Despite underpopulation, does OSU have the right to experiment on federally protected wild horses and burros or are they breaking the law?

 Is Oregon State University about to embark it their biggest PR nightmare?

Vet Spaying Wild Mare at Sheldon Wildlife Refuge

 

© EquineClinic.comn shared for educational purposes

© EquineClinic.comn shared for educational purposes

Oregon State University published the Q & A below based on the false premise, when the truth is wild horses are underpopulated in America today:

 

Frequently asked questions: OSU fertility research involving wild mares and burros

I understand that Oregon State University is involved in research on wild horses and burros.  Is this true?

Yes. The Bureau of Land Management (BLM) awarded Oregon State University money to help study fertility-control methods for wild horses and burros.

In 2014, the BLM asked for research proposals from a variety of scientific groups across the nation to help address the high population growth rates of wild horses and burros, including veterinarians, scientists, universities, pharmaceutical companies, and other research entities.  Additional details can be found here.  Since then, the BLM has provided awards to support over 20 projects.

Five universities with college of veterinary medicine programs received awards. Proposals from OSU were selected based on the quality of science, the expertise of the research investigator and the potential impact of the research. Oregon State University faculty were among those that submitted proposals to the BLM to help slow and stabilize the population growth rate of wild horses and burros. The BLM announced its decision on June 27 to proceed with the research to be conducted by Oregon State faculty. Details of that announcement can be found here.

How is Oregon State University involved?

As a research university, Oregon State conducts studies on important topics, and informs public policy-makers and the general public of those research findings.

This research will evaluate minimally invasive, humane, effective, and permanent procedures that would then be reviewed by the BLM as options to maintain sustainable herd levels.

Our role is in conducting research to inform BLM policy. Oregon State University’s role is not to develop policy.

Why did BLM decide that this type of research was necessary?

The Bureau of Land Management (BLM) developed the program after receiving a report with recommendations from a National Academy of Sciences committee, which had been tasked with performing a complete review of the BLM’s Wild Horse and Burro Management Program.

The National Academy of Sciences (NAS) published a video summary of that report, “Using Science to Improve the Wild Horse and Burro Program: A Way Forward”.

The NAS reports that the population of wild horses and burros is growing beyond the capacity of federal lands to support the health and welfare of these animals. Animals that are not healthy are susceptible to further suffering from disease, malnutrition, dehydration, and death. The BLM is reviewing a range of options to manage the population of these horses and burros at sustainable levels.

What did the National Academy of Sciences committee find?

The NAS committee emphasized that, on average, the population of wild horses and burros across the west is increasing by 15 – 20% per year, despite ongoing fertility control vaccination programs. The NAS urged the BLM to make wider use of fertility control options that are based on rigorous research.

Why would wild horse and burro populations be a concern? 

The population of wild horses and burros on federal lands is growing beyond the capacity of local, state, and federal resources to support the health and welfare of these animals, and maintain healthy range ecosystems.

An illustrated summary of BLM concerns and challenges related to our nation’s wild horses and burros can be found here. 

What does Oregon State University have to offer?

OSU faculty who responded to the BLM’s request for additional research felt very strongly that their contributions would benefit and improve the health and welfare of our wild horses and burros.

As a land-grant institution, Oregon State University faculty members often have the expertise needed to address issues that affect Oregon and the nation.

Results from this work will be analyzed and published in peer-reviewed forums, in addition to informing the BLM.  In this way, the work performed by OSU faculty will be available to the public.

For more information about how research is conducted at Oregon State University and academic freedom, please click here. 

How is animal safety and humane care ensured during research?

University-wide commitment to animal care, safety, and welfare is a top priority. Oregon State University recognizes both the importance of animals in research and teaching, and the scientific and ethical responsibilities inherent in the care of those animals.  Research activities undertaken by OSU faculty, staff, and students are reviewed and conducted in accordance with strict ethical principles, federal and state laws and regulations, and in compliance with Oregon State institutional policies.

Oversight of animal activities associated with OSU is provided by the Institutional Animal Care and Use Committee (IACUC). The IACUC’s main functions are to review, approve, and monitor research protocols, and ensure that animals are cared for according to all applicable federal and state laws, regulations, and Oregon State institutional policies.

Oregon State University additionally volunteers to have their animal program reviewed every three years by AAALAC, International, an independent accreditation agency for animal research programs. The accreditation process is very stringent and institutions with AAALAC accreditation are known for their commitment to excellence and humane animal care.

What methods are being studied in this research?

