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.
“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.
EXPANDED SUMMARY OF PZP’S ADVERSE EFFECTS, INCLUDING REFERENCES
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 ….” [20]
Some persons argue that, because PZP does not kill the mare, it is not really a “pesticide.” Actually, PZP does kill. As will be documented in this report, its use is associated with stillborn foals. In the long term, PZP will 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 is an anti-vaccine.
PZP’s Mode of Action as Stated in the Pesticide Registration Is a Disproved Hypothesis
The registrant of PZP advised the Environmental Protection Agency (EPA) 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. [7 and 13]
PZP’s True Mode-of-Action
So how does PZP really work? PZP tricks the immune system into waging 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.” [5] [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, oophoritis (inflammation of the ovaries), destruction of oocytes in all growing follicles, and depletion of resting follicles. The manufacturer of PZP as well as Bureau of Land Management (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.
PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion
In a telling study published back in 1992, the 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.” [6] Thus, 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. [21] 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 23 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and endocrine-disruptor side-effects.
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).” [4] 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.
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: Unnatural behavior.
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. [12 and 22] 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 boasts 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. [10] Many of these findings were confirmed by Kaur & Prabha as well as by Gray & Cameron. Please keep in mind these key findings: Stillbirths, and auto-immune oophoritis.
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, 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. [18]
Autoimmune Oophoritis Induced by PZP
Research by the Rose-Cihakova-Caturegli Laboratory at Johns Hopkins Pathology found: “Automimmune oophoritis can be induced by immunization with testis and ovarian antigen murine human zona pellucida 3 peptide (pZP3) in adjuvant.” [16] Here again, is causation of autoimmune disease by a ZP-type product. This finding confirms other research cited herein.
Autoimmune Oophoritis and Risk of Other Autoimmune Diseases
A study by Varras et al. disclosed that, in humans, autoimmune oophoritis carries the risk of the patient developing other autoimmune diseases. [23] The correlation between autoimmune oophoritis and subsequent other autoimmune disorders weighs against injecting fillies and mares with PZP repeatedly and en masse.
Prolonged Breeding Season, Unusually-late Parturition Dates with PZP
Nettles’ meta-analysis on PZP disclosed other 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 (Ransom et al. 2013) of three herds currently being managed by PZP — Little Book Cliffs, McCullough Peaks, and Pryor Mountain — found that the the parturition season lasted 341 days. [15] Ransom et al.’s finding of a nearly year-round birthing season supports the earlier finding by Nettles. 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.
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 describes 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 six-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 eight years to recover fertility after just three consecutive PZP treatments. [13]
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.” [15]
Because BLM keeps over 70 percent of the herds at levels below minimum-viable population (MVP), most herds qualify as “small refugia.” Pryor Mountain WHR is a small, isolated refuge, and its wild horses carry genes with rare alleles.
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 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 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.
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. [9]
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. [1] And as we shall see later in this report, that first shot of PZP may not be their first shot of PZP.
Researchers Again Express Concerns about the Abnormal Life-Spans of Sterilized Mares
Knight & Rubenstein 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.
PZP’s Destructive Antibodies Are Transmitted via the Placenta and Mother’s Milk
It gets worse. Sacco et al. reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. [17] These findings were disclosed in 1981. 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. [7 and 13] 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.
Recall again the Pryor Mountain fillies. If their dams were injected with PZP while pregnant or nursing, such fillies will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when those same fillies are injected at age 1½, 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.
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. [14]
Imagine if such a catastrophe were to befall the Pryor Mountain horses, whose herd-immunity is being eroded by PZP. Note that the Saiga deaths involved antelope-mothers and their calves. If Pryor Mountain’s few fertile mares and their foals perished all of a sudden, that would leave just stallions and sterile old mares. The herd would be composed of the living dead, reproductively speaking, its rare alleles extinguished. BLM is failing to proactively manage the Pryor Mountain herd with stochastic events taken into consideration. That is 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 remove “excess” wild horses from the range — 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 three years, the latest one in 2015.
Risks to Humans Who Administer PZP Injections
For 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. [20]
However, EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform pregnant women 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 warn 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 warn all women of the risk of ovarian dystrophy, oophoritis, ovarian cysts, 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 fail to emphasize the magnitude of the risk — the PZP-in-question is a horse-size dose.
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.” [19]
BLM has ignored and suppressed independent scientific findings about PZP’s adverse effects and unintended consequences. Instead, BLM continues to rely almost exclusively on the manufacturer’s claims — shown and known to be false — regarding PZP’s safety for use on horses and for handling by humans. BLM is thus non-compliant with the Policy and malfeasant in its responsibilities to protect staff, volunteers, and the wild horses under its jurisdiction. BLM is also misleading and disinforming Congress and the American public about the PZP pesticide.
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 independent researchers whose findings did not fully support his claims. Indeed, he recently submitted an Op-ed to The Salt Lake Tribune wherein he belittled the research of fellow scientists whose studies on PZP yielded results somewhat different from his own. [8] 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. [11] The manufacturer also disparaged members of the public — one of whom was a member of the Pennsylvania Game Commission — who 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.” [7] By these actions, the manufacturer violated the DOI’s Code of Scientific and Scholarly Conduct.
PZP Manufacturer Misled Trainees into Believing that PZP Was Safe
BLM staff and volunteers receive their training from PZP’s manufacturer in how to handle and administer the pesticide. BLM is 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.
First, the manufacturer has been quoted as saying that PZP is “so safe it is boring.” [3] 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 advocates are lulled into complacency, trusting that PZP is harmless to the Pryor Mountain horses and their rare genetic alleles. 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.” [2] Key words: “no side effects.” It is disturbing that a person who was, no doubt, motivated by a desire to help the horses has been disinformed regarding PZP’s safety-hazards to humans as well as to horses.
BLM Fails to Maintain Proper Supervision of the PZP Volunteers
The issue of safety is not the only concern. As BLM has admitted, volunteers darted the wrong mares on Pryor Mountain. These errors evidence that BLM has failed to maintain supervisory control over the volunteer-inoculators, allowing them to conduct the PZP-darting by themselves. The mistakes further evidence that the volunteers do not understand what is expected of them. Who can say whether other procedures were not complied with either. The fact that mares were darted who were ineligible for PZP per the then-current protocol, but who would be eligible under the proposed-but-not-yet-promulgated new “prescription,” suggests that the volunteers may have concluded — from BLM’s open contempt for the Constitution and disrespect for the NEPA process — that was okay for them to start darting otherwise-ineligible mares right away. Not surprisingly, BLM blames the volunteers for these mistakes, but probably has not informed them that they are being made to take the rap for management’s shortcomings.
Conclusions
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. BLM’s continuing to use PZP while ignoring and suppressing the evidence of its harmful effects constitutes malfeasance.
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This report was completed by Marybeth Devlin on December 24, 2015. Copyright Marybeth Devlin and Protect Mustangs 2015.
4. 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 at http://www.reproduction-online.org/content/139/1/45.full
5. 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
6. 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
7. 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
9. 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
10. Nettles, Victor F. (1997) Potential consequences and problems with wildlife contraceptives. Reproduction, Fertility and Development 9(1) 137 – 144. Retrieved from http://www.publish.csiro.au/paper/R96054.htm Accessed full pdf text via purchase of a copy from Csiro Publishing.
