Protect Mustangs is a 501c3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org
This Change.org petition is going to the US Senate, the US House of Representative and the President of the United States
On September 9, 2016, the Bureau of Land Management’s Wild Horse & Burro Advisory Board voted to kill the alleged 45,000 wild horses in tax-payer funded holding facilities and pastures. Do they want to cover-up the fraud that has been going on for years by killing the evidence?
Taxpayers and the general public want to know:
- How much fraud has been committed regarding the wild horse and burro count on public land and in corrals?
- How many budgets were approved using fraudulent information?
- How many wild horses have gone to slaughter?
- How many wild horses and burros have been shot and killed?
- How many unbranded foals did the kill-buyers get to sell overseas?
We request an immediate Congressional investigation and independent head count, with photo IDs, of the alleged 45,000 wild horses and burros rounded up and held in captivity–at taxpayer expense.
In addition, we call for an immediate moratorium on roundups, transport and removals for a precise independent count, with photo ID, of all the federally protected wild horses and burros in the wild. This must occur before any more wild horses or burros are rounded up and/or transported, trapped, chipped, collared, removed, sterilized, given pesticide PZP, GonaCon®, SpayVac®, IUDs, etc., researched or experimented on in any manner to prevent further fraud against taxpayers as well as prevent abuse against wild horses and burros who should be protected from harassment and abuse by law.
We request a complete inventory of the wild horses and burros at the following locations:
- Every Herd Management Area
- Every Herd Area
- Every “Complex”
- Every temporary holding facility
- Every short-term holding facility
- Every long-term holding facility, pasture, eco-sanctuary, etc.
- Mustang Heritage Foundation facilities and all equids in their program
- TIP Trainers’ facilities
- All private contractors’ facilities
- Research facilities
- Any other locations where wild horses and burros are held in captivity and/or live on public land.
The public, voters of America and taxpayers are outraged and demand immediate action. Thank you.
Sign and share the Change.org petition
Help fight the killing!
Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.
I have just read Ben Masters’ justification for the National Wild Horse and Burro Advisory Board’s recommendation to either adopt out, place, sell to killer buyers, or have BLM itself kill the 44,000 wild horses being held at public expense. His justification rests on the premise that the wild horses are destroying the habitats, not only in the Antelope Valley HMA’s eastern side around the Dolly Varden spring, but in many other similar areas throughout the West. I was also on this field trip and heard what the BLM officials had to say. It should be noted that on the west side there were much better habitat conditions and there were bands of wild horses here as well, though not as many. I also attended the Thursday meeting of the board and heard BLM’s presentations by Alan Shepherd, Nevada BLM wild horse and burro lead, and also by John Ruhs, Nevada BLM State Director, among others. I heard all the testimonies given, and was able to give testimony myself.
I think a lot is being overlooked and that there is a rushing to judgment concerning the wild horses and their effect on the ecosystem. Especially being overlooked is how the wild horses often find themselves being set up, placed into difficult situations, not allowed to adequately spread out. Much of this is due to not securing adequate water for them and to fencing. I am particularly concerned about the over-pumping of subterranean aquifers by ranchers and mining companies that lowers the water tables and causes many of the areas where wildlife still have a place to survive to be parched and declining ecologically speaking. This was particularly noticable in many parched mountain ranges above ranchers and also around large open-pit mining operations, where water tables have subsided at an alarming rate.
I have seen and photographed the graphic evidence of this during flights I have realized thanks to LightHawk pilots. One of the areas I overflew was eastern Nevada including in the Ely BLM district and also portions of the southern Elko BLM district where the Antelope Valley hma is located. I have been in this area several times before, hiked around,and spend considerable time there during two recent summers doing field investigation concerning the ecosystem, its condition, and the wild horses and other animals, including livestock and deer, sage grouse etc. What I noted was that the ranchers and miners are being given priority consideration and access to the most productive and intact portions of the Antelope Valley Complex as well as to the Triple B Complex of wild horse herd management areas just to the south in the Ely BLM District (White Pine County), and that the wild horses are being relegated to what’s left. This runs contrary to the provision of the Wild Horse and Burro Act that states that the legal 1971 lands where the wild horses and burros lived in 1971 be “devoted principally” (Section 2 c) though not exclusively to the welfare and benefit of the wild horses. What I see as happening is that the other interests are being given priority treatment and the wild horses left to defend for themselves. This is why they find themselves on the least productive lands.