One study will evaluate the removal of both ovaries without the need for any external skin incisions (ovariectomy via colpotomy). Ovariectomies are commonly used by veterinarians to stop egg production and related reproductive (“heat”) cycles in animals.

Another study will evaluate two surgical methods that will interrupt fertilization.  Animals undergoing these procedures will still have heat cycles but they will not conceive.  Tubal ligation is one method, and the other is oviduct ablation.  The use of these methods also avoids the need for external skin incisions.

I have concerns about the management of our nation’s wild horses and burros, and I don’t think Oregon State University should be involved.

As a research institution, work at Oregon State sometimes involves controversial issues.  In this case, research team members have offered their areas of expertise in designing a study whose results will be used to inform policy decisions by the BLM in the management of wild horse and burro populations.

Research data provided by Oregon State researchers will be part of the larger group of studies that BLM will consider as it reviews policies and procedures to respond to the 2013 NAS report.

More information on BLM management of wild horses and burros can be found here.

Who will perform this research?

The studies will be conducted by teams of licensed, highly qualified and experienced veterinary surgeons.

Are Oregon State students involved in this research?

No.  Students are not involved in these projects.

When was this proposal submitted?

Proposals were submitted to the BLM in 2014. 

How long will this research take to be completed?

The research will take place over the next two – five years.

How much will be spent on this research? Who will fund this proposed research?

The BLM has approved two grants to OSU totaling $348,000.

Where will this research be conducted?

The research will be conducted at the BLM’s wild horse and burro facility in Hines, OR. 

How and with whom will these research findings be shared with?

Oregon State researchers will report their results to the BLM; will publish findings in other peer-reviewed forums and share the results with the public.

Who decides to accept or reject these findings? Or implement them as a standard of future practice?

The BLM will make any decisions on future policies and practices. For more information click here.

Cross-posted for discussion from: http://oregonstate.edu/ua/ncs/blm-research-faq

Stay tuned for the backlash

PM Lennox meme

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




Does the meat Industry want to SLAUGHTER wild horses?

Read what the Pro-Slaughter advocates say about wild horses below. They are publishing this in pork industry publications!

Meat of the Matter: Wild and worrisome

Time for a brief quiz.

Question 1): How many wild horses and burros are currently roaming across the Western rangelands?

Question 2: How many wild horse and burros are adopted by private citizens each year?

Question 3): Absent “control measures,” how long does it take for the population of wild horses and burros to double in numbers?

Answers: 1). 67,000. 2). 2,500. 3). Four years.

In other words, each year there are thousands more of these feral animals being added to what is already an overpopulation across the semi-arid rangelands of Nevada, California, Utah and several other Western states.

In fact, the Bureau of Land Management announced last week that as of this March, there an estimated 67,000 wild horses and burros in the West public rangelands, which is a 15% increase over the estimated 2015 population.

The updated data are more than twice the number of horses on the range than is recommended under BLM land-use plans. It is also two and a half times the number of horses and burros that were estimated to be in existence when the Wild and Free Roaming Horses and Burros Act was passed 45 years ago in 1971.

“Over the past seven years we have doubled the amount of funding used for managing our nation’s wild horses and burros,” Neil Kornze, BLM Director, said in a statement. “Despite this, major shifts in the adoption market and the absence of a long-term fertility control drug have driven population levels higher.”

The major shift to which Kornze referred is a dramatic decrease in adoptions of wild horses, due to economics and other factors — ie, the fact that the wild mustangs, in particular, don’t adapt well to life in a stable.

Here’s the problem: The lifetime cost of caring for an unadopted horse removed from the range approaches $50,000 per animal. With 46,000 horses and burros already residing in off-range corrals and pastures, this means that without some way to place these animals with willing owners, BLM will spend more than a billion dollars to care for and feed them over the rest of their lives.

And there are plenty more where the current ones came from.

As The New York Times phrased the situation in a lengthy article two years ago, “There are now twice as many wild horses in the West as federal land managers say the land can sustain. The program that manages them has broken down, and unchecked populations pose a threat to delicate public land, as well as the ranches that rely on it.”

And the situation has only worsened since then.

A question of numbers

Keep in mind that the population of wild horses and burros affects not just agency budgets and wildlife populations, but impacts a significant economic and cultural resource: the grasslands of the West. When deer populations exceed their rural habitats east of the Mississippi, there is property damage and traffic accidents for suburban and rural residents to contend with, but there is far less impact on agriculture.

Not so out West. There simply isn’t carrying capacity for ever-expanding herds of horse and burros, while at the same time maintaining the grazing rights of ranchers and conserving the limited supply of grassland and water resources.