13. 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
15. 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
17. 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
18. 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
19. United States Department of the Interior. Integrity of Scientific and Scholarly Activities Policy. Code of Conduct. Retrieved from https://www.doi.gov/scientificintegrity
23. Varras M, Anastasiadis A, Panelos J, Balassi E, Demou A, Akrivis CH. (2013) Autoimmune oophoritis: Clinical presentation of an unusual clinical entity. OA Case Reports 2013 Jan 31;2(1):7. Retrieved from http://www.oapublishinglondon.com/article/369#
www.ProtectMustangs.org
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.
PZP is an immunocontraceptive and pesticide which causes an immune reaction to reject fertilization, while the females still come into estrus. Besides wrecking havoc on the immune system, injecting herds with PZP results in more fighting between males and many other behavior abnormalities.
Tule elk in Pt. Ryes National Seashore (Marin County, California) were part of a PZP (Porcine Zona Pellucida) experiment. Several years later there was a strange die-off.
Wildlife groups blamed park service management for leaving the elk fenced in during a drought–claiming that was the reason for the die-off.
Park service officials said the tule elk had water during the die-off.
“Some wildlife advocates have termed the situation a “die-off” and accuse the park service of allowing the elk to perish behind the fence that prevents them from finding enough food and water. Park service officials have a different view of what caused the population drop, and are hoping that new data will help address these concerns, especially as visitor interest peaks during the fall rutting season.” from: https://baynature.org/articles/on-the-fence/
Listen to Wildlife Ecologist Dave Press Discusses Tomales Point Elk and mention “there was water in the pond up there . . .” at 2:18.
It’s time to connect the dots and ask the obvious question: Did PZP lower the herds’ immune system and genetic diversity to the point of making them vulnerable to a die-off?
With suspect data regarding the long-term use of PZP on wild herds, more questions and answers are needed to prevent a similar die-off in America’s wild horses & burros.
With regards to wild horses, keep in mind what Marybeth Devlin wrote about PZP:
“PZP is a registered pesticide whose mechanism-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that target and attack the ovaries. PZP’s antibodies cause the mare to suffer ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. Not surprisingly, estrogen levels drop markedly as the ovaries are slowly destroyed. But PZP’s adverse effects are not limited to the individual animal. As a recent study — which included the Little Book Cliffs, Colorado herd and the McCullough Peaks, Wyoming herd — found, PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Further, the same study disclosed that the pesticide causes a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recover their fertility after suspension of PZP. However, some mares never recover — they are left permanently sterile, and quickly too. Indeed, yet another study found that sterility could occur in some mares from just three years of PZP injections or from just one treatment if the pesticide were given to a filly before she reached puberty. Because PZP messes with the immune system, it ironically works “best” — sterilizes faster — if the mare has a strong immune system. But, conversely, PZP may not work at all in mares whose immune function is weak or depressed. So, the pesticide discriminates against the very horses that Nature has best equipped for survival against disease while favoring and selecting for the immuno-compromised. Worse yet, tests performed via radioimmunoassay indicated that PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques.” [From: http://protectmustangs.org/?p=8529]
“Whenever an immune response is provoked, there is some risk of autoimmunity. Therefore immunocontraception trials typically check for signs of autoimmune disease.[17] One concern with zona pellucida vaccination, in particular, is that in certain cases it appears to be correlated with ovarian pathogenesis.[2] However, ovarian disease has not been observed in every trial of zona pellucida vaccination, and when observed, has not always been irreversible.[18]”
“Autoimmune diseases arise from an abnormal immune response of the body against substances and tissues normally present in the body (autoimmunity). . .”
“Earlier this year park service officials revealed that more than 250 tule elk died inside the fenced area over a two-year period, in part because pools that the herds rely on for water had gone dry. Meanwhile, ranchers are complaining about the free-range elk getting on their land and eating grass and drinking water intended for their dairy cattle and other agricultural operations.”
“Forty-five adult tule elk (Cervus elaphus nannodes) in good physical condition were translocated from a population located at Point Reyes National Seashore, Marin County (California, USA), to a holding pen 6 mo prior to release in an unfenced region of the park. Because infection with Mycobacterium avium subsp. paratuberculosis (Mptb) had been reported in the source population, the translocated elk underwent extensive ante-mortem testing using three Johne’s disease assays: enzyme linked immunosorbent assay (ELISA); agar gel immunodiffusion assay (AGID), and fecal culture. Isolation of Mptb was made from fecal samples in six of 45 elk (13%). All AGID results were negative while ELISA results for 18 elk (40%) were considered elevated. Elevated ELISA results or Mptb isolation from fecal samples were obtained for 22 of 45 elk (49%); these elk were euthanized and necropsied. Mycobacterium avium subsp. paratuberculosis was isolated from tissue in 10 of 22 euthanized elk (45%); of these 10 cases of confirmed infection, eight had elevated ELISA results (80%) and four were fecal culture positive (40%). One of 10 cases had histopathologic lesions consistent with Mptb infection. Mycobacterium avium subsp. paratuberculosis was also isolated from tissue from one of eight fetuses sampled. The number of tule elk found to be infected was unexpected, both because of the continued overall health of the source herd and the normal clinical status of all study animals.”
Mycobacterium avium subspecies paratuberculosis and Mycobacterium avium subsp. avium infections in a tule elk (Cervus elaphus nannodes) herd. 2006. http://www.ncbi.nlm.nih.gov/pubmed/17255437
Abstract
“Between 2 August and 22 September 2000, 37 hunter-killed tule elk (Cervus elaphus nannodes) were evaluated at the Grizzly Island Wildlife Area, California, USA, for evidence of paratuberculosis. Elk were examined post-mortem, and tissue and fecal samples were submitted for radiometric mycobacterial culture. Acid-fast isolates were identified by a multiplex polymerase chain reaction (PCR) that discriminates among members of the Mycobacterium avium complex (MAC). Histopathologic evaluations were completed, and animals were tested for antibodies using a Johne’s enzyme-linked immunosorbent assay (ELISA) and agar gel immunodiffusion. In addition, 104 fecal samples from tule elk remaining in the herd were collected from the ground and submitted for radiometric mycobacterial culture. No gross lesions were detected in any of the hunter-killed animals. Mycobacterium avium subsp. paratuberculosis (MAP) was cultured once from ileocecal tissue of one adult elk and was determined to be a strain (A18) found commonly in infected cattle. One or more isolates of Mycobacterium avium subsp. avium (MAA) were isolated from tissues of five additional adult elk. Gastrointestinal tract and lymph node tissues from 17 of the 37 elk (46%) examined had histopathologic lesions commonly seen with mycobacterial infection; however, acid-fast bacteria were not observed. All MAC infections were detected from adult elk (P = 0.023). In adult elk, a statistically significant association was found between MAA infection and ELISA sample-to-positive ratio (S/P) > or = 0.25 (P=0.021); four of five MAA culture-positive elk tested positive by ELISA. Sensitivity and specificity of ELISA S/P > or = 0.25 for detection of MAA in adult elk were 50% and 93%, respectively. No significant associations were found between MAC infection and sex or histopathologic lesions. Bacteriologic culture confirmed infection with MAP and MAA in this asymptomatic tule elk herd. The Johne’s ELISA was useful in signaling mycobacterial infection on a population basis but could not discriminate between MAA and MAP antibodies. The multiplex PCR was useful in discriminating among the closely related species belonging to MAC.
