The Modoc National Forest starts wild horse roundup from private and tribal lands today

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The Modoc National Forest started a wild horse roundup from private and tribal lands Sept. 26

According to the Forest Service, public viewing opportunities at the trap site will be available on a first come, first served basis for up to 14 people each day. Members of the public wishing to view the helicopters  chasing wild horses into traps must arrive an hour and a half prior to gather activities at Forest Headquarters, 225 W. 8th St., in Alturas, follow forest personnel to the trap site and remain at the viewing location until operations are completed for the day.

Viewers should bring plenty of water, lunch, stout footwear, hat and their own chair. There will be an approximate one-mile hike over rocky terrain from the parking area to each of the trap sites. The weather is expected to be hot and dry, and there is little shade available.

Members of the public will be asked to remain in a blind in order to avoid disrupting gather activities. Safety of visitors, gather personnel and the horses is top priority. The use of drones in the area will not be allowed due to safety concerns.

Public viewing will also be available at the temporary holding facility at Willow Creek Ranch, during the hours of 3–5 p.m. on days roundup activities occur. Operations may not occur every day, but as contractors determine.

Anyone interested in viewing roundup operations at taxpayer expense should contact Public Affairs Officer Ken Sandusky at (530) 233-5811.

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




Secret documents from 2008 reveal plan to kill and dispose of America’s wild horses and burros

© 2014 Anne Novak, all rights reserved.

© 2014 Anne Novak, all rights reserved.

 The Bureau of Land Management plots to wipe out wild horses and burros at taxpayer expense.  Is this how you want your tax dollars used?

“Jim says Burns takes them to a pit but they have always used it  . . .”

Notice that Pesticide PZP, made from slaughterhouse pig ovaries, is part of their wipe out plan. It sterilizes after multiple use. Their goal is zero population increase which would ruin natural selection and make it impossible for the species to survive climate change.

Members of the public and some organizations have been fooled into supporting Pesticide PZP as the “lesser of two evils”. Follow the money if you want to understand who profits from forcibly drugging wild mares with Pesticide PZP for population control.

The Humane Society of the United States (HSUS) is the registrant of Pesticide PZP https://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf. HSUS called native wild horses and burros “PESTS” on the EPA Pesticide Application. Have they changed the legal definition of wild horses and burros with the EPA application that should be revoked?

Scott Beckstead, who was born and raised on a working cattle ranch and now works for HSUS, reported at the BoLM’s Spring 2016 Wild Horse and Burro Advisory Board meeting that HSUS is experimenting on a stronger form of Pesticide PZP. Does “stronger” mean their new form of Pesticide PZP will forcibly sterilize native wild horses and burros with one injection?

Wild horses and burros are underpopulated on public land which is overpopulated by beef cattle and sheep. Ranchers, BoLM and others try to scapegoat wild horses and burros for range damage when the truth is commercial livestock is destroying, or already has destroyed, the ecosystem.

July 29, 2008

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“GonaCon® is also a product that needs to be relooked at for sterilization of mares.” (Quoted from item 4 above)

Read about the GonaCon® experiment at Water Canyon that launched in 2015: http://protectmustangs.org/?p=8488 They have hopes to use GonaCon™ on the whole Antelope Complex.

 

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August 12, 2008

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PM Aerial Photo 6

Thanks to Jane Cheuvront for the Google Earth photo)

Read our August 11th blog post: What’s in the mounds, craters and pits at American wild horse holding facilities? http://protectmustangs.org/?p=9458

See all the notes from the secret conference calls in 2008 about killing off America’s wild horses and burros: pm-blm-secret-killing-conference-calls-2008

 

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Special thanks to Dr. Patricia Haight, RIP, for acquiring the documents through FOIA.