BLM officials are trying to address the challenge on a number of fronts, including:

  • Sponsoring research on fertility control, which to date is neither effective nor inexpensive
  • Transitioning horses from off-range corrals to lower cost pastures, which at best may offer modest mitigation of the cost burden
  • Working to increase adoptions with new programs and partnerships, which won’t even get the populations stabilized at the levels of 10 or 15 years ago, when horse adoptions were far more popular

None of those measures — even in combination — will be enough, however, and so the agency announced in a statement that it would request two new pieces of legislation: One to permit the transfer of horses to other agencies that have a need for work animals; and another that would create a congressionally chartered foundation to help fund and support adoption efforts.

Unfortunately, all the money in the world can’t turn adoption in to a sustainable solution. Wild mustangs and feral burros make lousy pets and equally undesirable work animals. It’s one thing to “domesticate” bison, another “wild” species dependent on rangelands. The time, trouble and expense of keeping them corralled represents an investment recouped by selling the meat and hides, whereas the only reason to keep horses around these days is to ride them, either for pleasure, for racing or for equestrian competition.

Most wild horses are highly unsuited to all of the above.

As is true with any invasive species, the spectrum of control measures starts out with the least intrusive, most humane interventions. But unless such a limited strategy actually works, efforts must be ramped up — all the way to forcible population control.

I’ve yet to hear from any activist with a better solution.

Or one with an extra billion they’d like to donate to the cause.

The opinions expressed in this commentary are solely those of Dan Murphy, a veteran food-industry journalist and commentator. Cross-posted for education and discussion from PorkNetwork

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




$10,000 Reward for information on Wild Horse shooting

From a BLM press release

The Bureau of Land Management is offering a $10,000 reward for information leading to the arrest and conviction of the person(s) responsible for shooting and killing a wild horse in early October 2015 at the Northern Nevada Correctional Center, near Carson City, Nevada.

The BLM currently manages thousands of wild horses in accordance with the Wild Free-Roaming Horses and Burros Act of 1971, which gives the agency a mandate to protect and manage the animals. The Northern Nevada Correctional Center/Stewart Conservation Camp Saddle Horse and Burro Training Program is a cooperative partnership between the Bureau of Land Management (BLM) and the Nevada Department of Corrections-Silver State Industries. Through this training program, wild horses and burros are gentled and trained before being adopted. About 60 wild horses and burros are trained and adopted at the facility each year. Currently, the Northern Nevada Correctional Center horse program houses and maintains approximately 1,500 BLM horses.

Individuals with information about this incident are encouraged to call the BLM crime hotline phone number at: 1-800-521-6501

###

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

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

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

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

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

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

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

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

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

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

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

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

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

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

With love,
Anne

Anne Novak
Volunteer Executive Director
www.ProtectMustangs.org

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


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

 

URGENT: Comments due February 3 against wild horse mare sterilization experiment

574px-Blm.svg

There is no overpopulation of wild horses. BLM’s harvesting model based management via roundups is disrupting herd dynamics and increasing the birthrate. Even so BLM’s allegations of overpopulation are fraudulent based on false data. They don’t even account for the correct mortality rates in the wild. Predators need to be reintroduced if anything. Wild horses are a return-native species that help reduce catastrophic wildfires and create biodiversity. The BLM is trying to manage America’s wild horses to extinction. The bottom line is America’s federally protected wild horses are underpopulated today. The BLM is creating a false crisis to cash in on wild horses as laboratory animals for fertility control experiments.

The content below is a BLM Press Release and does not reflect the views of Protect Mustangs:

 

Hines, Ore. – The Bureau of Land Management (BLM) Burns District announces the availability of a draft Environmental Assessment (EA) for Mare Sterilization Research at Oregon’s Wild Horse Corral Facility in Hines. In cooperation with Oregon State University, the BLM is proposing to investigate the safety and efficacy of three separate methods of surgical sterilization of wild horse mares: ovariectomy via colpotomy, tubal ligation, and hysteroscopically-guided laser ablation of the oviduct papilla.

A 30-day public comment period on the EA is set for January 5 through February 3, 2016. Comments can be mailed or faxed to the BLM Burns Office at the address below, or submitted by email to: blm_or_bu_mareresearchea@blm.gov. Entire comments – including personal identifying information – may be published as part of the EA and Decision Record process. Copies of the draft EA are available for review at the BLM Burns District Office during regular business hours, or online at https://eplanning.blm.gov/epl-front-office. This link takes you to BLM’s new ePlanning website. To search for the EA and unsigned FONSI you can either use the map to locate Burns District or click on the “Text Search” tab and search by state, document type, year, and program.