Between 2 August and 22 September 2000, 37 hunter-killed tule elk (Cervus elaphus nannodes) were evaluated at the Grizzly Island Wildlife Area, California, USA, for evidence of paratuberculosis. Elk were examined post-mortem, and tissue and fecal samples were submitted for radiometric mycobacterial culture. Acid-fast isolates were identified by a multiplex polymerase chain reaction (PCR) that discriminates among members of the Mycobacterium avium complex (MAC). Histopathologic evaluations were completed, and animals were tested for antibodies using a Johne’s enzyme-linked immunosorbent assay (ELISA) and agar gel immunodiffusion. In addition, 104 fecal samples from tule elk remaining in the herd were collected from the ground and submitted for radiometric mycobacterial culture. No gross lesions were detected in any of the hunter-killed animals. Mycobacterium avium subsp. paratuberculosis (MAP) was cultured once from ileocecal tissue of one adult elk and was determined to be a strain (A18) found commonly in infected cattle. One or more isolates of Mycobacterium avium subsp. avium (MAA) were isolated from tissues of five additional adult elk. Gastrointestinal tract and lymph node tissues from 17 of the 37 elk (46%) examined had histopathologic lesions commonly seen with mycobacterial infection; however, acid-fast bacteria were not observed. All MAC infections were detected from adult elk (P = 0.023). In adult elk, a statistically significant association was found between MAA infection and ELISA sample-to-positive ratio (S/P) > or = 0.25 (P=0.021); four of five MAA culture-positive elk tested positive by ELISA. Sensitivity and specificity of ELISA S/P > or = 0.25 for detection of MAA in adult elk were 50% and 93%, respectively. No significant associations were found between MAC infection and sex or histopathologic lesions. Bacteriologic culture confirmed infection with MAP and MAA in this asymptomatic tule elk herd. The Johne’s ELISA was useful in signaling mycobacterial infection on a population basis but could not discriminate between MAA and MAP antibodies. The multiplex PCR was useful in discriminating among the closely related species belonging to MAC.”
“. . . Funding for tule elk projects has come from a variety of sources. To date, monetary support and in-kind services for the tule elk project has been received from the Rocky Mountain Elk Foundation, Point Reyes National Seashore Association, Committee for the Preservation of Tule Elk, California Department of Fish and Game, The Humane Society of the United States (HSUS), University of California at Davis, the National Park Service Natural Resource Preservation Program and In Defense of Animals.” [Evidently Suzanne Roy, currently the Director of the American Wild Horse Preservation Campaign–who pushes PZP based management–was working for IDA at the time.]
“. . . During the second phase of the contraceptive research project, the first vaccine will be administered by direct syringe injection. To administer the injection, 30 elk will be captured from a helicopter and hobbled by ground crews. Scientists will gather data on the individual elk and place a radio collar on each of the elk. The collar will allow scientists to follow the individual elk to determine the effectiveness of the contraceptive. After several weeks, a booster shot will be remotely administered, from ranges of 30 to 150 feet, by means of self-injecting darts. The darts are brightly colored and easily retrieved. A single annual booster inoculation will be administered to continue contraceptive effects for successive breeding seasons.”
Use of porcine zona pellucida (PZP) vaccine as a contraceptive agent in free-ranging tule elk (Cervus elaphus nannodes). published 2002: http://www.ncbi.nlm.nih.gov/pubmed/12220156
Abstract(note only a 5 year study. Why aren’t they studying the truly long-term effects?)
The potential for the application of porcine zona pellucida (PZP) immunocontraception in wildlife population management has been tested over a 15 year period and promises to provide a useful wildlife management tool. These studies have provided evidence indicating that the use of PZP immunocontraception in wildlife: (i) is effective at both the physiological and population level (Liu et al., 1989; Kirkpatrick et al., 1996; Turner et al., this supplement); (ii) is deliverable by remote means (Kirkpatrick et al., 1990; Shideler, 2000); (iii) is safe in pregnant animals (Kirkpatrick and Turner, this supplement); (iv) is reversible (Kirkpatrick et al., 1991; Kirkpatrick and Turner, this supplement); (v) results in no long-term debilitating health problems (Kirkpatrick et al., 1995; Turner and Kirkpatrick, this supplement); (vi) has no implications for passage through the food chain (Harlow and Lane, 1988); and (vii) is reasonably inexpensive (J. F. Kirkpatrick, personal communication). This report presents the results of a 5 year study in tule elk (Cervus elaphus nannodes), 3 years of which were on the application of PZP immunocontraception to an expanding elk population living in a wilderness area of Point Reyes National Seashore in Marin County, CA…”
Copies: jwhitloc@blm.gov, tchristense@blm.gov, eburghar@blm.gov
January 19, 2016
Cedar City Field Office
176 E DL Sargent Drive
Cedar City, UT 84721
Project Name: Sulphur Wild Horse Gather Plan
Document: Environmental Assessment — Preliminary
NEPA ID: DOI-UT-C010-2015-0011-EA
This letter responds to your request for substantive comments and new information that BLM-Cedar City should consider regarding the subject Plan. I submit mine as an interested party in behalf of the wild horses of the Sulphur Herd Management Area (HMA).
I support the use of radio collars to track the horses and the construction of a fence along Highway 21 for the safety of both horses and humans. However, I urge you to cancel the roundup-and-removals, discontinue PZP treatments, correct the fraudulent population-estimates, and take other specified corrective actions.
I suggest the addition of another alternative: Increase the AML, collar the horses, fence the Highway but remove interior fences, conserve apex predators, and install guzzlers throughout the HMA.
As for the proposed alternative, if BLM has confidence in the WinEquus population-growth modeling, then please note that the “removals only” alternative yields a median-trial average herd-size that is nearly 24% lower than the proposed alternative — 318 versus 417. As for PZP injections, they should be abandoned because they are dangerous to the mares, to the foals (born and unborn), and to the staff and volunteers that handle the pesticide.
For ease of reference, here are the links to the documents at issue:
BLM lists overpopulation and forage / water limitations as the need for the proposed action. The “overpopulation” in this case merely means “over AML”. And because the AML is arbitrary and unscientific, it is meaningless. Range-conditions function as natural feedback to wild horses, allowing them to self-regulate their numbers. That is how Nature works. BLM is meddling unnecessarily. The intervention that is needed would be to offset the impact of livestock-grazing — eliminating interior fences that block wild-horse movement and installation of trick-tanks (guzzlers) to capture and store precipitation.
The Proposed Action
BLM-Cedar City plans to conduct two-to-four helicopter-style roundups-and-removal operations over the next 10 years to bring the herd’s alleged overpopulation down to the low-bound of the arbitrary management level (AML) — 165 horses on 265,675 acres — and maintain it there. BLM claims there are “excess” horses but the EA does not reveal the number. Instead, the EA goes on and on about the historical numbers and removals. Not even a “ballpark” figure is listed for how many horses BLM would remove initially, some sources have mentioned “over 500.”
BLM further plans to forcibly inject all of those few mares it plans to allow back into the HMA with PZP-22, the long-acting version of the pesticide. PZP is known to sterilize after as few as three injections in mares, or after just one shot in fillies that have not yet reached puberty. And the EA states that BLM plans to administer PZP treatments to yearling fillies.
