Comments submitted to BLM to Protect the Pine Nut Wild Horses (Carson City, Nevada)

PM MArilyn © Eve Arnold Magnum Photos


John Axtell  (

Wild Horse and Burro Specialist

Carson City District Office

5665 Morgan Mill Road

Carson City, NV 89701

The Environmental Assessment for the Pine Nut Mountain wild horse management plan near Carson City, Nevada must take into account this herd management area (HMA) is extremely accessible to the public and international tourists with easy access from the San Francisco Bay Area as well as from the Reno International Airport and therefore the Pine Nut HMA must be preserved with the maximum level of wild horses as an educational public sanctuary on public land. The maximum level of wild horses should be determined through rigorous scientific study during a 10 year moratorium on roundups, fertility control and human intervention. Good science must prevail to ensure America’s Pine Nut wild horses–made famous in John Huston’s film THE MISFITS starring Clark Gable and Marilyn Monroe–will not be wiped out due to human intervention resulting in a lack of adaptability to survive climate change, etc.

Many photographers, poets, artists and filmmakers such as myself and our supporters rely on the Pine Nut HMA for accessibility to real wild horses on public land. We seek out wild horses to observe their natural behavior, beauty and inspiration. We don’t want to see sterile groups of wild horses nor those given pesticides ruining their bodies, natural behaviors who are part of an on the range breeding program with a “one foal” policy. We want the real deal, period

We represent thousands of supporters and ask that you do the following:

  • Halt helicopter and other removals to manage the population on the range utilizing reserve design, holistic land management with predation. Predators must not be killed but must fill their niche in the ecological balance of the Pine Nut HMA.
  • Move back into the HMA any alleged “nuisance” and other wild horses that are residing outside the HMA in areas that are not managed for wild horse habitat or that contribute to public safety concerns such as property damage and vehicle collisions. Conduct a study with a wild horse group to find and implement solutions to keep them inside the HMA.
  • Ensure that wild horses are not fenced off from water at the river.
  • Wild horses are not pests and therefore no pesticides should ever be used on native wild horses. PZP is dangerous:

“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 thatPZP’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

  • PZP, GonaCon, and Sterilization would ruin natural behavior that we specifically go to the Pine Nut HMA to study and enjoy. Therefore this junk must not be forced upon wild horses. No experiments. No collars. Respect their right to true freedom.
  • We request you re-evaluate AMLs to accommodate the present wild horse population without removals, making forage adjustments, if necessary, pursuant to CFR 43 C.F.R. 4710.5(a).
  • Conduct a complete headcount and public database with individual photos of every wild horse on the Pine Nut HMA with their basic information. Follow the wild horses and note all the deaths. Do you know even how many have died since birth in the past 2 years? How many have died of natural causes including predation and how many have been shot or poisoned by humans?
  • Increase penalties for killing wild horses.
  • Include a complete identification and analysis of the various causes of land degradation — AND their corresponding degree of impact — including but not limited to motorized uses (OHV, etc.), extractive uses (mining, etc.), various recreational uses, and other uses for each area, inside and outside of HMAs, analyzed in the EA.
  • The Environmental Assessment must include a complete disclosure and analysis showing the degree of disturbance that each of the following negative impacts has on the bi-state sage grouse: renewable energy projects, extractive uses, motorized vehicle uses, recreational activities, power lines, fencing and other man-made structures have on the bi-state sage grouse behaviors and habitat–mapped and analyze for the degree and range (circumference) of impact each has on bi-state sage grouse behaviors and habitat within the HMA.
  • Analyze the HMA exclusively to be used for wild horses and other wildlife to prevent the degradation of public lands within and outside the herd management area. Expand the HMA if needed to the original acreage designated to wild horses. What would the impacts be and how would the thriving natural ecological balance and Sage Grouse flourish?

We will not allow wild horses to be scapegoated for damage caused by other species or land users.

