URGENT: Stop BLM from using pregnant mares in Nazi-type sterilization experiments

Hundreds of pregnant mares were moved Friday January 22, 2016 from Palomino Valley Center (PVC) outside of Reno to the closed door facility in Fallon called Broken Arrow aka Indian Lakes.

Does BLM intend on using the pregnant mares from Beatys Butte in the horrible Nazi-type sterilization experiments in Oregon? These pregnant mares and members of their herd seem to have been rounded up because Country Natural Beefa supplier of Whole Food Market, was pushing for the roundup. Do they want the federally protected wild horses gone so they can use the public grazing land for beef?

Protect Mustangs officially requests the mares from Beatys Butte and all the mares at the Fallon facility be put up for adoption–not experimented on!

STOP the cruelty now! These are America’s icons of freedom.

Stop BLM from EXPERIMENTING on wild mares!

Sterilization experiments are cruel and with no merit

The Bureau of Land Management’s (BLM) overpopulation claims are fraudulent and any action such as experimentation for population control, fertility control, or other actions taken that are based on fraudulent information is wrongful. There are no “excess” wild horses on public land. Roundups have been based on fraudulent data. Read more about that here: http://protectmustangs.org/?p=8551

Americans must not allow tax dollars to fund experiments reminiscent of Dr. Joseph Mengele. The rights of American wild horses are being violated. Pregnant mares especially  must never be used in sterilization experiments!

There are no accurate head counts of wild horse populations, many herd management areas have no wild horses left on them,  and the BLM’s horrible customer service and poor marketing are the reason wild horse adoption has dropped. It’s as if the BLM wants their adoption program to fail.

Any and all experimentation based on the overpopulation myth must be stopped!

The BLM is proposing to conduct three research experiments “investigating the safety and effectiveness” of three separate methods of surgical sterilization of wild horse mares. The three proposed methods include ovariectomy via colpotomy (in photo above), tubal ligation and hysteroscopically-guided laser ablation of the oviduct papilla. The proposed studies would be conducted under financial assistance agreements with Oregon State University (OSU), with OSU staff serving as the principal investigators of the research. The three experiments combined would involve approximately 225 wild horse mares previously rounded up and removed from BLM Herd Management Areas (HMA). All three studies would be conducted at Oregon’s Wild Horse Corral Facility in Hines, Oregon and would be planned to begin in February 2016 with an estimated completion date of September 2020. This environmental assessment (EA) is a site-specific analysis of the potential impacts of the proposed action.

You are encouraged to write in your own words to oppose the wild horse sterilization experiment proposed on innocent wild mares. The deadline is February 3rd:

Mare Sterilization Research Project Lead
(541) 573-4411 BLM Burns District Office
28910 Highway 20 West
Hines, Oregon 97738
Email: blm_or_bu_mareresearchea@blm.gov
Fax: (541) 573-4411 — Attention: Mare Sterilization Research Project Lead

When writing your letter keep in mind the following:

  1. Your tax dollars are paying for the BLM’s programs, roundups and experiments if allowed to continue.
  2. There is no overpopulation of wild horses. They are underpopulated on the vast acreage of public land in the West.
  3. BLM’s harvesting model based management via roundups is disrupting herd dynamics and increasing the birthrate.
  4. BLM’s allegations of overpopulation are fraudulent based on false data. They don’t even account for the correct mortality rates in the wild.
  5. Predators should not be killed off and if there are none left then they need to be reintroduced for the thriving natural ecological balance.
  6. Wild horses are a return-native species that help reduce catastrophic wildfires and create biodiversity. We need the herds to reverse desertification.
  7. The BLM is creating a false overpopulation crisis to cash in on wild horses as laboratory animals for fertility control experiments while reducing the herds to nonviable levels.
  8. GonaCon™, PZP, SpayVac® are all pesticides that classify wild horses erroneously as pests–ultimately sterilize them and are not needed because wild horses are underpopulated. There are no “excess” wild horses.
  9. The BLM is trying to manage America’s wild horses to extinction.
  10. Sign and share the petition to stop the roundups here: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups
  11. Send your elected officials a handwritten letter and make an appointment to go in to see them.

