Done with the diversion

PM IA GAIA #8402 Carson July 2016

Pesticide PZP, promoted for birth control, has caused the divide, subterfuge, diversion, attacks and hate while at the same time revealing its connection to money, greed and politics. People are fooled. . . zealotry develops. . .hate mobs flourish. . . Wild horses suffer.

Focusing on a pesticide for birth control of a native species–that’s already being managed to extinction–is nuts.

What happened to “Stop the Roundups”? PZP doesn’t stop roundups. There are more wild horses being rounded up every year. PZP doesn’t stop slaughter either. The number of horses crossing the boarders to slaughter has increased.  PZP, made from slaughterhouse pig ovaries messes with native wild horses’ immune systems–that’s why it’s called an “immunocontraceptive’. Those pushing the pesticide call it as a “vaccine” for population control.

The fact that there are hardly any more wild horses left in the United States is ignored.

The fact that overkill is ruining the thriving natural ecological balance is ignored.

The fact that cattle and sheep are being poorly managed on public land and causing range damage is ignored.

Big mouths are scapegoating wild horses for range damage by sheep that’s wrecked havoc on the land years ago. Meanwhile America’s last wild horses endure living on public land that’s been ruined by livestock years ago.

We’ve done our part to educate people about PZP in the PZP Forum I created about 2 years ago. If people and organizations want to stick their head in the sand and ignore scientific facts about the many dangers of PZP (see the button above on www.ProtectMustangs.org) then they need to be held accountable when the wild herds are destroyed.

We aren’t working on PZP education anymore. That’s done.

Our focus in this movement is on helping to protect and save all the WILD horses we can save at this dire time in history. Please contact me by email Contact@ProtectMustangs.org if you want to adopt mustangs, purchase 3-Strikes wild horses, start a local network for saving wild horses or start a sanctuary of any size.

America’s wild horses need a huge herd of miracle workers to prevent their extinction at this point in history. You can make a difference now.

Many blessings,
Anne Novak

Founder and Director

Protect Mustangs and the American Wild Horse Institute

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




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

PM Economist Billions Spin Article

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

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

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

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

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

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

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

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

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

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

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

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

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



Lies, Spin and Subterfuge

The Cattlemen and livestock industry are making a huge push in Washington to give millions of tax-dollars to BLM for HUGE roundups to sterilize America’s last wild horses and burros. That means they will die out. Watch the Video testimonies here:


The House Committee on Natural Resources is stacked against wild horses and burros.

The vet called to testify seems to be from a wealthy Nevada ranching family. The Farm Bureau witness seems to be Pro-Slaughter for wild horses, etc.

The only representative for wild horses testifying is pushing for cooperative agreements with BLM as well as fertility control–Pesticide PZP–and that opens a pandora’s box for all forms of fertility control based on the BLM myth that wild horses are overpopulated : (

The Oil and Gas industry is about to launch a huge #Fracking boom in the areas where wild horses live so follow the money behind this rigged hearing. . .

PUBLIC comment allowed for 10 Business days after this meeting, which is July 7, 2016.
EMAIL: the Clerk: aniela.butler@mail.house.gov

This is YOUR call to action to JOIN the Alliance for Wild Horses and Burros to stop the slaughter, sterilizations, and stop the killing of America’s wild horses and burros. Go to https://www.facebook.com/Alliance-for-Wild-Horses-and-Burros-282933648725820/

Sign and share the petition for a 10 year Moratorium on Roundups: https://www.change.org/p/president-of-the-united-states-urgent-grant-a-10-year-moratorium-on-wild-horse-roundups-for-recovery-and-studies

Sign and share the petition to defund and stop the roundups as well as the slaughter: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups

Thank you!

From,

the Team at Protect Mustangs
(www.ProtectMustangs.org)
Facebook: https://www.facebook.com/ProtectMustangs

Member of the Alliance for Wild Horses and Burros (AWHB)
Facebook: https://www.facebook.com/Alliance-for-Wild-Horses-and-Burros-282933648725820/

 

Where are wild horses?™

 

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




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

PM Val Set Me Free

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

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




#BREAKING: Protect Mustangs calls for an end to animal cruelty

PM Secretary Jewell Continue reading

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

PM Tule Elk Males FIghting by austlee

PZP is an immunocontraceptive and pesticide which causes an immune reaction to reject fertilization, while the females still come into estrus. Besides wrecking havoc on the immune system, injecting herds with PZP results in more fighting between males and many other behavior abnormalities.

Tule elk in Pt. Ryes National Seashore (Marin County, California) were part of a PZP (Porcine Zona Pellucida) experiment. Several years later there was a strange die-off.

Wildlife groups blamed park service management for leaving the elk fenced in during a drought–claiming that was the reason for the die-off.