See the draft of the BLM Wild Horse and Burro Program Alternative Management Options from October 2008 the result of the secret conference calls: pm-blm-killing-plans

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(Fred T. Woehl, Jr. and Sue McDonnell, PhD. for Wild Horse & Burro Research are some of the Wild Horse and Burro Advisory Board members, who voted on September 9, 2016, to kill the alleged “unadoptable” wild horses and burros)

 

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




Fraudulent figures, sterilization and underpopulation

PM Burros Wild 2 © Carl Mrozek

To:  Heather van Blokland at KJZZ

Rio Salado College and Maricopa Community College, Arizona

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sincerely,

Marybeth Devlin

Miami, FL

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




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

Pm PZP Darts

Made with slaughterhouse pig ovaries PZP is dangerous to herd health

To:  Jacob Bunge, Wall Street Journal

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sincerely,

Marybeth Devlin

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

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

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




Conflict of interest, wild burros and pesticide PZP

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

(Photo Credit Rylee Isitt/WikiCommons)

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

Postmarked or Received by:

August 15, 2016

To:

BLM-Arizona

State Office

Colorado River District Office

Kingman and Lake Havasu Field Offices

Copies to:

CEQ, DOI, and BLM National Office

with hard-copy via Priority Mail to:

Bureau of Land Management

Kingman Field Office

2755 Mission Boulevard

Kingman, AZ  86401

Subject: Black Mountain Wild Burros

Project: PZP Fertility-Management Pilot

Proposed by: Humane Society of the United States

Document: Environmental Assessment ( EA )

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

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

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

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

BACKGROUND

The Proposal

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

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

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

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

Annual Roundups Probable

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

CONFLICTS OF INTEREST

HSUS — PZP’s Registrant

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

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

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

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

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

Mandate to Practice Scientific Integrity

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

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

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

FALSE PREMISES, FRAUDULENT NUMBERS

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

False Premise #1 — Lack of Predators

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

Healthy Predators, Healthy Ecosystem

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

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

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

Predator Reintroduction

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

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

False Premise #2 — High Reproductive Rate

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

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

Herd-growth rate Birth rate

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

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

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

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

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

Fraudulent Numbers

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

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

Fraudulent Estimates

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

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

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

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

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

    (1)     (2)     (3)

DeviationDeviationDeviation

from 15% from 7%             from 2%

per BLMper Studyper Study

without without with 5%

Foal orAdult Adult

PopulationGrowthAdult Mortality Mortality

Year Estimate Rate Mortality

2013   800   n/a    n/a    n/a    n/a

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

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

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

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

Arbitrary Management Level (AML)

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

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

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

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

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

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

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

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

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

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

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

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

How Would the New Levels Look?

Here are some numbers to compare and contrast.

Black Mountain HMA

Size:  925,425  total acres

Current Maximum Management Level:   478  wild burros

Acres per burro:  1,936

Current Exaggerated Population Estimate: 1,551  wild burros

Acres per burro:     597

IUCN Minimum Herd Size: 2,500  wild burros

Acres per burro:     370

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

Acres per burro:     185

Genetic Health of the Black Mountain Burros

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

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

The correct sampling approach and order are:

Sample current and continuing herd members.

Sample first, before considering any actions.

Sample large — 100 percent.

Test samples.

Manage per test-results and best-available science.

PZP — ADVERSE EFFECTS

PZP — The Pesticide

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

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

PZP — an Anti-Vaccine

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

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

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

PZP’s True Mode-of-Action

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

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

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

Included as a reference to the EA?  No.

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

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

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

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

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

Included as a reference to the EA?  No.

PZP Causes Ovarian Cysts

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

Included as a reference to the EA?  No.

PZP    Endocrine Disruptor    Elevated Testosterone    Masculinizing Effects   

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

PZP    Ovarian Cysts    Elevated Testosterone    Masculinizing Effects

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

PZP Causes Additional Adverse Effects

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

PZP Selects for Weak Immune Function

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

PZP Confers Dubious “Benefit” of Increased Longevity

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

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

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

Stillbirths;

Altered ovarian structure and cyclicity;

Interference with normal ovarian function;

Permanent ovarian damage; and

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

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

Included as a reference to the EA?  No.

Stillborn Foals — Recent Stillbirths Correlated with PZP

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

Included as a reference to the EA?  No.

