Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Email: blm_ut_sulphur@blm.gov

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

Document: Environmental Assessment — Preliminary

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

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

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

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

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

News Release — 2015 EA

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

News Release — 2015 Public-Safety Removals

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

Sulphur Gather Environmental Assessment — Preliminary

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Let’s do the math.

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

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

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

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

Discrepancies were evident per a review of the …

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

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

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

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

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

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

125 %
131 %
153 %
157 %
249 %

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

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

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

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

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

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

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

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

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

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

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

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

Here are excerpts from a news report:

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

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

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

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

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

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

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

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

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

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

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

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

The EA states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Marybeth Devlin





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

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

PM Gonacon Pesticide Fact Sheet

Read the entire Gonacon™ Pesticide Fact Sheet

Interview

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

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

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

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

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

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

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

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

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

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

574px-Blm.svg

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

PM PZP Test mares

(American wild horses used in fertility control experiments)

© John Cox, printed with permission

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

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

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





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

The feds’ mustang population “data” is a fraud 

By Marybeth Devlin

While pretending to rely on the assumption that herds grow 20% a year, the Bureau of Land Management (BLM) posts numbers up to 8 times higher than that to justify roundups, which are pre-scheduled on a rotation-basis, seeming to target particular herds. For instance, the Agency recently claimed that the famous Kiger herd in Oregon grew from 21 horses to 156 horses in just four years — an increase of 643%, which equates to a yearly average increase of 160%, which is 8 times higher than the 20% BLM supposedly uses. [1] Such growth is biologically impossible. Kiger is not an isolated example, although it is the worst found so far. Here are some other phony figures on population-growth recently claimed by BLM to make it appear that gathers were necessary:

Blawn Wash (UT)
297.4 % increase in 3 years, averaging 99.1 % per year

Fish Creek (NV)
80% increase in one year

Green Mountain (WY)
281% increase in four years, averaging 70.3% per year

Stewart Creek (WY)
311% increase in four years, averaging 77.8% per year
But herd-growth is unlikely to reach even 20 percent a year. It is important to understand that the birth-rate is not the same as–and should not be equated to–the population growth-rate. Here’s why: Horses die. An independent study reviewed BLM roundup-records for a representative sample of four herd management areas composed of 5,859 wild horses (Gregg, LeBlanc, and Johnston, 2014). While the researchers found an overall birth-rate of just under 20 percent, they also found that half of foals perish in their first year of life. Thus, the effective foal-to-yearling survival-rate is just 10 percent. Further, adult wild horses also perish. They succumb to illness, injury, and predation. Their death-rate must be taken into consideration as well. But BLM ignores mortality–foal and adult–in its population-estimates. Given the 50% foal mortality-rate, and the 5% or higher average annual death-rate of adult wild horses, herd-growth could not increase 20% a year, and a herd-population could not double in 4 years–refuting yet another BLM myth.

Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates–that is how BLM creates the false impression of a population-explosion. But “cooking the books” is not the only way BLM falsifies the population-picture. Another ruse BLM employs is restricting maximum herd-size below minimum-viable population (MVP) size. Then, whenever a herd is made to appear–via fictitious figures–to exceed the arbitrary management level, BLM screams “excess!” and declares an immediate need for mass-removals and sterilizations. It should be noted that more than 70 percent of the herds are “managed” below MVP.

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

Now BLM is distributing grant-money to universities and researchers to study more ways of dealing with the phantom overpopulation. All manner of sicko experiments are being carried out on the wild horses, such as treating them with endocrine disruptors and sterilizing them surgically. Why? Because BLM is a corrupt agency. It invented this counterfeit crisis to create a sense of urgency, which will pressure Congress to give the Agency extra money to “solve” a non-existent problem.

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

Contact your elected officials to make them aware of BLM’s fraudulent population claims to get funding for wild horse roundups and warehousing at great taxpayer expense: http://www.contactingthecongress.org

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

Visit www.ProtectMustangs.org for more information and click on the donate button help fight the injustice! You can make a difference.