A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed
Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes,
Ignorance of the new study that found the effective birth-rate averages 10 percent,
Ignorance of the new data showing “hands-off” management results in 5-to-8 percent growth,
Failure to include studies — both old and new — that reveal PZP’s damaging impacts, and
FRAUDULENT POPULATION ESTIMATES
Birth Rate versus Herd-Growth Rate
Before we examine BLM’s reported herd-growth rates of this HMA, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. BLM claims an average birth rate in wild-horse herds of about 20% a year. But herd-growth is unlikely to reach 20 percent a year. Here’s why: Horses die.
An independent study reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival rate is just 10 percent. Cedar City’s claim that 95% of the Sulphur foals survive is not credible. It is just self-serving for administrative convenience in equating the birth rate to the growth rate. That wrong assumption has been disproved. Moreover, I note that the 2013 inventory counted 25 foals born out of season. That anomaly was likely due to the PZP treatments, which research by Ransom et al. (2013) disclosed.
However, CCFO failed to include that study as a reference; and although it did cite another Ransom et al. study (2010), it was not included in the EA’s “References” section either.
Births outside the normal parturition-pulse put the survival of both the mares and foals at risk.
Adult Wild-Horse Mortality Rate Must Be Factored
But it is not only foals that die. Adult wild horses also perish. They succumb to illness, injury, and predation. Indeed, the EA claims that 8 horses were found dead in 2015. The adult death rate must be taken into consideration. Adult mortality is at least as high as the 5% a year for horses that die in short-term holding, where they are fed, watered, and provided care.
Given the 50% foal mortality-rate, and the 5%-or-higher average annual death rate of adult wild horses on the range, herd growth could not increase 20% a year, and a herd-population could not double in 4 years — refuting yet another BLM myth. But BLM ignores mortality — foal and adult — in its population-estimates, which exaggerates the numbers it posts.
The Herd-Growth Rate Must Necessarily Be Lower Than the Birth Rate
In light of the high foal-mortality rate and the expected adult wild-horse mortality rate, the herd-growth rate must always be lower than the average 20% birth rate. However, herd-growth rates many times higher than 20% — which would necessarily mean birth rates substantially higher still — are routinely found in BLM’s population data, including the year-to-year figures for Sulphur HMA and other HMAs under Cedar City Field Office’s jurisdiction. Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — that is one of the ways BLM creates the false impression of a population-explosion.
Stochastic Events Also Reduce Herd Growth
BLM also fails to consider another factor limiting herd growth — stochastic events — which are random catastrophes such as wildfires or contagious diseases or pesticide treatments that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.
There was such an event recently in Kazakhstan, where 120,000 endangered Saiga antelope — half the world’s population — died off suddenly and inexplicably.
Imagine if such a catastrophe were to befall the Sulphur herd. Note that the Saiga deaths involved antelope-mothers and their calves. What if Sulphur’s few fertile mares and their foals perished all of a sudden, leaving mainly stallions and sterile old mares? BLM must proactively manage the herd per IUCN International Union for the Conservation of Nature guidelines, if only in case of stochastic events.
Maximum AML Set Below Minimum Viable Population
But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear — via fictitious figures — to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP, including Sulphur. What is the MVP? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the 265,675 acres of the Sulphur HMA.
Phony Population-Estimates
According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.
718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).
This is improbable. Even if 87% were only the birth rate, it would be 335% higher than the 20% birth rate that BLM claims as average and which the independent study by Gregg et al. confirmed. Surely, herd growth — births minus deaths — could not be that high.
BLM attributes the impossibly-high estimate to “improved inventory methods.” But as has been pointed out to BLM previously, the “mark-resight” method, conducted by helicopter, appears to overcount the population. Indeed, as the report by the specialty-contractor who conducted the Red Desert Complex (Wyoming) census emphasized, there are assumptions and caveats that must be considered when evaluating the numbers, including the potential for having double-counted due to “horse activity (moving).” The method itself exaggerates the numbers.
HMA and HA Statistics reports for the Sulphur herd from 2008-2015,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in CCFO’s News-Release for 2015’s public-safety gather,
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2016
The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made initially, which caused them to compound. The beginning-of-the-year figure for 2015 — the pre-gather estimate — was per the BLM’s pre-safety-gather News Release.
Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
2008 250 435 + 87 BLM estimated foal-crop @ 20%.
Falsely equated it to the herd-growth rate.
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
——
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
Falsely equated it to the herd-growth rate.
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
Falsely equated it to the herd-growth rate.
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
—–
267 Post-gather estimate = 38+22+207
2011 267 + 53 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
PZP would not have affected mares
—– already pregnant when inoculated.
320 End-of-year estimate = 267+53
2012 320 + 64 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
But that birth-rate estimate was wrong.
PZP was at maximum effect and
—– would have reduced the foal-crop.
384 End-of-year estimate = 320+64
2013 384 +334 BLM estimated foal-crop @ 87%
Falsely equated it to the herd-growth rate.
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal-crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
Falsely equated it to the herd-growth rate.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 End-of-year estimate = 718+144-30-2
2015 830 Public health and safety excuse used
to justify removing 100 wild horses
without an EA.
February – 101 Number removed — plus 2 horses
said to be “domestic.”
The subject EA states: “Currently there are
approximately 200 head of wild horses that
are within 6 miles of Highway 21. These
horses are continually on the highway in search
of space, forage and water.” EA pdf-page 28
My comments: So, 200 took the place of the
100? Implausible. Wild horses roam. It’s their
nature. That’s why a safety-fence is needed.
—–
729 Adjusted population estimate
2015a 729 146 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
– 8 Deaths
—–
867 End-of-year estimate = 729+146-8
2016 867 173 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
—–
1040 Possible pre-gather estimate = 867+173
The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.
Not the First Time Population-Estimates Were Found to Be Flawed
In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …
125 %
131 %
153 %
157 %
249 %
Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.
Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
Recommendations: Stop the inflammatory rhetoric. For example, the EA warns, ominously: “If horse populations were allowed to continue to double or triple throughout the HMA, wild horses would utilize all of the available AUM’s allocated for other resources.” EA pdf-page 27 Scare tactics have no place in a legitimate EA. Stop the nonsense.
Societal Impact of Inflated Population-Data
The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly local elected officials and permittees — in an uproar over a false “overpopulation” that BLM’s faulty figures portray.
BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
County Commissions Pass Resolutions, but Commissioner Goes to Jail
The EA cited the resolutions that local county commissions have reportedly passed, demanding that BLM reduce the herd to AML. However, one of the ringleader-commissioners, Phil Lyman, was recently sentenced to jail after having been convicted of conspiring to operate off-road vehicles on public lands closed to off-road vehicles, and operation of off-road vehicles on public lands closed to off-road vehicles. He and a co-conspirator must pay their share of $96,000 in damage caused and serve 3 years probation.
Federal prosecutor Jared Bennett asked the judge to sentence Lyman to a “limited but reasonable” prison term to promote respect for the law and to deter others from committing the crime. Lyman knew the ride was illegal and he used his political office to recruit others to participate, he said.