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

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

Included as a reference to the EA?  No.

Why Do PZP-Treated Mares Steal Foals?

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

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

Foal-Stealing — Hormonal Hypothesis

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

Who is close to giving birth or

Who is separated from her own neonate or

Whose foal has recently died.

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

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

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

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

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

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

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

Included as a reference to the EA?  No.

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

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

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

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

A prolonged breeding season and

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

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

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

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

Included as a reference to the EA?  No.

Prolonged Delay in Recovery of Fertility

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

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

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

Ransom Advises Proceeding with Caution regarding PZP

The Ransom et al. study warned:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Included as a reference to the EA?  No.

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

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

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

PZP Continues the Use of Roundups and Removals

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

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

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

  

Risks to Humans Who Administer PZP Injections

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

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

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

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

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

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

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

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

Mandate to Practice Scientific Integrity

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

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

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

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

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

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

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

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

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

PZP — Conclusions about

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

ADDITIONAL CONCERNS AND INFORMATION

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

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

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

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

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

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

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

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

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

Bighorn Sheep — Study Shows No True Competition from Burros

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

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

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

Facilitation and Commensalism — Equids Enhance Livestock Production

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

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

Symbiosis — Burros Graze Old Growth — Cattle Prefer New Growth

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

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

ESTHETICS UGLIFIED VISITOR-EXPERIENCE RUINED

Scarlet Letters

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

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

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

Recreation and Wild Burro Viewing

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

Sincerely,

Marybeth Devlin


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




REFERENCES

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

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

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

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

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

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

37.  United States Department of the Interior.  Integrity of Scientific and Scholarly Activities Policy.  Code of Conduct.  Retrieved from https://www.doi.gov/scientificintegrity

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

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

39.  U.S. Department of Health and Human Services.  National Institutes of Health.  Endocrine Disruptors.  Retrieved from http://www.niehs.nih.gov/health/topics/agents/endocrine/

40.  U.S. Department of the Interior.  Bureau of Land Management.  Wild Horse and Burro Program Data.  Retrieved from   http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html

41.  U. S. Fish & Wildlife Service.  Ecological Services, Southwest Region.  The Mexican Wolf Recovery Program.  Retrieved from https://www.fws.gov/southwest/es/mexicanwolf/BRWRP_home.cfm

42.  U.S. National Library of Medicine.  National Institutes of Health.  Ovarian overproduction of androgens.  Retrieved from https://www.nlm.nih.gov/medlineplus/ency/article/001165.htm

43.  Varras M, Anastasiadis A, Panelos J, Balassi E, Demou A, Akrivis CH.  (2013)  Autoimmune oophoritis: Clinical presentation of an unusual clinical entity.  OA Case Reports 2013 Jan 31;2(1):7.  Retrieved from http://www.oapublishinglondon.com/article/369#

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

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

46.  World Atlas.  (2016, February 12 — Last modified)  Burro Facts: Animals of North America.  Retrieved from http://www.worldatlas.com/articles/burro-facts-animals-of-north-america.html

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




RED ALERT: Sage Creek (#1478) from Sarge’s herd has 3-Strikes, is miserable and needs to get to sanctuary not slaughter!

PM SAGE CREEK #1487 6 yr mare Fish Creek

Was Sage Creek (#1478) given Pesticide PZP like so many of the Fish Creek mares from Sarge’s herd who were rounded up, forcibly drugged but never released?

Look how the Bureau of Land Management inflates population numbers to justify roundups and the need for Pesticide PZP:

Fish Creek (NV)
256 = Population-estimate 2013
461 = Population-estimate 2014, before foaling season (January)
80.1% = Percentage increase in one year? Looks like some funny numbers!

Here are some Fish Creek mares at the BLM’s facility in Fallon, Nevada in 2015. They were going to be given Pesticide PZP and returned to the range but many were never returned. How many were slammed with 3-Strikes and where are they?

Can you find Sage Creek in with her relations?