Park service officials said the tule elk had water during the die-off.

“Some wildlife advocates have termed the situation a “die-off” and accuse the park service of allowing the elk to perish behind the fence that prevents them from finding enough food and water. Park service officials have a different view of what caused the population drop, and are hoping that new data will help address these concerns, especially as visitor interest peaks during the fall rutting season.” from: https://baynature.org/articles/on-the-fence/

Listen to Wildlife Ecologist Dave Press Discusses Tomales Point Elk and mention “there was water in the pond up there . . .” at 2:18.

 

It’s time to connect the dots and ask the obvious question: Did PZP lower the herds’ immune system and genetic diversity to the point of making them vulnerable to a die-off?

With suspect data regarding the long-term use of PZP on wild herds, more questions and answers are needed to prevent a similar die-off in America’s wild horses & burros.

With regards to wild horses, keep in mind what Marybeth Devlin wrote about PZP:

“PZP is a registered pesticide whose mechanism-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that target and attack the ovaries. PZP’s antibodies cause the mare to suffer ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. Not surprisingly, estrogen levels drop markedly as the ovaries are slowly destroyed. But PZP’s adverse effects are not limited to the individual animal. As a recent study — which included the Little Book Cliffs, Colorado herd and the McCullough Peaks, Wyoming herd — found, PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Further, the same study disclosed that the pesticide causes a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recover their fertility after suspension of PZP. However, some mares never recover — they are left permanently sterile, and quickly too. Indeed, yet another study found that sterility could occur in some mares from just three years of PZP injections or from just one treatment if the pesticide were given to a filly before she reached puberty. Because PZP messes with the immune system, it ironically works “best” — sterilizes faster — if the mare has a strong immune system. But, conversely, PZP may not work at all in mares whose immune function is weak or depressed. So, the pesticide discriminates against the very horses that Nature has best equipped for survival against disease while favoring and selecting for the immuno-compromised. Worse yet, tests performed via radioimmunoassay indicated that PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques.”  [From: http://protectmustangs.org/?p=8529]

 

Pm PZP Darts

Links of interest™:

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

“Whenever an immune response is provoked, there is some risk of autoimmunity. Therefore immunocontraception trials typically check for signs of autoimmune disease.[17] One concern with zona pellucida vaccination, in particular, is that in certain cases it appears to be correlated with ovarian pathogenesis.[2] However, ovarian disease has not been observed in every trial of zona pellucida vaccination, and when observed, has not always been irreversible.[18]”

 

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

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

 

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

 

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

 

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

 

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

“Earlier this year park service officials revealed that more than 250 tule elk died inside the fenced area over a two-year period, in part because pools that the herds rely on for water had gone dry. Meanwhile, ranchers are complaining about the free-range elk getting on their land and eating grass and drinking water intended for their dairy cattle and other agricultural operations.”

 

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

 

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

“Forty-five adult tule elk (Cervus elaphus nannodes) in good physical condition were translocated from a population located at Point Reyes National Seashore, Marin County (California, USA), to a holding pen 6 mo prior to release in an unfenced region of the park. Because infection with Mycobacterium avium subsp. paratuberculosis (Mptb) had been reported in the source population, the translocated elk underwent extensive ante-mortem testing using three Johne’s disease assays: enzyme linked immunosorbent assay (ELISA); agar gel immunodiffusion assay (AGID), and fecal culture. Isolation of Mptb was made from fecal samples in six of 45 elk (13%). All AGID results were negative while ELISA results for 18 elk (40%) were considered elevated. Elevated ELISA results or Mptb isolation from fecal samples were obtained for 22 of 45 elk (49%); these elk were euthanized and necropsied. Mycobacterium avium subsp. paratuberculosis was isolated from tissue in 10 of 22 euthanized elk (45%); of these 10 cases of confirmed infection, eight had elevated ELISA results (80%) and four were fecal culture positive (40%). One of 10 cases had histopathologic lesions consistent with Mptb infection. Mycobacterium avium subsp. paratuberculosis was also isolated from tissue from one of eight fetuses sampled. The number of tule elk found to be infected was unexpected, both because of the continued overall health of the source herd and the normal clinical status of all study animals.”

