Perverted Darting with Pesticide PZP

10 things you need to know about Pesticide PZP

1. PZP — The Pesticide: PZP is an EPA-registered pesticide manufactured from the ovaries of slaughtered pigs. Some persons argue that, because PZP does not kill the mare, it is not really a “pesticide.” Actually, PZP does kill. Stillbirths are associated with the pesticide’s use, meaning that some of its supposed contraceptive effects are actually feticidal.. In addition, over the long term, PZP weakens a herd immunologically, putting it at risk for eventual or even sudden extinction.

2. PZP — The Disproved Hypothesis: PZP’s manufacturer promoted the product as generating antibodies that “block sperm attachment.” But that marketing-hype was merely an untested hypothesis postulated three decades ago. Independent researchers found that PZP has a different effect, and many adverse effects.

3. PZP — The Actual Mode-of-Action: Behaving like a perverted vaccine, PZP tricks the mare’s immune system into making antibodies that cause ovarian dystrophy, autoimmune oophoritis, ovarian cysts, and premature ovarian failure. PZP quickly sterilizes mares that have a strong immune system but has no effect on those suffering from weak immunity. Thus, PZP both works and doesn’t work but, in the long run, selects for poor immune function. Weak immunity = weak resistance to infection, which could quickly wipe out a herd. PZP also affects the foals. If a mare is pregnant or nursing when darted, PZP antibodies are transferred to her offspring via the placenta and her milk. So, inadvertently, unborn and newborn foals receive a dose or two of the pesticide when their dams are injected.

4. PZP — The Danger to Humans: PZP is a powerful endocrine-disruptor. It causes a sharp drop in estrogen levels. Unfortunately, because the manufacturer misrepresented PZP as “so safe it is boring,” volunteer-darters have become lax in following safety-precautions. Accidental self-injection could result in severe adverse effects because the dose-in-question is sized for a horse.

5. PZP — The Year-Round Birthing-Season: A longitudinal study (Ransom et al. 2013) of three herds currently under treatment with PZP found that the the birthing-season lasts virtually year-round (341 days). Out-of-season births put the life of mares and their foals in jeopardy. Nature designed foals to be born in Spring, not year-round, and certainly not in Winter.

6. PZP — Prolonged Delay in Recovery of Fertility: Ransom et al. also found that, after suspension of PZP, it takes more than a year per each year-of-treatment before mares recover their fertility. PZP’s manufacturer conceded that it could take up to 8 years to recover fertility after just 3 consecutive years of PZP treatment.

7. PZP — Scientists Say Proceed with Caution: Ransom et al. warned: “The transient nature of … PZP can manifest into extraordinary persistence of infertility with repeated vaccinations, and ultimately can alter birth phenology in horses. This persistence … suggests caution for use in small refugia ….”

8. PZP — Contraindicated for Tiny, Isolated Herds: Several years ago, BLM convened a meeting of scientists on the topic of minimum herd-size for genetic fitness. Conclusion: “Smaller, isolated populations (<200 total census size) are particularly vulnerable ….” And that’s without PZP in the mix.

9. Slow Herd-Growth: Per independent research, wild-horse herds increase at a rate of only 5% a year; and wild-burro herds, just 2%. Such slow growth does not warrant pesticide treatments administered en masse every year. Eventual sterilization is inevitable, with extinction of the herd over the long term.

10. Predators: The right way to right-size the wild-horse population is Nature’s way — predators. But those predators — mountain lions, bears, wolves, and coyotes — are persecuted mercilessly. Wildlife Services exterminates what trophy-hunters don’t shoot. Predators help the herds by favoring survival-of-the-fittest and the best genetic adaptations. Predators are the “no-cost” solution.

by Marybeth Devlin
Wild Horse Advocate

This mare waits in the alley before being led into the chute where her age and body condition will be checked. After being treated with the PZP fertility control agent, this mare will be released back to the Owyhee HMA.

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



Underpopulation and fraud

PM-Carl-Mrozek-NV-Mustang-marked
In response to the Washington Post biased article pushing pesticide PZP on underpopulated wild horses and burros
Normal Growth Rate: Horses are a slow-growth species when it comes to reproduction. The gestation-period lasts over 11 months, and a mare produces just 1 foal. Gregg, LeBlanc, and Johnston (2014) found that the birth rate in wild-horse herds is almost 20%. Unfortunately, they also found that 50% of foals perish. At least 5% of adult wild horses also perish every year. Thus, the normal herd-growth rate for wild horses is only about 5%.
Fraudulent Growth Rates: Three herds were featured on the Advisory Board’s tour — Antelope Valley, Goshute, and Spruce Pequop. A review of BLM’s alleged growth figures for these herds showed biologically-implausible increases. From a combined total of 1,440 wild horses in 2013, BLM claimed the herds grew to 3,025 wild horses by 2016, a 110% increase. That would mean a 37% average growth rate, which is 740% times the norm. Moreover, if given a 37% growth rate, then to overcome foal mortality and adult mortality, the average birth rate would have to have been 84% — which is 420% times the normal birth rate. Ben Masters and fellow board members unknowingly “drank the Kool Aid” — they swallowed BLM’s propaganda. Truth be told, the range they toured had previously been overgrazed … by livestock.
Wild horses are underpopulated: Per BLM’s own geneticist, 83% of wild-horse herds suffer from arbitrary management levels (AMLs) set below minimum-viable population. For instance, the AML for Oregon’s Beaty’s Butte herd restricts the stocking-density to 1 wild horse per 7 square miles. If there are 2 wild horses per 7 square miles, BLM can technically declare an “overpopulation” because there is “double the number” that the preposterous AML allows. In contrast, BLM authorizes 119 cattle per 7 square miles. After eliminating 99% of the Beaty’s Butte herd, BLM replaced the wild horses with cattle to accommodate a rancher, who had secured a contract to supply grass-fed beef to an upscale grocery chain.
by Marybeth Devlin
Advisory Board Member for Protect Mustangs
Member of the Alliance for Wild Horses and Burros

Protect Mustangs is a 501c3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org




Comments against the Wyoming checkerboard roundup and removal

Via email:  blm_wy_checkerboard_hmas@blm.gov

    September 9, 2016

BLM Rock Springs Field Office

280 Highway 191 North

Rock Springs, WY 82901

Attn: Wild Horse and Burro Specialist

Subject: Checkerboard EA Comments

Project: Roundup-and-Removal — Announced

Document: Environmental Assessment ( EA )

NEPA ID: DOI-BLM-WY-D040-2016-0135-EA

This letter responds to your request for substantive comments and informed analysis that BoLM Rock Springs Field Office (RSFO) should consider regarding the subject EA.  I submit my comments as an interested party in behalf of the wild horses of the Adobe Town (AT), Great Divide Basin (GDB), and Salt Wells Creek (SWC) Herd Management Areas (HMAs) who are deemed to have roamed into the “checkerboard lands” — those where Federal and private property sections alternate in a checkerboard-like pattern — in numbers that exceed the arbitrary levels established by the Consent Decree.  Please note that in all instances where text has been emphasized, either through bold and/or italics, the emphasis was added by me.

