive efficiencies that are considerably less than 100%. The basis for this is unknown but is believed to be in part caused by delivery methods that require substantial heating during polymer vehicle fabrication, expose PZP to enzymatic fluids prior to entry into the bloodstream and allow gradual – not burst – release. Gradual release can potentially desensitize the immune system to the presence of PZP, resulting in inferior production of anti-PZP antibodies. Thus, an ideal delivery method would allow release of PZP in “bursts” at pre-determined intervals to assure constant immune stimulation. This project will seek to develop an electrospun technology that can allow long-term, ‘burst’ delivery of porcine zona pellucida (PZP) vaccines to the intramuscular environment of horses and burros to result in prolonged suppression of reproduction. For large-scale application, free roaming horses could be gathered in the field and processed through stock chutes for aging, at which time the implants will be inserted by trocar. The experiment will also carry out parallel in vitro and in vivo experiments to examine the potential of electrospun vehicles as immunocontraceptive carriers. An electrospun “universal delivery vehicle” will be developed to provide sustained release of effective levels of porcine zona pellucida (PZP) for immunocontraception over periods of at least three years. By careful design, fabrication and testing of two different electrospun designs, the researchers will create a comprehensive evaluation of this novel method of delivery.

Pm PZP Darts
7. The use of membrane disrupting peptide / peptoid LHRH conjugates to control wild horse and burro populations

Recipient: Louisiana State University
Summary: A three-year experiment for the development of an injectable agent that would inactivate hormones and decrease female and male gonad viability.
Details: The experiment is a multidisciplinary effort aimed at developing novel drugs to control wild horse and burro populations. Several types of drugs consisting of conjugates of membrane disrupting peptides (such as Phor 21) with luteinizing hormone releasing hormone (LHRH) currently exist. These drugs (such as LHRH-Phor 21 conjugate) effectively target, bind to and destroy prostate, testicular, breast and ovarian cancer cells, as well as testicular and ovarian cells that control reproduction. LHRH targets the cell and delivers Phor 21 to the cancer cell or the reproductive cell in the testes or ovary and destroys it. Preliminary experiments suggest that administration of this drug by a slow-release delivery system will destroy the cells that control spermatogenesis in the male and follicle growth, oocyte development, ovulation and cyclicity in the female. Preliminaryresults also show that LHRH-Phor 21 targets and destroys gonadotropic cells in the pituitary gland. This indicates that cessation of reproductive activity is the result of both central control at the level of the pituitary gland and on receptor binding cells in both male and female gonads. The experiment will also assess the effect the drugs have on pregnant mares, both in early gestation and late gestation.

PM PZP Syringe Yearling Meme

Additional details about these experiments can be found in the following documents:

Detailed Summary of University-led Experiments for Fertility Control Tools for Wild Horses
Review of Proposals to the BLM on Wild Horse and Burro Sterilization or Contraception: A Letter Report
Research with the U.S. Geological Survey

Through its partnership with U.S. Geological Survey (USGS), the BLM is undertaking important research aimed at delivering better methods and tools for managing wild horse and burro herds on public lands. These projects build upon on-going cooperation between the BLM and USGS that is implementing new methods to estimate wild horse and burro population size.

There are nine USGS experiments that have been approved or are on-going:
Collaring & radio marking (1 year): The aim is to develop safe GPS collars for tracking animals to determine habitat selection, movement ecology, population estimation, behavior, etc. GPS tracking might also help locating animals for contraceptive treatments.
Fecal DNA (genetics/population survey) (1.5 years): The experiment involves the collection and analysis of fecal DNA as a noninvasive method to determine genetic diversity and estimate population size.
Carrying capacity modeling (1 year): This experiment’s aim is to develop a coarse model to evaluate changes in animal carrying capacity in response to changes in vegetation production. The resulting model may help BLM to adapt plans in response to climatic change.