 

Mycobacterium avium subspecies paratuberculosis and Mycobacterium avium subsp. avium infections in a tule elk (Cervus elaphus nannodes) herd. 2006. http://www.ncbi.nlm.nih.gov/pubmed/17255437 

Abstract
“Between 2 August and 22 September 2000, 37 hunter-killed tule elk (Cervus elaphus nannodes) were evaluated at the Grizzly Island Wildlife Area, California, USA, for evidence of paratuberculosis. Elk were examined post-mortem, and tissue and fecal samples were submitted for radiometric mycobacterial culture. Acid-fast isolates were identified by a multiplex polymerase chain reaction (PCR) that discriminates among members of the Mycobacterium avium complex (MAC). Histopathologic evaluations were completed, and animals were tested for antibodies using a Johne’s enzyme-linked immunosorbent assay (ELISA) and agar gel immunodiffusion. In addition, 104 fecal samples from tule elk remaining in the herd were collected from the ground and submitted for radiometric mycobacterial culture. No gross lesions were detected in any of the hunter-killed animals. Mycobacterium avium subsp. paratuberculosis (MAP) was cultured once from ileocecal tissue of one adult elk and was determined to be a strain (A18) found commonly in infected cattle. One or more isolates of Mycobacterium avium subsp. avium (MAA) were isolated from tissues of five additional adult elk. Gastrointestinal tract and lymph node tissues from 17 of the 37 elk (46%) examined had histopathologic lesions commonly seen with mycobacterial infection; however, acid-fast bacteria were not observed. All MAC infections were detected from adult elk (P = 0.023). In adult elk, a statistically significant association was found between MAA infection and ELISA sample-to-positive ratio (S/P) > or = 0.25 (P=0.021); four of five MAA culture-positive elk tested positive by ELISA. Sensitivity and specificity of ELISA S/P > or = 0.25 for detection of MAA in adult elk were 50% and 93%, respectively. No significant associations were found between MAC infection and sex or histopathologic lesions. Bacteriologic culture confirmed infection with MAP and MAA in this asymptomatic tule elk herd. The Johne’s ELISA was useful in signaling mycobacterial infection on a population basis but could not discriminate between MAA and MAP antibodies. The multiplex PCR was useful in discriminating among the closely related species belonging to MAC.
Between 2 August and 22 September 2000, 37 hunter-killed tule elk (Cervus elaphus nannodes) were evaluated at the Grizzly Island Wildlife Area, California, USA, for evidence of paratuberculosis. Elk were examined post-mortem, and tissue and fecal samples were submitted for radiometric mycobacterial culture. Acid-fast isolates were identified by a multiplex polymerase chain reaction (PCR) that discriminates among members of the Mycobacterium avium complex (MAC). Histopathologic evaluations were completed, and animals were tested for antibodies using a Johne’s enzyme-linked immunosorbent assay (ELISA) and agar gel immunodiffusion. In addition, 104 fecal samples from tule elk remaining in the herd were collected from the ground and submitted for radiometric mycobacterial culture. No gross lesions were detected in any of the hunter-killed animals. Mycobacterium avium subsp. paratuberculosis (MAP) was cultured once from ileocecal tissue of one adult elk and was determined to be a strain (A18) found commonly in infected cattle. One or more isolates of Mycobacterium avium subsp. avium (MAA) were isolated from tissues of five additional adult elk. Gastrointestinal tract and lymph node tissues from 17 of the 37 elk (46%) examined had histopathologic lesions commonly seen with mycobacterial infection; however, acid-fast bacteria were not observed. All MAC infections were detected from adult elk (P = 0.023). In adult elk, a statistically significant association was found between MAA infection and ELISA sample-to-positive ratio (S/P) > or = 0.25 (P=0.021); four of five MAA culture-positive elk tested positive by ELISA. Sensitivity and specificity of ELISA S/P > or = 0.25 for detection of MAA in adult elk were 50% and 93%, respectively. No significant associations were found between MAC infection and sex or histopathologic lesions. Bacteriologic culture confirmed infection with MAP and MAA in this asymptomatic tule elk herd. The Johne’s ELISA was useful in signaling mycobacterial infection on a population basis but could not discriminate between MAA and MAP antibodies. The multiplex PCR was useful in discriminating among the closely related species belonging to MAC.”

 

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

 

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

 

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

“. . . Funding for tule elk projects has come from a variety of sources. To date, monetary support and in-kind services for the tule elk project has been received from the Rocky Mountain Elk Foundation, Point Reyes National Seashore Association, Committee for the Preservation of Tule Elk, California Department of Fish and Game, The Humane Society of the United States (HSUS), University of California at Davis, the National Park Service Natural Resource Preservation Program and In Defense of Animals.” [Evidently Suzanne Roy, currently the Director of the American Wild Horse Preservation Campaign–who pushes PZP based management–was working for IDA at the time.]

 

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

“. . . During the second phase of the contraceptive research project, the first vaccine will be administered by direct syringe injection. To administer the injection, 30 elk will be captured from a helicopter and hobbled by ground crews. Scientists will gather data on the individual elk and place a radio collar on each of the elk. The collar will allow scientists to follow the individual elk to determine the effectiveness of the contraceptive. After several weeks, a booster shot will be remotely administered, from ranges of 30 to 150 feet, by means of self-injecting darts. The darts are brightly colored and easily retrieved. A single annual booster inoculation will be administered to continue contraceptive effects for successive breeding seasons.”