For ease of reference, here are the links to the Dear Reader letter and to the Webpage where the EA is posted:

https://eplanning.blm.gov/epl-front-office/projects/nepa/59563/78510/89493/Dear_Reader_Letter_Public_Review_Checckerboard_EA_8-11-16.pdf

http://bit.ly/2bj4PzJ

Background

BoLM unwisely and unethically committed itself to reducing wild-horse numbers at harshly-low levels in the Checkerboard sections of three HMAs at issue.  Per the Consent Decree, once it was determined — or projected — that more than 100 wild horses were present (or might be) at some point in time in GDB, and/or that more than a combined total of 200 wild horses were (or might be) present at some point in time in AT and SWC, then RSFO would have them all removed.

Here are the number of horses that, BLM alleges that, per April 2016 surveys, were present in the checkerboard area of the following herd management areas (HMAs):

  25 Adobe Town

272 Great Divide Basin

187 Salt Wells Creek

——————————————

484 Total

RSFO proposes to remove not just the 484, but an additional 16, for an even 500.  RSFO acknowledges that it would not be removing “excess” wild horses.  RSFO further admits that the proposed removals would drop the population below the low-bound of the established arbitrary management level (AML).

Wild Horses Roam — Their Presence Is Fleeting, Their Numbers Are Fluid

Just because RSFO’s survey allegedly counted 484 wild horses in the Checkerboard does not mean that 484 are still there or were there the day after the census was conducted.  Wild horses are constantly on the move.  Just because they visit an area on certain days does not make them permanent residents.

Public Lands Commandeered by Private Interests

The Checkerboard area encompasses 2,427,220 acres, or 3,793 square miles.  Public lands total 1,695,517 acres — 2,649 square miles — and privately-held lands total 731,703 acres –1,143 square miles.  Thus, public lands constitute 70%, and private lands comprise 30%, of the Checkerboard.

Per the EA, the Rock Springs Grazing Association (RSGA) owns or “controls” the “majority” of the 30% of the privately-held Checkerboard area.  The EA does not reveal how significant that majority is, but it would have to be 51% or more, by definition, to be a majority.  If it were a “great” majority, then surely that point would have been made.  Thus, the conservative inference would be around 51%.  But to make the computations easier, and to give the benefit to the doubt, 60% will be used.

So, 60% x 30% = 18%.  What results is a minor percentage of private-profiteers calling the shots for how public lands are managed.  Unacceptable.

Wild-Horse Population-Density — Even If All 484 Were Only on Private Land

Let’s assume for the moment that 484 wild horses have established permanent residence in the 731,703 acres — 1,143 square miles — of privately-held checkerboard land.  The resultant population-density would be:

1 wild horse per 1,512 acres = 1 wild horse per 2.4 square miles.

Public Corruption — Appearance of

According to the Website of the American Wild Horse Preservation Campaign, the Rock Springs Field Manager has stated publicly:

For all intents and purposes, we consider all of the checkerboard private.”

If this direct quotation is accurate, then the Field Manager appears to be encouraging the private takeover of public lands.  No wonder the Bundy brothers and company felt emboldened by such BoLM “dog whistles” to seize control of the Malheur Wildlife Refuge.  Announcements like that suggest public corruption — abuse of public office to benefit private interests.

FRAUDULENT POPULATION ESTIMATES

Birth Rate versus Herd-Growth Rate

Before we examine BLM’s reported herd-growth rates of these HMAs, 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 of about 20% a year in wild-horse herds.  But the herd growth rate is unlikely to be that high.  Here’s why: Horses and burros die.

An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size of 5,859 wild horses.  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.  It is wrong for RSFO to use 20% as the growth rates.  It may be administratively convenient to equate the birth rate to the growth rate, but it is not valid.   

Adult Wild-Horse-and-Burro Mortality Rates Must Be Factored

But it is not only foals that die.  Adult wild horses also perish.  They succumb to illness, injury, and predation.  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, a practice 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 birth rate.  When BLM reports alleged herd-growth rates many times higher than 20% (horses) — that would necessarily mean birth rates substantially higher still.  Such implausible rates are routinely found in BLM’s population data, including the year-to-year figures for the subject HMAs.  Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — those are just some of the ways BLM creates the false impression of a population-explosion.

Stochastic Events Also Reduce Herd Growth

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

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

http://www.latimes.com/science/sciencenow/la-sci-sn-saiga-antelope-die-off-20150531-story.html

Imagine if such a catastrophe were to befall the subject herds.  Note that the Saiga deaths involved antelope-mothers and their calves.  What if these HMAs’ mares and their foals perished all of a sudden, leaving mainly stallions and sterile elderly mares?  BLM must proactively manage the herds per IUCN 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 the subject HMAs.  What is the MVP?  According to the International Union for the Conservation of Nature: 2500 per equid species, which could easily be accommodated by the acreage composing each of the subject HMAs.

Fraudulent Population Figures

BLM-RSFO’s data reports that the herds-in-question grew at biologically-impossible reproduction-rates.  Further, BLM-RSFO asserts that 484 of these imaginary horses were spotted in the checkerboard, thereby triggering their removal.

Name of HMA Population Population Percent

National OfcNational OfcIncrease

March 2015 March 2016

Adobe Town      602     1,030     71.0%

Great Divide Basin      199       670   236.7%

Salt Wells Creek      117       728   522.2%

BLM’s population-growth figures are fraudulent.  They are biologically impossible.  Even if the “data” represented only the birth rates, they would be as much as 100 times the normal birth rate.  Moreover, the bogus birth rates have been conflated with herd-growth rates.  The mortality rates were not factored.  Consider how such errors will compound and magnify over time.

In light of these fictitious figures, no action is the appropriate alternative.  BoLM-RSFO should be subjected to a forensic audit to determine who is behind the phony data.  Those staffers must be held accountable.

But Is There a Mandate to Practice Scientific Integrity?

Yes.  The Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct applies to all staff members as well as to contractors, partners, permittees, and volunteers.  The Code states: “Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved.  Most importantly, it must be trustworthy.”

