BIG NEWS: Baby SPITFIRE Born out of the WY14–saved from the clutches of slaughter!

PM Spitfire 2

Welcome Spitfire!

Baby Spitfire was born out of a miracle rescue. Her papa was brutally slaughtered shortly after 41 wild horses in Wyoming were rounded up in the March 2014 BLM stealth roundup and were quickly sold off by the WY Livestock Board at auction to the most prominent slaughterhouse in North America–who slaughters wild and domestic horses for human consumption abroad.

Mark Boone Junior (Bobby Elvis on Sons of Anarchy) and Anne Novak found the only mustangs left alive at the slaughterhouse yard–14 young and terrified wild horses. Thanks to everyone’s prayers and good vibes they resuced the WY14 back from the slaughterhouse before they were live-shipped and turned into sashimi over in Asia. Read about the rescue here: .

Little did they know that a member of the WY14 was carrying a little treasure through all the turmoil and terror.

Please help with a tax-deductible donation for the hay drive to get a semi-load of hay for the WY14-15. They are all growing and need more hay!

Welcome Spitfire! You will carry on the bloodline that those dumb bureaucrats at the BLM thought should be disposed of. SHAME on them.

Please donate and share the Hay Drive so the rescued wild horses can meet their goal quickly. The WY14 and Spitfire thank you for helping them survive and grow strong!

Sulphur roundup comments unveil the cruel scam Utah is running

Wild horses sold for Basashi Sushi (Horse Meat)

Wild horses sold for Basashi Sushi (Horse Meat)




February 25, 2015

Bureau of Land Management
Cedar City Field Office
176 East DL Sargent Drive
Cedar City, Utah 84721

Attention: Elizabeth R. Burghard, Cedar City Field Office Manager

Project Name: Sulphur HMA Public Health and Safety
Wild Horse Gather and Removal

Document: News Release

Dear Ms. Burghard:

I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …

Sulphur HMA

… and that are, reportedly, posing safety-concerns along Highway 21.

I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
Overpopulation, Forage Limitations

BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.

The Proposed Action

BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830″ (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.

The Issues

There are several important questions concerning the planned gather that BLM has not addressed.

What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21″? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?

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

Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.

Outsiders — Dealing with Roving Equids

Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.

Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.

Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?

And, most importantly, …

Why hasn’t Highway 21 been fenced off near the HMA?

BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.

Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses

Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.

I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.

Wildlife Underpasses — Historical Perspective

Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.

Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.

What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.

The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.

Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!

How Well Did the Highway 89 Underpasses Work?

Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.

Wildlife and Roads — Decision-Guide

At the link below, you will find information and resources regarding the use of overpasses, underpasses, and crosswalks for mitigating collisions between wildlife and vehicles.

You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
Unlikely Birth-Rate

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

Let’s do the math.

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

This is improbable.

Population and Gather Reports — The Data

Per a review of the …

HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,

discrepancies are evident.

Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015

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

Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
—— —– ———– ————– —————————————————

2008 250 435 + 87 BLM estimated foal-crop @ 20%
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
267 Post-gather estimate = 38+22+207

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

2013 384 +334 BLM estimated foal-crop @ 87%
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal- crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
830 Current estimate = 718+144-30-2
2015 830 Public health and safety excuse used to justify removing 100 wild horses without an EA.

The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.

Societal Impact of Inflated Population-Data

The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.

Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.

Mistakes Cost Wild Horses Their Freedom

The planned removals appear to have been hurriedly scheduled to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by faulty figures.

Not the First Time Population-Estimates Were Found to Be Flawed

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

125 %
131 %
153 %
157 %
249 %

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

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

Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).

Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.

Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.

Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.

Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.

BLM-Billings, which has been employing PZP for many years to contracept the Pryor Mountain herd, has found that PZP’s efficacy averages 90 percent.

A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.

However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.

Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.

Bottom line: Every benefit-of-the-doubt has been given.

Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths

2008 — 190 — BLM’s population-estimate post-gather November 2008

Year Herd-size
January 1

2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.

2010 — 228 — Foal-crop: 46. Dec. gather removed 30 horses, PZP 38 mares.

2011 — 244 — Foal-crop: 49. PZP does not affect already-pregnant mares.

2012 — 293 — Foal-crop: 59. Even though PZP at maximum-effect.

2013 — 352 — Foal-crop: 70. Even though PZP still in effect.