Mail or deliver to:

Mare Sterilization Research Project Lead
BLM Burns District Office
28910 Highway 20 West, Hines, Oregon 97738

Fax:

(541) 573-4411
Attention: Mare Sterilization Research Project Lead

The BLM is investing in a diverse portfolio of research projects to develop new, modern technologies and methods for wild horse and burro management.

Research is aimed at finding safe and effective ways to slow the population growth rate and reduce the need to remove animals from public lands. The studies are in response to a 2013 recommendation from the National Academy of

Science to develop new or improve existing population grown suppression methods for wild horses and is in accordance with The Wild Free-Roaming Horses and Burros Act of 1971. Utah, Wyoming and Oregon have current or upcoming research projects.

For further information about Oregon’s Mare Sterilization Research project or to have your name added to the project mailing list, contact the Project Lead at (541) 573-4400.

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

-BLM

The above is from a BLM Press Release and not reflecting the views of Protect Mustangs. The BLM is trying to manage America’s wild horses to extinction.


Official request to end GonaCon™ Experiment and others

The War on Wild Horses

The War on Wild Horses

——– Original Message ——–
Subject: Official request to stop experiments on Water Canyon wild
horses and others
From: <X@protectmustangs.org>
Date: Thu, January 28, 2016 6:30 pm
To: nvsoweb@blm.gov, eyfoweb@blm.gov, “Tom Gorey” <TGorey@blm.gov>,
director@blm.gov, mtupper@blm.gov, bnoyes@blm.gov

Dear Sirs,

The public is outraged that the small Water Canyon herd is being harassed and ruined for an experiment with GonaCon™–paid for with tax dollars. American wild horses are an indigenous species aka “returned-native” as well as being a national treasure. The public loves them.

Protections given to America’s free roaming wild horses and burros–according to the law–must be enforced.

The federally protected Water Canyon herd was underpopulated–with less than 60 wild horses of various ages on the herd management area (HMA). The herd is located on the western side of the vast Antelope Complex in northeastern Nevada, north of Ely.

This herd is already threatened with low genetic viability because the population is so small. American wild horses are not overpopulated on public land and are not “pests”. They should never be experimented on with an EPA restricted-use pesticide, or anything else.

PZP, another EPA restricted-use pesticide, was originally proposed by Nevada RAC member Jeanne Nations for a Water Canyon Pilot Program.

Now, according to your website, Ms. Nations is the Project Coordinator (volunteer) of the GonaCon™ Experiment. How did her previous PZP proposal flip into the GonaCon™ Experiment? Was the public allowed to comment on the proposed GonaCon™ Experiment?

Protect Mustangs is against forcibly drugging wild mares with risky pesticides, used for birth control, such as GonaCon™ (sterilant) or PZP (made from slaughterhouse pig ovaries) because they eventually sterilize the mares, ruin natural selection, negatively effect the herd’s immune system, cause abnormal herd behavior, etc.

The Bureau of Land Management’s (BLM) overpopulation claims are fraudulent and any action taken based on fraudulent information is wrongful. There are no “excess” wild horses on public land today. Read more about that here: http://protectmustangs.org/?p=8551 There are too many herd management areas that currently have no wild horses on them.

Commercial livestock often outnumbers wild horses on public land at more than 50 to 1. Native wild horses must no longer be the scapegoat for range damage.

53 Water Canyon wild horses were trapped last fall for this controversial experiment. Public observation was discouraged. 15 mares were harassed and forcibly drugged with GonaCon™. Then 15 mares along with 7 studs were returned to the Water Canyon federal herd management area (HMA).

Evidently one Water Canyon wild horse has already died during the experiment. Please provide information and photos/video documenting the Water Canyon wild horse who died as a result of this experiment. Have any other wild horses died since then? Will you be killing wild horses as part of the GonaCon Experiment?

The Bureau of Land Management (BLM) has broken up family bands, branded, harassed and permanently removed half of the small herd to forcibly drug and experiment on 15 wild mares with GonaCon™. The BLM has also harassed and endangered wild horses with radio collars who were returned to the range for the experiment. This is outrageous and all paid for with American tax dollars.

Ultimately the BLM plans on spending $11.5 million tax dollars on various experiments on wild horses over the next 5 years. The various experiments are listed here: http://protectmustangs.org/?p=8657

Adoption

The Water Canyon and other wild horses available for adoption are “wanted” but BLM’s adoption publicity, marketing and interface with the public is failing. If adoption rates are falling in the last decade it’s because BLM is removing more wild horses than they can adopt and doing a poor job at customer service with adopters. BLM’s failing adoption program does not justify experiments of any sort on wild horses and burros. Your adoption program needs an overhaul and the first thing you need to do is fix your rotten customer service.