Thank you for allowing us to participate in the public process.


Anne Novak

Executive Director

Protect Mustangs

Tel./Text: 415.531.8454

Read about native wild horses: 



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

PM Pine Nut Wild Horses ©Craig Downer

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

Marybeth Devlin comments on the Sulphur Wild Horse roundup plan


January 19, 2016
Cedar City Field Office
176 E DL Sargent Drive
Cedar City, UT 84721
Project Name: Sulphur Wild Horse Gather Plan

Document: Environmental Assessment — Preliminary

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

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

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

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

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

News Release — 2015 EA

News Release — 2015 Public-Safety Removals

Sulphur Gather Environmental Assessment — Preliminary
Overpopulation, Forage Limitations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Let’s do the math.

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

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

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

Discrepancies were evident per a review of the …

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

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

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

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

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

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

125 %
131 %
153 %
157 %
249 %

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

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

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

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

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

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

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

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

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

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

Here are excerpts from a news report:

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

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

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

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

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

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

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

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

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

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

The EA states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Marybeth Devlin

#TAKEACTION Comments are needed to save wild horses and due by Monday June 15th

PM BLM Nevada Roundup

The BLM’s HORRIBLE project goal is to maintain a population of only native 25-30 wild horses within the Water Canyon portion of the Antelope HMA. The current estimated population is only 66 wild horses.

Under the proposal, the BLM would capture the horses through bait and water trapping or by helicopter roundup, and treat and release only 25-30 wild horses back into the project area. Mares selected for release would be treated with PZP-22, a time-release pesticide for birth control (made from slaughterhouse pig ovaries) with an expected efficacy of about two years, despite the fact that it sterilizes after multiple use. The mares would be re-treated every 20-24 months and monitored to determine treatment effectiveness.

Despite the current low population, BLM trumps up allegations of “excess wild horses” to justify a waste of tax dollars and permanently remove traumatized herd members by offering them to the public through a trap site adoption.

You can read the proposal documents here:

The Bureau of Land Management (BLM) Ely District, Schell Field Office is soliciting public comment on the Water Canyon Wild Horse Growth Suppression Pilot Program Preliminary Environmental Assessment (EA). The Preliminary EA (DOI-BLM-NV-L020-2015-0014) was made available for review and comment on Friday, May 15, 2015. The 30-day comment period concludes Monday, June 15, 2015.

Comments will be accepted for 30 days until June 15, 2015. Interested individuals should address all written comments to the BLM Ely District Office, HC 33 Box 33500, Ely, NV 89301, Attn: Paul E. Podborny, Schell Field Manager, or fax them to Podborny at (775) 289-1910. Comments may also be submitted electronically at or comment throught the NEPA Register. Email comments sent to any other email address will not be considered.

Before including your address, phone number, e-mail address, or other personal identifying information in your comment, you should be aware that your entire comment – including your personal identifying information – may be made publicly available at any time.

The EA analyzes a proposal to conduct a pilot project to gather, and treat and release, as well as remove excess wild horses from inside the Water Canyon area, located within the Antelope Herd Management Area (HMA), about 60 miles north of Ely, Nevada.

Public comment extension granted for BLM’s Carson 15 to 20 year management plan

By U.S. Government [Public domain], via Wikimedia Commons

By U.S. Government [Public domain], via Wikimedia Commons

BLM Extends the Public Comment Period for the Carson City District Draft Resource Management Plan/Environmental Impact Statement for Another 30 Days

Carson City, Nev. – Nevada Bureau of Land Management (BLM) Acting State Director John Ruhs announced today that he will extend the current public comment period for the Carson City District Draft Resource Management Plan (RMP) and Environmental Impact Statement (EIS) an additional 30 days. The extended timeframe means that the comment period on the Draft RMP/EIS, which is currently set to close April 27, 2015, will now close on May 27, 2015.

This is the second 30-day extension making the full comment period an unprecedented 180 days.