Fish Creek Mares Indian Lakes aka Broken Arrow 2015

The BoLM doesn’t want to use widespread PZP they want a one-shot quick way to sterilize America’s wild horses based on the false premise that wild horses are overpopulated and need fertility control. . . when the truth is they are being managed to extinction!

Supporting PZP only supports the BLM’s divide and conquer game to ruin a united force to protect America’s wild horses. It’s time to focus on the wild horses not pesticides.

Now Sage Creek looks horrible and should be honored with a life in sanctuary away from those who brutally ripped her from her family and freedom when they rounded up the Fish Creek wild mares for Pesticide PZP–made from slaughterhouse pig ovaries.

PM SAGE CREEK #1487 6 yr mare Fish Creek Skinny

Here is what the Bureau of Land Management says about Sage Creek (#1478):

Sex: Mare Age: 6 Years   Height (in hands): 14

Necktag #: 1478   Date Captured: 02/19/15

Freezemark: 10621478   Signalment Key: HF1AAAAFJ

Color: Red Roan   Captured: Fish Creek (NV)

Notes:

Tag-#1478. 6 year old red roan mare gathered from the Fish Creek Herd Area in Nevada in February of 2015.

This horse is currently located in Palomino Valley, NV.  For more information, please contact Jeb Beck at (775) 475-2222 or e-mail: j1beck@blm.gov

For more about the sale program, go to:

http://www.blm.gov/wo/st/en/prog/whbprogram/adoption_program/sales.html

Update August 10: BLM said, “If no bids were placed on an animal in the last internet and a bidder that didn’t get the horse they choose as first pick didn’t decide to take a horse with no bid then those horses with no bids are available for pickup at PVC till August 22. After that date any remaining horses will be put on the next internet adoption. . . horses are available for pick up FROM PVC ONLY we will not ship as the truck is full at this point.”

From Protect Mustangs:

You can help by sharing Sage Creek’s (#1478) post to find a sanctuary who will give her a safe forever life and help her improve her body condition. Sage Creek never deserved to be forcibly drugged with Pesticide PZP under the false promise of returning to the wild, get 3-Strikes and become at-risk of ending up at slaughter. Share to help save her now!

Together we can turn this around.

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




Poppy (#1196) deserves to live in safety

PM Poppy #1196 3-Strike PVC FB

Poppy (#1196) is from the Silver King Herd Management Area (HMA) in Nevada. She was 5-years-old when she was rounded up to never have any sense of freedom or family again.

This American mustang survived in the wild as a foal when so many perish due to natural causes. Life in the wild is harsh and only about 50% of the foals born will live to be 2-years-old. This is survival of the fittest and exactly what makes American mustangs such a strong and special breed.

Now Poppy is 7 and has been help captive for 2 years without shade or shelter . . .

Please Help Poppy! She has been passed over in 3 adoptions because her photos are bad. That shouldn’t ruin her life. It’s not her fault.

By sharing this post on Facebook, Twitter and by email you can help Poppy find her forever home. She is for sale for $25 and she is wild. That means she will need to go to a trainer for gentling or her new person would need to borrow a high fenced round pen and gentle her like so many people do–with LOVE and patience.

Together we can make this happen!

BoLM says:

Sex: Mare Age: 7 Years   Height (in hands): 14

Necktag #: 1196   Date Captured: 11/11/14

Freezemark: 09621196   Signalment Key: HF1CAAEAD

Color: Brown   Captured: Silver King (NV)

Notes:

Tag-#1196. 7 year old brown mare gathered from the Silver King Herd Management Area in Nevada in November of 2014.

Sale information is here: http://www.blm.gov/wo/st/en/prog/whbprogram/adoption_program/sales.html

Update August 10: BLM said, “If no bids were placed on an animal in the last internet and a bidder that didn’t get the horse they choose as first pick didn’t decide to take a horse with no bid then those horses with no bids are available for pickup at PVC till August 22. After that date any remaining horses will be put on the next internet adoption. . . horses are available for pick up FROM PVC ONLY we will not ship as the truck is full at this point.”