2014 — 422 — Foal-crop: 84. But gather in Aug removed 30 horses.
2015 — 476 — including the 2014 foal-crop

2015 — 392 — excluding the 2014 foal-crop

It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.

Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.

Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …

Below minimum-viable population.

No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.

Planned Roundup Would Have a Devastating Impact on the Sulphur Herd

Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.

But it gets worse. Recent studies have shown BLM’s “20-percent-per-year” rule to be exaggerated by double.
Longitudinal Study Demonstrates Growth-Rate of Five-to-Ten-Percent

The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.

Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …

No removals
No predators

Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.

The ISPMB study casts doubt on BLM’s standard “20-percent-per-year” rule for estimating herd-growth. Certainly, assumed growth-rates of 29 percent IN 2010 and, especially, the 87 percent growth-rate the BLM assumed for 2014, are implausible. Further, because subsequent estimates were based on false, inflated previous estimates, the errors compounded.

Independent Research Discloses a 10% Foal-to-Yearling Survival-Rate

A study of BLM roundup-records for a representative sample of four herd management areas was recently published (Gregg, LeBlanc, and Johnston, 2014).

The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
Projections per a Ten-Percent Growth-and-Survival Rate

Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).

Sulphur HMA — Per 10% Growth — Modified by Removals, but NOT by PZP

2008 — 190 — BLM’s population-estimate post-gather Nov ’08

Year Herd-size
January 1

2009 — 190 — Foal-crop: 19.

2010 — 209 — Foal-crop: 21. Dec. gather removed 30 horses, PZP 38 mares.

2011 — 200 — Foal-crop: 20. PZP does not affect already-pregnant mares.

2012 — 220 — Foal-crop: 22. Even though PZP at maximum-effect.

2013 — 242 — Foal-crop: 24. Even though PZP still in effect.

2014 — 266 — Foal-crop: 27. But gather in Aug removed 30 horses.
2015 — 263 — including 2014 foals

2015 — 236 — excluding 2014 foals

It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.

Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.

However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …

Below AML and
Below minimum-viable population.

It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.

Could There Really Be 100 Wild Horses Wandering onto the Highway?

Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.

Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.

Happy Tone, Ugly Reality

BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.

Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21″;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
Sale to Slaughter for Sulphur HMA Captives

BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.

A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21″ removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.

Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21″ only to send them down a “highway to Hell”?
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP

BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.

A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:

BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.

Sulphur HMA — Utah — AML, and Acres per Wild Horse — Current

AML: 165 to 250 — Below minimum-viable population

Total acres: 265,711 — which is approximately 415 square miles

Acres per wild horse: 1,063 – 1,610 — about 1⅔ to 2½ square miles per horse
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Recommended

AML: 2,500 to 5,000 — Meets minimum-viable population per IUCN

Total acres: 265,711 — which is approximately 415 square miles

Acres per wild horse: 53 – 106 — about 6 to 12 horses per square mile

BLM’s National Authorized Livestock AUMs

But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?

BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.

Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.

157,000,000 acres of public lands on which BLM allows cattle

1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized

2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2

4,133,332 cows and calves = pairs x 2

38 acres per cow or calf

BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.

Actual Grazing Use Report — Form 4130-5

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

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

Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use

In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.

Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.

What If There Is Not Enough Forage to Support 5,000 Horses?

Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that

… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.
Genetic Evaluation of the Sulphur Herd

BLM notes that the Sulphur herd has Spanish Barb genetics. Many reportedly have the primitive dorsal stripe and “tiger stripes” on their legs.

Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.

Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.

The correct order is:

Sample first.
Sample complete — 100 percent.
Test samples.
Manage per test-results.

There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.

Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool

I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.

Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:

Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring

Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
Helicopters Are Not Safe

BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.

Peculiar Way of Addressing Safety Concerns

Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.

Helicopter-Drive — an Inhumane Roundup Method

Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.

Abusive Behavior by Helicopter Pilots during Gathers

As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.

There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.

No Horse Left Behind

The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.

An Angry Contractor May Be Headed Your Way

In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.

Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.

Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.

Some Observers May Be Pumped-Up Too

Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.

The political weather is unstable. That is another good reason to call off the roundup.

Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs

A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.

How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.

Possible Collusion with Permit-Holders

Perhaps, as you read this, permit-holding ranchers are in the HMA, pushing wild horses toward the Highway.
1. Stop action. Cancel gather.

2. Complete environmental assessment.

3. Correct errors in the population-estimates.

4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.

5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.

6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.

7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).

8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.