BLM-RSFO’s wild-horse population estimates are without merit.

Societal Impact of Inflated Population-Data

The population-estimates for the subject HMAs are flawed, exaggerated.  The political fallout of this error has been to keep the public — particularly state and 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.

Fraudulent Data Emboldens Scofflaw Ranchers, Costs Wild Horses Their Freedom

In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use.  The notorious Cliven Bundy and permittees Kevin Borba and Dan Filippini blatantly defied BLM’s authority; yet they were pacified with non-enforcement and concessions.  BLM enables and rewards such bad behavior by caving in to it.  Meanwhile, poor LaVoy Finnicum lost his life because, per precedent BLM stand-downs, he concluded that BLM and FBI would not enforce the law.

There are likely permittees in Wyoming emulating Bundy, Borba, and Filippini.  Certainly RSGA has no respect for the Act that was meant to protect America’s mustangs.  Wild horses must not lose their freedom merely so that BLM can placate greedy and rebellious elements in the human population.  If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that elected officials and ranchers are building due to the false appearance created by fictitious herd-growth figures.    

Voluntary Non-Use of AUMs Reflects Lowered Demand for Beef

BLM and its permit-holders protest that a lot of the livestock AUMs are in non-use, sometimes mandatorily, other times voluntarily.  They complain loudly, pointing to the seeming excess of wild horses — an illusion caused by BLM’s phony figures.

Bloomberg News published an article recently concerning the state of the beef market.  In the US, consumer-demand for beef is down to levels not seen in 40 years.  The US cattle-herd population is at a 60-year low and is expected to drop further.  The article explored why this situation exists.

Bloomberg noted that beef is a premium product, with a significantly higher price-point.  US consumers are turning to lower-cost meats, such as pork and chicken.  Further, the strength of the dollar makes US beef exports less competitive in the global marketplace.  Thus, it does not make economic sense for a rancher to produce more beef, given current conditions.  So, reduced demand and lowered cattle-population are important reasons why AUM-usage is down.  It has nothing to do with wild horses.

http://www.bloomberg.com/news/articles/2015-10-04/beef-isn-t-for-dinner-anymore-as-americans-devour-cheaper-pork

Authorized v. Actual Livestock Use

BLM also argues 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.”

http://www.blm.gov/style/medialib/blm/noc/business/eforms.Par.2064.File.dat/4130-005.pdf

http://www.gpo.gov/fdsys/pkg/FR-2014-08-22/html/2014-20049.htm

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.

USDA Reports Beef-Cattle Now Weigh More — AUM Calculations Need to Be Reformed

The same Bloomberg article noted that the average weight of a beef-cattle animal has increased to 1,385 pounds, up 32 pounds from just the previous year.  Please note that the AUM was originally set per a weight of 1,000 pounds.  But, in the meantime, what the industry refers to as “genetics” — technologically-advanced selective breeding — has increased average weight by 38½ percent, with better-than two percent of that increase coming in the past year alone.  BLM needs to charge more AUMs for cattle — as well as charge more per AUM — in accordance with true market-rates.

On the other hand, the AUM for a horse presumes a 1,000-pound saddle horse.  But mustangs tend to be smaller and lighter, weighing 700 to 800 pounds.  Moreover, in contrast to cattle, wild horses are “easy-keepers” that thrive on poor-quality forage.

BLM needs to revisit and reform how it assesses forage-usage for cattle versus wild horses.  Cattle need an AUM surcharge; wild horses need an AUM discount that reflects the less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.

HELICOPTERS — Inappropriate for Counting Wild Horses

Aerial Inventories Produce Gross Over-Counts

BLM likes to attribute impossibly-high estimates to “improved inventory methods.”  But as has been pointed out to BLM previously, the “mark-resight” and the “simultaneous double-count” methods, conducted by helicopter, overcount the population.  Indeed, as the report by the specialty-contractor who conducted the Red Desert Complex (also in 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.  See pdf-pages 84-87 at the link below.

http://www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html

I note that the 2015 Checkerboard Census Report also mentioned that assumptions had been used but contended that an under-count was likely.  That assumption is not only incorrect but opposite to the facts.  When more horses are “seen” than could possibly exist, the method is faulty and likely fraudulent, given the “cooperation” of RGSA.  Finally, I note the absence of photographs.

Both the Roundup-Contractor and BoLM Are Looking to “Make Their Numbers”

A glance at the map of the HMAs in question reveals that they are contiguous, and public lands are interspersed with private lands.  How easy it would be for a profit-motivated helicopter-pilot to “poach” wild horses from strictly public lands by driving them into the target-area.  What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?

In its response to this topic, which was raised during scoping, BoLM said that it would monitor the helicopter’s flight-path to keep this from happening.  But BoLM’s purpose in conducting equid cleansing is to please the permittees.  BoLM has committed to removing 500 wild horses to comply with the Consent Decree, and the roundup-contractor expects to earn the amount that corresponds to 500 captured wild horses.  The helicopter-pilot is looking to “make his numbers” but so is BoLM.  Thus, BoLM has a conflict of interest in needing the contractor to remove any 500 horses that he can find.  The wild horses are fungible — one is as good as another — to make the pilot his money and to enable BoLM to fulfill its agreement with the arbitrary Consent Decree.  Consequently, wild horses would lose their freedom for the private profit of RSGA and the helicopter-contractor, and for the administrative convenience of BoLM.  Unacceptable.

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.  However, removing horses that have wandered into the checkerboard area just creates a vacuum for other horses to fill.  Thus, removing them is an ineffective population-control strategy.  The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs.  The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant.  Thus, removal is not a true solution — it just perpetuates the situation and leads to the elimination of more mustangs than necessary.  Moreover, the wanderers may be only temporary visitors or refugees, not permanent residents.  Worse yet, they may have been driven into the checkerboard by the helicopter.  RSFO acknowledges as much in the EA, but still pursues the removal-without-return alternative.

Recommendations:  In legitimate instances of straying, RSFO should first encourage the wild horses to return to their proper place, then address those factors that caused the animals to leave home.  Would palatable plantings draw the wild horses to the areas RSFO wants them to use?  What about siting mineral licks deep inside the HMAs, away from the Checkerboard?  Have guzzlers been installed to provide water sources deep within the boundaries?  Aversive conditioning could also be employed to shoo the wild horses into the solid-block public lands.  Certainly, positive reinforcement coupled with aversive conditioning would be an effective and cost-effective solution.  RSFO should specify preventive and reactive measures in this regard as part of its management approach.  Return outsiders to the solid-block public-lands areas of the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from the Checkerboard (aversive techniques).