“We felt that another extension was warranted to allow the public plenty of time to analyze the important resource issues considered in this plan,” said Ruhs.

Once finalized, the Carson City District RMP will provide management direction for the 4.8 million acres of public land in western Nevada and eastern California managed by the Carson City District. The five alternatives in the Draft RMP/EIS offer a range of approaches to achieve and maintain desired resource conditions in the area over the coming 15 to 20 years. The Draft RMP/EIS addresses some of the following issues: Areas of Critical Environmental Concern (ACEC), lands and realty, utility corridors, wind energy, travel management, recreation, lands with wilderness characteristics, minerals, wild and scenic rivers, and visual resource management.

Written comments related to the Carson City District Draft RMP/Draft EIS may be submitted by any of the following methods:
• Website:
• E-mail:
• Fax: (775) 885-6147
• Mail: BLM Carson City District, Attn: CCD RMP, 5665 Morgan Mill Rd., Carson City, NV 89701.

Individuals or groups that have already submitted comments during the first 150 days may submit supplementary comments through then end of the open period.

Copies of the Carson City District Draft RMP/EIS are available in the Carson City District Office at the above address or on the following website:


Dry Creek Partnership Successes Continue with Treatment of Noxious Weeds


A partnership that began in 2012 among the Bureau of Land Management Cody Field Office, Marathon Oil Corporation and Friends of a Legacy (FOAL) continues to achieve successes toward its goal of improving water sources for the benefit of wild horses, wildlife and livestock inside the McCullough Peaks Wild Horse Herd Management Area (HMA) east of Cody, Wyoming.

Saltcedar is removed along Dry Creek.
Russian olive and
saltcedar were recently treated on 900 acres of public land along Dry
Creek east of Cody.

Most recently, the group partnered with Park County and Big Horn County weed and pest districts to treat Russian olive and saltcedar on 900 acres of public land along Dry Creek. The invasive plants were sprayed with herbicide, beginning at the bridge where U.S. Highway 14/16/20 crosses Dry Creek approximately 21 miles east of Cody, and continuing downstream to the east.Russian olive and saltcedar, both designated as noxious weeds by the Wyoming Weed and Pest Council, create numerous negative impacts on river function, native plant and wildlife species, wildlife habitat, and water quality and quantity. By removing these water-loving plants, wild horses, wildlife and livestock will benefit from more water in the creek and the space created for native vegetation to flourish.

“We are so appreciative of FOAL and Marathon Oil for the progress we continue to make along the Dry Creek drainage,” said BLM Assistant Field Manager Delissa Minnick. “And the recent Russian olive and saltcedar treatments would not have been possible without the additional contributions of herbicides and work crews from Park County and Big Horn County weed and pest districts.”

Treatments are expected to continue this spring, and re-treatments to spray re-growths will be needed in future years. In addition, tall, mature tamarisk in the area will be mulched using a skidsteer with a masticator attachment.

“FOAL is dedicated to and honored to be a partner in reducing the impact of invasive species in the HMA for the benefit of all of the flora and fauna that depend on the Dry Creek drainage,” said Warren Murphy, president of FOAL.

Projects completed by the Dry Creek Water Augmentation partners over the past few years include the identification of viable water supply alternatives; installation and testing of two shallow water supply wells along Dry Creek; purchase and installation of solar powered pumps; construction of a 2.5-mile long water delivery system; and the improvement of several reservoirs in the HMA, which are critical for capturing spring snow melt.

Future plans include the construction of a second pipeline and installation of various points of use for the delivered water including guzzlers, reservoirs, watering basins and wetlands along the pipelines for water storage and distribution to wildlife.

Marathon Oil has operated in this area since 1917 and has partnered with the BLM on numerous resource improvement projects. To ensure the success of the Dry Creek Water Augmentation Project, Marathon Oil has secured grants and provided funding to the National Wild Turkey Federation to implement fieldwork and construction projects.