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

(Photo by BLM. Roundup paid for with your tax dollars.)
Addendum:

[1] Using simple division to calculate the average increase is how most people would “do the math”–dividing the percentage increase (643%) by the number of years (4). Expressing the average that way is readily understandable. However, another way of calculating it is what is called the “compound annual growth rate” (CAGR). Per that method, herd-growth can be likened to compound interest that you earn on a savings account; except of course that horses do die, which complicates the computations. But for now, let’s assume that horses never die, because that’s the assumption that BLM makes.

Using the free, online CAGR tool linked below, you would enter Kiger’s beginning population–21–and its alleged ending population–156–and the number of years that had passed–4. Then press the “Calculate CAGR” button, and the tool will compute the compound annual growth rate. For the Kiger herd, the CAGR is 65%, which is “only” 3.25 times higher–instead of 8 times higher–than 20%.

Here is the tool to compute CAGR:

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

Here are the other herds cited and their CAGRs. Fish Creek stays the same because its growth is just for one year.

Blawn Wash (UT)
38 = Population-estimate 2012
151 = Population-estimate 2014, including new foals

297.4 % = Percentage increase in three years
99.1 % = Simple average annual growth-rate
58.4 % = Compound annual growth-rate (CAGR)

Fish Creek (NV)
256 = Population-estimate 2013
461 = Population-estimate 2014, before foaling season (January)
80.1% = Percentage increase in one year

Green Mountain (WY)
258 = Population-estimate post-gather at the end of 2011
982 = Population-estimate in 2015 — including that year’s foals*

281.0 % = Percentage increase in four years
70.3 % = Simple average annual growth-rate
39.7 % = Compound annual growth-rate (CAGR)

Stewart Creek
124 = Population-estimate post-gather at the end of 2011
509 = Population-estimate in 2015 — including that year’s foals*

311.0 % = Percentage increase in four years
77.8 % = Simple average annual growth-rate
42.3 % = Compound annual growth-rate (CAGR)
* BLM’s population-modeling criteria said foals were not included in the AML. Evidently, they were.

Further Insight into Calculating Population-Growth

At the link below, you will find a discussion posted by the University of Oregon, providing a comparison between the simple average and the compound annual growth-rate methodologies for calculating annual percentage population-growth.

As will be readily apparent, the simple average approach is “straight-line” and … simple. Forgive yet another pun, but the average person can easily understand it and “do the math.”

The compound annual method, on the other hand, is extraordinarily complicated to compute, which is why the online tool is almost a necessity.

What is important is that both are legitimate ways of describing the data.

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

It should be kept in mind that population-growth estimates must consider births and deaths, not just births. That’s one reason why the Gregg et al. study was so important — it established, per BLM’s own documentation, a slightly-less than 20-percent birth-rate and a 50-percent foal mortality-rate. So, a wild-horse herd growth-rate of, for example, 65%, would have to mean a birth-rate that was much higher than 65% to offset foal deaths (50%) and adult deaths (5%).

 





Sulphur roundup comments unveil the cruel scam Utah is running

Wild horses sold for Basashi Sushi (Horse Meat)

Wild horses sold for Basashi Sushi (Horse Meat)

 

Email: eburghar@blm.gov

copy: jpalma@blm.gov

February 25, 2015

Bureau of Land Management
Cedar City Field Office
176 East DL Sargent Drive
Cedar City, Utah 84721

Attention: Elizabeth R. Burghard, Cedar City Field Office Manager

Project Name: Sulphur HMA Public Health and Safety
Wild Horse Gather and Removal

Document: News Release

Link:

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

I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …

Sulphur HMA

… and that are, reportedly, posing safety-concerns along Highway 21.

I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
REASONS CITED BY BLM FOR SPECIAL ROUNDUP
Overpopulation, Forage Limitations

BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.

The Proposed Action

BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830” (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.

The Issues

There are several important questions concerning the planned gather that BLM has not addressed.

What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21”? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?

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

Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.

FENCE OFF HIGHWAY 21
Outsiders — Dealing with Roving Equids

Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.

Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.

Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?

And, most importantly, …

Why hasn’t Highway 21 been fenced off near the HMA?

BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.

Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses

Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.

I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.

Wildlife Underpasses — Historical Perspective

Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.

Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.

What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.

http://www.sltrib.com/sltrib/news/56291923-78/wildlife-deer-highway-utah.html.csp

The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.

https://wildlife.utah.gov/hunting/plans/deer_27.pdf

Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!

http://www.sltrib.com/info/staff/1714705-156/deer-utah-wildlife-mule-habitat-million

How Well Did the Highway 89 Underpasses Work?

Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.

http://www.deseretnews.com/article/865603956/Deer-crossings-successful-but-not-perfect.html?pg=all

Wildlife and Roads — Decision-Guide

At the link below, you will find information and resources regarding the use of overpasses, underpasses, and crosswalks for mitigating collisions between wildlife and vehicles.

http://www.wildlifeandroads.org/decisionguide/2_1_6.cfm

You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
FLAWED POPULATION ESTIMATES
Unlikely Birth-Rate

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

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.

Population and Gather Reports — The Data

Per a review of the …

HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,

discrepancies are evident.

Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015

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

Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
—— —– ———– ————– —————————————————

2008 250 435 + 87 BLM estimated foal-crop @ 20%
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
——
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
—–
267 Post-gather estimate = 38+22+207

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

2013 384 +334 BLM estimated foal-crop @ 87%
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal- crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 Current estimate = 718+144-30-2
2015 830 Public health and safety excuse used to justify removing 100 wild horses without an EA.

The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.

Societal Impact of Inflated Population-Data

The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.

Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.

Mistakes Cost Wild Horses Their Freedom

The planned removals appear to have been hurriedly scheduled to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by faulty figures.

Not the First Time Population-Estimates Were Found to Be Flawed

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

125 %
131 %
153 %
157 %
249 %

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

Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it inadvertently portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER BLM METHODOLOGY
Projections per a Twenty-Percent Foal-Survival Rate

Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).

Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.

Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.

Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.

Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.

http://www.einsten.net/pdf/110242569.pdf

BLM-Billings, which has been employing PZP for many years to contracept the Pryor Mountain herd, has found that PZP’s efficacy averages 90 percent.

http://www.blm.gov/style/medialib/blm/mt/field_offices/billings/wild_horses/2015_fertility_ea.Par.54014.File.dat/PMWHR%20fertility%20preliminary%20EA%202015.pdf

A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.

http://www8.nationalacademies.org/cp/projectview.aspx?key=49392

However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.

Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.

Bottom line: Every benefit-of-the-doubt has been given.

Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths

2008 — 190 — BLM’s population-estimate post-gather November 2008

Year Herd-size
January 1

2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.

2010 — 228 — Foal-crop: 46. Dec. gather removed 30 horses, PZP 38 mares.

2011 — 244 — Foal-crop: 49. PZP does not affect already-pregnant mares.

2012 — 293 — Foal-crop: 59. Even though PZP at maximum-effect.

2013 — 352 — Foal-crop: 70. Even though PZP still in effect.

2014 — 422 — Foal-crop: 84. But gather in Aug removed 30 horses.
2015 — 476 — including the 2014 foal-crop

2015 — 392 — excluding the 2014 foal-crop

It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.

Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.

Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …

Below minimum-viable population.

No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.

Planned Roundup Would Have a Devastating Impact on the Sulphur Herd

Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.

But it gets worse. Recent studies have shown BLM’s “20-percent-per-year” rule to be exaggerated by double.
TRUE HERD-GROWTH RATE, FOAL-TO-YEARLING SURVIVAL RATE = 10%
Longitudinal Study Demonstrates Growth-Rate of Five-to-Ten-Percent

The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.

Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …

No removals
No predators
No PZP

Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.

http://www.ispmb.org/Letter.html

The ISPMB study casts doubt on BLM’s standard “20-percent-per-year” rule for estimating herd-growth. Certainly, assumed growth-rates of 29 percent IN 2010 and, especially, the 87 percent growth-rate the BLM assumed for 2014, are implausible. Further, because subsequent estimates were based on false, inflated previous estimates, the errors compounded.

Independent Research Discloses a 10% Foal-to-Yearling Survival-Rate

A study of BLM roundup-records for a representative sample of four herd management areas was recently published (Gregg, LeBlanc, and Johnston, 2014).

http://protectmustangs.org/wp-content/uploads/2014/04/PM-Population-Growth-4.25.14-FINAL.pdf

The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER NEW RESEARCH-FINDINGS
Projections per a Ten-Percent Growth-and-Survival Rate

Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).