Protect Mustangs and our members are very interested in the Water Canyon wild horses. We have visited the 11 orphans at the Palomino Valley Center (PVC), outside Reno, several times per week since December 18, 2015. Our members are shocked the weanlings and yearlings each have one strike against them after the failed trap-site adoption on December 5th.

We are is committed to ensuring the 11 Water Canyon orphans (#WC11) will not receive a 2nd or 3rd strike. The 3rd strike would strip away their federal protections according to the Burns Amendment of the Free Roaming Wild Horse & Burro Protection Act (1971). Legally this would allow the BLM to euthanize the youngsters or engage in unlimited sales to kill buyers for slaughter.

We have been regularly evaluating the youngsters, documenting their situation, publicizing the need for them to find good homes in pairs–to get them out of the pen at PVC with no shade or shelter while helping adopters navigate the BLM red tape and BLM’s slow adoption communications.

Did you realize the public wants to adopt the Water Canyon wild horses because they know about them now and like them? As of this writing, all but 2 orphans at PVC have been adopted.

According to an August 2015 BLM news release, “The BLM plans to remove 30-40 excess wild horses and offer them to the public for adoption through its Wild Horse and Burro Adoption Program.” Where are all the other Water Canyon wild horses who have been permanently removed from their home? How many have been adopted as of today?

Are the other Water Canyon pregnant mares, studs and colts at the Broken Arrow facility in Fallon, Nevada–which is closed to the public? If so we officially request you immediately open the facility for public observation and to promote adoption.

Members of Protect Mustangs would like to view the Water Canyon wild horses, take photographs and video of the wild horses to promote them for adoption. One of our videos had more than 24,000 views in a few days which sparked a huge interest in adopting the Water Canyon wild horses.

The American public wants to adopt and/or purchase the remaining Water Canyon wild horses removed from public land–including the pregnant mares. Those over 10 can be purchased outright through the BLM’s sale program.

The public is outraged the BLM is experimenting on America’s icons of freedom and symbols pioneering spirit of the West.

Protect Mustangs wants to ensure no other wild horses will be used for any kind of experimentation. America’s wild horses are naturally fertile for the species to survive through natural selection. Using federally protected wild horses as lab animals for population control experiments is cruel and unusual treatment and must stop now.

We officially request you cease the Water Canyon GonaCon™ Experiment and all the other experiments listed here http://protectmustangs.org/?p=8657 now.

Federally protected wild horses and burros are to be protected from harassment according to the law. You can read the Wild and Free Roaming Horses and Burros Act of 1971 here: https://en.wikipedia.org/wiki/Wild_and_Free-Roaming_Horses_and_Burros_Act_of_1971

Sincerely,
Anne Novak

Anne Novak
Executive Director
Protect Mustangs
Tel./Text: 415.531.8454
X@ProtectMustangs.org

Read about native wild horses: http://protectmustangs.org/?page_id=562

Twitter: https://twitter.com/TheAnneNovak
Facebook: https://www.facebook.com/ProtectMustangs
In the news: https://newsle.com/AnneNovak

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




Background:
Water Canyon Wild Horse Growth Suppression Pilot Program

http://www.blm.gov/nv/st/en/fo/ely_field_office/blm_programs/wild_horses_and_burros/Water_Canyon_Growth_Suppression_Pilot_Program.html

Public observation of gather, etc was discouraged:
http://www.blm.gov/nv/st/en/fo/ely_field_office/blm_programs/wild_horses_and_burros/Water_Canyon_Growth_Suppression_Pilot_Program/publicviewing.html
12/16/15 Adopt a Water Canyon Foal Press Release
http://www.blm.gov/nv/st/en/info/newsroom/2015/december/ely__blm_offers_public.html

Release Date: 12/16/15
Contacts: Chris Hanefeld , 775-289-1842 , chanefel@blm.gov
News Release No. ELY 2016-006