PM PZP Syringe FB
Mare Contraception -SpayVac Pen Trial II (5 years): This experiment will help determine the efficacy of alternative SpayVac contraceptive vaccine formulations that are potentially longer acting than conventional PZP vaccines.
Evaluating Behavior of Spayed Free-Roaming Mares (4 years): The experiment will determine the effects of spaying on behavior, interactions, and movement of spayed mares among a breeding herd. The study will also determine the population level effect on herd growth.
Evaluating Behavior of Geldings among a Breeding Herd (4 years): This experiment will determine any effects of gelding on behavior, movement, interactions and changes in habitat selection.
Two Sentinel Horse Herd Management Area (HMA) Demography Studies (2 studies, each of 5 years): These experiments will provide demographic data sets for use in new population models and serve as control HMAs for gelding and spayed mare field studies.
Burro Sentinel HMA Demography Study (5 years): The experiment will involve collecting data on the survival, fertility, fecundity, recruitment, movements, range use, habitat selection and social behavior of wild burros. These data will be used in population modeling.
The BLM has requested or is reviewing proposals for the following projects with USGS:
Evaluate the Use of a Silastic O-Ring Intrauterine Device (IUD) in Mares (4 years): This experiment will determine any effects on mare health resulting from the long-term presence of the silastic O-ring IUD. This IUD has effectively prevented pregnancy in domestic mares during one breeding season.
Burro Population Survey Method Development (2.5 years): This experiment will test two new population survey methods for wild burros. The existing simultaneous double-observer method, when applied to burros, tends to lead to underestimates of true burro population size.
WinEquus II – Population Model with Cost/Benefit Outputs (1.5 years): This experiment will develop a model that compares population modeling outcomes and projects the costs, benefits and expected population growth resulting from management actions that involve PZP, removals, spaying, gelding and other population growth suppression tools.
Testing Efficacy of Contraceptives for Female Burros (3-4 years): Contraceptive vaccines have yet to be used on wild burros due to limited research and unknown effects. This study will examine the efficacy of various existing vaccines.

PM Hazard Foter Public domain Marked Sterilize

© Protect Mustangs, 2016


PZP Pushers are misleading the public as there is no evidence of overpopulation

PM PZP Auto-immune disease

PZP = Slow Extinction

While touted as a “vaccine,” porcine zona pellucida — PZP — is actually a perversion of a vaccine — an anti-vaccine — whose mode-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that attack the ovaries, inducing ovarian dystrophy, oophoritis (inflammation of the ovaries), and ovarian cysts. Worse yet, per radioimmunoassay, the PZP antibodies are transferred from mother to young via the placenta and milk. The antibodies cross-react with and bind to the zonae pellucidae of female offspring. Although hyped as a “non-hormonal” method of birth-control, PZP causes estrogen-levels to plummet as the ovaries degenerate. Despite the manufacturer’s claim that PZP is “reversible,” its effects wear off unpredictably. In herds under PZP “management,” the birthing season extends to nearly year-round, putting the life of the foals and mares at risk. Because PZP messes with the immune system, it “works” best on the healthiest fillies and mares — those with strong immunity — ironically, rendering them sterile even with just a few treatments. Filles injected with PZP before they have reached puberty are particularly vulnerable to immediate sterilization. Conversely, PZP has little-to-no effect on fillies and mares with a weak immune system — they continue to become pregnant. Thus, a herd being treated with PZP is undergoing selective breeding for low immunity, which puts the population at risk for disease — and ultimately, extinction. ~Marybeth Devlin, member of The Facebook Forum on PZP for Wild Horses and Burros.

PZP = Slow Extinction

No excess wild horses in the Pryors

PM PZP Betrayal

 

PZP is a risky pesticide. Will it ruin the treasured herd?

By Marybeth Devlin

The issue underpinning the use of PZP and the continuing cycle of removals of wild horses from the Pryor Mountain Wild Horse Range is: Whether there are excess wild horses. No, there aren’t. BLM creates the illusion of an overpopulation by administratively setting the maximum herd-size below minimum-viable population. The International Union for the Conservation of Nature determined that, if a herd were managed carefully per a stud-book, it could sustain itself genetically at a minimum of 500 individuals. Compare that number to BLM’s maximum: 120.

In fact, according to the latest genetic analysis, the Pryor Mountain herd is evidencing “a general trend for a decline in variations levels of the herd.” The recommendation was to “increase population size.” Yet, BLM stubbornly insists on its own failed approach of artificially limiting herd-size, declaring that it disagrees with the scientific “interpretation.”

But can the range accommodate more horses? Yes. By way of comparison, BLM allots 38 acres per cow or calf when setting the stocking-rate for livestock grazing. Thus, the 33,187 acres that compose the Pryor Mountain habitat can support 500 to 873 horses. When the WHR is restored to its original configuration, 44,920 acres, the high-bound can be increased to 1,182.

As for PZP, numerous independent studies have disproved the old theory that PZP merely blocks sperm attachment. In fact, PZP’s mechanism of action is to alter ovarian function, causing inflammation of the ovaries and cyst formation. PZP provokes an auto-immune response, wherein the pig-ovary-derived PZP antibodies attack the mares’ ovaries, resulting in dystrophy of those reproductive organs. Despite being hyped as a non-hormonal contraceptive, PZP causes “markedly depressed oestrogen secretion” in mares treated for just three consecutive years. The latter finding was disclosed by Dr. Kirkpatrick himself 23 years ago. PZP-use is associated with stillbirths, altered ovarian structure and cyclicity, interference with normal ovarian function, permanent ovarian damage, prolonged breeding season, and unusually-late birthing dates. A particularly troubling finding suggests that PZP can be selective against a certain genotype in a population.