Please contact your elected officials and politely request they take immediate action on your behalf to stop the experiments on wild horses. You can find the contact information for your elected officials here: http://www.contactingthecongress.org

Call & Email the following as well:

Oregon Governor
Kate Brown
Phone: 503/378-4582
Fax: 503/378-8970
Email: http://www.oregon.gov/gov/Pages/share-your-opinion.aspx

Senior Senator Ron Wyden
(the one who can stop this)
tel (202) 224-5244
fax (202) 228-2717
https://www.wyden.senate.gov/contact

BLM Oregon
State Director
Jerome E. Perez
Phone: 503-808-6026
Email: BLM_OR_Prospecting_EA@blm.gov

Share this with everyone you know.

Check back on our website for daily updates. Together we can stop this and turn this around.



Background reading:

BLM Press Release on Plans to Experiment with Sterilization Wild Mares: http://www.blm.gov/or/districts/burns/files/BU_MareSterilizationEA_Jan2015.pdf

Mare Sterilization Research Environmental Assessment https://eplanning.blm.gov/epl-front-office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdf

Mare Sterilization Research https://eplanning.blm.gov/epl-front-office/eplanning/projectSummary.do?methodName=renderDefaultProjectSummary&projectId=56292

 

 




Does PZP result in wild herds with lower immune systems and potential for die-offs?

PM Tule Elk Males FIghting by austlee

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]

 

Pm PZP Darts

Links of interest™:

Immunocontraception (Wikipedia): https://en.wikipedia.org/wiki/Immunocontraception

“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 disease (Wikipedia): https://en.wikipedia.org/wiki/Autoimmune_disease 

“Autoimmune diseases arise from an abnormal immune response of the body against substances and tissues normally present in the body (autoimmunity). . .”

 

ZonaStat-H is the EPA restricted-use pesticide–PZP–for wild horses and burros the registrant calls “pests”: http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

 

Tule elk: http://www.nps.gov/pore/learn/nature/tule_elk.htm

 

Tule elks at Pt. Reyes National Seashore (National Park Service): http://www.nps.gov/pore/getinvolved/supportyourpark/upload/volunteer_docent_info_tule_elk_elkmanagement_v5.0_1.pdf

 

Challenges face tule elk management in Point Reyes National Seashore  http://www.mercurynews.com/pets-animals/ci_28311296/challenges-face-tule-elk-management-point-reyes-national

“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.”

 

Paratuberculosis or Johne’s disease (Wikipedia): https://en.wikipedia.org/wiki/Paratuberculosis

 

Testing for Mycobacterium avium subsp. paratuberculosis infection in asymptomatic free-ranging tule elk from an infected herd.  http://www.ncbi.nlm.nih.gov/pubmed/12910759

“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.”

 

Epizootic of paratuberculosis in farmed elk http://www.johnes.org/handouts/files/Elk_outbreak.pdf

 

TESTING FOR MYCOBACTERIUM AVIUM SUBSP. PARATUBERCULOSIS INFECTION IN ASYMPTOMATIC FREE-RANGING TULE ELK FROM AN INFECTED HERD (Journal of Wildlife Diseases, : http://www.bioone.org/doi/pdf/10.7589/0090-3558-39.2.323

 

Immuno-Contraception Research for Managing Tule Elk Population – Phase I Scheduled to Begin on August 6, 1997 http://www.nps.gov/pore/learn/news/newsreleases_19970805_elkimmunocontraception97.htm

“. . . 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.]

 

Immuno-Contraception Research for Managing Tule Elk Population – Phase II Scheduled to Begin on June 15, 1998  http://www.nps.gov/pore/learn/news/newsreleases_19980615_elkimmunocontraception98.htm

“. . . 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…”

 

Copyright Protect Mustangs.org 2016





Tracy Mohr speaks out against against experiments to wipe out wild horses

The War on Wild Horses

The War on Wild Horses

Advocate sees how disturbed the Sheldon wildlife preserve wild horses are after decades of experimentation 

Tracy Mohr writes:

Here is a link: http://www.blm.gov/wo/st/en/prog/whbprogram/science_and_research/usgs_partnership.html to the BLM’s page of all the research they are proposing to do on the wild horses to “effectively manage them” on public lands. Keep in mind that the bottom line for BLM is that the proposed procedures, “when applied, are expected to result in a static to decreasing population level”.