This horse is currently located in Palomino Valley, NV.  For more information, please contact Jeb Beck at (775) 475-2222 or e-mail: j1beck@blm.gov

Stop the Roundups for Experiments, Pesticide PZP and removals!

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




Groups who want Pesticide PZP used on America’s last wild horses

 

According to a press release by Return to Freedom Sanctuary, who seems to have received money from the BLM in the past, the following groups want to use PZP on wild horses:

Alliance of Wild Horse Advocates

American Society for the Prevention of Cruelty to Animals

American Wild Horse Preservation Campaign

Animal Legal Defense Fund

Animals Voice

Animal Welfare Institute

Black Hills Wild Horse Sanctuary

Center for Animal Protection and Education

Citizens Against Equine Slaughter

The Cloud Foundation

Corolla Wild Horse Fund

Friends of a Legacy

Front Range Equine Rescue

Habitat for Horses

Hidden Valley Wild Horse Protection Fund

Horses for Life Foundation

Humane Society of the United States

Jicarilla Mustang Heritage Alliance

Least Resistance Training Concepts

Lifesavers Wild Horse Rescue

Montgomery Creek Ranch

National Mustang Association, Colorado Chapter

Oregon Wild Horse & Burro Association

Photographers for the Preservation of Wild Horses and Burros

Pine Nut Wild Horse Advocates

Respect 4 Horses

Return to Freedom Wild Horse Sanctuary and Preservation

Salt River Wild Horse Management Group

Serengeti Foundation

Southern Sun Farm Sanctuary

Steadfast Steeds

Virginia Range Wildlife Protection Association

Wild Equid League (Colorado)

Wild Horses of America Foundation

Wild Horse Connection

Wild Horse Education

Wild Horse Observers Association

Wild Horse Preservation League

Pm PZP Darts

 

PZP = Slow Extinction

 

Don’t let yourself be fear mongered. Read the Science Against PZP:

The Fact Sheet on PZP: http://protectmustangs.org/?p=8749

PZP is Dangerous: http://protectmustangs.org/?page_id=6922

 

PM No Evidence Overpopulation

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




Did you join the group requesting Nazi-like sterilization experiments on pregnant wild mares?

© EquineClinic.comn shared for educational purposes

© EquineClinic.comn shared for educational purposes

See the list of sterilization activists who are asking for sterilization experiments on wild mares below

A group of Pro-Experiment activists on a Bureau of Land Management (BoLM) support Facebook page called Wild Horses, BLM and Logical Solutions (https://www.facebook.com/groups/1446611602254365/) , have asked the BoLM to experiment on wild horses. They wrote a letter calling for the Oregon sterilization experiments. They also asked for PZP to be used on the more tame herds. Pro-Experiment activists in their group signed it. Pro-Slaughter activists signed it too.

If you have “joined” their group–just to watch what this treacherous group of Pro-Slaughter, Pro-Experiment, Pro-Livestock, Pro-Pesticide PZP activists, BoLM employees and supporters, etc. are up to–know that they count all their group members as people supporting their agenda for sterilization experiments on wild pregnant mares in Oregon and elsewhere.

Recently one of their admins boasted, “We have 2,000 members . . . “.

We were very shocked to see The Cloud Foundation board member, Linda Gresham Hanick, vocal in the Wild Horses, BLM and Logical Solutions group but since this group not only pushes for sterilization experiments on pregnant mares but also pushes for Pesticide PZP–like the Cloud Foundation who calls and partners with BLM for Pesticide PZP–we understand why their board member might be there. (http://www.blm.gov/style/medialib/blm/mt/main_story.Par.31432.File.dat/TopStoryHorse.pdf)

Hanick seems to have been also a vocal member of a group Facebook shut down for Harassment and Hate Speech targeting our volunteer executive director, Anne Novak who created the Forum on PZP for Wild Horses & Burros on Federal Land (https://www.facebook.com/groups/ForumPZPWildHorsesBurros) educating thousands of people on Pesticide PZP. Novak is against experimenting on wild horses, against horse slaughter and a strong advocate for wild horse freedom often quoted in the news.