“We’re grateful for the partnerships we have with these groups,” said Environmental Professional Mike Williams with Marathon Oil’s Wyoming Asset Team. “Such successful water augmentation in the Dry Creek drainage wouldn’t have been possible without the significant collaborative input and commitment that each organization brings to the project.”

FOAL is a non-profit wild horse advocacy organization that has been partnering with the BLM under a separate MOU since 2006 to coordinate and cooperate on opportunities for public education, to enhance habitat for all creatures living within the McCullough Peaks HMA and to assist the BLM in managing the McCullough Peaks wild horses.

FOAL has received grants from the Wyoming Wildlife and Natural Resource Trust and the Park County Winter Recreation Coalition Fund (held by the Wyoming Community Foundation) that have contributed to the success of the Dry Creekheld by the Wyoming Community Foundation Water Augmentation Project.

“On-going collaboration focused on improving the habitat and the availability of water resources is very important,” said FOAL Executive Director Marion Morrison. “We’re seeing great results due to the significant contributions of expertise, resources, and passion from every member of this partnership.”

It is hoped the partnership will continue to grow with the addition of new participants and public involvement. The partners hope to enlist volunteers in the future to plant native species along Dry Creek to further improve habitat. For more information, or to participate in Dry Creek habitat enhancement work, please contact BLM Wild Horse Specialist Tricia Hatle at 307-578-5900.

The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2014, the BLM generated $5.2 billion in receipts from public lands.
–BLM–Cody Field Office   1002 Blackburn Street      Cody, WY 82414

Pinenuts wild horses featured in French TV documentary ~ STOP the ROUNDUP


La chasse au mustangs (2010)


“I’m grateful to have worked on this film together with the French director and cinematographer and thankful we were able to get such revealing footage. Thank you to Barbara Clarke at DreamCatcher Sanctuary and Laura Leigh who stood in for Craig Downer who was unreachable and out in the field the day we shot this. All the scenes in the wild were shot in the Pinenut Herd Management Area (HMA) near Carson City and close to Reno/Tahoe. These horrible roundups must be stopped. Contact your senators and representative and request they stop this tragedy paid for with tax dollars.” –Anne Novak, Executive Director of Protect Mustangs  (Video ©2010 TF1)

Now the BLM and the PZP Advocates want to roundup the Pine Nut Herd and give them the EPA restricted-use pesticide known as PZP-22 which sterilizes after multiple us. Protect Mustangs is against PZP and roundups. America’s wild horses deserve to be forever wild and free.

BLM Press Release Date: 01/20/15
Contacts: 775-885-6107
News Release No. 2015-15

BLM to Host Tour of Pine Nut Herd Management Area Gather

Carson City, Nev. – The Carson City District, Sierra Front Field Office is holding a public pre-gather tour on Friday, January 23, 2015. The public will meet at the Dayton Valley Dog Park (located at Old Como and Dayton Valley Road) in Dayton, Nevada, at 10:00 a.m. The tour is expected to last approximately three hours. Because of road conditions a four wheel-drive high clearance vehicle is required. Visitors must RSVP by calling the Gather Information Hotline at 775-861-6700, option 2 and leave a message, or call Lisa Ross, Public Affairs Specialist, at 775-885-6107, email

“This pre-gather tour is being offered to provide an opportunity for the interested public to obtain information about the Pine Nut Gather, by interacting with BLM staff as they provide an overview of gather operations,” said Sierra Front Field Manager Leon Thomas.

The BLM will gather approximately 332 wild horses and remove approximately 200 excess wild horses within and outside the Pine Nut Herd Management Area (HMA). As many as 132 wild horses will be released back to the range following the gather. The gather area is located south of Dayton and east of Carson City and Gardnerville, Nevada within Lyon, Douglas, and Carson City Counties. The gather is scheduled to begin late January 2015.