In other words, the goal of all this research is to reduce the number of horses on public lands over time through permanent sterilization, with extinction being the eventual result.

If anyone is familiar with the concept of Trap-Neuter-Return (TNR) with feral cats, it is the method proven most effective to reduce and eventually eliminate feral cat colonies.

The most concerning part of all this is that according to the National Academy of Sciences (NAS) 2013 report, there is no scientific basis used by BLM to determine the number of horses that should be on the range, nor does BLM know how many horses are actually on the range. Population estimates have been know to be 800% higher than actual numbers. The NAS report also stated that current management practices (ie. removals) are actually contributing to higher rates of population growth due to decreased competition for forage and water.

So how can BLM say they need to reduce wild horse reproduction when they don’t really know how many horses are on the range or how many horses the range can hold?

Yet the BLM continues to reduce the number of horses allowed while increasing the number of livestock permitted to graze on public lands.

Make no mistake, the goal is to eliminate wild horses from public lands.

We currently have 45 horses from the Sheldon National Wildlife Refuge, and some of these procedures had been done on the horses prior to their removal. It is obvious to us that higher male to female ratios, and spaying of mares and gelding and vasectomizing of males, does affect herd dynamics.

This was not the intention of the Wild Free-Roaming Horse and Burro Act of 1971, which was to preserve wild horses and burros on the land where they were found, and keep them free from slaughter and harassment from man.

This research is not only unnecessary because there is no wild horse or burro overpopulation, but it is redundant, has already been shown to be detrimental to overall herd health, and will result in the eventual elimination of wild horses from our public lands.

~ Tracy Mohr, founder The Mustang Project

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.
——————————————-

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

Marybeth Devlin





Conversation about fertility control with Brett Hass, retired biologist previously with NSA (part 1)

Don’t let pesticides like Gonacon™, PZP or SpayVac® manage native wild horses to extinction. The Spin Dr.’s and some ignorant horse advocates are pushing fertility control on underpopulated wild horses. Know the truth and expose those spewing the spin.

PM Gonacon Pesticide Fact Sheet

Read the entire Gonacon™ Pesticide Fact Sheet

Interview

John Cox: Brett, you’re a retired biologist, previously with the NSA for how many years?

Brett Hass: 46 long years John. We met in Vietnam, when we a lot younger my friend (smiles). We were doing wildlife and vegetation studies in your AO (area of operations). That was my first assignment with the NSA, as a matter of fact.

John Cox: Let’s cut through all of that. What do you think of Gonacon™ and some of the other fertility controls BLM is using?

Brett Hass: As usual, and as government agencies do and BLM and DOI are extremely guilty, they pretend that science guides its wild horse and burro management strategies. So the agencies involved go forth and resolve issues, supposedly, with experimental drugs–in this case GonaCon™. The question is, in reality, does it resolve anything at all, or is it simply to further experimentations with this drug and the wild horses the most expendable of situations currently?

The problem is very obvious, with the first-time use of an experimental drug, they act like children with a new toy–but this toy is extremely dangerous, to not only the horses and actually lead them to extinction, but the environmental consequences are apparently neglected entirely? (shakes his head negatively). . .

But let’s get real, the very absence of science contradicts any time of sound reasoning for its use whatsoever. So once again we have a government agency, using a Nazi-Type experimental fertility drug on horses and other wildlife–without knowing, or even acknowledging for that matter, what the long-term consequences are–or in perception–the problems that will arise in its actual use.

There is no resolution, as I reviewed the population situation and see first hand there is no over-population if wild horses just within the BLM numbers alone; but livestock, that is a completely different matter, in reality.

John Cox: In your appraisal of the information you’ve read, would you, as a tenured Wildlife Biologist for over 50 years, use this drug?