I Hate Group Reviewed by FB and Closed screen Shot 2016-05-06 at 12.29.26 AM

Many of the signors of the Ovarian Ligation and PZP letter were active members of a public group Facebook shut down for Harassment and Hate Speech targeting Anne Novak. Keep in mind Novak and other members of the Alliance for Wild Horses and Burros have been speaking out against the experiments since they announced them.

We have evidence of members of the Hate Group engaging in stalking, harassment, hate speech, etc. plotting to interfere with Anne Novak’s work, Protect Mustangs‘ mission as we as the mission of The American Wild Horse Institute, care of the wild horses rescued back from the slaughterhouse known as the Wyoming 14™ (WY14™) plus others and evidence of their plot to smear Novak’s good reputation and more.

Below are the names of the members of Logical Solutions who signed the letter calling for sterilization experiments on pregnant mares:

Proposal of Ovarian Ligation
By Sandee Force on Monday, August 24, 2015

From: Members of Wild Horses, BLM and Logical Solutions

To: U.S. Wild Horse and Burro Advisory Council

Re: Population Management of wild herds on HMAs

The members of the Wild Horses, BLM and Logical Solutions have spent time considering potential solutions to the ever increasing number of horses and burros needing to be removed from the range held in both Long Term Holding and Short Term Holding. We feel that a two pronged program would both greatly decrease the number of animals needing to maintained in this manner and allow older mares to live out their lives on the range.

We would like to suggest that ovarian ligation be put into an immediate test program in at least 2 and preferably 3 herds using herds that are widely watched and recorded by regional photographers. Our suggestion would allow for mares that are old enough to have had at least 4-5 foals accessed at gathering and removed to the closest holding facility to do ovarian ligation by a veterinarian who has experience in this procedure. We would suggest that working with the state veterinary school located closest to each facility would be the optimal way to get young vets trained on this procedure and to potentially hire vets specifically for the program from this pool of trained professionals.We realize that standard policy would normally be to spend a number of years doing in pen trials with horses that would be scheduled to go to LTH. We feel that this can be bypassed by using herds that are currently being observed and by training the photographers to record information on these mares that would give accurate information about how they assimilate back into the herds. We would like to suggest that along with the ovarian ligation all fillies 3 and under be given PZP and allowed to be more mature at first foaling.

To summarize our proposal as accurately as possible, allowing for changes needed by region or herd.

1. Two to three test herds be chosen that mares will be brought in and those 3 and under be given the correct dosage of PZP for their age and mares that are of an age to have 4-5 foals on the ground have the ovarian ligation procedure done to at the holding
facility. Those mares that are operated on can be held for an appropriate period for recovery at the facility to document reaction and to ensure proper healing of all incisions before being returned to the area that they were captured. Any foals that are under weaning age should stay with the mare in the holding facility and be release with her. Use a
small hip brand to designate ovarian ligation for observation purposes.

2. Any mare that shows a major genetic defect or has thrown multiple foals with genetic disorders should automatically be put into the ovarian ligation program no matter what the age.

3. Train photographers and volunteers to work with the USGS and Universities to properly document range interaction of both the mares who have been given ovarian ligation and those fillies given PZP. Video and photographic documentation of herd/band interaction would be ideal. It is imperative to have USGS and at least one University involved in both
documentation and study of the effect of ovarian ligation on herd dynamics and the health and well being of both, mares and foals as well as the local bands that they belong to.

4. Document the short and long term consequences of ovarian ligation on the mares, i.e. heath, longevity, and acceptance/position within the band. Note if the mares are removed from the bands and act like bachelor stallion bands.

5. Within 3 years if the results of the test herds are good expand to other BLM managed herds with the goal to cut down on required gathers to once every 6-8 years.

6. Look into the possibility of darting with PZP every 2 years to expand the time young mares have a chance to mature before starting to foal.