And though Alan Shepherd repeatedly stated that no livestock had grazed the declining land around the Dolly Varden Spring for ca. 7 years, sorely lacking was a revelation of the historical use by livestock in past years. An area that has been severely impacted by decades of livestock grazing can take centuries to recover, and I have reason to believe that the area around the Dolly Varden spring is just such an area. During all these 45 years since the Wild Horse and Burro program has been in effect, there has been ample opportunity for our BLM and USFS to secure much more adequate and well-spaced watering and foraging areas that would have obviated the present crisis we witnessed around Dolly Varden.
I also noted how all of the wild horses both on the east and the west sides of Antelope Valley HMA as well as its south side coming along Hwy 93 were very flighty and took off immediately when our cars stopped to view them. On the northwest side of the Antelope Valley HMA at the end of the day (near Deer Spring), I stayed longer and tried to get closer to a few bands far off to the south. Though I drove a few miles, these bands and particularly their lead stallions would never let me get within a mile of them. From a lifetime of experience as an observer of the wild horses mainly in my home state of Nevada, I know this to be a sure sign that the wild horses are being persecuted, particularly shot at with long-range rifles. So now perhaps we know the reason why the wild horses from the east side are not coming over to the west side of the hma where the grass is lusher! The horses on the west side were considerably more frightened than those on the east side, though these too were quite afraid of people and their cars, clearly alarmed when our tour caravan came into view.
During my brief presentation I indicated how it is the human population and its impacts upon natural ecosystems both here in Nevada, in the U.S.A. and around the world, that are presently reaching crisis levels. How convenient it is then to shift the focus of attention upon such a noble and highly evolved animal as the horse, returning to living in its natural state, and to claim that it is the one who is overpopulating, all the while ignoring all of its many positive contributions to the ecosystem. I have written a book on this subject and in chapter II, I point out how the post gastric, caecal digestive system of the horses and burros provides a much needed balance to the monopolization of our public lands by ruminant digesting grazers such as cattle, sheep and deer. The horses and burros contribute much more humus to build the soils and many more intact seeds capable of germinating than do the ruminant grazers that much more thoroughly digest and break down what they eat. I go on to elaborate on this and to explain many of the positive benefits that accrue from this basic biological observation in my book. It is available through Amazon and is entitled The Wild Horse Conspiracy. You can read it as an ebook and considerable portions of it in the preview. www.amazon.com/dp/1461068983
I would also like for you to note that although Ben Masters alludes to similar extremely degraded conditions being caused by the wild horses throughout the West, again each area has its own special history, and the vying of special interests especially livestock ranchers, mining companies, oil and gas companies, Off Road Vehicle operators, and Hunters for the available resources often works very much against the wild horse and burro interests. In other words, they end up getting the short end of the stick, being placed on the bottom of the totem pole by profit-oriented individuals and corporations as well as the government officials who largely serve the latter rather than the General Public’s major interest in this Quality of Life issue. I have found this to be almost invariably the case in visiting and investigating many of the wild horse and burro herd areas/herd management areas on BLM lands and wild horse and burro territories on USFS lands in several states, as I discuss in some detail in my book.
I would also like to address Masters’ advocating for the intensive and widespread use of PZP to inhibit the reproduction of mares. The effects of PZP upon individual wild horses and their social units, be these bands or herds, have been studied by professional behavioral zoologists, such as Dr. Cassandra Nunez, and there are some serious detrimental effects that have been noted. These have been the subject of peer reviewed articles and used in court cases that have recognized their serious effects on the wild horses. In short, we should not overly compromise the future well-being of the wild horses in the wild, take away their natural vitality, in order to obtain a “quick drug fix” instead of doing right and providing adequate resources, space, habitat, etc. for long-term viable and thriving wild horses able to realize their ecological niche in their legal areas. We must not replace natural selection by artificial selection by people, as this will only thwart the natural, ecological adaptation of the horses and burros to each particular ecosystem. Remember that Section 3 a of the Act clearly states that the wild horses and burros must be allowed and managed “to achieve and maintain a “thriving natural ecological balance on the public lands” and “at the minimum feasible level” of management, or interference. The Act’s preamble also clearly states that they are to be considered “as an integral part of the natural system of public lands”. To me this clearly signifies being allowed to naturally adapt to the ecosystem where they have their legal rights. Why is this being denied them in spite of the law?!