Brett Hass: Absolutely not! There is no pertinent reasoning to use it right now and especially on wild horses or much of anything else for that matter. Our wildlife and environment is simply too important to be so frivolous with such activity, especially an unknown situation, as fertility drugs used in our natural environment. But as you say, ignorance is quite something, and our government seems to portray ignorance quite well, and frankly the only situation they seem to be competent to accomplish.

Much more on this discussion with Brett Hass later . . .

574px-Blm.svg

Below is the original PZP Pesticide Fact Sheet before HSUS seems to have lobbied the EPA to make changes to the chemical class. It’s still only approved as a pesticide to manage pests. PZP is made from slaughterhouse pig ovaries mixed with modified freund’s complete adjuvant.

PM PZP Test mares

(American wild horses used in fertility control experiments)

© John Cox, printed with permission

John Cox is a Vietnam Vet, living in the mountains of the Pacific Northwest who writes about the environment. He’s passionate about saving America’s wild horse herds and wolves. 

Read John Cox’s blog at: https://prophoto7journal.wordpress.com

Have you read about the Gonacon™ Experiment on the Water Canyon herd and the UNLUCKY 11 orphans? It all started as a PZP proposal and went down the slippery slope. . .  Read about it here: http://protectmustangs.org/?p=8488





BLM Fakes Population Growth to Wipe Out America’s Wild Horses

The feds’ mustang population “data” is a fraud 

By Marybeth Devlin

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.

TAKE ACTION: Sign and share by email the Petition to Stop the Wild Horse and Burro Roundups and Slaughter here: https://www.change.org/p/defund-and-stop-the-wild-horse-amp-burro-roundups

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

Click “Like” https://www.facebook.com/ProtectMustangs for updates and alerts

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 is the tool to compute CAGR:

http://www.miniwebtool.com/cagr-calculator/?present_value=100&future_value=200&num=4

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.

http://pages.uoregon.edu/rgp/PPPM613/class8a.htm

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%).

 





Complaint to the Office of the Inspector General regarding BLM killing 28 wild horses near Las Vegas

 

To the Office of the Inspector General at the United States Department of Interior

Dear Sirs,

We officially request a full investigation into the management of wild horses and land use planning 6 years before the roundup, the roundup itself, feeding, veterinary care and killing of the 28 Cold Creek wild horses who had become skinny.

  • Why didn’t the BLM help these federally protected wild horses get the forage they needed earlier?
  • Why didn’t the BLM move the native wild horses up to areas with more forage?
  • What happened to their forage?
  • What about the livestock grazing permits? (see attached)
  • What organizations were pushing for BLM to use PZP, a controversial EPA restricted use pesticide for “birth control”–made from slaughterhouse pig ovaries–that sterilizes after multiple use? http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf
  • Are the wild horses getting pushed out and killed as part of the New Energy Frontier–to put massive solar farms on fragile desert land and therefore impacting wildlife? https://eplanning.blm.gov/epl-front-office/projects/lup/2900/49868/54310/LV-RMP_Poster_Renewable_Energy.pdf
  • Why aren’t the Cold Creek wild horses getting their fair share of the land that is for their principal but not exclusive use according to the 1971 Free Roaming Wild Horse & Burro Protection Act?
  • Why is the agency appointed “appropriate management level” (AML) for wild horses so low when a genetically viable herd needs more members?
  • Why is the BLM limiting access to the public to bare witness to this cruel roundup?
  • Was euthanasia chosen for convenience and the bottom line, pure and simple?
  • Did they look at the feed and labor involved vs adoptability and take the cheap and easy way out?

Rescues and members of the public would have helped bring the Cold Creek wild horses back to health if manpower was an issue. Adoption would have been simple once they healed because people know about them and cherish them.

Tourists from around the world, visiting Las Vegas, love the wild horses of the American West.

The BLM continues to roundup more beloved Cold Creek wild horses and we pray they will not kill any more but nurse them back to health.

The public is outraged.

We thank you for investigating into the wrongdoings surrounding the management, roundup and killing of 28 Cold Creek wild horses, provide transparency and shine the light of truth.

Sincerely,
Anne Novak

 

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

Why does France TV 2 report mostly from the side of BLM and pro-slaughter advocates?