A population inventory completed in August 2014 documented 332 wild horses. The Appropriate Management Level (AML) for the HMA is 119-179 wild horses. Based on the inventory, and monitoring data showing impacts from an over-population of the HMA, BLM has determined that removal of the excess wild horses is necessary to achieve a thriving natural ecological balance.
Protect Mustangs is against the BLM’s false comment here: Excessive grazing from wild horses has not only degraded the sage-grouse habitat, but has also reduced the availability of native forage grasses within the HMA, thereby decreasing the number of wild horses that can be supported by current range conditions. Wild horses are not the source of habitat degradation but off road vehicles are. It’s time for the BLM to tell the truth.
Of the approximately 132 wild horses released back to the range, an estimated 66 mares will receive a 22-month Porcine Zona Pellucida (PZP-22) immunocontraceptive vaccine treatment prior to release. This vaccine will extend the time between gathers, and reduce the number of excess wild horses that would need to be removed in the future. The sex ratio of the released animals will be dependent on the sex ratio of the gathered wild horses. [PZP is an EPA approved restricted-use pesticide as seen here:  For more information, facts and public discussion about PZP visit the PZP Forum on Facebook here:]
For more information contact Lisa Ross at 775-885-6107.

The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2013, the BLM generated $4.7 billion in receipts from public lands.
Carson City District 5665 Morgan Mill Road Carson City, NV 89703


Take Action: Save 6 wild horse herds BLM wants to wipe out!

PM Craig Downer by Rona Aguilar

Wild horse expert sounds alarm

As the new Director of Ecology and Conservation at Protect Mustangs and a concerned Carson Valley resident, I attended the Bureau of Land Management’s (BLM) “Carson City District Draft Resource Management Plan (RMP) / Environmental Impact Statement (EIS)” meeting at the Spark’s Nugget hotel casino on Tuesday, January 13, from 5 to 7 pm.

I spoke with several BLM officials including John Axtell, the Wild Horse and Burro Specialist for this district, and Leon Thomas, Field Manager for the Sierra Front Field Office. I voiced my concerns that stakeholders who previously gave much input for increased numbers and resources in regard to wild horses were being ignored in the Draft Resource Management Plan.

I heard the overview explanation of the document by Colleen Sievers, RMP Project Lead, and instructions for reviewing it. I had given earlier input during the 2012 Scoping meetings in Carson City, along with many other pro-wild horse stakeholders.

It’s important to note there are two new wilderness designations that have just been passed by Congress for this area: Pine Forest and Wovoka Wilderness Areas.

Wild horses need you more than ever to stand up for them and here’s why:

There are five alternatives presented in the RMP document, one of which is No Action, or status quo, that will include improvements for Sage Grouse survival, but little else. Another is for maximizing resource exploitation that would be disaster for many natural values upon which the long term survival of life depends. Another (Alternative C) is for maximizing conservation of nature, and another is for bringing a so-called balance of these (Alternative E). This is the preferred alternative although it does not allocate enough land, water and forage for native wild horses who are needed to reduce wildfires, restore balance to the ecosystem, and reverse desertification on public land.

The Conservation Alternative would greatly reduce livestock grazing and expand wilderness designations but pro-wild horse stakeholders and native wild horses themselves appear to have been ignored. Wild horses should be regarded as native restorers of these natural ecosystems, but in the BLM’s Draft RMP there are serious errors which imply that they are non-native invasive pests with no value to the ecosystem. This, of course, is false.

In my preliminary view, and pending a more thorough analysis of this document, it’s  outrageous to see that federal officials appear to have completely neglected the wishes of stakeholders favoring wild horses. They unfairly sided with wild horse enemies to zero out herd management areas (HMAs). The BLM’s preferred alternative are plans to zero out six wild horse “herd management areas,” (HMA’s) rendering them “herd areas.” This is a twisting of language by which the original designation of a “herd area” as an area for wild populations of wild horses/burros in perpetuity, now according to BLM means an area where the wild horses/burros have been eliminated, or “zeroed out.”