Sulphur HMA — Per 10% Growth — Modified by Removals, but NOT by PZP

2008 — 190 — BLM’s population-estimate post-gather Nov ’08

Year Herd-size
January 1

2009 — 190 — Foal-crop: 19.

2010 — 209 — Foal-crop: 21. Dec. gather removed 30 horses, PZP 38 mares.

2011 — 200 — Foal-crop: 20. PZP does not affect already-pregnant mares.

2012 — 220 — Foal-crop: 22. Even though PZP at maximum-effect.

2013 — 242 — Foal-crop: 24. Even though PZP still in effect.

2014 — 266 — Foal-crop: 27. But gather in Aug removed 30 horses.
2015 — 263 — including 2014 foals

2015 — 236 — excluding 2014 foals

It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.

Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.

However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …

Below AML and
Below minimum-viable population.

It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.

Could There Really Be 100 Wild Horses Wandering onto the Highway?

Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.

Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.

Happy Tone, Ugly Reality

BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.

Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21”;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
ADOPTION … OR HIGHWAY TO HELL?
Sale to Slaughter for Sulphur HMA Captives

BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.

A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21” removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.

http://rtfitchauthor.com/2014/12/11/

Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21” only to send them down a “highway to Hell”?
SULPHUR HERD’S AML WAS SET AT A GENETICALLY NON-VIABLE LEVEL
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP

BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.

A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:

http://data.iucn.org/dbtw-wpd/edocs/1992-043.pdf

http://coreybradshaw.files.wordpress.com/2011/03/traill-et-al-2007-biol-conserv.pdf

BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.

Sulphur HMA — Utah — AML, and Acres per Wild Horse — Current

AML: 165 to 250 — Below minimum-viable population

Total acres: 265,711 — which is approximately 415 square miles

Acres per wild horse: 1,063 – 1,610 — about 1⅔ to 2½ square miles per horse
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Recommended

AML: 2,500 to 5,000 — Meets minimum-viable population per IUCN

Total acres: 265,711 — which is approximately 415 square miles

Acres per wild horse: 53 – 106 — about 6 to 12 horses per square mile

BLM’s National Authorized Livestock AUMs

But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?

BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.

Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.

157,000,000 acres of public lands on which BLM allows cattle

1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized

2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2

4,133,332 cows and calves = pairs x 2

38 acres per cow or calf

BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.

Actual Grazing Use Report — Form 4130-5

As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Annual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”

http://www.blm.gov/style/medialib/blm/noc/business/eforms.Par.2064.File.dat/4130-005.pdf

http://www.gpo.gov/fdsys/pkg/FR-2014-08-22/html/2014-20049.htm

Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the reports is suspect.

Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use

In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.

http://wildhorseeducation.org/2015/01/09/nevada-rancher-gets-bill-for-livestock-trespass-in-wild-horse-area/

Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.

What If There Is Not Enough Forage to Support 5,000 Horses?

Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that

… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.

http://www.habitatforhorses.org/an-update-seen-through-the-eyes-of-one-biologist/
LONG-TERM VIABILITY OF THE SULPHUR HERD
Genetic Evaluation of the Sulphur Herd

BLM notes that the Sulphur herd has Spanish Barb genetics. Many reportedly have the primitive dorsal stripe and “tiger stripes” on their legs.

http://www.blm.gov/ut/st/en/fo/cedar_city/wild_horses_and_burros/sulphur_hma.html

Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.

Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.

The correct order is:

Sample first.
Sample complete — 100 percent.
Test samples.
Manage per test-results.

There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.

Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool

I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.

Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:

http://evolution.berkeley.edu/evosite/evo101/IIIDGeneticdrift.shtml

Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring

Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
A HELICOPTER-ROUNDUP IS ILL-ADVISED FOR SEVERAL REASONS
Helicopters Are Not Safe

BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.

Peculiar Way of Addressing Safety Concerns

Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.

Helicopter-Drive — an Inhumane Roundup Method

Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.

Abusive Behavior by Helicopter Pilots during Gathers

As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.

There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.

No Horse Left Behind

The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.

An Angry Contractor May Be Headed Your Way

In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.

Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.

http://wildhorseeducation.org/2015/02/22/standoff-obstructs-pioneering-effort-for-wild-horses/

Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.