BLM Offers Public Unique Opportunity to Adopt Water Canyon Wild Horses

ELY – The Bureau of Land Management (BLM) is offering the public the opportunity to adopt a foal gathered from the Water Canyon portion of the Antelope Herd Management Area in eastern Nevada. Nine weanlings and two yearlings are being held together at the National Wild Horse and Burro Center at Palomino Valley, north of Reno, Nev.
The horses are available for walk-up adoption from 8 a.m. to 4 p.m., Monday through Friday, and 8 a.m. to 2 p.m., Saturdays. All of the horses have received vaccinations and their bloodwork is completed. Brand inspections will be performed and health certificates issued on all adopted horses.
Pictures of the horses are available online on the BLM’s Flickr album “Water Canyon Foals Available for Adoption” at http://bit.ly/1N85QV1. Applications are available for download (.pdf) at http://on.doi.gov/1A0eAfw.
For more information, contact Jeremy Wilhelm, BLM public contact person, at (775) 475-2222.
The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2014, the BLM generated $5.2 billion in receipts from public lands.
–BLM–

Ely District Office 702 North Industrial Way Ely, NV 89301

Water Canyon Wild Horse Growth Suppression Pilot Program: https://eplanning.blm.gov/epl-front-office/projects/nepa/47287/57875/62666/Final_Water_Cyn_Preliminary_EA_508.pdf

USDA-Developed Vaccine for Wild Horses and Burros Gains EPA Registration (Feb 13, 2013): https://www.aphis.usda.gov/newsroom/2013/02/pdf/horse_vaccine_approval.pdf

GonaCon™ the EPA restricted use pesticide information sheet: https://www.aphis.usda.gov/wildlife_damage/nwrc/registration/content/Speciman%20Labels/speciman%20label56228-41%20GonaCon%20Equine%2001-13.pdf

GonaCon™, PZP and SpayVac® have all previously been used in experiments and should not be used because America’s wild horses are underpopulated–especially the Water Canyon herd. Here is some scientific data. The experiments were called for based on an overpopulation myth: https://www.aphis.usda.gov/wildlife_damage/nwrc/publications/10pubs/miller103.pdf

Abstract
Context. Contraception is increasingly used as a management technique to reduce fertility in wildlife populations; however, the feasibility of contraceptive formulations has been limited until recently because they have required multiple treatments to achieve prolonged infertility.

Aims. We tested the efficacy and evaluated potential side effects of two contraceptive formulations, a porcine zona pellucida (PZP) formulation, SpayVac® and a gonadotrophin-releasing hormone (GnRH) formulation GonaCon-B!, in a population of free-roaming feral horses (Equus caballus). Both formulations were developed to provide several years of infertility with one injection.

GonaCon™ experiment is already going on at Theodore Rossevelt National Park so no need for a Water Canyon experiment: http://bismarcktribune.com/news/state-and-regional/park-s-wild-horses-an-experiment-in-birth-control/article_a13a157e-816a-11e4-a261-ffd6de663204.html




Donate to save wild horses with the law on their side!

PM Helicopter Mustang Roundup

We are grateful our sucessful legal actions have stopped roundups and saved thousands of lives in the Pine Nut and Fort McDemitt areas. Protect Mustangs is creating a legal team to continue the fight for wild horse freedom in the courts. We almost didn’t find lawyers in time to help save the Pine Nut herd. We need to hire a staff lawyer

The team at Protect Mustangs feels legal action is a very important area of focus with a huge impact to save many lives.

Please make your donation to the Wild Horse Legal Fund today because the Pine Nut, Nevada, California, Wyoming, and other wild horses need legal protection again. The palm greasers going to BLM want them gone and we will take action. Click here to donate: https://www.gofundme.com/MustangLaw2016





Did you know that Academy Award-winner Michael Blake (Dances with Wolves), RIP, joined our Fort McDermitt lawsuit in 2013 to help stop two years of horrible roundups that were sending wild horses to slaughter?

MICHAELBLAKE Oscar
Michael Blake wins Oscar for writing Dances with Wolves
This is what Michael Blake wrote on August 21, 2013:

I, Michael Lennox Blake, declare and state as follows:

1. I am an author as well as a screenwriter. I have written several books and screenplays including Dances with Wolves, which was released to international acclaim in 1990. In 1991, I won every major award for my screenplay for Dances with Wolves, including an Academy Award, Golden Globe, Writer’s Guild Award, and the Silver Spur. I have also received public service awards including the Eleanor Roosevelt Award and the Americanism Award, in addition to many other awards during my life.

2. I reside in Sonoita, Arizona. I am a member of Protect Mustangs, and also am on the Advisory Board for Protect Mustangs. In a professional capacity I am an author and screenwriter. I support the work that Protect Mustangs does to protect wild horses and advocate for effective wild horse conservation on public lands.

3. I have visited Nevada for decades to see the wild horses, study them, and be inspired by them for my work. I have explored the lands of Nevada where the wild horses roam in freedom for inspiration and research for my work. I intend to return to these areas so I may continue to be inspired and do research for my work.