As a Wild Free-Roaming Horses and Burros Act, I have presented a Reserve Design proposal to the National Wild Horse and Burro Advisory Board as well s to the BLM Wild Horse and Burro Program itself. I had done so repeatedly and outlined a way forth that does not involve all these cruel and unnatural manipulations and restrictions upon the wild ones. I have presented this proposal as a way to achieve long-term genetically viable, ecologically well-adapted, and naturally self-stabilizing populations that would live in harmony with and contribute positively to all the other plants and animals in the legal herd management areas and territories. These wild horse/burro-containing ecosystems would be enhanced ecosystems, not degraded ones, if we people would only give them adequate habitat. Key to the success of Reserve Design is the provision of viably sized habitat of good enough quality for the horse/burro populations to realize the above. Such provision is what has been so sorely lacking in the past, and this is what must change today. Please check out my Reserve Design proposal at www.gofundme.com/mstngreservedesign and let me know what you think. I believe it is in the true spirit of the Wild Free-Roaming Horses and Burros Act and that we Americans both can and should restore the true and noble intent of this unanimously passed act. It is one that has to do with the Quality of Life we all experience and is a General Public issue.
I appreciate your listening to what I have to say. The horses are depending upon us. What is happening in Antelope Valley, the West, North America, or on Planet Earth today is not their fault. They are restorers of North American wildlife and ecosystems in many places, and they are of ancient and long-standing ancestry here. They are awesome presences and quickly revert to living in harmony with nature, reviving their age-old instincts. We should give them adequate areas where they can be themselves and prove their healing work in our world.
Submitted by Craig C. Downer, Wildlife Ecologist. A.B. UCB; M.S. UNR; Ph.D. Cand. U. Durham UK. Link to his article The Horse and Burro as Positively Contributed Returned Natives in North America is http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12 or just Google it by title and author. Website to check out is www.thewildhorseconspiracy.org in which the links to the article and how to order his book are present.
Listen to Craig Downer starting at 55 min mark on Big Blend Radio: http://www.blogtalkradio.com/big-blend-radio/2016/09/12/nature-connection-pipelines-and-wild-horses
Also please consider signing this important petition to stop this massacre of the wild horses and burros from happening: The link to this petition is: http://www.thepetitionsite.com/907/592/301/demand-nokill-45000-wild-horses-burros-in-holding/
Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.
Protect Mustangs, a 501c3 nonprofit organization calls for protests against the Bureau of Land Management’s (BoLM) Wild Horse Advisory Board’s decision today to euthanize all the allegedly “unadoptable” wild horses in long-term holding. They also voted to push more wild horses through advertised adoption events to strike them out quicker! Under former Secretary Salazar, the BoLM has irresponsibly rounded up more wild horses than they could ever adopt out at once. Is it because Salazar is a fifth generation rancher paying back a promise to the Cattlemen’s lobby? Since then the federal agency has been hoarding America’s wild horses in captivity at huge tax-payer expense without correcting the failed adoption program. Now they want to kill the mustangs they call “unadoptable” and sterilize all the wild horses living in freedom on the range. Protect Mustangs is calling for the Bureau of Land Management to #PutThemBack on the 1971 herd areas in the West and stop sterilization. More than one-third of the herd areas have been zeroed out.
“We will fight this outrageous plan to kill and sterilize America’s icons of freedom and we will win,” states Anne Novak, executive director of Protect Mustangs. “The public is not going to tolerate this. The Bureau of Land Management is a rogue agency and their advisory board is made up of people favoring the livestock industry except for one person. The bogus board of mustang haters needs to be dismantled and recreated with wild horse and burro experts–not cattlemen with a huge conflict of interest. It’s time to put America’s wild horses and burros back on public land where they belong.”
Who are the wild horses in long-term holding? Are they mostly 3-Strike mustangs from the BoLM’s failed adoption program with rotten customer service? Others are over 10 years old and should have been left out on the range to live their lives out in peace.
Check back here for updates and donate to Protect Mustangs for legal fees to fight with the law by clicking here www.PayPal.me/ProtectMustangs or go here to donate on the crowd-funding site: https://www.gofundme.com/FightwithLaw
The fight is on!