Some Observers May Be Pumped-Up Too

Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.

http://www.idahostatejournal.com/news/state/blm-holds-off-on-plan-to-return-mustangs-to-range/article_5eaf59ac-008c-5977-8f3a-491f9e9dad06.html

The political weather is unstable. That is another good reason to call off the roundup.

Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs

A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.

How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.

Possible Collusion with Permit-Holders

Perhaps, as you read this, permit-holding ranchers are in the HMA, pushing wild horses toward the Highway.
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
1. Stop action. Cancel gather.

2. Complete environmental assessment.

3. Correct errors in the population-estimates.

4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.

5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.

6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.

7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).

8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.

9. Conduct a 100-percent evaluation of the Sulphur HMA herd’s genetic status.

10. Say “No” to helicopters.
—————————————-

Sincerely,

Marybeth Devlin

Craig Downer speaks out against proposed roundup and PZP drugging

PM Craig Downer by Rona Aguilar

Statement by Craig C. Downer, Wildlife Ecologist and author of The Wild Horse Conspiracy (2014) concerning the BLM plans for the Pine Nut Herd Management Area (HMA) wild horse population recently announced by the Carson City BLM District Office.

December 24, 2014

Yesterday I received the Carson City BLM’s BLM Nevada News announcement of Dec. 19, 2014, from Lisa Ross, the Public Relations official. In this, the Sierra Front Field Office announced its Decision to round up 332 wild horses and permanently remove 200 of these, while releasing 132 back into the range but only after injecting the mares, estimated at 66, with 22-month Porcine Zona Pellucida (PZP-22), an immunocontraceptive vaccine whose long-term effects on the well-being of the wild horses is highly questionable.

The claim by these BLM officials is that there is an “overpopulation” of wild horses in the Pine Nuts, in other words, “excess” wild horses and that these animals are damaging the ecosystem, degrading sage-grouse habitat and reducing native grass plants. No mention, however is made of the fact that cattle and sheep grazing pressure on the grasses and other forage species is several times that of the wild horses here. Nor is any mention made of the many positive contributions the wild horses make to bolster the ecosystem as non-ruminant, post gastric digesters who complement the ruminant grazers.

I visit the Pine Nut Range frequently and am not at all convinced of the terse and perfunctory claims made in the BLM’s recent announcement. What I have observed in the Pine Nut Range is actually an under-population of wild horses who are in the process of filling their ecological niche, but are no where near filling their niche.

The arguments for the wild horse “gather” presented by the BLM are contrived and based on their desire to justify the continuing monopolization by livestock grazing permittees, mainly, but also the hunters and the Nevada Department of Wildlife, as well as other exploiters of this beautiful mountain range and its ecosystem. The claim that the wild horses are affecting the Sage-Grouse leks are highly suspect, as I have seen wonderful harmony between the wild horses and the Sage-Grouse. This issue, I feel, is being used conveniently to avoid reducing livestock. How easy to simply blame the deterioration on the wild horses, but how dishonest!

The so called Appropriate Management Level that the BLM has set for this vast range (at least 30 miles long and in places 15 miles wide) of 119 to 179 individuals is a gross injustice to the wild horses and to the many public citizens of Nevada and elsewhere. We greatly appreciate this historic herd and wish to observe a full and exuberant population of mustangs here, not an overly reduced, mere token number that is not even at a genetically viable level, and that is not permitted to adapt naturally and harmoniously to this rich ecosystem.

From observations I have gathered, the PZP vaccine will disrupt normal social interactions and cause much frustration and dysfunction among the members of this herd. There is much cover up concerning this drug and the problems for the wild horses are not being fully revealed by those promoting it, including wild horse supporters who are being manipulated into supporting PZP but relinquishing their protest of the unfair AML and the monopolization of the grazing resource by livestock interests. In doing so, they are abandoning the true intent of the WFHBA and the long-term well being of this mustang herd in the wild by going along with their semi-domestication!

To me what is happening in the Pine Nuts and with its wild horses is another “quick drug fix” the likes of which so much of modern, technologically oriented society is wont to adopt when confronted with “problems”. In other words, rather than making the needed sacrifices to share the land and freedom with the beautiful wild horses, thus allowing them to realize a truly long-term viable population in this range, true to the pure intent of the Wild Free-Roaming Horses and Burros Act of 1971 (WFHBA that was unanimously passed and remains very popular among the General Public), our officials have chosen to shirk their legal duty and “do a number” on these animals and their public supporters.