The EA states that there have been requests over the past two years from land owners adjacent to the Sulphur HMA for removal of wild horses. These requests most surely came from renegade ranchers, such as LaVoy Finicum of Arizona who, inspired by Cliven Bundy, has gone public with his refusal to recognize BLM’s authority, to pay his grazing fees, and to comply with season-of-use. In Nevada, in addition to Cliven Bundy, Kevin Borba and Dan Filippini blatantly defied BLM’s authority; yet they too were pacified with concessions. BLM enables and rewards such bad behavior by caving in to it. There are likely permittees in Utah emulating Bundy, Borba, Filippini, and Finicum.
The EA’s proposed removals of wild horses and pesticide-treatments on the few allowed to remain appear designed to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by fictitious figures on herd-growth.
Bundy Brothera and Finicum Lead Armed Takeover of the Malheur National Wildlife Refuge
Ammon and Ryan Bundy, along with LaVoy Finicum are the “spokesmen” who have commandeered the Malheur Wildlife Refuge. Armed for battle, they continue, as of this writing, to occupy. Using Federal vehicles and machinery, they tore down a fence built to keep trespass-livestock out. They come and go as they please, even soliciting snacks and coffee creamer (French Vanilla) from supporters. The situation is out of control. BLM and FBI appear to be kowtowing to the rebels.
Here are excerpts from a news report:
The militants occupying the Refuge asked Harney County ranchers to tear up their leases with the Bureau of Land Management and stop paying the federal government to graze cattle on public land.
“I’ve done it. Cliven Bundy’s done it,” said LaVoy Finicum, an Arizona rancher and the militants’ defacto spokesman. “Now is the day. Now is the time. Are you going to wait for tomorrow? For next week? Next month? Next year? When? When will you stand up if not now?”
Finicum invited the ranchers to cancel their leases with the BLM at a ceremony before the media at the refuge on Saturday. He said two ranchers, one from New Mexico and another from Harney County, are scheduled to void their contracts publicly.
Ryan Bundy went on to emphasize his view that breaking away from the federal government means ranchers wouldn’t have to follow federal laws, like the Endangered Species Act.
LaVoy and the Bundys also acknowledged their proposition is risky. They said any rancher who joined them would get protection from the armed militants ….
The Comprehensive Animal Welfare Program (CAWP) for rounding up wild horses has farcical features. For example, hitting, kicking, striking, and beating a wild horse “in an abusive manner” is prohibited. The guidelines do not define at what point such mistreatment would be deemed “abusive” and, at any rate, there are no consequences identified for violating the prohibition.
Another example: The roundup–helicopter–the CAWP okays the use of helicopters — is not allowed to hit a wild horse. (There is plenty of video-footage showing that such ramming occurs.) If the helicopter hits a wild horse, what to do? The CAWP says: Document it! Again, there are no penalties for such abuse.
Yet another example: The helicopter-pilot must not drive wild horses to the point of exhaustion. The attending veterinarian–if there is one (the CAWP requires one be present but the EA says there “may” be one)–must “check for signs of exhaustion.” And …? And, nothing. Just check. No penalties.
One more example: The CAWP allows electric prods to be used on the horses “no more than three times during a procedure … except in extreme cases with approval ….” Who’s counting? Who is able to supervise properly in the chaotic conditions of a wild-horse roundup? Hotshots are abusive and should never be used. Ever.
BLM Lies about Impact of Abusive Roundup
The EA’s standard wording disinforms the reader that virtually all negative impacts of roundups disappear within hours to several days of when wild horses are released back into the HMA. That is false. Please refer to the report linked below. I recommend BLM add it to the “References” section after studying it and reforming your methods accordingly.
As required by regulation [43 CFR 4740.1(b)], a public hearing was held in Price, Utah on December 8, 2015 and will be held in subsequent years to discuss the use of helicopters and motorized vehicles in the management of Utah BLM’s wild horses and burros. … Comments received from the Preliminary Environmental Assessment (EA) and at those public meetings will be considered and, if applicable, will be addressed in management actions, NEPA documents, and decision documents using the most current direction from the National Wild Horse and Burro Program. EA pdf-page 44
I submitted detailed, substantive comments for the hearing. By now, BLM should have acted upon them and made reforms.
BLM Lies about Foal Weaning
In more standard wording, the EA states: “Nearly all foals that would be gathered would be over four months of age and some would be ready for weaning from their mothers. In private industry, domestic horses are normally weaned between four and six months of age.” EA pdf-page 37
Please note that in “private industry,” foals receive special feed and supplements, and they would be sheltered from the elements. In the wild, foals nurse for many months longer than in domestic settings, where the profit-motive leads breeders to wean early — a traumatic event for both foals and their dams.
Increased Foaling Rates?
BLM claims to need to reduce the wild-horse population. Yet the EA states: “Achieving the AML and improving the overall health and fitness of wild horses could also increase foaling and foaling survival rates over the current conditions.” EA pdf-page 36 This is an example of BLM’s eagerness to justify the unjustifiable. But in so doing, BLM belies its own contentions.
BLM Lies about Population Growth
In looking for every reason not to adopt any alternative but the proposed one, BLM insists repeatedly that unless mass-removals and PZP treatments are conducted, “… wild horse populations may increase at a faster rate and exceed the high end of the AML ….” EA pdf-page 38 However, that contradicts the WinEquus population-projections, which show a higher median-trial population for the proposed action.
BLM Lies about PZP Safety
The EA claims PZP injections would not affect unborn foals. That is false.
Sacco et al. reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. These findings were disclosed in 1981. Yet, PZP is regularly administered to pregnant and lactating mares, who transfer the destructive antibodies to their fetus, via the placenta, and to their foal, via mother’s milk.
If mares are injected with PZP while pregnant or nursing, these fillies will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when such fillies are injected as yearlings, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized in utero or while nursing.
The EA warns that gender-ratios could become lopsided if the proposed action were not taken: “Near normal populations exhibit a 1:1 sex ratio. Population shifts favoring males could occur as males are better adapted to compete for resources during changing environmental conditions.” EA pdf-page 41
But BLM also advises that, for the WinEquus population-modeling trials, one of the assumptions employed was: “Sex ratio at birth: 58% males.” EA pdf-page 90 Further, I note that following the 2008 gather, 12 females and 17 males were returned to the range, giving males a 59:41 percent advantage to the males. Finally, bachelor-stallions are more successful in escaping from helicopter-roundups. They have no mares and foals to protect. So, the roundup-method itself creates a post-gather herd skewed to more males than females.
BLM Uses Obsolete Range Assessment Technique
The EA states that the “Key Forage” method was used to evaluate range-conditions. The full title of that approach is the “Key Forage Plant” (KFP) method. However, KFP is obsolete, having been replaced by the Landscape Appearance method as far back as 1996. Moreover, per Technical Reference 1734-7, Ecological Site Inventory, such qualitative assessments “may result in reduced accuracy, limiting use of the data.” If for only this reason, I cannot rely on the EA’s representations regarding conditions in the Sulphur HMA.
BLM Lies about Year-Round Wild-Horse Presence
The EA states that wild horses do more damage because they are present year-round as opposed to livestock, which supposedly are not. However, inspection of the Active-Use chart EA pdf-page 20 reveals that nearly 49% of the livestock allotments are used year-round, and 67% are used 8-to-12 months. Further, actual-use is whatever the permit-holders self-report. Going back to the rogue ranchers in open rebellion against BLM, it is likely that real use is much higher than “actual.”