Update on Cleo April 2012: We found an adopter for Cleo but the BoLM had already shipped her out. When we told the Nevada BLM that the adopter was willing to go to long-term holding (Midwest) to get her they said that was impossible. They said they would only sell 100 horses at a time out of long term holding. The adopter could only take Cleo. The BLM said it was impossible.
Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.
To: Heather van Blokland at KJZZ
Rio Salado College and Maricopa Community College, Arizona
I am emailing you directly because comments cannot be posted to your article.
First, let me commend you for correctly identifying PZP as a “sterilization drug.” The Bureau of Land Management (BoLM) and the Humane Society of the United States (HSUS) both like to refer to it as “birth control,” but PZP is actually a sterilant. More on that later. The reason for my email is to alert you that BoLM has given you false information regarding the wild horses and burros.
While a reporter or any member of the public should be able to secure accurate data from government agencies, BoLM’s data is fraudulent as concerns wild horses and burros. BoLM is aggressively pursuing a disinformation campaign against the mustangs, concocting a crisis that does not exist, and using scare-tactics to secure increased funding for itself. Let me now address certain points cited in your article.
Herd-growth rates: Equids are slow-growth species when it comes to reproduction. The gestation period for horses lasts 11 months, and a mare produces just 1 foal. The gestation period for burros lasts 12 to 14 months, and a jenny is less fertile than a mare. While an independent study of BoLM’s records did confirm an almost 20% birth rate for wild-horse herds, and an almost 15% birth rate for wild-burro herds, the study also found that 50% of foals perish before their first birthday. Thus, the effective increase in population from new foals is just 10% for wild horses and 7% for wild burros. Adult mustangs also die. They succumb to illness, injury, and predation at a rate of at least 5% a year. So, what is a normal herd-growth rate? Around5% for wild horses and about 2% for wild burros, probably less in each case. Thus, a herd could not double every four years — that’s just BoLM propaganda.
Fraudulent figures: There is no overpopulation except on BoLM’s falsified spreadsheets. Reviews of the agency’s population-estimates reveal biologically-impossible herd-growth rates. For instance, in Arizona, BoLM reported that the Big Sandy herd grew from 250 burros to 754 burros in one year, a 202% increase. In Nevada, BoLM would have us believe that the Lava Beds herd grew from 40 burros to 350 burros in one year, a 775% increase. In Wyoming, BoLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase. The agency’s “data” is chock-full of such preposterous growth-estimates. So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that the numbers have been falsified.
Wild horses and burros are underpopulated: Per the guidelines of BoLM’s own geneticist, 83% of the wild-horse herds and 90% of the wild-burro herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP). Low AMLs enable BoLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP. For instance, the AML for Arizona’s Black Mountain herd was set at 382 to 478 wild burros. The Black Mountain Herd Management Area comprises 925,425 acres, or 1,446 square miles. Thus, per the AML, BoLM implies that each burro needs 1,936 to 2,423 acres, or about 3 to 4 square miles per burro. If BoLM projects there to be 2 burros per 3 square miles, the agency declares an “overpopulation” because there is “double the number” that the AML allows. As you can see, being “over AML” is meaningless as well as misleading. But the low AMLs, combined with falsified, biologically-impossible herd-growth estimates, give BoLM an excuse to scapegoat those few wild horses and burros for the range-damage done by the millions of livestock that overgraze the public lands.
Adoptions: Have not declined — let alone “disappeared” — contrary to what BoLM led you to believe. It’s just that BoLM used to count the thousands of sales-for-slaughter as “adoptions.” Now that only true adoptions — “forever-family” placements — qualify, it just seems as if the number has declined. However, wild horses are not homeless horses. They have a home — where they belong — on the range.
HSUS: Is the registrant of PZP / ZonaStat-H with the Environmental Protection Agency. Thus, HSUS’ information is not impartial because the organization has its reputation to protect. Further, HSUS has submitted a proposal for a multi-year project in which BoLM would pay for HSUS staff to experiment on Arizona’s burros via “opportunistic” darting with PZP.
Pesticide: PZP is not just a sterilant but also a registered pesticide that was approved by the EPA for use on wild horses and burros “where they have become a nuisance.” However, PZP was registered without the standard testing requirements. There is currently a lawsuit challenging the legitimacy of the registration, especially in light of new studies that have disclosed PZP’s many adverse side-effects.