The figure of 2,500 is the number of individual horses recommended for the viability of a wild population by the IUCN Species Survival Commission Equid Specialist Group. So why is this being ignored and such cripplingly low AMLs being adopted? It is clear to me that the wild horse enemies are getting their way almost 100% and that like overly spoiled juveniles these ranchers, hunters, etc., throw a tantrum every time they are asked to share.

The Pine Nut herd is being over managed, or reduced, to a dysfunctional level and the sound tenets of Reserve Design for a thousand or more wild horses that would allow for naturally self-stabilizing and ecologically harmonious populations is being ignored by the authorities (though I have presented it to them on numerous occasions including to their RAC and National Advisory boards. Though their heart seems not to be attuned to the true and pure intent of the WFHBA, the good news is that this deplorable situation can change with the reawakening of a noble resolve to curb livestock and other overweening monopolies and to restore the Pine Nut mustangs to a much fairer and more viable population level.

I call upon BLM authorities to discontinue their insidious disinformation campaign that ignores the positive contributions that wild horses, as returned North American natives, make to the ecosystem (soils building, seed dispersal, fire prevention, etc.). From the Secretary of Interior, to the BLM and US Forest Service heads, to the Wild Horse and Burro program directors on down, there is an urgent need to “come clean,” to “own up,” and to rectify and “make up” for all the past injustices that have been committed with the aim of either crippling or eliminating America’s last wild horses. These animals are deeply rooted in America, far more deeply than most people seem to realize. They are an ancient and long-standing presence dating back millions of years, and they are true healers of the land and the life that dwells thereon. I have come to realize this so fully after a lifetime of wild horse observation and meditation. The challenge of restoring the herds and of learning to share the land and freedom with the horses, likewise their cousins the burros, is a critically important one, one linked to all of the other critical challenges facing our human kind today. To ignore or make light of this challenge is not right. IN the spirit of Christmas, the Festival of Lights, or whatever traditions one celebrates during these Holy Days of renewal and recommitment, I call upon everyone to honor the place of the wild horse upon the land that is their ancient home, knowing we will be blessed for so doing and even in ways we at present can scarce imagine.

For a complete revelation concerning the above, please go to my website and consult the new edition of my book. Here are the links: www.thewildhorseconspiracy.org (see my 2014 article under Resources section) and for my well-rounded book order as eBook or printed book (illustrated & well referenced/ indexed book at special reduced price on Amazon: www.amazon.com/dp/1461068983 . Also go to protectmustangs.org for a thorough-going defense of these magnificent American heritage animals.

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

Dear Friends of Wild Horses and Burros

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Many blessings,
Anne

 

Anne Novak
Executive Director
Protect Mustangs
San Francisco, California

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

Twitter: https://twitter.com/TheAnneNovak
Facebook: https://www.facebook.com/ProtectMustangs
In the news: http://protectmustangs.org/?page_id=218

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

 

 

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

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

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

by Martin Griffith Associated Press

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Wild horse overpopulation myth debunked

Nevada mustang © Carl Mrozek

Nevada mustang © Carl Mrozek

 

WILD HORSE POPULATION GROWTH

Research Collaboration by

Kathleen Gregg Environmental Researcher

Lisa LeBlanc Environmental Researcher

Jesica Johnston Environmental Scientist April 25, 2014

 

INTRODUCTION

The recent National Academy of Science (NAS) report on the Wild Horse and Burro Program determined that the Bureau of Land Management (BLM) has no evidence of excess wild horses and burros; because the BLM has failed to use scientifically sound methods to estimate the populations (NAS, 2013). The NAS cited two chief criticisms of the Wild Horse and Burro Program: unsubstantiated estimates in herd management areas (HMA), and management decisions that are not based in science (NAS, 2013).

Effective wild horse and burro management is dependent on accurate population counts and defensible assumptions. The Bureau of Land Management (BLM) routinely uses the assumption that wild horse and burro herds increase annually at an average rate of 20%. However, our review of available scientific literature combined with an analysis of BLM data for 5,859 wild horses found that approximately 50% of the foals survived to the age of 1 year, which indicates a 10% population growth rate based on yearling survival rates.