4. In 1992, I helped commission the first comprehensive aerial census of wild horses in Nevada. In almost every herd area, the horses were far less numerous than the BLM estimated. The final count in our survey was 8,324.

5. Protect Mustangs’ members are interested in wild horses, and I support their work to protect wild horses’ freedom and safety from cruel and harmful practices including but not limited to illegal roundups. Their mission is to educate the public about indigenous wild horses, protect and research American wild horses on the range, and help those who have lost their freedom. Protect Mustangs works to educate the public about the decisions and activities of the government that impact wild horses, and find solutions for wild horse conservation that does not include roundups and auctioning off wild horses for slaughter. Members of the public and horse advocates across the United States are interested in and support Protect Mustangs’ work to protect wild horses due to their recreational, scientific, spiritual, ecological, cultural, artistic, historical, iconic, and aesthetic values.

6. I wrote in my book Twelve the King:

“But he and hundreds of thousand like him are gone now from this beautiful land, and for that reason alone I could not stop as I traveled over four hundred miles of Nevada roads. Something evil is still afoot in this land, and it has left its imprint everywhere. In all those miles of open, free country, the mark of evil is present in what is absent. The wild horses are missing from the land.”

7. I have written extensively about the American West and find inspiration seeing and studying wild horses. If these unbranded, wild horses are rounded up and removed by the USDA Forest Service and/or the BLM on tribal land, or elsewhere by the Forest Service and/or the BLM, I will be harmed because I will no longer have the ability to study them or be inspired for my books, stories and other works.

8. Wild horses and their connection with the land in the American West inspire me to write. I have plans to spend time in the future using and enjoying these lands and studying free-roaming wild horses on public lands in the Owyhee HMAs and where the wild horses roam in the Humboldt-Toiyabe National Forest, as well as on tribal lands. The proposed gather on USDA Forest Service and tribal lands will forever remove wild and free-roaming horses that I rely upon in my professional and personal capabilities.

9. I derive significant satisfaction and happiness from the existence of native wild, free- roaming horses. Ensuring the continued existence and distribution of wildlife including wild horses in the West is of the utmost importance to me and has directly influenced my life a great deal. The West is far different than the East because the West still has wildlife—including wild horses that inspire me to write fiction and non-fiction.

10. If the Fort McDermitt Horse Gather proceeds as planned, it will prevent me and other members of Protect Mustangs from recreating, enjoying, studying, being inspired from, and writing about the wild horses in the area in the future. I am very unlikely to continue deriving benefit and inspiration concerning the wild horses in an area where they have been removed and herd numbers drastically reduced as is proposed by the Fort McDermitt Horse Gather and the 2013 Agreement between the Forest Service and Fort McDermitt Tribal Council. Our members share these views as well.

11. I have been studying and gaining inspiration from seeing wild horses in Nevada throughout my life. I have certain plans to continue visiting these wild areas of Nevada authorized for roundup, including the Humboldt-Toiyabe National Forest, throughout my lifetime. For the aforementioned reasons I would be directly harmed should the unbranded, wild horses at issue in the Fort McDermitt Horse Gather be removed and the horses rounded up and be allowed to go to holding, auction, sale, or slaughter.

[End of Michael Lennox Blake’s declaration]

HELP build the legal fund today so Protect Mustangs can continue to fight for wild horses in court. We are a unique group dedicated purely to the protection and preservation of America’s wild horses. We need to act quickly and independently to HELP SAVE wild horses with legal action. Please make a donation today and share this fundraiser: https://www.gofundme.com/MustangLaw2016 or donate via PayPal to Contact@ProtectMustangs.org

Thank you for taking action today to help save the wild horses!

Many blessings,
Anne

Anne Novak
Volunteer Executive Director
www.ProtectMustangs.org
Non-profit mission: Protect and preserve native and wild horses

PROTECT MUSTANGS
PO Box 5661
Berkeley, CA. 94705





PM Pine Nut 332 90K meme

Lennox August 2014

Lies, subterfuge and PZP

PM PZP Dr liu

Forcibly drugging wild mares with PZP at the Carson Prison

By,

Carl Mrozek

Unfortunately, the secret mandate to turn our public lands into vast oil, gas and coal fields–interspersed with millions of cattle under Bush–Cheney has continued unabated under Obama with geothermal fields, plus solar and wind farms being added to the mix of revenue generating initiatives, many on lands reserved by law for primary use by wild horses and burros.

Even as their herds diminish under constant assault by all of these special interests on public lands, wild horses continue to be scapegoats for degradation of public lands due to overpopulation, by the BLM which over-counts then by at least 200% while greatly exaggerating their rate of population  increase–based on optimal conditions and zero mortality.