9. Conduct a 100-percent evaluation of the Sulphur HMA herd’s genetic status.

10. Say “No” to helicopters.


Marybeth Devlin

Save wild horses in Oregon from getting more strikes

Please help network these wild horses to a good home. They received a STRIKE against them from the last Internet Adoption because they were passed over. 

PM Mary in Foal #08022753

MARY in foal #08022753

Sex: Mare Age: 7 Years Height (in hands): 14.1

Necktag #: 2753 Date Captured: 10/14/14

Color: Bay Captured: Palomino Buttes (OR)

Tag#-2753. This is a 7 year-old bay mare gathered from the Palomino Buttes HMA in OR in October 2014. Freezemark: 08022753

There is a likely possibility that this mare is currently carrying a foal. By the time the internet adoption closes and shipping arrangements are made, this horse will be too far along in her pregnancy to travel healthily via livestock truck hauling. Therefore…this horse MUST BE PICKED UP directly from Oregon’s Wild Horse Corral Facility in Hines, OR.

PM Mary in Foal 3


There were no bids placed on MARY during the last Internet Adoption so she received another STRIKE.


PM Mary in Foal #08022753


Mary needs someone to care for her and her foal. If she gets 3 STRIKES the BLM can legally sell her to slaughter according to the Burns Amendment. Please contact us if you run into BLM red tape. Our email is


PM Sam #13022735

SAM is only 2 years old and he received another STRIKE

Sex: Gelding Age: 2 Years Height (in hands): 14.1

Necktag #: 2735 Date Captured: 10/14/14

Color: Bay Captured: Palomino Buttes (OR)

Tag#: 2735. This is a 2 year old bay gelding gathered from the Palomino Buttes HMA in OR in October 2014. Freezemark: 13022735

This horse is currently located at the Corral Facility in Hines, Oregon. For more information, contact Patti Wilson at email or Tara at

Pick up options (by appt): Burns, OR; Delta, UT; Elm Creek, NE; Pauls Valley, OK; Piney Woods, MS.

Other pick up options: Ewing, IL (march 20); Montgomery, AL (March 27).
Adoption confirmation for this animal must be finalized no later than Noon Mountain February 12, 2015. After this date, all unclaimed animals will be available for in-person walk up adoption ONLY.

There were no bids placed on SAM during the Internet Adoption so he received another dangerous STRIKE

PM Sam #13022735 Trot


Controversy over PZP

nt B:W

Which Way Is Best?

by Mar Wargo

Wild Horse groups and individuals are making deals with the Bureau of Land Management (BLM) behind the US Publics’ back and each others’. Just like BLM, they do not adhere to the Wild Free Roaming Horse & Burro (WFRH&B) Act of 1971. Rather they do as BLM and they ignore the science; they break the 1971 Act for personal gain and to fulfill the Salazar Plan which did not release enough educational info to be debated with the public as is law. Public involvement is needed for this is Public Lands and Public wild horses at stake. This country loves these entities and wants them safe. Competition for programs, $$, credit and influence between wild horse .orgs has simply become unprofessional.

We began by fighting the Salazar Plan in 2009. Now the goal to defeat this plan has ended and turned much of the advocacy away from either stopping the roundups or to actively administering drugs not designed for use on wild horses. Our wild horses are not cattle to be abused with the trauma of roundups for administering a drug BLM has not been using correctly from the get go. There is a booster they just do not bother with. How has this omission of part of BLM’s failed-so-far program actually affected BLM’s data on the use of PZP? I have to wonder. It sounds rather sinister to be using only part of a drug. I hear it is because they cannot or will not hold the mares for the full time period so they can receive the booster.

Save our wild horses and wild burros in the wild.

Today I find people who were once adamantly against PZP have either followed their personal mentors as they changed their minds and took up the PZP banner and dealt with BLM and made deals and I bet, just my opinion, got some money too. But they are no longer fighting the fight I came back to in 2007. They are no longer attempting to protect the Public lands the wild ones were given. They will break down family behaviors and we will not see wild natural behavior ever again when people select stallions and which mares will reproduce. This is a domestic endeavor. Our horses and burros have legal lands and laws that need to shear off the BLM Amendments and develop science in the field as the law intended.