 


PM Photo Wild Horses ©AdventureJournalist

The overpopulation myth is dangerous

Recently France TV 2 came to the American West to report on the “problems” caused by the “overpopulation” of wild horses. Someone either fed them the story or they did a little research on Google about American mustangs and found the Bureau of Land Management’s (BLM) authoritative spin, vast website and their new America’s Mustang campaign to get their overpopulation message out, couched with pretty pictures and enticing video footage of huge herds running, helicopter roundups, etc. making news reporting easy. What foreign journalists would think the BLM is lying about wild horses chasing cows away from water sources when they have so much “factual” material out there to back up their position that there are too many wild horses?

France TV 2 reports:

From: http://www.francetvinfo.fr/monde/usa/video-les-chevaux-sauvages-se-reproduisent-trop-vite-un-probleme-pour-l-ouest-americain_949025.html

Synopsis Translation:

Wild horses reproduce too fast, a problem for the American West

The United States prohibits mustang slaughter but the same authorities want to limit their number to 25,000 although there are already 50,000 on the land

Mustangs are no longer welcome in the American West. Federal authorities ring the alarm for the overpopulation of wild horses on the land. There will be 150,000 in five years if nothing is done to stop their expansion. A bigger problem than the horses reproducing quickly and devouring everything on their path, according to the administration, is what is creating conflicts with certain ranchers.

2,000 horses were removed in 2015, an insufficient number

The Unites States prohibits slaughtering mustangs, but the same authorities want to limit their number to 25,000 but 50,000 mustangs are on the land. The ranchers who share the land with the wild horses won’t tolerate limited access to water sources in areas invaded by wild horses. The mustangs chase off their livestock.

In total, 2,000 chevaux were gathered in 2015, an insufficient number to reach the fixed objective, but the animal defenders call the process barbaric. Different methods have been launched without results, and that’s pushing the federal authorities to propose an award of one and a half million dollars to find a long lasting solution for the wild horse problem.

BLM’s spin dominates news report

Sadly the myths reported as truth in the France TV 2 news report were not countered effectively and the good counter points ended up in the trash. The journalists interviewed BLM staff on the range. They met with ranchers who push the overpopulation myth and are pro-slaughter–including Callie Hendricksen. They interviewed Carol Walker, photographer,  legal plaintiff and board member of Wild Horse Freedom Federation at a watering hole with a lot of mustangs. The journalists reported on training at a prison program with failed adoptions being the undertone. France TV 2 seems to have heard from all sides of the issue to be fair but who were their handlers? Was it Callie Hendrickson or BLM’s staff over at their America’s Mustang campaign? The news editor crafted the story from the materials shot in the field resulting in the BLM and pro-slaughter viewpoint out in front. The whole story focused on the alleged overpopulation of wild horses in a country that prohibits slaughter with the feds offering $1.5 million to whoever find the lasting solution for population control. Sounds like the BLM pitched this story to push their heinous agenda.

The French report shows the advocacy where we are losing the battle. . . We are split. . .  A portion of the advocacy is supporting the overpopulation myth and offering solutions to the false problem. Are there really too many native wild horses left in the wild?

Overpopulation must exist to justify radical zero growth fertility control measures such as PZP, castration, field spaying and slaughter

When wild horse groups support BLM’s overpopulation myth–with advocates pushing PZP as the “solution” to the “problem”–the overpopulation myth gets stronger and is eventually seen as truth. Reporting on myths as truth is a tactic used to sway public opinion–the second largest super power according to the President of the United States.

If we don’t all stand up to disprove the overpopulation myth then slaughter, sterilization and cruel roundups will be the end result.

PZP, made from slaughterhouse pig ovaries, is used for slow extermination because science proves it sterilizes after multiple use while the general public doesn’t notice. It’s a way to manage them to extinction, period. Proponents of the one foal only policy are jeopardizing survival of the species. What happens when the mare is sterilized through PZP applications and her “one foal” dies in the wild?

BLM has no accurate head counts of wild horses. The National Academy of Sciences stated in their 2013 report that there is “no evidence” of overpopulation, period.

Time to stand together

It’s time for all advocates to come together to protect wild horses. Together we are a mighty force for the wild ones.