 

Use of porcine zona pellucida (PZP) vaccine as a contraceptive agent in free-ranging tule elk (Cervus elaphus nannodes). published 2002: http://www.ncbi.nlm.nih.gov/pubmed/12220156 

Abstract (note only a 5 year study. Why aren’t they studying the truly long-term effects?)
The potential for the application of porcine zona pellucida (PZP) immunocontraception in wildlife population management has been tested over a 15 year period and promises to provide a useful wildlife management tool. These studies have provided evidence indicating that the use of PZP immunocontraception in wildlife: (i) is effective at both the physiological and population level (Liu et al., 1989; Kirkpatrick et al., 1996; Turner et al., this supplement); (ii) is deliverable by remote means (Kirkpatrick et al., 1990; Shideler, 2000); (iii) is safe in pregnant animals (Kirkpatrick and Turner, this supplement); (iv) is reversible (Kirkpatrick et al., 1991; Kirkpatrick and Turner, this supplement); (v) results in no long-term debilitating health problems (Kirkpatrick et al., 1995; Turner and Kirkpatrick, this supplement); (vi) has no implications for passage through the food chain (Harlow and Lane, 1988); and (vii) is reasonably inexpensive (J. F. Kirkpatrick, personal communication). This report presents the results of a 5 year study in tule elk (Cervus elaphus nannodes), 3 years of which were on the application of PZP immunocontraception to an expanding elk population living in a wilderness area of Point Reyes National Seashore in Marin County, CA…”

 

Copyright Protect Mustangs.org 2016





Feds want to use 11 million tax dollars to experiment on American Wild Horses and Burros

Note from Protect Mustangs: If you don’t like this then: 1.) Go see your congressional representative this week and ask them to intervene to stop these horrible experiments on America’s wild horses who are being managed to extinction. 2.) Sign and share this petition and email it to everyone you know: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups Groups like The Cloud Foundation and the coalition led by The American Wild Horse Preservation Campaign seem to be misleading the public because they have chosen pushing PZP (controlled by The Humane Society of the United States) over championing wild horse freedom on public land. They slip appeals for PZP in the bottom of their online petitions hoping the public won’t notice what they are signing. That was the beginning of this slippery slope towards experimentation and extinction. Why? Follow the money, fear mongering and the seduction to campaign for drugging wild horses and burros with a risky pesticide made from slaughterhouse pig ovaries to block fertility. . . 3.) It’s time to join Protect Mustangs to protect our national treasures. Go to www.ProtectMustangs.org to sign up. 4.) You can donate to the Wild Horse Legal Fund also. The crowd funding link is here: https://www.gofundme.com/MustangLaw2016 or donate by www.PayPal.com to Contact@ProtectMustangs.org and please mark your donation is for the “Legal Fund”. Thank you for taking action today! Together we can turn this around.





The Bureau of Land Management (BLM) wants to use American tax dollars in several cruel experiments to develop methods of wild horse and burro population control–despite the fact that there is no overpopulation of wild horses or burros. The BLM anticipates the total cost of the experiments to be $11 million over 5 years.The research is being conducted by university scientists as well as scientists from the U.S. Geological Survey.

Research with Universities results in experimenting on wild horses and burros

In its 2013 report to the BLM, the National Academy of Sciences (NAS) found that no highly effective, easily delivered and affordable fertility-control methods were currently available for use on wild horses and burros. The most promising birth control, PZP, made from slaughterhouse pig ovaries, is limited in the duration of its effectiveness (1-2 years). At the same time, after multiple applications or if applied to young fillies it permanently sterilizes native wild horses.

The BLM released a solicitation for experimentation to develop new or improve existing population growth suppression methods for wild horses. (http://www.blm.gov/wo/st/en/info/newsroom/2015/july/nr_07_07_2015.html)  The following seven research projects were reviewed and recommended by an NAS panel of experts and are consistent with recommendations made to the BLM by its Wild Horse and Burro Advisory Board who is biased against wild horses and prefers livestock use public land for cheap grazing.

Wild Horse & Burro Advisory Board Meeting in 2013

 

© EquineClinic.comn shared for educational purposes

© EquineClinic.comn shared for educational purposes

1. Evaluation of minimally invasive methods of contraception in wild horse and burro mares: tubal ligation and hysteroscopically-guided oviduct papilla laser ablation. This was pushed by pro-slaughter advocates who want the horses free of fertility control drugs so they can go to slaughter eventually.