We now have several or more versions of advocacy; PZP and no roundups (and no horses very soon in small HMAs). This is what I have referred to as a “Stop Gap” and also for wild horses on sanctuaries. In captivity this drug may have been of good use or not. I know those who will never use PZP again! Then we have the PZP AND Round Ups?! Business as usual. You Have to wonder what this is all about! Are folks just tired of this after only 5 years? Velma Johnston did not tire after a mere 5 years. I find this outlook arrogant as it is the BLM outlook and advocates in good faith have been taken down the wrong paths by trusted mentors. Non-Horse Professionals continue to ignore the lack of science and the needed use of it to actually create good holistic management. I guess they are worn out? This is little different than joining BLM. I am ashamed to realize I supported organizations who could betray our wild ones so casually and without actually ever explaining to their donating public what they were doing behind everyones’ back with their money. They are supporting what we know are destructive BLM policies and continue to ignore the 1971 WFRH&B Act just like BLM. Why not get a job with them? Because supporting BLM is going to be responsible for further destruction of our wild herds.

PZP and roundups. Have we all been standing still while particular orgnizations make a living off the wild horses? Well, yes, we have.

Last but not least are the NO PZP folks, science oriented, eager to see creative management get on the land with our wild ones- people I work with. Come join us at Protect Mustangs. Find the Face Book page, visit the website, READ and be amazed at what is really going on with your wild horses. Celebrate the wild horse and wild burro. Keep them free and safe from all harm. Join the real deal. We need people and funds for the programs already in the works with adopted BLM wild mustangs, their care and use as ambassadors to the American public.

We are also in need of a 10 year Moratorium to create and administer holistic and science based management. Our wild ones face a very hostile environment in many places now. Removals must end and good MANAGEMENT WITHOUT BLM is the best future we can give them on their own lands. If no one talks with anyone and everything is a secret, how can we progress?

# # #


Ken Salazar’s Wild Horse Plan Fuels Accusations That He’s In The Pocket Of Ranchers, Associated Press, 2010:

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

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

Opposition grows to Salazar’s plan to move wild horses to Midwest preserves, Associated Press 2009

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

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

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

7 Preserves Envisioned to Manage Wild Horses, New York Times, 2009

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

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

. . . ”

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

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

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

Sheryl Crow Slams Salazar’s Wild Horse Plan, Huffington Post 2010

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

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

Madeleine Pickens praises Salazar wild horse plan, Horsetalk, 2009

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

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

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



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


Injection-Site Reactions in Wild Horses (Equus caballus) Receiving an Immunocontraceptive Vaccine, By James E. Roelle and Jason I. Ransom,

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

Ecologist Craig Downer speaks out against using PZP in the Pryors

Why end natural selection in the Pryors? Should humans run a wild horse breeding program or does nature know best?

The Horse and Burro as Positively Contributing Returned Natives in North America, Craig Downer 2014

 Mar Wargo is an environmentalist and artist.

Captive wild horses need homes ASAP #WildHorseWednesday


COCO #8243 is a 2 year old filly from the Jackson Mountains in Nevada. She is soulful, friendly and curious and will gentle easily with love and bonding from what we could observe. She has a very kind eye and likes people. She is a sweetheart. Adoption is through BLM. Call Palomino Valley at 775-475-2268 to adopt COCO #8243. Don’t let anything they say keep you from adopting the wild horse you want. We can recommend haulers and can help you brainstorm if any adoption problems come up. BLM loves their red tape. We hope they will make adopting wild horses a more friendly experience from now on and heard a new polite voice on the phone so let’s hope they’ve changed. Please let us know once your application for COCO  is approved so we can stop promoting her. She is a very deep soul who will be your friend for life.



OWYHEE #9462 is an intelligent and kind 2 year old gelding from the Little Owyhee herd management area (HMA) in Nevada. He is interested in people and really wants to leave the BLM to be loved in a forever home.  Adoption is through BLM. Call Palomino Valley at 775-475-2268 to adopt OWYHEE #9462. Don’t let anything they say keep you from adopting the wild horse you want. We can recommend haulers and can help you brainstorm if any adoption problems come up. BLM loves their red tape. Tall fencing is only required until your horses are gentled then you may keep them with your other horses. Please let us know once your application for OWYHEE is approved so we can stop promoting him. He is a real bonder who will learn quickly if you go slowly. The key is patience and knowing that they are teaching us as well.



SPIRIT QUEEN #0309 is a regal 7 year old mare from the Diamond HMA in Nevada. She belongs in the wild but was captured as so many were . . . She was calling for help to get out of BLM because she is so unhappy inside the pens. She likes women and needs to live with other horses in a pasture. She could be a wonderful partner using natural horsemanship techniques yet always being careful not to hurt her with tack that doesn’t fit just right. She would prefer to have a partner who would ride her bareback and out on trails. She’s not the sort of horse spirit that should ever be dominated, broken or forced to live in a small space with only an arena.