HELICOPTERS — Dangerous to Humans

Scheduled Airliners — Safe; Helicopters — Crash-Prone

As cited in my scoping comments but reiterated here out of concern for staff-wellbeing, the American public considers travel-by-air to be safe, even routine.  Crashes are rare, and fatalities, few.  Thus, it is easy to assume that all flight is safe, which is not the case.

Helicopters are notorious for crashing.  Please compare and contrast Wyoming’s aviation crash-records of scheduled air carriers versus helicopters during the 10-year period from January 1, 2006 to December 31, 2015 — per the National Transportation Safety Board (NTSB):

Scheduled Air Carriers (“Part 121”)

    1  — Accidents (minor events excluded)

    0  — Accidents that resulted in fatalities

Helicopters

  13  — Accidents (minor events excluded)

    1  — Accident that resulted in a fatality

    1  — Number of persons that died in that accident

In Wyoming, for the period in question, there has been 1 accident involving a scheduled air carrier.  Nobody died.  Helicopters, in contrast, have had 13 accidents — 13 times more — including 1 that involved a fatality.  At the link below, you can replicate the searches to verify these data.

http://www.ntsb.gov/_layouts/ntsb.aviation/index.aspx

Helicopter Census Method Puts BLM Personnel at Risk

BLM’s environmental assessments often allude to the use of “multiple experienced observers” (presumedly BLM staffers) to count and photograph wild horses — or what they think are wild horses — while being flown in grid patterns over the range.

Given the crash-proneness of helicopters, BoLM could face a tragedy — with the loss of key personnel, friends, and colleagues in an accident.  Counting wild horses does not justify this risky method.

HELICOPTERS — Dangerous to Horses

Inhumane Roundup Method

BoLM’s use of helicopters to round up the wild horses is inhumane.  The horses are terrified by the thunderous, high-intensity noise as they are pursued by the low-flying helicopter.  They are blasted with sand, dirt, and gravel from the rotor wash.  Panicked by the chaos, they stampede, injure themselves, and become separated from their babies and bandmates.  Mares miscarry.  Foals become orphans.  Many horses die from stress, even more have to be euthanized.  Helicopter-style roundups are abusive, especially to foals, older horses, and pregnant mares.  This is unacceptable.

Recommendations:  Helicopter-style roundups must be abolished.  Roundups in extreme temperatures — either the summer heat or the winter cold — must end.  Stampeding horses for countless miles — causing them to lather with sweat and then bringing them to an abrupt halt — must be prohibited.  Forcing the horses to run long distances over rough terrain, thereby wrecking the delicate hooves of the newborns and resulting in lameness and even death — must never happen again.

BoLM should institute the kind approach to gathering wild horses.  Roundups should be done slowly, quietly, and gently using the bait-and-water trapping approach.  This method also tends to preserve family unity, which is essential to wild-horse social structure.

Abusive Behavior by Helicopter Pilots during Gathers

As has been documented on video, helicopter-pilots conducting roundups become frustrated by horses’ lack of cooperation.  Impatient to get the animals moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the creatures 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 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

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 BoLM officials present did nothing to stop the abuse.  What’s more, this cruelty took place in plain view of observers holding video cameras.  Imagine what went on out of sight and off camera.

HELICOPTERS — Dangerous to the Environment

Possibility of a Post-Crash Fire’s Leading to a Wildfire

The crash of a roundup-helicopter could result in a fuel-spill.  Especially in these times of drought, when there is an abundance of dry brush, a wildfire could be sparked.  Thus, even the environment is at risk from the use of helicopters to round up wild horses.  It bears repeating that, because herd management areas are typically in remote locations, it would be difficult to put out a post-crash fire and keep it from getting out of control.

CONCLUSIONS

1.  RSFO should repudiate the arbitrary and corrupt Consent Decree.

2.  RSFO’s Field Manager should stop making seditious announcements, leading rogue ranchers to believe that public lands are private and emboldening them to break the law, putting public safety at risk.

3.  RSFO should select either Alternative A — No Action, or Alternative C — Removal-and-Return.

———————————————-

Sincerely,

Marybeth Devlin

6880 SW 27th ST

Miami, FL 33155-2916

marybethdevlin@bellsouth.net

305  665-1727

———————————————-

References:

§ 1334. Private maintenance; numerical approximation; strays on private lands; removal; destruction by agents THE WILD FREE-ROAMING HORSES AND BURROS ACT OF 1971 (PUBLIC LAW 92-195) Retrieved from

18 U.S. Code § 2383 – Rebellion or insurrection.  Cornell University Law School.  Retrieved from https://www.law.cornell.edu/uscode/text/18/2383

18 U.S. Code § 2384 – Seditious conspiracy.  Cornell University Law School.  Retrieved from https://www.law.cornell.edu/uscode/text/18/2384

American Wild Horse Preservation Campaign.  (2016, August-September)  BLM Wyoming Wild Horse Wipeout Continues – Action Needed Today!  Retrieved from http://act.wildhorsepreservation.org/p/dia/action3/common/public/?action_KEY=23543

Public corruption.  Definition.  Cornell University Law School.  Retrieved from https://www.law.cornell.edu/wex/public_corruption

Romboy, Dennis.  (2015, December 18)  “Judge sentences San Juan Commissioner Phil Lyman to 10 days in jail, 3 years of probation.”  Deseret News.  Deseret Digital Media.  Retrieved from http://www.deseretnews.com/article/865643995/Judge-sentences-San-Juan-Commissioner-Phil-Lyman-to-10-days-jail-3-years-of-probation.html?pg=all

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.




Fraudulent figures, sterilization and underpopulation

PM Burros Wild 2 © Carl Mrozek

To:  Heather van Blokland at KJZZ

Rio Salado College and Maricopa Community College, Arizona

I am emailing you directly because comments cannot be posted to your article.

http://kjzz.org/content/360434/feds-look-solution-wild-horse-burro-overpopulation

First, let me commend you for correctly identifying PZP as a “sterilization drug.” The Bureau of Land Management (BoLM) and the Humane Society of the United States (HSUS) both like to refer to it as “birth control,” but PZP is actually a sterilant.  More on that later.  The reason for my email is to alert you that BoLM has given you false information regarding the wild horses and burros.

While a reporter or any member of the public should be able to secure accurate data from government agencies, BoLM’s data is fraudulent as concerns wild horses and burros.  BoLM is aggressively pursuing a disinformation campaign against the mustangs, concocting a crisis that does not exist, and using scare-tactics to secure increased funding for itself.  Let me now address certain points cited in your article.