Sterilizing mustangs: PZP is a potent weapon in BoLM’s arsenal — for its biological warfare against the wild horses. But population control for wild horses is unnecessary because there is no overpopulation. Why would we contracept herds whose population is inadequate for genetic viability? Why would we contracept herds based on falsified figures? Logically we wouldn’t and ethically we shouldn’t. Further, if PZP were going to stop the roundups, it would have done so long ago for the famous Pryor Mountain herd, home to Cloud, the stallion who was the subject of a number of documentaries that aired on PBS. The Pryor Mountain mares have been darted with PZP for nearly two decades. Yet roundups have been scheduled there like clockwork every 3 years and, in spite of intensifying the PZP treatments recently, BoLM tried to implement yearly roundups until stopped by a Friends of Animals lawsuit.
PZP — the anti-vaccine: PZP causes disease — auto-immune disease. PZP “works” by tricking the immune system into producing antibodies that target and attack the ovaries. The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. The mare’s estrogen-levels drop markedly as PZP destroys her ovaries. Ultimately, PZP sterilizes her. Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function. Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries. But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed. Those mares fail to respond to PZP. They keep getting pregnant and producing foals who, like their dams, suffer from weak immune-function. So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised. Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.
Health-risks to volunteers: As for the well-meaning volunteers who dart wild horses, EPA’s Pesticide Fact Sheet for PZP advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility. Unfortunately, PZP’s manufacturer misrepresented PZP as “so safe it is boring.” But research shows that PZP is a powerful hormone disruptor. Further, consider the magnitude of the risk — the PZP-in-question is a horse-sized dose. If volunteers think PZP is safe, they will be less likely to protect themselves from this dangerous pesticide.
Mengelian experiments: The Big Lie of “overpopulation” is the pretext for BoLM’s war against the wild horses, and the wild horses are prisoners of that war. It’s BoLM’s version of the “Shock Doctrine,” wherein the agency concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People. Now, BoLM is funding surgical-sterilization studies on the equine POWs to develop a Final Solution to the “problem” — handing out $11 million for these diabolical experiments. The grant money is surely intended to buy loyalty and silence potential criticism from academia. Plus, BoLM, a corrupt, rogue agency, gets to cloak itself in respectability by affiliating with prestigious universities.
Should you wish to learn more about how BoLM is mismanaging Arizona’s wild burros, I would be happy to send you a copy of comments recently submitted. Just let me know.
Beware of fear mongering and stand strong for wild horses to remain wild and free as the 1971 law protects them to be. YOU are needed by the wild horses to stay grounded and fight for them.The PESTICIDE PZP PUSHERS have created a big mess by pushing fertility control on wild horses in the West. They falsely claim Americans want fertility control when the truth is Americans want our wild horses protected on public land so they can be wild and free. Free is not forcibly drugged with Pesticide PZP made from slaughterhouse pig ovaries or any other form of fertility control.
Wild and free needs to be free as nature intended.
We all agreed on stopping the roundups but the PZP PUSHERS took that one step further to push their PZP management goal. They hired salaried employees to manipulate the public. Before long people were signing online letters and petitions without reading the whole thing–especially where it called for “humane management” the buzz phrase for Pesticide PZP. Even Robert Redford seems to have been fooled into asking for “humane management” because of the way the PZP PUSHERS twisted the information claiming it’s just “birth control” and not telling people about the dangers found here: http://protectmustangs.org/?page_id=6922
Pushing for Pesticide PZP as fertility control went along with the Bureau of Land Management’s (BoLM) and Cattlemen’s lobby’s overpopulation LIE. Pushing for fertility control was Pandora’s box and down a slippery slope. Now the Bureau of Land Management has jumped on the false claim that the public wants “fertility control” and so they are calling for experiments to find new ways to quickly sterilize America’s wild horses as a result. The Cattlemen’s have issued a statement against mare sterilization for their Pro-Kill agenda and you can read it here: https://www.scribd.com/mobile/doc/315053204/Cattleman-Statement-Against-Mare-Sterilization-Exp Isn’t it time we pull back and fight for America’s wild horses to be protected so they can live in freedom not buy into an overpopulation myth to sterilize, kill or slaughter them.