Adoption is through BLM. Call Palomino Valley at 775-475-2268 to adopt SPIRIT QUEEN # 0309. Don’t let anything they say keep you from adopting the wild horse you want. We can recommend haulers and can help you brainstorm if any adoption problems come up. BLM loves their red tape. Tall fencing is only required until your horses are gentled then you may keep them with your other horses. Please let us know once your application for SPIRIT QUEEN #0309 is approved so we can stop promoting her. She will teach you about the wonders of nature if you listen . . . and quiet your mind.


Email us at if you need help adopting any of these wonderful wild horses.  Check back often. We will be adding photos to this page.

Wild Horse Wednesday™ is one of Protect Mustangs’ education and outreach programs

Tobacco science scapegoats wild horses for livestock damage in the West

Dave Philipps writes an anti-wild horse story with pro-slaughter undertones–ignoring the fact that livestock grazing is destroying public land

By Anne Novak, Founder of Protect Mustangs

In his New York Times piece, As Wild Horses Overrun the West, Ranchers Fear Land Will Be Gobbled Up, Philipps writes,

“There are now twice as many wild horses in the West as federal land managers say the land can sustain. The program that manages them has broken down, and unchecked populations pose a threat to delicate public land, as well as the ranches that rely on it.”

Why is Philipps ignoring the 2013 National Academy of Sciences’ statement that there is “no evidence of overpopulation”?

Philipps also avoids the fact that commercial livestock outnumbers wild horses more than 50 to I on public land.

If left unchecked, horse populations could decimate grass and water on public lands, he said, potentially leading to starvation among horse herds and other native species, as well as lawsuits from ranchers and wildlife groups.

Why is the Pulitzer Prize-winner spreading myths that America’s wild horses are not native by writing this?

Wild horses today are the descendants of stray American Indian ponies and cavalry mounts, as well as more recent ranch stock. Roaming a patchwork of parched rangeland roughly the size of Alabama, they have been protected by federal law since 1971 from capture or hunting. Since then, the Bureau of Land Management, which oversees most of the herds, has said that keeping the population around 26,000 would ensure the long-term health of the horses and the land.

Surely this investigative journalist learned that wild horses are indigenous.

Below are some excerpts from scientific papers on wild horses as native or ‘returned-native’ species:

In 2010, Jay Kirkpatrick and Patricia Fazio explained the following in Wild Horses as Native North American Wildlife:

The key element in describing an animal as a native species is (1) where it originated; and (2) whether or not it co‐evolved with its habitat. Clearly, E. 6 caballus did both, here in North American. There might be arguments about “breeds,” but there are no scientific grounds for arguments about “species.”

The non‐native, feral, and exotic designations given by agencies are not merely reflections of their failure to understand modern science but also a reflection of their desire to preserve old ways of thinking to keep alive the conflict between a species (wild horses), with no economic value anymore (by law), and the economic value of commercial livestock.

Native status for wild horses would place these animals, under law, within a new category for management considerations. As a form of wildlife, embedded with wildness, ancient behavioral patterns, and the morphology and biology of a sensitive prey species, they may finally be released from the “livestock‐gone‐loose” appellation.

In June 2014 the American Journal of Life Science published The Horse and Burro as Positively Contributing Returned Natives in North America, by Craig Downer who writes,

“Fossil, genetic and archeological evidence supports these species as native. Also, objective evaluations of their respective ecological niches and the mutual symbioses of post-gastric digesting, semi-nomadic equids support wild horses and burros as restorers of certain extensive North American ecosystems.”

Read the extensive paper here:

Other truths were ignored also. . . For example, Public Employees for Environmental Responsibility (PEER) has produced factual reports proving livestock is causing extensive range damage. Philipps fails to mention this damage in his article. Here are some examples of PEER’s excellent information:

Data Backs BLM Manager’s Allotment Cuts in Face of “Cowboy Express” Protest

Washington, DC (September 25, 2014)— A U.S. Bureau of Land Management District Manager from Nevada targeted by angry Nevada ranchers was more than justified in removing cattle from drought-stricken public rangeland, according to data released today by Public Employees for Environmental Responsibility (PEER). Tomorrow, protesting ranchers start a “Cowboy Express” ride to Washington demanding removal of BLM Battle Mountain District Manager Douglas Furtado as an “abusive federal employee” even as conservation groups urge that Furtado be commended not condemned for his actions.