PZP is touted as reversible; however, a recent study warned that just three years of treatment, or administration of the first PZP injection before puberty, may trigger infertility in some mares. Thus, only two PZP injections could be viewed as relatively safe, but it appears that even one injection is risky. The researchers warned that inducing sterility may have unintended consequences on population dynamics by, ironically, increasing longevity while eliminating the mares’ ability to contribute genetically.

Most pertinent to the Pryor Mountain herd is a longitudinal study on three herds treated with PZP — Little Book Cliffs, McCullough Peaks, and … Pryor Mountain. The researchers found that the birthing season lasted nearly year-round: 341 days. Out-of-season births put the life of the foals and the mares at risk. That same longitudinal study found that, following suspension of PZP injections, there was a delay in the mares’ recovery of fertility that lasted 411.3 days (1.13 years) per each year of PZP treatment. Thus, mares injected for four consecutive years (per BLM’s “prescription”) would be expected to take 1,645.2 days (4.51 years) to regain reproductive capacity. If disaster were to befall the Pryor Mountain horses, even if PZP were stopped immediately, it would take years for the herd to recover, if ever.

PZP has neither stopped nor slowed the roundups. Only lack of holding space has done that. Even the Pryor Mountain herd, injected for decades with PZP, is facing removals again this summer (per the usual three-year cycle) in addition to an intensified PZP “prescription” to be administered per an “equal opportunity program” eerily similar to Communist-China’s one-child policy. What’s ironic is that, for all the interference, BLM has achieved basically the same — or worse — record as has been attained the International Society for the Protection of Mustangs and Burros. ISPMB complies with the “hands-off” minimum-feasible management approach stipulated by the Wild and Free-Roaming Horses and Burros Act. ISPMB’s two wild herds grew 8.73 and 5.08 percent, respectively, without PZP and without removals. Pryor Mountain’s most recent report — reflecting management with PZP and with removals — grew by 8.26 percent.

BLM needs to get out of the way of Nature. Let the Pryor Mountain herd find its own appropriate population level.

(Note: Beware of petitions pushing PZP. Be sure to read everything you sign these days especially the fine print!)

Please donate to Protect Mustangs’ Legal Fund: https://www.gofundme.com/mustanglaw2016 to help the voiceless in court. Thank you!

Despite protests, BLM returns wild horses to range in Nevada

Fish Creek Mares Indian Lakes aka Broken Arrow 2015

April 12, 2015

RENO, Nev. (AP) — Despite the protests of a rural county and rancher, the U.S. Bureau of Land Management has returned some 160 wild horses to the range in central Nevada.

The agency returned the horses to the Fish Creek Herd Management Area near Eureka on Tuesday after being cleared to do so by the Interior Board of Land Appeals.

The BLM originally had planned to return some 100 mares treated with a fertility control vaccine and 80 studs to the HMA on Feb. 20. They were among 424 horses removed from the HMA during a roundup that ended earlier in February.

The bureau routinely thins what it calls overpopulated herds on public land across the West, sending horses that aren’t adopted by the public to pastures in the Midwest for the rest of their lives.

The agency also routinely releases mares treated with fertility control drugs back to the range after being rounded up. Varying numbers of studs also are released back to the range to help maintain the genetic viability of herds.

Eureka County commissioners and rancher Kevin Borba filed an appeal with the Interior Board of Land Appeals to block the return of any of the 424 horses to the range and to challenge the BLM’s assessment of how many horses the HMA can support.

But the board affirmed the BLM’s authority to return 162 of the horses to the range. Arguments in the case continue on the underlying claims.

Borba has said the BLM has drastically reduced his livestock allotments in the HMA while allowing well over twice as many horses in it as it can support. He and Eureka commissioners seek the removal of more horses.

Horse advocates praised the BLM’s return of the horses to the range, saying it’s in line with recommendations released in 2013 by a National Academy of Sciences panel calling for increased emphasis on fertility control to keep horse numbers down.

“Now is the time to move forward with innovative management that makes sense, keeping wild horses on their range and saving millions of tax dollars in the long term,” Neda DeMayo, president of Return to Freedom, said in a statement. “It is time for a new direction instead of wasting time and money obstructing positive solutions that will benefit the horses, wildlife, ranchers and the range.”

But not all horse advocacy groups support the use of fertility control drugs on mares.

“We want to see drug-free holistic management used for native wild horses,” said Anne Novak, executive director of Protect Mustangs. “(The fertility control vaccine) PZP sterilizes after multiple use and we’re concerned that will ruin survival of the fittest.”