John Axtell told me that there was not enough forage or water in these areas and that their numbers were too low. However, he conveniently failed to mention how cattle and sheep have been given the great majority of forage allocations in these same areas, or how the BLM has intentionally failed to exercise the wild horses and burros’ Implied Federal Water Rights that come with any major federal act of Congress in order to secure their basic survival requirements.

The areas that the BLM appears to be planning to zero out in the preferred alternative includes some HMA’s north of Reno such as Granite Peak and Flannigan that have been assigned truly ridiculous, low appropriate management levels (AML)—plus or minus 20 or so horses.

The minimum number for a genetically viable herd is 2,500 wild horses, according to the IUCN Species Survival Commission Equid Specialist Group and these levels are even a far cry from the suspect 150 individuals that BLM documents often cite as being genetically viable for a population.

BLM also wants to eliminate the historic Wassuk wild horse herd in the Wassuk HMA just north of Mt. Grant–where Axtell told me about 125 wild horses still survive.

Axtell claimed there was not enough forage for the horses here. I can’t believe this. I have repeatedly visited this wonderful spirited herd of Spanish-type mustangs and over many decades.

Nevadan biologist and teacher Steven Pelligrini studied the Wassuk herd for his Master’s Degree in biology at the University of Nevada-Reno. His thesis was presented to the public and to the Congress in support of the passage of the Wild Free-Roaming Horses and Burros Act of 1971, when he went to testify together with Wild Horse Annie and his professor Dr. John Pontrelli of UNR.

The Carson City BLM’s RMP is targeting our wild horses for removal yet it is mandated to protect them. There exists large-scale public support for them both among the local public, nationally and internationally.

We must stand up and fight for the Wassuk wild horses and for the other venerable wild horse herds that are being dishonestly used as scapegoats for abuses attributable to uncaring people.

I noticed that at the meeting leaders of the Toiyabe Sierra Club and long time wild horse enemies, were present, and engaged with the BLM wild horse specialists and other officials. It appears they have been working to undermine the wild horse presence on public lands for many years, and I am very disturbed about this.

In the “Toiyabe Trails” publication that goes out to many thousands as a free quarterly publication, their President, Tina Nappe seems to be given carte blanche to badmouth wild horses, while those who used to be afforded the opportunity to reply, such as myself, no longer are given this basic right, even in the form of a short letter to the editor.

In spite of the horrible news in the RMP, I was urged to make a strong statement concerning my reasons against the proposed “zeroings out”. These would include how the wild horses are not getting fair grazing allocations compared to livestock in their legal areas, failure to develop or fend for watering sources for the animals and illegal fencing prohibiting their “free-roaming” lifestyle, an inherent part of the Wild Free-Roaming Horses and Burros Act.

Protect Mustangs is calling all wild horse supporters to speak out strongly in an informed and intelligent manner, for the wild horses and burros of the Carson City BLM District. This RMP/EIS revision will govern land use policy for the next 15-20 years and we must not allow it to be a death sentence for the wild horses and burros, which it largely appears to be.

This is the public’s chance to improve the treatment of the wild horses and burros, and we cannot allow another act of subterfuge.

The proposal can be viewed online at and more information can be found here:

Here are some talking points:

1.) Both horse and burro evolution originate and have immense multi-million year duration in North America.

2.) As post-gastric digesters, different from ruminant digesters, the equids truly restore balance to the North American ecosystem. There is a lopsided preponderance of ruminants today, encouraged by established rancher, hunter, and other linked interests.

3.) Natural predators must not continue to be persecuted and eliminated, such as puma and wolf, natural predators of the wild equids.