In July, Battle Mountain District Manager Furtado ordered livestock removed from parched range on the sprawling 332,000-acre Argenta allotment in northern Nevada after conditions fell below thresholds that ranchers and BLM had previously agreed would trigger removal. The ranchers contend that Furtado’s actions were arbitrary but an analysis of Geographic Information Systems and BLM data reveal range in terrible ecological shape:

  • Nearly every Battle Mountain allotment evaluated failed range health standards for wildlife and water quality, largely due to livestock grazing;
  • Half of the Argenta Allotment, and roughly 30% of the Battle Mountain District is habitat for sage grouse, a species being reviewed for listing under the Endangered Species Act. BLM has been directed to protect the species’ habitat but 90% of assessed sage grouse habitat was in Battle Mountain allotments failing standards due to livestock; and
  • Fence line contrasts visible in satellite imagery show that public lands in the checkerboarded allotment are far more heavily grazed than private lands, suggesting that ranchers are more protective of their own lands than they are of publicly-owned range.

Read the full article here.

Agency Sage Grouse Review Puts Thumb on Scale to Magnify Wild Horse and Burro Effects

Washington, DC (September 16, 2014)— The method used by the U.S. Bureau of Land Management to assess range conditions is seriously skewed toward minimizing impacts from domestic livestock and magnifying those from wild horses and burros, according to an appraisal by Public Employees for Environmental Responsibility (PEER). As a result, the BLM’s approach to range management targets scattered wild horses and burros while ignoring far more numerous cattle.

The agency’s assessment is part of a 2013 report on factors influencing conservation of the Greater Sage-Grouse, a ground-dwelling bird whose numbers have declined as much as 90% across the West and which is under consideration for protection under the Endangered Species Act. That report concludes that twice the area of sage grouse habitat is negatively impacted by wild horses and burros than the area negatively impacted by livestock. A PEER appraisal of the methodology found –

  • BLM calculates the “area of influence” of wild horses and burros on sage grouse habitat based merely on their presence within Herd Management Areas in sage grouse habitat, while it considers livestock impact to have occurred only when livestock grazing allotments fail the agency’s Land Health Status (LHS) standard for wildlife;
  • If the agency used the same approach for calculating the area of influence of livestock within BLM grazing allotments on sage grouse habitat as it did for wild horses and burros, the area of influence for livestock would be roughly 14 times that given in the report and more than six times that of wild horses and burros; and
  • Within BLM’s own grazing allotment LHS database records, livestock grazing is cited as a cause of failure to achieve a land health standard 30 times more often than are wild horses and burros.

“At BLM apparently not all hooves are created equal,” said PEER’s Advocacy Director Kirsten Stade, noting that the LHS evaluations cover more than 20,000 grazing allotments and examine whether a grazing allotment meets the agency’s standards for rangeland health with respect to several vegetation and habitat conditions. “This helps explain why wild horses are regularly removed from the range but livestock numbers are rarely reduced.”

Read the full article here.

33 million Acres of BLM Grazing Allotments Fail Basic Rangeland Health Standards

Washington, DC (May 14, 2012)— A new federal assessment of rangelands in the West finds a disturbingly large portion fails to meet range health standards principally due to commercial livestock operations, according to Public Employees for Environmental Responsibility (PEER). In the last decade as more land has been assessed, estimates of damaged lands have doubled in the 13-state Western area where the U.S. Bureau of Land Management (BLM) conducts major livestock leasing.

The “Rangeland Inventory, Monitoring and Evaluation Report for Fiscal Year 2011” covers BLM allotments in Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington and Wyoming. The report totals BLM acreage failing to meet rangeland health standards in measures such as water quality, watershed functionality and wildlife habitat:

  • Almost 40% of BLM allotments surveyed since 1998 have failed to meet the agency’s own required land health standards with impairment of more than 33 million acres, an area exceeding the State of Alabama in size, attributed to livestock grazing;
  • Overall, 30% of BLM’s allotment area surveyed to date suffers from significant livestock-induced damage, suggesting that once the remaining allotments have been surveyed, the total impaired area could well be larger than the entire State of Washington; and
  • While factors such as drought, fire, invasion by non-native plants, and sprawl are important, livestock grazing is identified by BLM experts as the primary cause (nearly 80%) of BLM lands not meeting health standards.