Borba has said he thinks the fertility control vaccine is far less effective than the BLM and horse advocates claim, and horse numbers will further explode as a result. Ranchers view wild horses as competition for scare forage in the arid West.

Cross-posted for educational purposes only from the San Francisco Chronicle.

Experimenting on wild horses creates cheap R & D for drugmakers

PM PZP Syringe Yearling Meme

Did you know that America’s wild horses are used in extensive fertility control EXPERIMENTS for decades involving forced drugging of PZP, a pesticide made from slaughterhouse pig ovaries on federally protected and state wild horses, field spaying, and more. Which wild horse and humane groups are involved in cruel experimentation that results in killing wild horses to perform necropsies, ripping out ovaries in the field to look for PZP damage, carving up pregnant mares, etc.?

The horse’s reproductive system is very close to a human reproductive system. . .

With many developing countries hungry for long-lasting human contraception, is the pharmaceutical industry being subsidized by tax dollars to fund fertility control experiments on wild horses with the immunocontraceptive PZP and other experimental drugs? Are they cashing in on a cheap laboratory–on the range? As you will read below, the cost to research and develop a new drug is $2.6 billion dollars so follow the money and the decades of PZP and fertility control experiments points to the obvious.

Cost to Develop and Win Marketing Approval for a New Drug Is $2.6 Billion

BOSTON – Nov. 18, 2014 – Developing a new prescription medicine that gains marketing approval, a process often lasting longer than a decade, is estimated to cost $2,558 million, according to a new study by the Tufts Center for the Study of Drug Development.

The $2,558 million figure per approved compound is based on estimated:
Average out-of-pocket cost of $1,395 million
Time costs (expected returns that investors forego while a drug is in development) of $1,163 million
Estimated average cost of post-approval R&D—studies to test new indications, new formulations, new dosage strengths and regimens, and to monitor safety and long-term side effects in patients required by the U.S. Food and Drug Administration as a condition of approval—of $312 million boosts the full product lifecycle cost per approved drug to $2,870 million. All figures are expressed in 2013 dollars.
The new analysis, which updates similar Tufts CSDD analyses, was developed from information provided by 10 pharmaceutical companies on 106 randomly selected drugs that were first tested in human subjects anywhere in the world from 1995 to 2007.

“Drug development remains a costly undertaking despite ongoing efforts across the full spectrum of pharmaceutical and biotech companies to rein in growing R&D costs,” said Joseph A. DiMasi, director of economic analysis at Tufts CSDD and principal investigator for the study.

He added, “Because the R&D process is marked by substantial technical risks, with expenditures incurred for many development projects that fail to result in a marketed product, our estimate links the costs of unsuccessful projects to those that are successful in obtaining marketing approval from regulatory authorities.”

In a study published in 2003, Tufts CSDD estimated the cost per approved new drug to be $802 million (in 2000 dollars) for drugs first tested in human subjects from 1983 to 1994, based on average out-of-pocket costs of $403 million and capital costs of $401 million.

The $802 million, equal to $1,044 million in 2013 dollars, indicates that the cost to develop and win marketing approval for a new drug has increased by 145% between the two study periods, or at a compound annual growth rate of 8.5%.

According to DiMasi, rising drug development costs have been driven mainly by increases in out-of-pocket costs for individual drugs and higher failure rates for drugs tested in human subjects.

Factors that likely have boosted out-of-pocket clinical costs include increased clinical trial complexity, larger clinical trial sizes, higher cost of inputs from the medical sector used for development, greater focus on targeting chronic and degenerative diseases, changes in protocol design to include efforts to gather health technology assessment information, and testing on comparator drugs to accommodate payer demands for comparative effectiveness data.

Lengthening development and approval times were not responsible for driving up development costs, according to DiMasi.

“In fact,” DiMasi said, “changes in the overall time profile for development and regulatory approval phases had a modest moderating effect on the increase in R&D costs. As a result, the time cost share of total cost declined from approximately 50% in previous studies to 45% for this study.”

The study was authored by DiMasi, Henry G. Grabowski of the Duke University Department of Economics, and Ronald W. Hansen at the Simon Business School at the University of Rochester.

ABOUT THE TUFTS CENTER FOR THE STUDY OF DRUG DEVELOPMENT

The Tufts Center for the Study of Drug Development (http://csdd.tufts.edu) at Tufts University provides strategic information to help drug developers, regulators, and policy makers improve the quality and efficiency of pharmaceutical development, review, and utilization. Tufts CSDD, based in Boston, conducts a wide range of in-depth analyses on pharmaceutical issues and hosts symposia, workshops, and public forums, and publishes Tufts CSDD Impact Reports, a bi-monthly newsletter providing analysis and insight into critical drug development issues.

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