Please sign and share these petitions:
Stop sterilizations and Slaughter of 100,000 wild horses: https://www.change.org/p/president-of-the-united-states-congress-president-stop-sterilization-slaughter-of-100-000-wild-horses-burros
Defund the Roundups: https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups
Send a handwritten letter to your confessional representative and your 2 senators and include the top page of these 3 petitions. Ask them to protect them from being wrongfully treated as pests. Tell them people want to adopt wild horses but are discouraged because the Bureau of Land Management’s adoption program is a failure due to poor marketing and rotten customer service. Therefore the wild horses should not be punished for lazy government employees. Ask your elected officials to intervene on your behalf to stop halt all roundups and all fertility control–including experiments because there is no independent accurate census of wild horses and burros in the wild. Tell them to stop spending taxpayer funds to pull native wild horses off public land for commercial livestock grazing and welfare ranching. Let them know that all the wild horses and burros should be put back onto public land in herd areas that have little to no wild equids left and to stop killing predators to save taxpayers one billion dollars over the next 20 years. That is the truth.
Do they walk near wild horses often with their camera so they trust them? Then one day they shoot them with Pesticide PZP for population control–when there aren’t enough left in the wild.
Do they tell wild horse lovers that Pesticide PZP is so safe they “could drink it” when they already work for the BLM?
Was it the Emmy, the money or the politics that made them quit fighting for wild horse freedom?
First they pitched their buddies at the BLM for a Pesticide PZP Pilot Program then they switched to a position with the GonaCon® Experiment. Why?
Since when are vegans pushing for slaughterhouse pig ovaries to be mixed into a pesticide and shot into wild mares? What kind of vegans are they?
They call themselves ‘family planners” for wild and free wild horses when they should call themselves salaried Spin Dr.s pushing pesticides and labeling wild horses “pests”–the worst thing the could have done to this native species.
We will not tolerate the lies and the back-room deals to eventually sterilize our beautiful wild horses–indigenous to this land.
They collaborate with the BLM and do not represent the horse loving people of this land that they try to fool.
Go back to your world focusing on money, power and fame. Leave our wild ones alone. We must protect them for the generations to come. . . for the keepers of the land, animals, sea, sky and stars. . . Go back to your money that cannot buy happiness, love nor peace.
Leave our wild horses alone.
Made with slaughterhouse pig ovaries PZP is dangerous to herd health
To: Jacob Bunge, Wall Street Journal
Dear Mr. Bunge: Regarding your article — They Shoot Horses (With Birth-Control Darts), Don’t They? — here are facts to correct the lies and disinformation you have been told.
Sting of the dart: If it were only a sting! Fact: Many wild horses develop an abscess at the dart-injection site.
Bogus ballooning population: Wild horses are a slow-growth species when it comes to reproduction. The gestation period lasts 11 months, and a mare produces just 1 foal. While an independent study of BLM’s records confirmed an almost 20% birth rate, that study also found that 50% of foals perish before their first birthday. Thus, the effective increase in population from new foals is just 10%. But adult mustangs also die. They succumb to illness, injury, and predation at a rate of at least 5% a year. So, what is a normal herd-growth rate? About 5%, probably less.
Fraudulent figures: The Big Lie of “overpopulation” is the pretext for BLM’s war against the wild horses, and the wild horses are prisoners of that war. It’s BLM’s version of the “Shock Doctrine,” wherein BLM concocted a phony crisis to push through policies antithetical to the Wild Horse Act against the will of The People. There is no overpopulation except on BLM’s falsified spreadsheets. Reviews of BLM’s population-estimates reveal biologically-impossible herd-growth rates. For instance, in Utah, BLM claimed that the Conger herd grew from 156 horses to 285 horses in one year, an 82.7% increase, to which BLM tacked on another 20% by counting the unborn foals — the fetuses. In Wyoming, BLM declared that the Salt Wells Creek herd grew from 29 horses to 616 horses in 6 months (yes, months), a 2,024% increase. BLM’s “data” is chock-full of such preposterous growth-estimates. So, when you hear talk of how the wild horses are reproducing “exponentially,” that’s a sure sign that BLM has falsified the data.
Wild horses are underpopulated: Per the guidelines of BLM’s own geneticist, 83% of the herds suffer from arbitrary management levels (AMLs) set below minimum-viable population (MVP). Low AMLs enable BLM to claim an “excess” in herds whose numbers, even if they were over AML, would still not reach MVP. So being “over AML” is meaningless as well as misleading. But the low AMLs, combined with falsified, biologically-impossible herd-growth estimates, give BLM an excuse to scapegoat those few wild horses for the range-damage done by the millions of livestock that overgraze the public lands.