Herd-growth rates:  Equids are slow-growth species when it comes to reproduction. The gestation period for horses lasts 11 months, and a mare produces just 1 foal.  The gestation period for burros lasts 12 to 14 months, and a jenny is less fertile than a mare.  While an independent study of BoLM’s records did confirm an almost 20% birth rate for wild-horse herds, and an almost 15% birth rate for wild-burro herds, the study also found that 50% of foals perish before their first birthday.  Thus, the effective increase in population from new foals is just 10% for wild horses and 7% for wild burros.  Adult mustangs also die.  They succumb to illness, injury, and predation at a rate of at least 5% a year. So, what is a normal herd-growth rate?  Around5% for wild horses and about 2% for wild burros, probably less in each case.  Thus, a herd could not double every four years — that’s just BoLM propaganda.

Fraudulent figures:  There is no overpopulation except on BoLM’s falsified spreadsheets.  Reviews of the agency’s population-estimates reveal biologically-impossible herd-growth rates.  For instance, in Arizona, BoLM reported that the Big Sandy herd grew from 250 burros to 754 burros in one year, a 202% increase.  In Nevada, BoLM would have us believe that the Lava Beds herd grew from 40 burros to 350 burros in one year, a 775% increase.  In Wyoming, BoLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase.  The agency’s “data” is chock-full of such preposterous growth-estimates.  So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that the numbers have been falsified.

Wild horses and burros are underpopulated:  Per the guidelines of BoLM’s own geneticist, 83% of the wild-horse herds and 90% of the wild-burro herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP).  Low AMLs enable BoLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP.  For instance, the AML for Arizona’s Black Mountain herd was set at 382 to 478 wild burros.  The Black Mountain Herd Management Area comprises 925,425 acres, or 1,446 square miles.  Thus, per the AML, BoLM implies that each burro needs 1,936 to 2,423 acres, or about 3 to 4 square miles per burro.  If BoLM projects there to be 2 burros per 3 square miles, the agency declares an “overpopulation” because there is “double the number” that the AML allows.  As you can see, being “over AML” is meaningless as well as misleading.  But the low AMLs, combined with falsified, biologically-impossible herd-growth estimates, give BoLM an excuse to scapegoat those few wild horses and burros for the range-damage done by the millions of livestock that overgraze the public lands.

Adoptions:  Have not declined — let alone “disappeared” — contrary to what BoLM led you to believe.  It’s just that BoLM used to count the thousands of sales-for-slaughter as “adoptions.”  Now that only true adoptions — “forever-family” placements — qualify, it just seems as if the number has declined.  However, wild horses are not homeless horses.  They have a home — where they belong — on the range.

HSUS:  Is the registrant of PZP / ZonaStat-H with the Environmental Protection Agency.  Thus, HSUS’ information is not impartial because the organization has its reputation to protect.  Further, HSUS has submitted a proposal for a multi-year project in which BoLM would pay for HSUS staff to experiment on Arizona’s burros via “opportunistic” darting with PZP.

Pesticide:  PZP is not just a sterilant but also a registered pesticide that was approved by the EPA for use on wild horses and burros “where they have become a nuisance.”   However, PZP was registered without the standard testing requirements.  There is currently a lawsuit challenging the legitimacy of the registration, especially in light of new studies that have disclosed PZP’s many adverse side-effects.

Sterilizing mustangs:  PZP is a potent weapon in BoLM’s arsenal — for its biological warfare against the wild horses.  But population control for wild horses is unnecessary because there is no overpopulation.  Why would we contracept herds whose population is inadequate for genetic viability?  Why would we contracept herds based on falsified figures?  Logically we wouldn’t and ethically we shouldn’t.  Further, if PZP were going to stop the roundups, it would have done so long ago for the famous Pryor Mountain herd, home to Cloud, the stallion who was the subject of a number of documentaries that aired on PBS.  The Pryor Mountain mares have been darted with PZP for nearly two decades.  Yet roundups have been scheduled there like clockwork every 3 years and, in spite of intensifying the PZP treatments recently, BoLM tried to implement yearly roundups until stopped by a Friends of Animals lawsuit.

PZP — the anti-vaccine:  PZP causes disease — auto-immune disease.  PZP “works” by tricking the immune system into producing antibodies that target and attack the ovaries.  The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles.  The mare’s estrogen-levels drop markedly as PZP destroys her ovaries.  Ultimately, PZP sterilizes her.  Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function.  Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries.  But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed.  Those mares fail to respond to PZP.  They keep getting pregnant and producing foals who, like their dams, suffer from weak immune-function.  So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised.  Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.

Health-risks to volunteers:  As for the well-meaning volunteers who dart wild horses, EPA’s Pesticide Fact Sheet for PZP advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure.  EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility.  Unfortunately, PZP’s manufacturer misrepresented PZP as “so safe it is boring.”   But research shows that PZP is a powerful hormone disruptor.  Further, consider the magnitude of the risk — the PZP-in-question is a horse-sized dose.  If volunteers think PZP is safe, they will be less likely to protect themselves from this dangerous pesticide.

Mengelian experiments:  The Big Lie of “overpopulation” is the pretext for BoLM’s war against the wild horses, and the wild horses are prisoners of that war.  It’s BoLM’s version of the “Shock Doctrine,” wherein the agency concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People.  Now, BoLM is funding surgical-sterilization studies on the equine POWs to develop a Final Solution to the “problem” — handing out $11 million for these diabolical experiments.  The grant money is surely intended to buy loyalty and silence potential criticism from academia.  Plus, BoLM, a corrupt, rogue agency, gets to cloak itself in respectability by affiliating with prestigious universities.

Should you wish to learn more about how BoLM is mismanaging Arizona’s wild burros, I would be happy to send you a copy of comments recently submitted.  Just let me know.

Sincerely,

Marybeth Devlin

Miami, FL

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.




Yellow journalism in Wall Street Journal pushing pesticide as “birth control” on wild horses?

Pm PZP Darts

Made with slaughterhouse pig ovaries PZP is dangerous to herd health

To:  Jacob Bunge, Wall Street Journal

Dear Mr. Bunge:  Regarding your article — They Shoot Horses (With Birth-Control Darts), Don’t They? — here are facts to correct the lies and disinformation you have been told.

Sting of the dart:  If it were only a sting!  Fact: Many wild horses develop an abscess at the dart-injection site.