4.) PZP and other tamperings with basic biology and social structure of wild horses and burros is contrary to the “minimum feasible” management tenet of the WFHBA as stated in Section 3 a. See my 19 points of law on pages xi to xiii of The Wild Horse Conspiracy. See sections on PZP  in the Index as well

5.) Also look up “Pine Nut wild horse herd area” in the Index of my book for more specific information

To be most effective, please make your own personal analysis of the pertinent sections of this document about which you are knowledgeable and/or concerned, especially the wild horses and burros. You can submit your comments electronically by email to:  or by US mail to: BLM Carson City District, Attn: CCD RMP, 5665 Morgan Mill Road, Carson City, NV 89701.

Send a copy of your comments to your two senators and your representative asking them to intervene.

The deadline for these comments is March 27th, 2015. Questions can be addressed to Colleen Sievers, Carson City District RMP Project Lead. Tel. 775-885-6000

Examples of what BLM consider to be substantive and nonsubstantive comments can be found at 

Thank you for standing up for the wild ones!

Craig C. Downer
Wildlife Ecologist
Director of Ecology and Conservation at Protect Mustangs
Author of The Wild Horse Conspiracy
and The Horse and Burro as Positively Contributing Returned Natives in North America (American Journal of Life Science)

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


BLM Ely, Nevada, district to roundup native wild horses

Visit Nevada?

The Bureau of Land Management (BLM) Ely District is scheduled in early November to begin rounding up and removing approximately 120 alleged excess wild horses from in and around the Triple B and Silver King herd management areas (HMAs) in eastern Nevada.

Details will be posted on the district website as they become available. The roundups are allegedly necessary to prevent further damage to private property and provide for public and animal safety.

The district will remove about 70 alleged excess wild horses from the Triple B HMA, located about 30 miles northwest of Ely, that are allegedly damaging private property, and allegedly harassing and breeding domestic stock resulting in landowner complaints. Appropriate Management Level (AML) for the Triple B HMA is 215-250 wild horses. The current population is 1,311 wild horses.

The district will remove up to 50 excess wild horses from in and around the Silver King HMA. The horses to be gathered are located about 120 miles south of Ely. They are an alleged safety concern on U.S. Highway 93 and are damaging private property, resulting in property owner complaints. The AML for the Silver King HMA is 60-128 wild horses. The current population is 452 wild horses.

The BLM claims attempts to keep wild horses away from private property and the highway, including trapping and relocating animals to other portions of the HMAs, have been unsuccessful.

The BLM will utilize the services of roundup contractor Cattoor Livestock Roundup, Inc., of Nephi, Utah, which uses a helicopter to locate and stampede wild horses toward a set of corrals to be trapped and who has already been paid millions of tax dollars, year after year. The pilot is assisted by a ground crew and a domesticated horse, known as a Judas horse who is trained to lead wild horses into the corral.

Wild horses removed from the range will be transported to the National Wild Horse and Burro Center at Palomino Valley, in Reno, Nevada, where they will be offered for adoption to qualified individuals. Wild horses for which BLM is unable to adopt out will be placed in long-term pastures where they will be allegedly humanely cared for and retain their “wild” status and protection under the 1971 Wild Free-Roaming Horses and Burros Act.

A Wild Horse Gather Information Line has been established at 775/861-6700. A recorded message will provide information on daily gather activities and schedules. The BLM will also post daily gather information on its website.

Public lands within the HMAs will be open to the public during gather operations, subject to necessary safety restrictions, and the BLM will make every effort to allow for public viewing opportunities. The BLM has established protocols for visitors to ensure the safety of the wild horses, the public, and BLM and contract staff. The protocols are available at under “Observation Opportunities.”