“Livestock’s huge toll inflicted on our public lands is a hidden subsidy which industry is never asked to repay,” stated PEER Advocacy Director Kirsten Stade, noting that the percentage of impairment in lands assessed remains fairly consistent over the past decade. “The more we learn about actual conditions, the longer is the ecological casualty list.”

Read the full article here.

Scientists Told to Not Consider Grazing Due to Fear of Lawsuits and Data Gaps

Washington, DC — The U.S. Bureau of Land Management is carrying out an ambitious plan to map ecological trends throughout the Western U.S. but has directed scientists to exclude livestock grazing as a possible factor in changing landscapes, according to a scientific integrity complaint filed today by Public Employees for Environmental Responsibility (PEER). The complaint describes how one of the biggest scientific studies ever undertaken by BLM was fatally skewed from its inception by political pressure.

Funded with up to $40 million of stimulus funds, BLM is conducting Rapid Ecoregional Assessments in each of the six main regions (such as the Colorado Plateau and the Northern Great Plains) covering the vast sagebrush West. A key task was choosing the “change agents” (such as fire or invasive species) which would be studied. Yet when the scientific teams were assembled at an August 2010 workshop, BLM managers informed them that grazing would not be studied due to anxiety from “stakeholders,” fear of litigation and, most perplexing of all, lack of available data on grazing impacts.

Exclusion of grazing was met with protests from the scientists. Livestock grazing is permitted on two-thirds of all BLM lands, with 21,000 grazing allotments covering 157 million acres across the West. As one participating scientist said, as quoted in workshop minutes:

“We will be laughed out of the room if we don’t use grazing. If you have the other range of disturbances, you have to include grazing.”

Read the full piece here.

Why hasn’t Phillips used PEER’s information to report fairly or is he only chomping on what the Cattlemen’s lobby feed him?

The Times article also pushes the wild horse overpopulation myth to fool people into believing there is a problem. For example, In northeastern Nevada only 1,338 wild horses are allowed on 1.8 million acres of public land designated for their primary but not exclusive use. Hardly overpopulated.

Holistic range management options aren’t discussed but the massive slaughter of captive wild horses is brought up like a ticking time bomb. The truth is, there are more wild horses in government holding than living in freedom on the range. Those left on the range have a red flag birthrate. The herds fear extinction and mother nature doesn’t want them to die off. If the Bureau of Land Management didn’t take so many off the range, birthrates would be normal and herds would self-stabilize. Princeton University working with the International Society for the Protection of Mustangs and Burros has learned in a 14 year study that wild horse herds with functional social structures contribute to low herd growth compared to BLM managed herds.

In the UK, wildlife managers are using wild horses to heal the land and restore biodiversity. Holisitic management can work on America’s public lands if people would take the time to learn a new system but it seems they are just too lazy. . . Lazy, like the journalist who doesn’t do basic research for his article.

Has someone done a “follow the money” on Dave Philipps to see what’s really spurring him on? Now that’s an article I would find informative.


Links of interest™:

Dave Philipps’ spin piece in the New York Times:

Kirkpatrick, J.F., and P.M. Fazio. Revised January 2010. Wild Horses as Native North American Wildlife. The Science and Conservation Center, ZooMontana, Billings. 8 pages.

Craig C. Downer, The Horse and Burro as Positively Contributing Returned Natives in North America, American Journal of Life Sciences. Vol. 2, No. 1, 2014, pp. 5-23. doi: 10.11648/j.ajls.20140201.12

National Academy of Sciences: Using Science to Improve the BLM Wild Horse and Burro Program.

Princeton University and ISPMB: Wild horse herds with functional social structures contribute to low herd growth compared to BLM managed herds

Wild horses of Wildwood:


Horse contraceptive study raises concerns

October 29, 2010
By Laurie Dixon
Research indicates the long-term horse contraceptive, porcine zona pellucida (PZP), extends the breeding season in wild horses, raising concerns over the social consequences of the drug on herds.

PZP, which is derived from pig eggs, is increasingly being used in wild horse herds . . .

Read more:

Dangerous bill puts America’s wild horses at risk of slaughter

©Cynthia Smalley


Dear Friends of Wild horses and burros,

It’s bad when the BLM holds captive mustangs with no shade or shelter but if we all don’t rally quickly to stop a misleading bill in Congress, we could witness America’s cherished wild horses being sold to slaughter by the thousands instead of being held captive in holding pens or living in freedom as the law intended–safe from harassment and slaughter.