The goal of this plan is to decrease the rate of population growth on the range.
In conjunction it would allow these older mares to stay on the range without adding to population growth until their deaths and not have to be gathered and shipped to Long Term Holding Facilities for their senior years. Between the ovarian ligation and using PZP on the fillies the herd’s rate of growth could be reduced by 50% per year. This would substantially help both the range and the cost of gathering and housing the horses and burros while keeping more horses on the range. By hip branding the mares that have had ovarian ligation you would be able to gate cut those mares back onto the range at any subsequent gather and not have to haul them off the range.

Some of the herds suggested for this procedure are South Steens, Oregon; Sand Wash Basin, Colorado; Twin Peaks, California; and/or BLM HMA around the Reno/Carson area of Nevada. These are herds that have been previously documented and in the case of both Sand Wash Basin and South Steens there is photographic documentation of the herds for 5-7 years that would be available to work within this project.

Respectfully
Submitted,

Sandra Force – Junction City, Oregon
AJ Sutton- Lawndale,Ca.
Kari Masoner – Tuson, Arizona
Ana Andrick – Wellington, Colorado
Nancy Warrick Kerson – Napa, California
Kathleen T. Granzow – Genoa City, Wisconsin
Thomas P. Brunshilde – Hammond, Wisconsin
Karen Goodroad – Pleasant Hill, Oregon
Lea Erwood – Rosedale, IN.
Kathryn Shirley – Holly Springs, North Carolina
Margaret Rothauge (Maggie) Creswell, Oregon
Angela Robey – Witch Well, AZ
Tom Hool – Casper, Wyoming
Debbra Dotson Christensen – Coquille, Oregon
Stephanie Jones – Eugene, Oregon
Jamie M. Adkins – Casper, Wyoming
Lisa Sink-Sheridan, Oregon
Beverly Shaffer – Burns, Oregon
Ramona Bishop – Burns, Oregon
Shyla Creasey – Oregon
Stacey Harnew –
Andi Harmon – Burns, Oregon
Keelyn Fawcett – Salem, OR
Kimberly Omnes
Mark Omnes
Angela “Angel” Rakestraw – Dinwiddie, Va
Jennifer Gregton – Midvale, Idaho
Iris Benson – Corvallis, Oregon
Karen Landis – Centralia, WA
Candy Nichols – Poolville, TX
Christina Picchi
Bree Alsman – Sandy, Oregon
JoAnna Lamb – Boardman, Oregon
Tracey Westbury – Bellingham, Washington
Cathy Smith – Pleasant Hill, Oregon
Rhonda Chayer – Barton, Vermont
Debbie Jackson – Ellensburg, Washington
Jes Sothern – Oregon
Rex Moore – Denton, Texas
Rose Howe – Monument, Oregon
Kerry O’Brien – Van Nuys, CA.
Susan Clogson – Woodinville, Washington
Nancy Willard – Eugene, Oregon
Loretta M. Jones – Redmond, Oregon
Jennie Kreutzer – Arlington, Washington
Monica Shifflet – New Haven, PA
Crystal Cooke – Clovis, New Mexico
Christie Brown – Daphne, Alabama
Pat Garcia – Burnet, Texas
Carrie Marie Fuesler – Brownsville, Oregon
Jackie Mousseau – Clinton Township MI
Betty Forman
Kathy Tellechea – Lexington, OR
Jim Bishop – Hines, Oregon
Angela Huston – St Louis, Missouri
Mike Huston – St Louis, Missouri
Kay Hamilton – Phoenix, OR
Richelle Wilson – Hillsboro, OR
Suzanne Ganazzi – Point Reyes Station, California
Tina Smith – Sommers, Conn
Andrea Walker – Fort Worth, Texas
Jeni Adler Snyder, Oklahoma
Ash Michael – Madison, South Dakota
Ashley Lawler
Brigid Piccaro – Acton, California
Kathryn Meyer – Orion, MI
Nancy Kohl – Surprise, Arizona
Jeni Adler – Snyder, Oklahoma
Kate Bogel – Howell, New Jersey
Lara Mogensen – Ellensburg, Washington
Carol Davis – Selma, Oregon
Susan Humphrey – Hot Springs, South Dakota
Gini Everts – Eugene, Oregon 

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




#URGENT: File a complaint against Nazi-like population control experiments on America’s wild horses!