Roundups in and outside the Triple B HMA were analyzed in the Triple B, Maverick-Medicine, and Antelope Valley HMA Gather Plan and Environmental Assessment (EA), signed in May 2011 and available at Gather activities in and around the Silver King HMA were analyzed in the Ely District Public Safety and Nuisance Gather EA signed in August 2014 and available at

For more information, contact Chris Hanefeld, BLM Ely District public affairs specialist, at 775/289-1842 or

Sign up for Intro to Environmental Law (free)

(Photo © Grandma Gregg)

(Photo © Grandma Gregg)

What:  Introduction to Environmental Law and Policy Course
When:  Starts Monday, January 13, 2014  (This is not a cutoff date.)
Where:  Anywhere, anytime, on-line.
Length:  Six weeks
Professor:  Don Hornstein, J.D., University of North Carolina at Chapel Hill
Cost:  FREE — including all materials that you’ll need
Register:  FREE — It’s a very simple procedure too.
Earn:  A Statement of Accomplishment, but no college credit.
Prerequisites:  None.  Designed for the under-grad.
Format:  Videos (15 to 20 minutes each) and short readings per topic.
Repeat:  Rewatch the videos and reread the readings as often as you like.
Quizzes:  Typically 8 questions, multiple choice.  Take when you’re ready.
Retake:  To improve your score on any test, you can retake it … twice!
Participation:  There are opportunities to take part in a forum if you’d like.
Professor Hornstein teaches what is known as “positive law” (what the law actually is) as opposed to “normative law” (what the law ought to be).  He is an outstanding teacher.  
The course imparts insight into how lawyers and judges think and reason with regard to environmental law.  It does not specifically address wild horse and burro issues.  But the information is still relevant for our purposes.  For instance, one of the first topics covered is “nuisance law.”  On the surface, it might not seem applicable to our advocacy.  But wait — don’t the wild horses and burros get blamed for being nuisances when they step outside the invisible boundaries of their herd management area?  So, understanding “nuisance” as a legal concept — determining what is and what is not deemed a nuisance according to the courts — can make us better-able to defend our clients.  Advocates who have reviewed and responded to BLM environmental assessments will already be familiar with many of the terms, concepts, and laws that are discussed.  
Dr. Hornstein has many teaching assistants that help him.  They are eager to answer questions.  Also, you will find that students from all over the world, not just America, take the course.  Last term, there were reportedly about 20,000!  Yes, twenty thousand!  

 A special thanks to Marybeth Devlin for bringing this class to our attention.


@SecretaryJewell Freeze the roundups & return stockpiled wild horses, burros to the range! #Sequester

Sequester means stop fiscal fiasco. Freeze the roundups. Return all wild horses and burros to the range.

Sequester means stop fiscal fiasco. Freeze the roundups. Return all wild horses and burros to the range.

Put a freeze on all roundups due to the Sequester. Return captive wild horses & burros to their public sanctuaries known as Herd Management Areas (HMAs). Tell the Wild Horse & Burro Advisory Board NO slaughter for native wild horses! Contact your elected officials and Sally Jewell, the new Secretary of Interior. Ask them to intervene.

Keep them safe!

Join the international rally on April 27th to stop horse slaughter, stop the roundups and stand up for the voiceless wild horses and burros!

Read about our call to put a freeze on roundups due to the Sequester. Horseback Magazine reports Below is an excerpt:

WASHINGTON (April 8, 2013)–Last week Protect Mustangs, the California based conservation group, officially called for the Bureau of Land Management (BLM) to put a freeze on roundups and return all wild horses and burros, in government funded holding, to herd management areas in the West. They cited the current climate of federal economic instability as putting captive wild horses and burros at risk. As of April 7th, Protect Mustangs has not received a response from BLM officials.

“It’s fiscal folly to roundup more wild horses and burros than they can adopt out,” explains Anne Novak, executive director for Protect Mustangs. “The roundups need to stop now. We are calling for the more than 50,000 stockpiled native wild horses and historic burros to be returned immediately to public land. We are concerned the government won’t be able to pay for their feed and care during the federal fiscal crisis. We need to be proactive to ensure their safety. If a government shutdown occurs, their only chance of survival is in the wild.”