I challenge all group leaders and advocates to put aside personal differences, break their contracts with BLM and agree to fight together to protect America’s wild horses for once and for all. Together we can do this.

Many blessings,

Anne

 

Anne Novak

Executive Director

www.ProtectMustangs.org

Contact@ProtectMustangs.org

 

Links of interest™:

France TV reports on the overpopulation problem: http://www.francetvinfo.fr/monde/usa/video-les-chevaux-sauvages-se-reproduisent-trop-vite-un-probleme-pour-l-ouest-americain_949025.html

U.S. looking for ideas to help manage wild-horse overpopulation (Washington Post): http://www.washingtonpost.com/national/health-science/us-looking-for-ideas-to-help-manage-wild-horse-overpopulation/2014/01/26/8cae7c96-84f2-11e3-9dd4-e7278db80d86_story.html?wprss=rss_national

Outrage over secret documents planning to kill or slaughter 50,000 native wild horses: http://protectmustangs.org/?p=777

Petition to Defund and Stop Wild Horse Roundups: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups

The Atlantic reports on Callie Hendrickson’s contentious appointment to represent the public on the Wild Horse & Burro Advisory Board in 2012: http://www.theatlantic.com/national/archive/2012/02/the-lasso-tightens-around-americas-wild-horses/252948/

Callie Hendrickson: http://www.zoominfo.com/p/Callie-Hendrickson/277533708

EPA pesticide fact sheet on PZP: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

Native wild horses are not pests ~ Stop managing them to extinction

Dear Friends of Wild Horses and Burros

Protect Mustangs is a national nonprofit organization making grassroots count. Our mission is to protect and preserve native and wild horses. Besides engaging mostly in outreach and education about the wild horse crisis, we advocate for holistic land management, self-sustaining herds and reserve design. We are calling for a 10 year moratorium on roundups for the herds to recover from the roundups and for studies to form good management plans. Right now there are no accurate census counts on the range so we don’t even have a clear picture of the few wild horses left living in freedom.

Our members don’t see an overpopulation or “excess” of wild horses on public land, even if the population is over BLM’s biased appropriate management level (AML). Livestock outnumbers wild horses more than 50 to 1 on the range. Yet wild horses are always scapegoated for damage by special interest groups.

We are deeply concerned that the use of FDA approved “restricted use pesticides” such as PZP–an immunocontraceptive made from pig ovaries that people call birth control–sterilizes mares after multiple uses and should never be used on nonviable herds, those herds with less than 150 wild horses. Genetic diversity is essential for survival and using PZP surely will curtail that. There is one herd in Nevada currently being treated by wild horse advocates that seems to have less than 50 wild horses. This worried us.

Wild horses are a native species and not pests. Sadly there are factions who are treating wild horses as individuals and ignoring the herd element and other factions treating wild horses as invasive pests.

Despite decades of experimental research on wild mares, the FDA would not approve PZP as safe. Eventually the EPA approved it as a restricted use pesticide. You can see the pesticide fact sheet here: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

How can drugging mares with restricted use pesticides be honoring their freedom? Most of the time the BLM will need to round them up to dart them anyway. You can hear the BLM official speak about that here: http://www.thespectrum.com/videos/news/local/cedar-city/2014/08/06/13698391/

We are also concerned PZP and other sterilants affect behavior and that mares will be subjected to live in unnatural situations.

Ruining survival of the fittest and natural selection is our biggest concern if man chooses who breeds and how many foals are born. The herds must adapt to upcoming environmental and climate changes in order to survive, therefore genetic variability is essential at this pivotal time.

You can read about PZP on these various posts: http://protectmustangs.org/?s=PZP+&submit=Search

Here you can read about Gonacon on these posts: http://protectmustangs.org/?s=gonacon&submit=Search

This is also a good post to read about the ISPMB and Princeton study that shows wild horse herds with functional social structures contribute to low herd growth compared to BLM managed herds: http://protectmustangs.org/?p=6057

You can search other topics you might have questions about in our search bar too: http://protectmustangs.org

We are 100% volunteer and are working to help the wild horses without any conflict of interest as far as we can tell. We do not receive funding from influencers, corporations or organizations connected with the drug PZP, the pharmaceutical industry, Big Oil and Gas or other energy, ranching and mining sources. That’s why your donations are so important.