Recipient: Oregon State University
Summary: A one-year experiment that will aim to develop a minimally invasive surgical sterilization method for wild horse mares that requires no incisions.
Details: In an effort to develop minimally invasive, low-risk techniques for contraception and population control in female wild horses and burros, the experiment will evaluate two procedures, tubal ligation and hysteroscopically-guided laser ablation of the oviduct papilla in standing sedated females. For tubal ligation, the research team hypothesizes that a flexible endoscope inserted through a small incision in the vaginal vault will allow visualization of each oviduct in mares. Use of a diode laser or cautery instrument will allow effective fulguration followed by bloodless sectioning of the oviduct. This procedure should allow successful sterilization of up to 100% of female wild horses and burros gathered in any particular location as a single event. For the hysteroscopic procedure, the recipients expect to endoscopically visualize each oviduct papilla in standing, sedated, non-pregnant mares. A diode laser will be used to seal the opening between the oviduct and each uterine horn, thus preventing subsequent fertilization. The proposed procedures do not involve major surgery, are expected to have minimal complications while approaching 100% effectiveness, and when applied, are expected to result in a static to decreasing population level. Additionally, tubal ligation is a technique commonly performed in humans. The development of an acceptable sterilization technique will help control the population levels of wild horses and burros.


2. Tubo-ovarian ligation via colpotomy as a method for sterilization in mares

Recipient: University of Kentucky
Summary: A two-year experiment to develop different surgical approaches for tubal ligation in mares.
Details: The overall goal of this experiment is to develop methodology for the safe, economical and effective sterilizationof mares via colpotomy (vaginal incision) to achieve: 1) ovarian necrosis / atrophy via application of a ligature to the ovarian pedicle and 2) simultaneous sterilization via tubal ligation (i.e., tubo-ovarian ligation). The project will help determine the effectiveness of a custom-designed instrument for placement of a polyamide (nylon) cable tie around the ovarian pedicle and oviduct of mares via colpotomy for tubo-ovarian ligation. The procedure, conducted in the standing animal under sedation and local anesthesia, is expected to induce permanent sterilization of treated mares. The researchers will assess any post-operative complications of the procedure in mares and the effects on the health of mares to determine long-term effects on the reproductive tract, the overall health of mares and the fertility of mares undergoing the procedure, and the feasibility of these procedures in pregnant mares.

PM Sick Filly PVC March 25 2014
3. Functional assessment of ovariectomy (spaying) via colpotomy of wild mares as an acceptable method of contraception and wild horse population control

Recipient: Oregon State University
Summary: A six-month experiment that will determine whether an existing accepted surgical sterilization procedure commonly used for domestic mares can be safely conducted on wild horses.
Details: This experiment proposes to conduct a large-scope investigation of the safety and practicality of spaying mares as a tool for wild horse population control. Specifically, the researchers will help determine whether ovariectomy via vaginal colpotomy can be safely and effectively performed on wild mares that have been selected for non-breeding status. Non-breeding horses could then be returned to the range to live out their natural lives without individually contributing to population growth. The proposed research effort is based on recent pilot studies that have suggested the potential for surgery-related health complications from ovariectomy in adult female horses is low (near 1%). When evaluating options for field techniques, spaying (ovariectomizing) mares as a population control method is not recommended unless it can be performed in a safe, practical, and effective manner. The results of this study will provide standardized, baseline outcomes for this surgical procedure which can be directly compared to other less invasive procedures being conducted and evaluated by the same research team.

PM WC11 Lucky 11 Map

Map of Western United States showing 12 current field research/pilot projects.

4. Re-immunization of Free-Ranging Horses with GonaCon Immunological Vaccine: Effects on Reproduction, Safety, and Population Performance

Recipient: Colorado State University
Summary: A two-year experiment will focus on further study of Gonocon, an approved and labeled contraceptive vaccine for equids.

PM PZP Injection
Details: This experiment will focus on the effectiveness of GonaCon as an immunological vaccine, with five objectives: 1) to begin to determine the optimum and most effective re-vaccination schedule with GonaCon vaccine for suppressing reproductive rates in free-ranging horses, the duration of effectiveness, and the return to fertility following treatment; 2) to determine the safety and physiological side-effects (if any) in feral horses following re-vaccination with GonaCon including visual assessment of general health, body condition, injection site reactions, effects on current pregnancy, and neonatal health and survival; 3) to determine the effects of GonaCon vaccination on the behavioral side-effects (if any) in free-ranging horses including quantitative assessment of the effects on daily activity patterns and social interactions; 4) to develop and test a safe and effective dart configuration and injection system for remotely administering GonaCon vaccine to free-ranging horses by means of a syringe dart; and 5) to develop a Bayesian model to forecast the consequences of different GonaCon vaccine treatments on feral horse population dynamics at THRO. [Teddy Roosevelt National Park].