BLM Hauls Water but Fails to Install Guzzlers
BLM states that water is the limiting factor for wild-horse populations, and claims to have hauled 160,000 galllons of water into the HMA last summer for the wild horses. EA pdf-page 20 What this points to is the need for guzzlers — trick-tanks — to capture and store whatever precipitation there is.
BLM Falsely Blames Wild Horses for Damage to Riparian Areas
In its zeal to condemn the wild horses, BLM lumps wild horses in with livestock as responsible for damage to riparian areas. Yet, the EA also notes that it “is not the nature of wild horses to rest exceedingly at water sources.” EA pdf-page 53 Stop the false accusations. Your bias is showing.
BLM Plans to Use Barbed Wire for Safety Fence
Horses and barbed wire do not mix. Yet, the EA states that barbed wire will be used for the fence along Highway 21. That is not good enough. You need to use appropriate materials that pose less risk of injuring the horses.
Here are some links to information on the various types of fences and their price-ranges. Note: I have no connection whatsoever with any of these groups.
The EA admits, without further explanation: “Construction of fences within Sulphur HMA boundaries could inhibit the free-roaming nature of wild horses.” EA pdf-page 42 It is time to remove interior fences, not to install more. This matter needs to be resolved.
Finally, Some Truth-Telling
It was refreshing to encounter at least some truthfulness in the EA:
At the turn of the century, large herds of livestock grazed on unreserved public domain in uncontrolled open range. Eventually, the range was stocked beyond its capacity, causing changes in plant, soil and water relationships. Some speculate that the changes were permanent and irreversible, turning plant communities from grass and herbaceous species to brush and trees. EA pdf-page 43
BLM needs to stick to the facts and cease blaming wild horses for what livestock already did.
——————————————-
Please consider these substantive comments and new information — new to BLM — and make the necessary course-corrections and reforms.
Sincerely,
While pretending to rely on the assumption that herds grow 20% a year, the Bureau of Land Management (BLM) posts numbers up to 8 times higher than that to justify roundups, which are pre-scheduled on a rotation-basis, seeming to target particular herds. For instance, the Agency recently claimed that the famous Kiger herd in Oregon grew from 21 horses to 156 horses in just four years — an increase of 643%, which equates to a yearly average increase of 160%, which is 8 times higher than the 20% BLM supposedly uses. [1] Such growth is biologically impossible. Kiger is not an isolated example, although it is the worst found so far. Here are some other phony figures on population-growth recently claimed by BLM to make it appear that gathers were necessary:
Blawn Wash (UT)
297.4 % increase in 3 years, averaging 99.1 % per year
Fish Creek (NV)
80% increase in one year
Green Mountain (WY)
281% increase in four years, averaging 70.3% per year
Stewart Creek (WY)
311% increase in four years, averaging 77.8% per year
But herd-growth is unlikely to reach even 20 percent a year. It is important to understand that the birth-rate is not the same as–and should not be equated to–the population growth-rate. Here’s why: Horses die. An independent study reviewed BLM roundup-records for a representative sample of four herd management areas composed of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth-rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival-rate is just 10 percent. Further, adult wild horses also perish. They succumb to illness, injury, and predation. Their death-rate must be taken into consideration as well. But BLM ignores mortality–foal and adult–in its population-estimates. Given the 50% foal mortality-rate, and the 5% or higher average annual death-rate of adult wild horses, herd-growth could not increase 20% a year, and a herd-population could not double in 4 years–refuting yet another BLM myth.
Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates–that is how BLM creates the false impression of a population-explosion. 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.
BLM also fails to consider another factor limiting herd-growth–stochastic events–which are random catastrophes such as wildfires or contagious diseases that suddenly wipe out mass-numbers of herd-members. Stochastic events can result in no-growth or even negative growth.
Now BLM is distributing grant-money to universities and researchers to study more ways of dealing with the phantom overpopulation. All manner of sicko experiments are being carried out on the wild horses, such as treating them with endocrine disruptors and sterilizing them surgically. Why? Because BLM is a corrupt agency. It invented this counterfeit crisis to create a sense of urgency, which will pressure Congress to give the Agency extra money to “solve” a non-existent problem.
Contact your elected officials to make them aware of BLM’s fraudulent population claims to get funding for wild horse roundups and warehousing at great taxpayer expense: http://www.contactingthecongress.org
Visit www.ProtectMustangs.org for more information and click on the donate button help fight the injustice! You can make a difference.
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.
(Photo by BLM. Roundup paid for with your tax dollars.) Addendum:
[1] Using simple division to calculate the average increase is how most people would “do the math”–dividing the percentage increase (643%) by the number of years (4). Expressing the average that way is readily understandable. However, another way of calculating it is what is called the “compound annual growth rate” (CAGR). Per that method, herd-growth can be likened to compound interest that you earn on a savings account; except of course that horses do die, which complicates the computations. But for now, let’s assume that horses never die, because that’s the assumption that BLM makes.
Using the free, online CAGR tool linked below, you would enter Kiger’s beginning population–21–and its alleged ending population–156–and the number of years that had passed–4. Then press the “Calculate CAGR” button, and the tool will compute the compound annual growth rate. For the Kiger herd, the CAGR is 65%, which is “only” 3.25 times higher–instead of 8 times higher–than 20%.
Here are the other herds cited and their CAGRs. Fish Creek stays the same because its growth is just for one year.
Blawn Wash (UT)
38 = Population-estimate 2012
151 = Population-estimate 2014, including new foals
297.4 % = Percentage increase in three years
99.1 % = Simple average annual growth-rate
58.4 % = Compound annual growth-rate (CAGR)
Fish Creek (NV)
256 = Population-estimate 2013
461 = Population-estimate 2014, before foaling season (January)
80.1% = Percentage increase in one year
Green Mountain (WY)
258 = Population-estimate post-gather at the end of 2011
982 = Population-estimate in 2015 — including that year’s foals*
281.0 % = Percentage increase in four years
70.3 % = Simple average annual growth-rate
39.7 % = Compound annual growth-rate (CAGR)
Stewart Creek
124 = Population-estimate post-gather at the end of 2011
509 = Population-estimate in 2015 — including that year’s foals*
311.0 % = Percentage increase in four years
77.8 % = Simple average annual growth-rate
42.3 % = Compound annual growth-rate (CAGR)
* BLM’s population-modeling criteria said foals were not included in the AML. Evidently, they were.
Further Insight into Calculating Population-Growth
At the link below, you will find a discussion posted by the University of Oregon, providing a comparison between the simple average and the compound annual growth-rate methodologies for calculating annual percentage population-growth.
As will be readily apparent, the simple average approach is “straight-line” and … simple. Forgive yet another pun, but the average person can easily understand it and “do the math.”
The compound annual method, on the other hand, is extraordinarily complicated to compute, which is why the online tool is almost a necessity.
What is important is that both are legitimate ways of describing the data.
It should be kept in mind that population-growth estimates must consider births and deaths, not just births. That’s one reason why the Gregg et al. study was so important — it established, per BLM’s own documentation, a slightly-less than 20-percent birth-rate and a 50-percent foal mortality-rate. So, a wild-horse herd growth-rate of, for example, 65%, would have to mean a birth-rate that was much higher than 65% to offset foal deaths (50%) and adult deaths (5%).