Bogus ballooning population:  Wild horses are a slow-growth species when it comes to reproduction.  The gestation period lasts 11 months, and a mare produces just 1 foal.  While an independent study of BLM’s records confirmed an almost 20% birth rate, that study also found that 50% of foals perish before their first birthday.  Thus, the effective increase in population from new foals is just 10%.  But adult mustangs also die.  They succumb to illness, injury, and predation at a rate of at least 5% a year.  So, what is a normal herd-growth rate?  About 5%, probably less.

Fraudulent figures:  The Big Lie of “overpopulation” is the pretext for BLM’s war against the wild horses, and the wild horses are prisoners of that war.  It’s BLM’s version of the “Shock Doctrine,” wherein BLM concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People.  There is no overpopulation except on BLM’s falsified spreadsheets.  Reviews of BLM’s population-estimates reveal biologically-impossible herd-growth rates.  For instance, in Utah, BLM claimed that the Conger herd grew from 156 horses to 285 horses in one year, an 82.7% increase, to which BLM tacked on another 20% by counting the unborn foals — the fetuses.  In Wyoming, BLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase.  BLM’s “data” is chock-full of such preposterous growth-estimates.  So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that BLM has falsified the data.

Wild horses are underpopulated:  Per the guidelines of BLM’s own geneticist, 83% of the herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP).  Low AMLs enable BLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP.  So being “over AML” is meaningless as well as misleading.  But the low AMLs, combined with falsified, biologically-impossible herd-growth estimates, give BLM an excuse to scapegoat those few wild horses for the range-damage done by the millions of livestock that overgraze the public lands.

Whose grass?  In fact, it is the livestock who are eating the wild horses’ grass.  Some background — the dedicated wild-horse habitats cover only 11% of BLM land.  Cattle are allowed to graze about 5 times that much, including within all but 4 of the wild-horse herd areas.  Yet in those official wild-horse habitats where livestock are given allotments, the mustangs are restricted to 18% of the forage while the cattle get 82%.

Bogus billion:  The wild horses being held in captivity are the “legacy” of former Secretary Salazar’s equid cleansing era, during which he had thousands of wild horses removed from the range.  However, the mortality rate of captive wild horses is about 8% a year.  So, obviously, since they are not reproducing, their numbers will steadily drop, showing that BLM’s billion-dollar figure for their care is just another Lie.  The Wild Horse and Burro program, if run per the minimum-feasible management-model specified by Law, would not cost much at all.  BLM does not lack for resources.  There are 22 million acres of legally-designated wild-horse herd areas — which BLM previously took away for expediency — that can be reopened as habitat.  The horses now held captive can be released to those areas, where the cost of their upkeep will be $0.

Adoptions:  Have not declined.  It’s just that BLM used to count sales-for-slaughter as “adoptions.”  Now, only “forever-family” placements qualify.  However, wild horses are not homeless horses.  They have a home — where they belong — on the range.

Persecuted predators:  Contrary to BLM’s disinformation campaign, wild horses do have natural predators — mountain lions, bears, wolves, and coyotes.  But those predators are persecuted mercilessly.  The government exterminates what the hunters don’t shoot.  However, the International Society for the Protection of Mustangs and Burros — Wild Horse Annie’s foundation — notes that even without predators, wild-horse herds self-regulate their numbers, with population-growth in the single digits.

Science and Conservation Center:  Is the manufacturer and distributor of PZP / ZonaStat-H.  Thus, its information is not impartial.  PZP is a registered pesticide that was approved by the EPA for use on wild horses and burros “where they have become a nuisance.”   However, PZP was registered without the standard testing requirements.  There is currently a lawsuit challenging the legitimacy of the registration, especially in light of studies that have disclosed PZP’s many adverse side-effects.

Shooting wild horses:  PZP is a potent weapon in BLM’s arsenal — for its biological warfare against the wild horses.  But birth control for wild horses is unnecessary because there is no overpopulation.  Why would we contracept herds whose population is inadequate for genetic viability?  Why would we contracept herds based on falsified figures?  Logically we wouldn’t and ethically we shouldn’t.  Further, if PZP were going to stop the roundups, it would have done so long ago for the Pryor Mountain herd, which has been darted with PZP for nearly two decades.  Yet roundups have been scheduled there like clockwork every 3 years and, in spite of intensifying the PZP treatments recently, BLM tried to implement yearly roundups until stopped by a Friends of Animals lawsuit.

PZP — the anti-vaccine:  PZP causes auto-immune disease.  PZP “works” by tricking the immune system into producing antibodies that target and attack the ovaries.  The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles.  The mare’s estrogen-levels drop markedly as PZP destroys her ovaries.  Ultimately, PZP sterilizes her.  Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function.  Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries.  But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed.  Those mares fail to respond to PZP.  They keep getting pregnant and producing foals who, like their dams, suffer from weak immune-function.  So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised.  Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.

Health-risks to volunteers:  As for the well-meaning volunteers who dart wild horses, EPA’s Pesticide Fact Sheet for PZP advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure.  EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility.  Unfortunately, PZP’s manufacturer has misrepresented PZP as “so safe it is boring.”   But research shows that PZP is a powerful hormone disruptor.  Further, consider the magnitude of the risk — the PZP-in-question is a horse-size dose.  If volunteers think PZP is safe, they will be less likely to protect themselves from this dangerous pesticide.  Indeed, please note that in the photo accompanying your article, Ms. Bolbol is not in compliance with EPA’s safety-precautions.  She is not wearing the required protective gear.

Mengelian experiments:  Now, BLM wants to perform diabolical sterilization experiments on these equine POWs to develop a Final Solution to the “problem”.  BLM is handing out $11 million for sterilization-studies.  The grant money is surely intended to buy loyalty and silence potential criticism from academia.  Plus, BLM, a corrupt agency, gets to cloak itself in respectability by affiliating with prestigious universities.

The ugly side of PZP is humane-washed by feel-good features that describe it with humor, sweetness and light.  However, the true story of PZP is one of scandal, whose deceit and danger — to both horses and humans — must be exposed.  That is the story that needs to be reported.

Sincerely,

Marybeth Devlin

 Marybeth Devlin is a member of the Protect Mustangs Advisory Board and a member of the Alliance for Wild Horses and Burros
This mare waits in the alley before being led into the chute where her age and body condition will be checked. After being treated with the PZP fertility control agent, this mare will be released back to the Owyhee HMA.

This mare waits in the alley before being led into the chute where her age and body condition will be checked. After being treated with the PZP fertility control agent, this mare will be released back to the Owyhee HMA.

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.