5. The Effect of Immunization against Oocyte Specific Growth Factors in Mares

Recipient: Colorado State University
Summary: A two-year experiment to develop a new, permanent contraceptive vaccine for wild horse mares.
Details: This experiment will focus on vaccination against two key proteins in wild horse and burro females, either alone or in combination, which may result in permanent sterility through premature oocyte depletion. The depletion of oocytes may occur by simply causing them all to become atretic prematurely and/or accelerating the process so that after a single season the mares and jennies have depleted their oocyte reserves. To test this hypothesis, the researchers will vaccinate mares against the proteins and track their sexual behavior, follicular growth, hormonal profile and ultimately total oocyte count over a two-year period. The long-term goal is to develop a vaccine that can cause permanent sterility after a single dose.

PM Burros Wild 2 © Carl Mrozek

Cruel way to drag foal by pulling bailing twine around their neck (Photo © Bo Rodriguez)

Cruel way to drag foal by pulling bailing twine around their neck (Photo © Bo Rodriguez)

6. Electrospun delivery to enhance the effectiveness of immunocontraception strategies in equids

Recipient: Ohio State University
Summary: A four-year experiment that will attempt to develop a new delivery vehicle for porcine zona pellucida (PZP) – a temporary contraceptive currently used in some wild horse herds – that would increase the duration of the vaccine’s effectiveness.
Details: To reduce population on public lands, horse immunocontraception has largely focused on the use of PZP in free-roaming wild populations. The vaccine appears to act by stimulating anti-PZP antibodies that bind to the surface of the ovulated egg, preventing sperm attachment. While performance has been satisfactory, recent results have been associated with contraceptive efficiencies that are considerably less than 100%. The basis for this is unknown but is believed to be in part caused by delivery methods that require substantial heating during polymer vehicle fabrication, expose PZP to enzymatic fluids prior to entry into the bloodstream and allow gradual – not burst – release. Gradual release can potentially desensitize the immune system to the presence of PZP, resulting in inferior production of anti-PZP antibodies. Thus, an ideal delivery method would allow release of PZP in “bursts” at pre-determined intervals to assure constant immune stimulation. This project will seek to develop an electrospun technology that can allow long-term, ‘burst’ delivery of porcine zona pellucida (PZP) vaccines to the intramuscular environment of horses and burros to result in prolonged suppression of reproduction. For large-scale application, free roaming horses could be gathered in the field and processed through stock chutes for aging, at which time the implants will be inserted by trocar. The experiment will also carry out parallel in vitro and in vivo experiments to examine the potential of electrospun vehicles as immunocontraceptive carriers. An electrospun “universal delivery vehicle” will be developed to provide sustained release of effective levels of porcine zona pellucida (PZP) for immunocontraception over periods of at least three years. By careful design, fabrication and testing of two different electrospun designs, the researchers will create a comprehensive evaluation of this novel method of delivery.

Pm PZP Darts
7. The use of membrane disrupting peptide / peptoid LHRH conjugates to control wild horse and burro populations

Recipient: Louisiana State University
Summary: A three-year experiment for the development of an injectable agent that would inactivate hormones and decrease female and male gonad viability.
Details: The experiment is a multidisciplinary effort aimed at developing novel drugs to control wild horse and burro populations. Several types of drugs consisting of conjugates of membrane disrupting peptides (such as Phor 21) with luteinizing hormone releasing hormone (LHRH) currently exist. These drugs (such as LHRH-Phor 21 conjugate) effectively target, bind to and destroy prostate, testicular, breast and ovarian cancer cells, as well as testicular and ovarian cells that control reproduction. LHRH targets the cell and delivers Phor 21 to the cancer cell or the reproductive cell in the testes or ovary and destroys it. Preliminary experiments suggest that administration of this drug by a slow-release delivery system will destroy the cells that control spermatogenesis in the male and follicle growth, oocyte development, ovulation and cyclicity in the female. Preliminaryresults also show that LHRH-Phor 21 targets and destroys gonadotropic cells in the pituitary gland. This indicates that cessation of reproductive activity is the result of both central control at the level of the pituitary gland and on receptor binding cells in both male and female gonads. The experiment will also assess the effect the drugs have on pregnant mares, both in early gestation and late gestation.

PM PZP Syringe Yearling Meme

Additional details about these experiments can be found in the following documents:

Detailed Summary of University-led Experiments for Fertility Control Tools for Wild Horses
Review of Proposals to the BLM on Wild Horse and Burro Sterilization or Contraception: A Letter Report
Research with the U.S. Geological Survey

Through its partnership with U.S. Geological Survey (USGS), the BLM is undertaking important research aimed at delivering better methods and tools for managing wild horse and burro herds on public lands. These projects build upon on-going cooperation between the BLM and USGS that is implementing new methods to estimate wild horse and burro population size.