You probably have witnessed what happens when the states “manage” wild horses. . . In the case of the 41 wild horses from Dry Creek, Wyoming, 37 were sold to the Canadian slaughterhouse. We are so grateful to have rescued 14 youngsters (8mo-2 yrs) who were all going to be butchered for human consumption abroad.

Below is an Associated Press article that is going viral this weekend while the National Association of Counties is meeting in New Orleans. The Utah Commissioners are trying to get a joint resolution backed which would put American wild horses at-risk of being killed and slaughtered to “dispose of them.” Of course the politicians don’t pitch it this way. No . . . they cover that part up and make their resolution and their legislation look like it has animal welfare in mind. You can see the bill below.

Let’s hope this article shines the light on their sinister plans. It’s time to fight for the protection of wild horses.

Bill seeks to allow states to manage wild horses
By Martin Griffith, Associated Press

RENO, Nev. (AP) — A Utah congressman has introduced legislation to allow Western states and American Indian tribes to take over management of wild horses and burros from the federal government.

Rep. Chris Stewart said the U.S. Bureau of Land Management has mismanaged the animals on public rangelands and states should have the option of managing them.

An overpopulation of horses is pushing cattle off the range, the Republican lawmaker said, and leading to the destruction of important habitat for native species.

“States and tribes already successfully manage large quantities of wildlife within their borders,” Stewart said in a statement. “If horses and burros were under that same jurisdiction, I’m confident that new ideas and opportunities would be developed to manage the herds more successfully than the federal government.”

But Anne Novak, executive director of California-based Protect Mustangs, said her group opposes the legislation because it would lead to states and tribes killing the animals or selling them off for slaughter for human consumption.

The government is rounding up too many mustangs while allowing livestock to feed at taxpayer expense on the same rangeland scientists say is being overgrazed, she said.

“We’ve had firsthand experience with states and tribes managing wild horses, and it’s horribly cruel,” Novak said in a statement. “They ruthlessly remove wild horses and sell them to kill-buyers at auction. Severe animal abuse would be the result of the (legislation).”

The Bureau of Land Management says it’s doing all it can, given budget constraints, overflowing holding pens and a distaste for the politically unpopular options of either ending the costly roundups or slaughtering excess horses.

The bill’s introduction comes at a time when the bureau has been under increasing pressure from ranchers to remove horses that they say threaten livestock and wildlife on rangelands already damaged by drought.

In Utah, Iron County commissioners had threatened to gather up hundreds of mustangs themselves, saying the government refuses to remove enough horses in herds that double in size every five years.

Iron County Commissioner Dave Miller said he and commissioners from Utah’s Beaver and Garfield counties are trying to drum up support for a resolution in support of the legislation at the National Association of Counties annual conference in New Orleans, which ends Monday.

“The resolution will be instrumental in getting Chris Stewart’s bill through Congress because it shows support across the nation,” he told The Spectrum of St. George, Utah.

Stewart said his Wild Horse Oversight Act would extend all protections that horses and burros enjoy under the federal Wild Free-Roaming Horses and Burros Act of 1971 while giving states the opportunity of implementing their own management plans.

Under the bill, the states could form cooperative agreements to manage herds that cross over borders, and the federal government would continue to monitor horses and burros to ensure that population numbers as prescribed by the 1971 act are maintained.

The bureau estimates 40,600 of the animals — the vast majority horses — roam free on bureau-managed rangelands in 10 Western states. The population exceeds by nearly 14,000 the number the agency has determined can exist in balance with other public rangeland resources and uses.

Some 49,000 horses and burros removed from the range are being held in government-funded short- and long-term facilities.

# # #

Cross-posted from the San Francisco Chronicle for educational purposes:

Please share this news with your friends and help with a donation to feed and care for the WY14 and the other wild horses in our Outreach Program here:

Hear a commissioner spin his pitch while interviewed on a friendly radio station in Utah:

Take action and contact your county commissioners and all your elected officials to request they do not support rogue commissioners in Utah and ask that they do not support the individual states managing wild horses because it would put them at risk of slaughter.

Now is the time to stand up and fight for the voiceless!  Together we can turn this around.

Many blessings,

Anne Novak
Executive Director

PM WH&B Oversight Act Web


PM WH&B Oversight Act 2



at Wynema Ranch