The clock is ticking. Oregon State University isn’t stopping. They are going ahead with their Nazi-like population control experiments on wild mares and a lot of them are pregnant! The experiments were encouraged by a bunch of sick pro-slaughter, pro-cattle activists that work in darkness to bring the “final solutions” to America’s underpopulated wild horses and burros. These people have no soul. They have no empathy for the suffering these horrible experiments will inflict on WILD horses . . . wild animals . . . wildlife . . . that the law was supposed to protect.

Take action right now and fill out this Animal Welfare Complaint: https://www.aphis.usda.gov/aphis/ourfocus/animalwelfare/complaint-form. Mention that the procedures used to sterilize wild horses in the experiments at Oregon State University and elsewhere are cruel. Let them know that wild horses are underpopulated and the basis for these heinous experiments is false. Underpopulated wild horses and burros in America don’t need population control or birth control.

America’s wild horses and burros need your help to live and survive on public land set aside for them in 1971–the public sanctuary that is open 24/7 at no charge. The wild ones need YOU to go to your elected officials’ home offices and push for their protection.

Please also send an email to your congressman/woman and your 2 senators. Their contact information is here: http://www.contactingthecongress.org/ Short handwritten letters have the most impact as elected officials see them representing the opinion of 1000 voters.

Ignore anyone who says birth control is a tool in the stupid toolbox. Who’s toolbox are they talking about?

Ignore the spin doctors claiming they are overpopulated. It’s a lie.

The Bureau of Land Management’s (BoLM) claim there are 67,000 wild horses and burros combined in all western states is based on no more than an inflated guess. The BoLM have no headcount and no evidence according to the National Academy of Sciences. Even if there were 67,000 wild horses and burros left in the wild that would be too few to survive serious changes in climate, disease and environmental disaster. Do you want to see our majestic symbols of freedom and the American spirit become extinct forever? No you don’t, so take action. Your voice counts.

Don’t get distracted from the facts:

America’s wild horses and burros are being wiped off public land because greedy people and corporations with no conscious want to exploit the wild ones’ territory for profit–big profit. These people who are out for big money need to find the win-win, respect the environment and learn to work with–not annihilate–the last free roaming wild horses and burros. After all, wild horses prevent wildfires that could hurt their money making projects (oil and gas wells, solar energy zones, mining, etc.) These people should realize cattle will never roam like wild horses do and therefore cannot replace the wild herds for fire prevention.

Stop BLM from EXPERIMENTING on wild mares!

Tell your friends, family, co-workers and neighbors what’s going on and tune into our website daily for updates on the fight to save America’s wild horses! www.ProtectMustangs.org There are a lot of ways you can help by using your voice right from your computer. If we all don’t do something now then hundreds of wild horses will be cruelly carved up in Nazi-like population control experiments to rid the land of wild horses. Our beloved wild ones have been wrongfully labelled “pests” in the Pesticide PZP EPA application. Also based on the overpopulation lie, thousands of wild horses could end up at slaughter soon if they are not all accounted for and placed in safe homes.

Your elected officials need to be contacted regularly by email, handwritten letters and in meetings to stop the abuse against wild horses and keep them living in real freedom. . . in the wild.

It’s time to send an email requesting an appointment to get your elected officials involved in protecting America’s iconic wild horses and burros. Yes really protect them–not forcibly drug them with Pesticide PZP or sterilize them.

Do you realize YOUR voices in government have been fed a bunch of lies based on a false premise from other elected officials, lobbyists and traitor “advocates” as well? Follow the money . . . Then move beyond that to real “solutions” to protect real freedom. Make your voice heard.

From the Team at Protect Mustangs
www.ProtectMustangs.org

a member for the Alliance for Wild Horses and Burros

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