There are nine USGS experiments that have been approved or are on-going:
Collaring & radio marking (1 year): The aim is to develop safe GPS collars for tracking animals to determine habitat selection, movement ecology, population estimation, behavior, etc. GPS tracking might also help locating animals for contraceptive treatments.
Fecal DNA (genetics/population survey) (1.5 years): The experiment involves the collection and analysis of fecal DNA as a noninvasive method to determine genetic diversity and estimate population size.
Carrying capacity modeling (1 year): This experiment’s aim is to develop a coarse model to evaluate changes in animal carrying capacity in response to changes in vegetation production. The resulting model may help BLM to adapt plans in response to climatic change.

PM PZP Syringe FB
Mare Contraception -SpayVac Pen Trial II (5 years): This experiment will help determine the efficacy of alternative SpayVac contraceptive vaccine formulations that are potentially longer acting than conventional PZP vaccines.
Evaluating Behavior of Spayed Free-Roaming Mares (4 years): The experiment will determine the effects of spaying on behavior, interactions, and movement of spayed mares among a breeding herd. The study will also determine the population level effect on herd growth.
Evaluating Behavior of Geldings among a Breeding Herd (4 years): This experiment will determine any effects of gelding on behavior, movement, interactions and changes in habitat selection.
Two Sentinel Horse Herd Management Area (HMA) Demography Studies (2 studies, each of 5 years): These experiments will provide demographic data sets for use in new population models and serve as control HMAs for gelding and spayed mare field studies.
Burro Sentinel HMA Demography Study (5 years): The experiment will involve collecting data on the survival, fertility, fecundity, recruitment, movements, range use, habitat selection and social behavior of wild burros. These data will be used in population modeling.
The BLM has requested or is reviewing proposals for the following projects with USGS:
Evaluate the Use of a Silastic O-Ring Intrauterine Device (IUD) in Mares (4 years): This experiment will determine any effects on mare health resulting from the long-term presence of the silastic O-ring IUD. This IUD has effectively prevented pregnancy in domestic mares during one breeding season.
Burro Population Survey Method Development (2.5 years): This experiment will test two new population survey methods for wild burros. The existing simultaneous double-observer method, when applied to burros, tends to lead to underestimates of true burro population size.
WinEquus II – Population Model with Cost/Benefit Outputs (1.5 years): This experiment will develop a model that compares population modeling outcomes and projects the costs, benefits and expected population growth resulting from management actions that involve PZP, removals, spaying, gelding and other population growth suppression tools.
Testing Efficacy of Contraceptives for Female Burros (3-4 years): Contraceptive vaccines have yet to be used on wild burros due to limited research and unknown effects. This study will examine the efficacy of various existing vaccines.

PM Hazard Foter Public domain Marked Sterilize

© Protect Mustangs, 2016


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

PM Helicopter Mustang Roundup

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

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

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





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

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

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

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

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

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

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

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

6. I wrote in my book Twelve the King:

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

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

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

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

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

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

[End of Michael Lennox Blake’s declaration]

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

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

Many blessings,
Anne

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

PROTECT MUSTANGS
PO Box 5661
Berkeley, CA. 94705





PM Pine Nut 332 90K meme

Lennox August 2014

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

The War on Wild Horses

The War on Wild Horses

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

Tracy Mohr writes:

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

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

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

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

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

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

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

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

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

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

~ Tracy Mohr, founder The Mustang Project

Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Email: blm_ut_sulphur@blm.gov

Copies: jwhitloc@blm.gov, tchristense@blm.gov, eburghar@blm.gov
January 19, 2016
Cedar City Field Office
176 E DL Sargent Drive
Cedar City, UT 84721
Project Name: Sulphur Wild Horse Gather Plan

Document: Environmental Assessment — Preliminary

NEPA ID: DOI-UT-C010-2015-0011-EA
This letter responds to your request for substantive comments and new information that BLM-Cedar City should consider regarding the subject Plan. I submit mine as an interested party in behalf of the wild horses of the Sulphur Herd Management Area (HMA).

I support the use of radio collars to track the horses and the construction of a fence along Highway 21 for the safety of both horses and humans. However, I urge you to cancel the roundup-and-removals, discontinue PZP treatments, correct the fraudulent population-estimates, and take other specified corrective actions.

I suggest the addition of another alternative: Increase the AML, collar the horses, fence the Highway but remove interior fences, conserve apex predators, and install guzzlers throughout the HMA.

As for the proposed alternative, if BLM has confidence in the WinEquus population-growth modeling, then please note that the “removals only” alternative yields a median-trial average herd-size that is nearly 24% lower than the proposed alternative — 318 versus 417. As for PZP injections, they should be abandoned because they are dangerous to the mares, to the foals (born and unborn), and to the staff and volunteers that handle the pesticide.