Ms. Wilder is disinformed. PZP does not “cause eggs to reject sperm.” That hypothesis has been disproved. PZP is a registered pesticide whose mechanism-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that target and attack the ovaries. PZP’s antibodies cause the mare to suffer ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. Not surprisingly, estrogen levels drop markedly as the ovaries are slowly destroyed. But PZP’s adverse effects are not limited to the individual animal. As a recent study — which included the Little Book Cliffs, Colorado herd and the McCullough Peaks, Wyoming herd — found, PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Further, the same study disclosed that the pesticide causes a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recover their fertility after suspension of PZP. However, some mares never recover — they are left permanently sterile, and quickly too. Indeed, yet another study found that sterility could occur in some mares from just three years of PZP injections or from just one treatment if the pesticide were given to a filly before she reached puberty. Because PZP messes with the immune system, it ironically works “best” — sterilizes faster — if the mare has a strong immune system. But, conversely, PZP may not work at all in mares whose immune function is weak or depressed. So, the pesticide discriminates against the very horses that Nature has best equipped for survival against disease while favoring and selecting for the immuno-compromised. Worse yet, tests performed via radioimmunoassay indicated that PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques.
But there is no need for PZP or any other population-reduction measures. BLM’s wild-horse overpopulation “data” is a fraud. Reviews of BLM’s year-to-year growth-estimates for various herds disclosed biologically-impossible growth-rates. For instance, just recently in Oregon, BLM claimed that the famous Kiger herd’s population grew from 21 horses to 156 horses in just four years — an increase of 643%. Stealthily inserting bogus birth-rates into the data, then wrongly equating the birth-rate with the population growth-rate, and failing to factor in the mortality-rate — that is how BLM creates the false impression of a population-explosion. Another ruse BLM employs is restricting maximum herd-size below minimum-viable herd-size. Then, whenever a herd is made to appear — via false 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% of the herds are “managed” below minimum-viable size, including Spring Creek Basin.
While touted as a “vaccine,” porcine zona pellucida — PZP — is actually a perversion of a vaccine — an anti-vaccine — whose mode-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that attack the ovaries, inducing ovarian dystrophy, oophoritis (inflammation of the ovaries), and ovarian cysts. Worse yet, per radioimmunoassay, the PZP antibodies are transferred from mother to young via the placenta and milk. The antibodies cross-react with and bind to the zonae pellucidae of female offspring. Although hyped as a “non-hormonal” method of birth-control, PZP causes estrogen-levels to plummet as the ovaries degenerate. Despite the manufacturer’s claim that PZP is “reversible,” its effects wear off unpredictably. In herds under PZP “management,” the birthing season extends to nearly year-round, putting the life of the foals and mares at risk. Because PZP messes with the immune system, it “works” best on the healthiest fillies and mares — those with strong immunity — ironically, rendering them sterile even with just a few treatments. Filles injected with PZP before they have reached puberty are particularly vulnerable to immediate sterilization. Conversely, PZP has little-to-no effect on fillies and mares with a weak immune system — they continue to become pregnant. Thus, a herd being treated with PZP is undergoing selective breeding for low immunity, which puts the population at risk for disease — and ultimately, extinction. ~Marybeth Devlin, member of The Facebook Forum on PZP for Wild Horses and Burros.
PZP is a risky pesticide. Will it ruin the treasured herd?
By Marybeth Devlin
The issue underpinning the use of PZP and the continuing cycle of removals of wild horses from the Pryor Mountain Wild Horse Range is: Whether there are excess wild horses. No, there aren’t. BLM creates the illusion of an overpopulation by administratively setting the maximum herd-size below minimum-viable population. The International Union for the Conservation of Nature determined that, if a herd were managed carefully per a stud-book, it could sustain itself genetically at a minimum of 500 individuals. Compare that number to BLM’s maximum: 120.
In fact, according to the latest genetic analysis, the Pryor Mountain herd is evidencing “a general trend for a decline in variations levels of the herd.” The recommendation was to “increase population size.” Yet, BLM stubbornly insists on its own failed approach of artificially limiting herd-size, declaring that it disagrees with the scientific “interpretation.”
But can the range accommodate more horses? Yes. By way of comparison, BLM allots 38 acres per cow or calf when setting the stocking-rate for livestock grazing. Thus, the 33,187 acres that compose the Pryor Mountain habitat can support 500 to 873 horses. When the WHR is restored to its original configuration, 44,920 acres, the high-bound can be increased to 1,182.
As for PZP, numerous independent studies have disproved the old theory that PZP merely blocks sperm attachment. In fact, PZP’s mechanism of action is to alter ovarian function, causing inflammation of the ovaries and cyst formation. PZP provokes an auto-immune response, wherein the pig-ovary-derived PZP antibodies attack the mares’ ovaries, resulting in dystrophy of those reproductive organs. Despite being hyped as a non-hormonal contraceptive, PZP causes “markedly depressed oestrogen secretion” in mares treated for just three consecutive years. The latter finding was disclosed by Dr. Kirkpatrick himself 23 years ago. PZP-use is associated with stillbirths, altered ovarian structure and cyclicity, interference with normal ovarian function, permanent ovarian damage, prolonged breeding season, and unusually-late birthing dates. A particularly troubling finding suggests that PZP can be selective against a certain genotype in a population.
PZP is touted as reversible; however, a recent study warned that just three years of treatment, or administration of the first PZP injection before puberty, may trigger infertility in some mares. Thus, only two PZP injections could be viewed as relatively safe, but it appears that even one injection is risky. The researchers warned that inducing sterility may have unintended consequences on population dynamics by, ironically, increasing longevity while eliminating the mares’ ability to contribute genetically.
Most pertinent to the Pryor Mountain herd is a longitudinal study on three herds treated with PZP — Little Book Cliffs, McCullough Peaks, and … Pryor Mountain. The researchers found that the birthing season lasted nearly year-round: 341 days. Out-of-season births put the life of the foals and the mares at risk. That same longitudinal study found that, following suspension of PZP injections, there was a delay in the mares’ recovery of fertility that lasted 411.3 days (1.13 years) per each year of PZP treatment. Thus, mares injected for four consecutive years (per BLM’s “prescription”) would be expected to take 1,645.2 days (4.51 years) to regain reproductive capacity. If disaster were to befall the Pryor Mountain horses, even if PZP were stopped immediately, it would take years for the herd to recover, if ever.
PZP has neither stopped nor slowed the roundups. Only lack of holding space has done that. Even the Pryor Mountain herd, injected for decades with PZP, is facing removals again this summer (per the usual three-year cycle) in addition to an intensified PZP “prescription” to be administered per an “equal opportunity program” eerily similar to Communist-China’s one-child policy. What’s ironic is that, for all the interference, BLM has achieved basically the same — or worse — record as has been attained the International Society for the Protection of Mustangs and Burros. ISPMB complies with the “hands-off” minimum-feasible management approach stipulated by the Wild and Free-Roaming Horses and Burros Act. ISPMB’s two wild herds grew 8.73 and 5.08 percent, respectively, without PZP and without removals. Pryor Mountain’s most recent report — reflecting management with PZP and with removals — grew by 8.26 percent.
BLM needs to get out of the way of Nature. Let the Pryor Mountain herd find its own appropriate population level.