Our vision is to speak out for the voiceless, stop the BLM from being cruel to wild horses and work towards a solution for healthy management keeping wild horses on the range based on good science. We have a petition out for the 10 year moratorium on all roundups. Please sign and share it here: http://www.change.org/petitions/sally-jewell-urgent-grant-a-10-year-moratorium-on-wild-horse-roundups-for-recovery-and-studies

Thank you for reaching out to us. It’s important to do the research and find the answer for yourself so you can feel good about taking action to help save the last of the wild horses and burros.

We are grateful you care so deeply about saving America’s wild ones.

Many blessings,
Anne

 

Anne Novak
Executive Director
Protect Mustangs
San Francisco, California

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: http://protectmustangs.org/?page_id=218

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

 

 

Associated Press reports: Feds seek extra holding space for western mustangs

Wild War Horse (Photo © Cynthia Smalley, all rights reserved.)

Wild War Horse (Photo © Cynthia Smalley, all rights reserved.)

by Martin Griffith Associated Press

RENO, Nev. (AP) — Federal land managers are under fire from animal welfare activists for seeking extra holding space for wild horses removed from western rangelands.

With current facilities nearing capacity, the U.S. Bureau of Land Management is accepting bids until Aug. 29 from contractors interested in either operating short-term corrals in 31 states in the Midwest and East or long-term pastures.

After removing horses from the range, the bureau places them in short-term facilities until they are either adopted or shipped to pastures in the Midwest where they spend the rest of their lives. The agency routinely thins what it calls overpopulated herds on public land.

BLM officials, in a statement Thursday, said they plan to open “multiple” short-term corrals that can handle at least 150 horses each in various states along and east of the Mississippi River. They also seek one or more long-term pastures that can accommodate from 100 to 5,000 mustangs each.

The bureau has not yet awarded contracts for bids it received earlier this year from contactors interested in running short-term corrals in 17 states in the West and Midwest.

Bureau spokesman Tom Gorey said the total number of new holding facilities and their cost would depend on the number and quality of bids submitted. About two-thirds of the agency’s budget covers holding costs.

“We want to get out of the holding business, but at the moment that’s not possible,” Gorey told The Associated Press. “The bottom line is we have to make sure we have enough off-range holding for horses that are removed.”

Budget constraints are prompting the bureau to remove just 2,400 wild horses and burros from the range during the fiscal year ending Sept. 30, down from 4,176 in 2013 and 8,255 in 2012. The vast majority of animals targeted for removal are horses.

But horse advocates criticized the agency’s plans for more holding space, saying it continues to “stockpile” horses at a growing cost to taxpayers with about as many mustangs now living in holding facilities as on the range.

“The BLM continues to refuse to reform its broken wild horse program,” said Suzanne Roy, director of the American Wild Horse Preservation Campaign. “The agency is intent on sticking American taxpayers with the bill for rounding up and warehousing captured mustangs instead of listening to the scientists and the American public, and humanely managing wild horses and burros on the range.”

Gorey said activists’ demands to halt the removal of horses from the range are unrealistic because herds grow at an average rate of 20 percent a year and can double in size every four years.

According to the latest figures provided by the BLM, a total of 49,209 horses and burros freely roamed 10 Western states as of March 1, the vast majority of them mustangs. That estimate exceeds by more than 22,500 the number the BLM has determined can exist in balance with other public rangeland resources and uses.

Off the range, there were 47,272 wild horses and burros in short-term corrals and long-term pastures as of July 30, the agency said.

Anne Novak of the California-based group Protect Mustangs accused the bureau of inflating horse numbers to justify their removal from the range to accommodate ranching, mining and oil and gas interests.

“The truth is we never see an overpopulation of wild horses on public land,” she said. “Overpopulation is a farce made to milk Congress for more money to clear public land for industrialization.”

Cross-posted from the Denver Post for educational purposes: http://www.denverpost.com/breakingnews/ci_26264815/feds-seek-extra-holding-space-western-mustangs This article has gone viral.