For ease of reference, here are the links to the documents at issue:

News Release — 2015 EA

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

News Release — 2015 Public-Safety Removals

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

Sulphur Gather Environmental Assessment — Preliminary

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

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

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

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

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

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

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

Before we examine BLM’s reported herd-growth rates of this HMA, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. BLM claims an average birth rate in wild-horse herds of about 20% a year. But herd-growth is unlikely to reach 20 percent a year. Here’s why: Horses die.

An independent study reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival rate is just 10 percent. Cedar City’s claim that 95% of the Sulphur foals survive is not credible. It is just self-serving for administrative convenience in equating the birth rate to the growth rate. That wrong assumption has been disproved. Moreover, I note that the 2013 inventory counted 25 foals born out of season. That anomaly was likely due to the PZP treatments, which research by Ransom et al. (2013) disclosed.

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

However, CCFO failed to include that study as a reference; and although it did cite another Ransom et al. study (2010), it was not included in the EA’s “References” section either.

Births outside the normal parturition-pulse put the survival of both the mares and foals at risk.
Adult Wild-Horse Mortality Rate Must Be Factored

But it is not only foals that die. Adult wild horses also perish. They succumb to illness, injury, and predation. Indeed, the EA claims that 8 horses were found dead in 2015. The adult death rate must be taken into consideration. Adult mortality is at least as high as the 5% a year for horses that die in short-term holding, where they are fed, watered, and provided care.

Given the 50% foal mortality-rate, and the 5%-or-higher average annual death rate of adult wild horses on the range, herd growth could not increase 20% a year, and a herd-population could not double in 4 years — refuting yet another BLM myth. But BLM ignores mortality — foal and adult — in its population-estimates, which exaggerates the numbers it posts.
The Herd-Growth Rate Must Necessarily Be Lower Than the Birth Rate

In light of the high foal-mortality rate and the expected adult wild-horse mortality rate, the herd-growth rate must always be lower than the average 20% birth rate. However, herd-growth rates many times higher than 20% — which would necessarily mean birth rates substantially higher still — are routinely found in BLM’s population data, including the year-to-year figures for Sulphur HMA and other HMAs under Cedar City Field Office’s jurisdiction. Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — that is one of the ways BLM creates the false impression of a population-explosion.
Stochastic Events Also Reduce Herd Growth

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

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

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

Imagine if such a catastrophe were to befall the Sulphur herd. Note that the Saiga deaths involved antelope-mothers and their calves. What if Sulphur’s few fertile mares and their foals perished all of a sudden, leaving mainly stallions and sterile old mares? BLM must proactively manage the herd per IUCN International Union for the Conservation of Nature guidelines, if only in case of stochastic events.
Maximum AML Set Below Minimum Viable Population

But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear — via fictitious figures — to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP, including Sulphur. What is the MVP? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the 265,675 acres of the Sulphur HMA.
Phony Population-Estimates

According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.

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

Let’s do the math.

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

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

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

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

Discrepancies were evident per a review of the …

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

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

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

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

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

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

125 %
131 %
153 %
157 %
249 %

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

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

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

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

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

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

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

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

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

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

The EA’s proposed removals of wild horses and pesticide-treatments on the few allowed to remain appear designed to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by fictitious figures on herd-growth.
Bundy Brothera and Finicum Lead Armed Takeover of the Malheur National Wildlife Refuge

Ammon and Ryan Bundy, along with LaVoy Finicum are the “spokesmen” who have commandeered the Malheur Wildlife Refuge. Armed for battle, they continue, as of this writing, to occupy. Using Federal vehicles and machinery, they tore down a fence built to keep trespass-livestock out. They come and go as they please, even soliciting snacks and coffee creamer (French Vanilla) from supporters. The situation is out of control. BLM and FBI appear to be kowtowing to the rebels.

Here are excerpts from a news report:

The militants occupying the Refuge asked Harney County ranchers to tear up their leases with the Bureau of Land Management and stop paying the federal government to graze cattle on public land.

“I’ve done it. Cliven Bundy’s done it,” said LaVoy Finicum, an Arizona rancher and the militants’ defacto spokesman. “Now is the day. Now is the time. Are you going to wait for tomorrow? For next week? Next month? Next year? When? When will you stand up if not now?”

Finicum invited the ranchers to cancel their leases with the BLM at a ceremony before the media at the refuge on Saturday. He said two ranchers, one from New Mexico and another from Harney County, are scheduled to void their contracts publicly.

Ryan Bundy went on to emphasize his view that breaking away from the federal government means ranchers wouldn’t have to follow federal laws, like the Endangered Species Act.

LaVoy and the Bundys also acknowledged their proposition is risky. They said any rancher who joined them would get protection from the armed militants ….

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

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

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

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

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

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

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

The EA states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

BLM needs to stick to the facts and cease blaming wild horses for what livestock already did.
——————————————-

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

Marybeth Devlin