Conflict of interest, wild burros and pesticide PZP

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

(Photo Credit Rylee Isitt/WikiCommons)

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

Postmarked or Received by:

August 15, 2016

To:

BLM-Arizona

State Office

Colorado River District Office

Kingman and Lake Havasu Field Offices

Copies to:

CEQ, DOI, and BLM National Office

with hard-copy via Priority Mail to:

Bureau of Land Management

Kingman Field Office

2755 Mission Boulevard

Kingman, AZ  86401

Subject: Black Mountain Wild Burros

Project: PZP Fertility-Management Pilot

Proposed by: Humane Society of the United States

Document: Environmental Assessment ( EA )

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

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

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

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

BACKGROUND

The Proposal

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

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

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

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

Annual Roundups Probable

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

CONFLICTS OF INTEREST

HSUS — PZP’s Registrant

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

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

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

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

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

Mandate to Practice Scientific Integrity

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

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

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

FALSE PREMISES, FRAUDULENT NUMBERS

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

False Premise #1 — Lack of Predators

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

Healthy Predators, Healthy Ecosystem

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

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

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

Predator Reintroduction

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

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

False Premise #2 — High Reproductive Rate

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

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

Herd-growth rate Birth rate

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

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

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

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

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

Fraudulent Numbers

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

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

Fraudulent Estimates

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

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

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

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

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

    (1)     (2)     (3)

DeviationDeviationDeviation

from 15% from 7%             from 2%

per BLMper Studyper Study

without without with 5%

Foal orAdult Adult

PopulationGrowthAdult Mortality Mortality

Year Estimate Rate Mortality

2013   800   n/a    n/a    n/a    n/a

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

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

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

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

Arbitrary Management Level (AML)

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

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

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

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

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

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

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

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

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

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

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

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

How Would the New Levels Look?

Here are some numbers to compare and contrast.

Black Mountain HMA

Size:  925,425  total acres

Current Maximum Management Level:   478  wild burros

Acres per burro:  1,936

Current Exaggerated Population Estimate: 1,551  wild burros

Acres per burro:     597

IUCN Minimum Herd Size: 2,500  wild burros

Acres per burro:     370

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

Acres per burro:     185

Genetic Health of the Black Mountain Burros

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

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

The correct sampling approach and order are:

Sample current and continuing herd members.

Sample first, before considering any actions.

Sample large — 100 percent.

Test samples.

Manage per test-results and best-available science.

PZP — ADVERSE EFFECTS

PZP — The Pesticide

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

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

PZP — an Anti-Vaccine

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

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

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

PZP’s True Mode-of-Action

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

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

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

Included as a reference to the EA?  No.

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

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

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

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

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

Included as a reference to the EA?  No.

PZP Causes Ovarian Cysts

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

Included as a reference to the EA?  No.

PZP    Endocrine Disruptor    Elevated Testosterone    Masculinizing Effects   

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

PZP    Ovarian Cysts    Elevated Testosterone    Masculinizing Effects

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

PZP Causes Additional Adverse Effects

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

PZP Selects for Weak Immune Function

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

PZP Confers Dubious “Benefit” of Increased Longevity

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

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

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

Stillbirths;

Altered ovarian structure and cyclicity;

Interference with normal ovarian function;

Permanent ovarian damage; and

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

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

Included as a reference to the EA?  No.

Stillborn Foals — Recent Stillbirths Correlated with PZP

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

Included as a reference to the EA?  No.

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

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

Included as a reference to the EA?  No.

Why Do PZP-Treated Mares Steal Foals?

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

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

Foal-Stealing — Hormonal Hypothesis

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

Who is close to giving birth or

Who is separated from her own neonate or

Whose foal has recently died.

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

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

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

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

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

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

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

Included as a reference to the EA?  No.

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

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

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

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

A prolonged breeding season and

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

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

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

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

Included as a reference to the EA?  No.

Prolonged Delay in Recovery of Fertility

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

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

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

Ransom Advises Proceeding with Caution regarding PZP

The Ransom et al. study warned:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Included as a reference to the EA?  No.

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

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

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

PZP Continues the Use of Roundups and Removals

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

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

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

  

Risks to Humans Who Administer PZP Injections

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

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

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

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

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

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

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

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

Mandate to Practice Scientific Integrity

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

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

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

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

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

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

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

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

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

PZP — Conclusions about

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

ADDITIONAL CONCERNS AND INFORMATION

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

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

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

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

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

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

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

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

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

Bighorn Sheep — Study Shows No True Competition from Burros

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

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

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

Facilitation and Commensalism — Equids Enhance Livestock Production

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

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

Symbiosis — Burros Graze Old Growth — Cattle Prefer New Growth

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

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

ESTHETICS UGLIFIED VISITOR-EXPERIENCE RUINED

Scarlet Letters

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

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

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

Recreation and Wild Burro Viewing

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

Sincerely,

Marybeth Devlin


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




REFERENCES

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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




Protect the wild horses in Modoc National Forest from a brutal helicopter roundup ~ Put up a fence!

PM UFS Devils Garden

By Marybeth Devlin

It is good to know that the US Forest Service is promoting adoptions of wild horses. However, no roundup should occur.

Inadequate Population of Wild Horses in Devil’s Garden

The International Union for the Conservation of Nature recommends a minimum-viable population (MVP) of at least 2,500 for a wild-horse herd. The arbitrary management level (AML) for the wild horses of The Garden — 206 to 402 — is way-below MVP. The AML implies that each wild horse needs 578 to 1,129 acres. But how many acres does BLM estimate each cow or calf needs? Answer: 38 acres. So, absolutely, The Garden’s 232,500 acres could support 2,500 horses at 93 acres per horse. I further note that it was USFS who split the horses’ habitat into 2 sections and, in so doing, took away 25,500 acres, which were then given over to commercial livestock, which already had many more grazing slots than the horses. Indeed, USFS allows nearly 4,000 cattle to graze in The Garden, where the horses are supposed to, by law, have principal use.

Costs and Method

Spending $600,000 on a helicopter roundup is a waste of taxpayer money, especially because there is a better way. Modoc National Forest Office declared that it had all the necessary equipment on hand to conduct bait-trapping operations in a humane manner. Therefore, the bait-trapping method should be used — when the herd substantially exceeds the IUCN guidelines for MVP. Bait-trapping is the cost-effective and humane technique.

Helicopters, in contrast, pose risks to both humans and horses. Their crash-record is high, with numerous fatalities. Using helicopters to chase wild horses is inhumane, especially in The Garden, where the landscape has been described as “… brutal for gathering. Dense stands of Western Juniper and many rocky outcropping make this landscape one of the most difficult places in the country to gather wild horses.”