BLM’s solution to this fabricated overpopulation explosion of wild horses and burros has been massive roundups which are now being replaced by large-scale birth control with PZP (porcine zone pellucida) which results in sterilization after multiple applications. While their tactics have grown more sophisticated, BLM’s overall management program is much the same: Management for Extinction–only slower and less visible than before. Many herds have achieved balanced population levels with little or no management but today all the $$ is on fertility control, short-term and sterilization, long-term–not on natural population control, because this won’t eradicate the herds as ordained by the power brokers in DV. Alas if we don’t wake up, expose and oppose the lies and subterfuge re: the widespread use of PZP soon, our iconic native wild horses may join blue and bowhead whales in the waiting line for extinction–sooner than later.

PM-Carl-Mrozek-NV-Mustang-marked

PM Burros Wild © Carl Mrozek

Carl Mrozek

Carl Mrozek’s nature clips are seen often on CBS Sunday Morning News. He is currently making a documentary on Wild Burros.

Palomino Mustangs on CBS News: http://www.cbsnews.com/videos/nature-wild-palomino-horses/

Pine Nut Wild Horses on CBS News: http://www.cbsnews.com/videos/nature-wild-horses/ (BLM tried to roundup and decimate this herd but Protect Mustangs stopped the roundup in court)

Red Rock Wild Horses on CBS News: http://www.cbsnews.com/videos/wild-horses-of-nevada-50087668/ (BLM removed them)

Cold Creek Wild Horses on CBS News: http://www.cbsnews.com/videos/wild-horses-of-nevada/ (BLM rounded them up and took them away)

 





Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Email: blm_ut_sulphur@blm.gov

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:

News Release — 2015 EA

http://www.blm.gov/ut/st/en/info/newsroom/2015/December/EAsulphurwildhorsegather.html

News Release — 2015 Public-Safety Removals

http://www.blm.gov/ut/st/en/info/newsroom/2015/february/public_safety_concerns.html

Sulphur Gather Environmental Assessment — Preliminary

http://www.blm.gov/style/medialib/blm/ut/natural_resources/wild_horses_and_burros/general.Par.73121.File.dat/Preliminary%20Sulphur%20Gather%202015%20EA_12_18_15.pdf
REASONS CITED FOR GATHER-REMOVE-CONTRACEPT PLAN
Overpopulation, Forage Limitations

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

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

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

http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p
Baseless and Biased Assumptions

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

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

http://www.ncbi.nlm.nih.gov/pubmed/23383018

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.

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

Imagine if such a catastrophe were to befall the 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.

http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html

Let’s do the math.

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

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

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

http://www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html
Population and Gather Reports — The Data

Discrepancies were evident per a review of the …

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

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

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

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

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

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

125 %
131 %
153 %
157 %
249 %

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

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

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

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

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

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

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

http://www.deseretnews.com/article/865643995/Judge-sentences-San-Juan-Commissioner-Phil-Lyman-to-10-days-jail-3-years-of-probation.html?pg=all
Bogus Data Inflames Local Ranchers and Costs Wild Horses Their Freedom

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

http://www.stgeorgeutah.com/news/archive/2015/11/01/mgk-finicum-blm-dispute-bundy/#.VjeBkW7ko1c

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 ….

http://www.opb.org/news/article/ammon-bundy-oregon-grazing-blm-finicum-crane/
QUESTIONABLE CAWP, FALSE REASSURANCES
CAWP Condones Abuse

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

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

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

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

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

http://thecloudfoundation.files.wordpress.com/2010/04/bruce-nock-report-final.pdf
BLM Fails to Address Results of Helicopter Hearing

The EA states:

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

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

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

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

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

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

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

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

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

http://www.ncbi.nlm.nih.gov/pubmed/7328557
BLM Lies about Gender Ratio

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

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

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

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

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

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

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

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

http://horseandrider.com/article/field-guide-to-horse-fences-13317

http://www.progressivecattle.com/topics/facilities-equipment/4793-building-fence-a-yearly-job-on-every-ranch

http://www.extension.iastate.edu/agdm/livestock/html/b1-75.html

http://www.rammfence.com/fence/coated-wire-fence/coated-wire-fence-rolls/high-impact-raceline-coated-wire.html
BLM Notes Interior Fences Block Wild Horses

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

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

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

BLM needs to stick to the facts and cease blaming wild horses for what livestock already did.
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Please consider these substantive comments and new information — new to BLM — and make the necessary course-corrections and reforms.
Sincerely,

Marybeth Devlin