(Note: Beware of petitions pushing PZP. Be sure to read everything you sign these days especially the fine print!)
I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …
Sulphur HMA
… and that are, reportedly, posing safety-concerns along Highway 21.
I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
REASONS CITED BY BLM FOR SPECIAL ROUNDUP
Overpopulation, Forage Limitations
BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.
The Proposed Action
BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830” (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.
The Issues
There are several important questions concerning the planned gather that BLM has not addressed.
What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21”? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?
A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed
Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.
FENCE OFF HIGHWAY 21
Outsiders — Dealing with Roving Equids
Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.
Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.
Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?
And, most importantly, …
Why hasn’t Highway 21 been fenced off near the HMA?
BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.
Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses
Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.
I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.
Wildlife Underpasses — Historical Perspective
Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.
Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.
What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.
The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.
Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!
Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.
At the link below, you will find information and resources regarding the use of overpasses, underpasses, and crosswalks for mitigating collisions between wildlife and vehicles.
You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
FLAWED POPULATION ESTIMATES
Unlikely Birth-Rate
According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.
718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).
This is improbable.
Population and Gather Reports — The Data
Per a review of the …
HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,
discrepancies are evident.
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015
The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made. The beginning-of-the-year figure for 2015 — the pre-gather estimate — is per the BLM’s News Release.
Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
—— —– ———– ————– —————————————————
2008 250 435 + 87 BLM estimated foal-crop @ 20%
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
——
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
—–
267 Post-gather estimate = 38+22+207
2011 267 + 53 BLM estimated foal-crop @ 20%
PZP would not have affected mares
—– already pregnant when inoculated.
320 End-of-year estimate = 267+53
2012 320 + 64 BLM estimated foal-crop @ 20%
But that estimate was wrong.
PZP was at maximum effect and
—– would have reduced the foal-crop.
384 End-of-year estimate = 320+64
2013 384 +334 BLM estimated foal-crop @ 87%
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal- crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 Current estimate = 718+144-30-2
2015 830 Public health and safety excuse used to justify removing 100 wild horses without an EA.
The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.
Societal Impact of Inflated Population-Data
The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.
Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
Mistakes Cost Wild Horses Their Freedom
The planned removals appear to have been hurriedly scheduled to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by faulty figures.
Not the First Time Population-Estimates Were Found to Be Flawed
In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …
125 %
131 %
153 %
157 %
249 %
Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.
Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it inadvertently portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER BLM METHODOLOGY
Projections per a Twenty-Percent Foal-Survival Rate
Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.
Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.
Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.
Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.
A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.
However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.
Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.
Bottom line: Every benefit-of-the-doubt has been given.
Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths
2008 — 190 — BLM’s population-estimate post-gather November 2008
Year Herd-size
January 1
2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.
2011 — 244 — Foal-crop: 49. PZP does not affect already-pregnant mares.
2012 — 293 — Foal-crop: 59. Even though PZP at maximum-effect.
2013 — 352 — Foal-crop: 70. Even though PZP still in effect.
2014 — 422 — Foal-crop: 84. But gather in Aug removed 30 horses.
2015 — 476 — including the 2014 foal-crop
2015 — 392 — excluding the 2014 foal-crop
It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.
Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …
Below minimum-viable population.
No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.
Planned Roundup Would Have a Devastating Impact on the Sulphur Herd
Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.
But it gets worse. Recent studies have shown BLM’s “20-percent-per-year” rule to be exaggerated by double.
TRUE HERD-GROWTH RATE, FOAL-TO-YEARLING SURVIVAL RATE = 10%
Longitudinal Study Demonstrates Growth-Rate of Five-to-Ten-Percent
The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.
Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …
No removals
No predators
No PZP
Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.
http://www.ispmb.org/Letter.html
The ISPMB study casts doubt on BLM’s standard “20-percent-per-year” rule for estimating herd-growth. Certainly, assumed growth-rates of 29 percent IN 2010 and, especially, the 87 percent growth-rate the BLM assumed for 2014, are implausible. Further, because subsequent estimates were based on false, inflated previous estimates, the errors compounded.
Independent Research Discloses a 10% Foal-to-Yearling Survival-Rate
A study of BLM roundup-records for a representative sample of four herd management areas was recently published (Gregg, LeBlanc, and Johnston, 2014).
The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER NEW RESEARCH-FINDINGS
Projections per a Ten-Percent Growth-and-Survival Rate
Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Sulphur HMA — Per 10% Growth — Modified by Removals, but NOT by PZP
2008 — 190 — BLM’s population-estimate post-gather Nov ’08
2011 — 200 — Foal-crop: 20. PZP does not affect already-pregnant mares.
2012 — 220 — Foal-crop: 22. Even though PZP at maximum-effect.
2013 — 242 — Foal-crop: 24. Even though PZP still in effect.
2014 — 266 — Foal-crop: 27. But gather in Aug removed 30 horses.
2015 — 263 — including 2014 foals
2015 — 236 — excluding 2014 foals
It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.
Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …
Below AML and
Below minimum-viable population.
It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.
Could There Really Be 100 Wild Horses Wandering onto the Highway?
Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.
Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.
Happy Tone, Ugly Reality
BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.
Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21”;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
ADOPTION … OR HIGHWAY TO HELL?
Sale to Slaughter for Sulphur HMA Captives
BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.
A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21” removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.
Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21” only to send them down a “highway to Hell”?
SULPHUR HERD’S AML WAS SET AT A GENETICALLY NON-VIABLE LEVEL
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP
BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.
A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:
BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Current
AML: 165 to 250 — Below minimum-viable population
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 1,063 – 1,610 — about 1⅔ to 2½ square miles per horse
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Recommended
AML: 2,500 to 5,000 — Meets minimum-viable population per IUCN
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 53 – 106 — about 6 to 12 horses per square mile
BLM’s National Authorized Livestock AUMs
But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?
BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.
Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.
157,000,000 acres of public lands on which BLM allows cattle
1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized
2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2
4,133,332 cows and calves = pairs x 2
38 acres per cow or calf
BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.
Actual Grazing Use Report — Form 4130-5
As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Annual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”
Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the reports is suspect.
Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use
In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.
Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.
What If There Is Not Enough Forage to Support 5,000 Horses?
Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that
… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.
Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.
Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.
The correct order is:
Sample first.
Sample complete — 100 percent.
Test samples.
Manage per test-results.
There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.
Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool
I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.
Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:
Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring
Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
A HELICOPTER-ROUNDUP IS ILL-ADVISED FOR SEVERAL REASONS
Helicopters Are Not Safe
BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.
Peculiar Way of Addressing Safety Concerns
Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.
Helicopter-Drive — an Inhumane Roundup Method
Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.
Abusive Behavior by Helicopter Pilots during Gathers
As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.
There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.
No Horse Left Behind
The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.
An Angry Contractor May Be Headed Your Way
In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.
Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.
Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.
Some Observers May Be Pumped-Up Too
Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.
The political weather is unstable. That is another good reason to call off the roundup.
Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs
A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.
How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.
Possible Collusion with Permit-Holders
Perhaps, as you read this, permit-holding ranchers are in the HMA, pushing wild horses toward the Highway.
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
1. Stop action. Cancel gather.
2. Complete environmental assessment.
3. Correct errors in the population-estimates.
4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.
5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.
6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.
7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).
8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.
9. Conduct a 100-percent evaluation of the Sulphur HMA herd’s genetic status.