Dealing with Roving Equids

Horses will roam. It is their nature. Surely, that’s why the Law is known as the Wild and Free-Roaming Horses and Burros Act. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered into onto private and Tribal lands just creates a vacuum for other horses to fill. Thus, removing them is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs. The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant. Thus, removal is not a true solution. Instead, it perpetuates the problem and leads to the removal of more mustangs, a costly and unnecessary recurring action. More unfairly, the wandering equids may be only temporary visitors, not permanent residents. Worse yet, they may be driven out of their habitat by a profit-motivated helicopter pilot eager to “make his numbers.”

Prevention First

USFS and BLM should implement preventive measures to keep wild horses home in their habitat. Fence The Garden’s perimeters — after correcting all boundary-line discrepancies, making sure migration corridors are open, and restoring any herd-area land previously taken away. Next, address those factors that allowed the animals to leave home. For instance: Do fences need repair? It would be more effective for USFS and BLM to pay for new fences than to pay for a helicopter-gather. Removing wild horses will not mend fences.

 Marybeth Devlin is on Protect Mustangs’s Advisory Board and is a member of the Alliance for Wild Horses and Burros

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




Outrage over pro-kill, anti-mustang article in today’s Economist

PM Economist Billions Spin Article

Today The Economist published an article titled America is set to spend billions on taming its growing wild-horse population with fake projected costs in the multi-billions for shock value and pro-kill, pro-slaughter, pro-sterilization undertones. It’s clear the media piece goes beyond yellow journalism and was placed in the economist by a PR firm paid for by public land-grabbers who hate wild horses. Otherwise, how could such an article, filled with outrageous errors and lack of facts, get into the publication?

The $1 billion figure that BLM claims it would cost to care for the wild horses held in captivity has ballooned.  Keep in mind that in an article posted in the Rawlins Times, BLM inflated that number to $2.3 billion — 230% times the original number.
In today’s Economist.com article, the $2.3 billion has swelled to $4.6 billion — 200% times higher still.

This “article” is trying to put pressure on Congress to kill or sterilize America’s beloved wild horses. The motives are clear.

Marybeth Devlin, Protect Mustangs Advisory Board member and member of the Alliance for Wild Horses and Burros wrote the following in the comment section. Let’s hope people will read the facts:

“The Big Lie of “overpopulation” is the pretext for BLM’s war against the wild horses. It’s BLM’s version of the “Shock Doctrine,” wherein BLM concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People.

In fact, horses are a slow-growth species when it comes to reproduction. The gestation-period lasts over 11 months, and a mare produces just 1 foal. While an independent study of BLM’s records did confirm a nearly 20% birth rate, that study also found that 50% of foals perish before their first birthday. Thus, the effective increase in population from new foals is just 10%. However, adult mortality must also be taken into consideration. Adult mustangs succumb at a rate of at least 5% a year. So, what is a normal herd-growth rate? Around 5%, probably less. Thus, a herd could not double in 4 or 5 years, debunking another BLM falsehood. But BLM stealthily inserts herd-growth rates far higher than 20% in its reports — biologically-impossible herd-growth rates. For instance, in Wyoming, BLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase. BLM’s “data” is chock-full of preposterous growth-estimates. So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that BLM has falsified the data. You should also know that the National Academy of Sciences was required by the terms of its grant to draw conclusions per BLM’s figures — the falsified figures. The NAS was not allowed to collect data independently. Thus, BLM wired the results to confirm its lies.

Wild horses are underpopulated. Per the guidelines of BLM’s own geneticist, more than 80% of the herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP). Low AMLs enable BLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP. So being “over AML” is meaningless as well as misleading. But those low AMLs, combined with fraudulent, biologically-impossible herd-growth estimates, give BLM an excuse to scapegoat those few wild horses for the range-damage done by the millions of livestock that overgraze the public lands.

PZP is a potent weapon in BLM’s arsenal — for its biological warfare against the wild horses. PZP is a registered pesticide. Its mechanism-of-action is to cause auto-immune disease — tricking the immune system into producing antibodies that target and attack the ovaries. The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. The mare’s estrogen-levels drop markedly as PZP destroys her ovaries. Ultimately, PZP sterilizes her. A recent study — which included the McCullough Peaks herd — found that PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.

As for the wild horses held in captivity, they are the “legacy” of former Secretary Salazar’s equid cleansing era, during which he had tens of thousands of wild horses removed from the range. However, the mortality rate of captive wild horses is about 8% a year. So, obviously, since they are not reproducing, their numbers will steadily drop, showing that BLM’s billion-dollar figure for their care was bogus — it was just another Lie. But that Lie has ballooned. BLM has taken the $1 billion figure that it originally announced, multiplied it by 230%, and then multiplied that number by another 200%, amplifying the fraud. When BLM lies, it lies Big.

The Wild Horse and Burro program, if administered per the minimum-feasible management-model specified by Law, would not cost much at all. BLM does not lack for resources. There are 22 million acres of legally-designated wild-horse herd areas — which BLM previously took away for political expediency — that can be reopened as habitat. The horses now held captive can be released to those areas, where the cost of their upkeep will be $0.

Contrary to BLM’s disinformation campaign, wild horses do have natural predators — mountain lions, bears, wolves, and coyotes. But those predators are persecuted mercilessly. The government exterminates what the hunters don’t shoot. However, the International Society for the Protection of Mustangs and Burros — Wild Horse Annie’s foundation — notes that even without predators, their wild-horse herds self-regulate their numbers, with population-growth in the single digits.

Finally, adoptions have not declined. It’s just that BLM used to count sales-for-slaughter as “adoptions.” Now, only “forever-family” placements qualify. However, mustangs are not homeless horses. They are wild horses whose home is on the range.”

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



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

PM PZP Injection

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

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

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

Worse yet, Sacco et al. (1981) found that PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring. This is bad news because BLM regularly administers PZP to pregnant and lactating mares, who transfer the destructive antibodies to their filly-foals. Thus, the fillies get their first treatment with PZP in utero, while nursing, or both.

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

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

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

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

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

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

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

~ Marybeth Devlin, Wild Horse Advocate

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




Smear campaign launched to coerce voices against cruel experiments on pregnant mares

PM Val Set Me Free

“After coming out strongly against the Feds funding $11 million for cruel population control experiments on pregnant mares, we are under attack from those who push for experiments and population control. Members of BLM support groups on Facebook have intensified their slander, online-bullying and stalking to the point of trespassing and breaking the law to further their campaign of hate. These people want to manage America’s wild horses to extinction.” –Anne Novak, Executive Director of Protect Mustangs

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