METHODS AND DATA

The data and analysis is based on the BLM’s wild horse and burro removal and processing documents acquired under the Freedom of Information Act. The data sets were evaluated separately, and then combined to total 5,859 wild horses, captured, aged, and branded by BLM. This data is the basis for the analysis in this report and the accompanying chart in table 1 below.

Burro data was also calculated for foal and yearling survival. That data indicated a 7% population growth rate for burros based on yearling survival, but that data is not included here as burros are not present in all of the HMAs.

The data was collected from 4 herds captured by BLM in Nevada and California in 2010 and 2011. The data below in table 1 shows the individual herds and accumulated age structure data which supports the overall conclusion. Wild horse foals and yearlings were tallied for population increases and in all four samples, recorded a combined foaling rate of less than 20%, but only half or 50% survived to the age of 1 year (see table 1 below).

Table 1 Age Structure Yearling Survival Rate

PM Population growth

 

DISCUSSION

This research does not include or reflect the additional adult mortality rates due to the complexity of population dynamics, but does raise serious questions about the validity of the BLM’s assumed 20% annual herd population growth rate. Furthermore, the BLMs assumption fails to consider that wild horse populations are dynamic due to isolation and have varied rates of reproduction and survival due to changing climates, forage, competition, disturbance and environmental conditions. All these are factors that can lead to varied herd growth rates and each herd should be evaluated separately.

This research paper is supported by previous studies using age structure data completed by Michael L. Wolfe, Jr. in 1980 titled “Feral Horse Demography: A Preliminary Report”. Mr. Wolfe cited observations in 12 HMAs, over a period of 2 to 5 years, and covered a much broader range over six Western states. He questioned the annual rate increase of 20%, and found that first-year survival rates to range between 50% and 70% (Wolfe, 1980).

Other supporting research includes The National Academy of Science National Wild and Free-Roaming Horse and Burro report of 1982, which states, “…several biases in the (BLM) census data, cited or calculated rates of increase based on a number of published values for reproduction and survival rates, as well as sex and age ratios, and concluded annual rates of increase of ten percent or less” (NAS, 1982).

The NAS 2013 report also used age structure data to estimate population growth. However, the report used foaling rates to draw conclusions about the population growth; rather than first year survival rates (NAS, pg.51-52 2013). This and other studies challenge the assumption that the 20% foaling rate provides an adequate measure of population growth.

The BLM bases their management decisions on environmental assessments that cite inflated population estimates. As shown in this study and previous research, the BLM’s assumption of a 20% annual wild horse population growth rate is not based in science; leading to unsubstantiated population estimates with no evidence of excess wild horses.

 

REFERENCES

National Academy of Science 2013, “Using Science to Improve the BLM Wild Horse and Burro Program – A Way Forward”
http://www.nap.edu/openbook.php?record_id=13511&page=R1

Johnston, J. (2011). California’s, Wild Horses and Burros: Twin Peaks HMA.

http://csusdspace.calstate.edu/xmlui/bitstream/handle/10211.9/1492/WHB_Thesis_Final%2011.30.11.pdf?seq uence=1

“Feral Horse Demography: A Preliminary Report”, Michael L. Wolfe, Jr.

http://www.jstor.org/discover/10.2307/3897882?uid=3739560&uid=2&uid=4&uid=3739256&sid=2110368888 4451

National Academy of Science 1982, “Wild and Free-Roaming Horses and Burros”

http://books.google.com/books?id=Q2IrAAAAYAAJ&printsec=frontcover#v=onepage&q&f=false

U.S. Department of the Interior, Bureau of Land Management Freedom Of Information Act (2012). FOIA BLM FY12-011 1278.

U.S. Department of the Interior, Bureau of Land Management Freedom Of Information Act (2012). FOIA BLM- 2012-00934.

U.S. Department of the Interior, Bureau of Land Management Freedom Of Information Act (2012). FOIA BLM 2012-01046.

U.S. Department of the Interior, Bureau of Land Management Freedom Of Information Act (2012). FOIA BLM 2012-00250.

Download the paper here: PM Population Growth 4.25.14 FINAL