Whose grass? In fact, it is the livestock who are eating the wild horses’ grass. Some background — the dedicated wild-horse habitats cover only 11% of BLM land. Cattle are allowed to graze about 5 times that much, including within all but 4 of the wild-horse herd areas. Yet in those official wild-horse habitats where livestock are given allotments, the mustangs are restricted to 18% of the forage while the cattle get 82%.
Bogus billion: The wild horses being held in captivity are the “legacy” of former Secretary Salazar’s equid cleansing era, during which he had thousands of wild horses removed from the range. However, the mortality rate of captive wild horses is about 8% a year. So, obviously, since they are not reproducing, their numbers will steadily drop, showing that BLM’s billion-dollar figure for their care is just another Lie. The Wild Horse and Burro program, if run per the minimum-feasible management-model specified by Law, would not cost much at all. BLM does not lack for resources. There are 22 million acres of legally-designated wild-horse herd areas — which BLM previously took away for expediency — that can be reopened as habitat. The horses now held captive can be released to those areas, where the cost of their upkeep will be $0.
Adoptions: Have not declined. It’s just that BLM used to count sales-for-slaughter as “adoptions.” Now, only “forever-family” placements qualify. However, wild horses are not homeless horses. They have a home — where they belong — on the range.
Persecuted predators: Contrary to BLM’s disinformation campaign, wild horses do have natural predators — mountain lions, bears, wolves, and coyotes. But those predators are persecuted mercilessly. The government exterminates what the hunters don’t shoot. However, the International Society for the Protection of Mustangs and Burros — Wild Horse Annie’s foundation — notes that even without predators, wild-horse herds self-regulate their numbers, with population-growth in the single digits.
Science and Conservation Center: Is the manufacturer and distributor of PZP / ZonaStat-H. Thus, its information is not impartial. PZP is a registered pesticide that was approved by the EPA for use on wild horses and burros “where they have become a nuisance.” However, PZP was registered without the standard testing requirements. There is currently a lawsuit challenging the legitimacy of the registration, especially in light of studies that have disclosed PZP’s many adverse side-effects.
Shooting wild horses: PZP is a potent weapon in BLM’s arsenal — for its biological warfare against the wild horses. But birth control for wild horses is unnecessary because there is no overpopulation. Why would we contracept herds whose population is inadequate for genetic viability? Why would we contracept herds based on falsified figures? Logically we wouldn’t and ethically we shouldn’t. Further, if PZP were going to stop the roundups, it would have done so long ago for the Pryor Mountain herd, which has been darted with PZP for nearly two decades. Yet roundups have been scheduled there like clockwork every 3 years and, in spite of intensifying the PZP treatments recently, BLM tried to implement yearly roundups until stopped by a Friends of Animals lawsuit.
PZP — the anti-vaccine: PZP causes auto-immune disease. PZP “works” by tricking the immune system into producing antibodies that target and attack the ovaries. The antibodies cause ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. The mare’s estrogen-levels drop markedly as PZP destroys her ovaries. Ultimately, PZP sterilizes her. Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function. Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries. But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed. Those mares fail to respond to PZP. They keep getting pregnant and producing foals who, like their dams, suffer from weak immune-function. So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised. Worse yet, radioimmunoassay tests indicated that PZP antibodies are transferred from mother to female offspring via the placenta and milk.
Health-risks to volunteers: As for the well-meaning volunteers who dart wild horses, EPA’s Pesticide Fact Sheet for PZP advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility. Unfortunately, PZP’s manufacturer has misrepresented PZP as “so safe it is boring.” But research shows that PZP is a powerful hormone disruptor. Further, consider the magnitude of the risk — the PZP-in-question is a horse-size dose. If volunteers think PZP is safe, they will be less likely to protect themselves from this dangerous pesticide. Indeed, please note that in the photo accompanying your article, Ms. Bolbol is not in compliance with EPA’s safety-precautions. She is not wearing the required protective gear.
Mengelian experiments: Now, BLM wants to perform diabolical sterilization experiments on these equine POWs to develop a Final Solution to the “problem”. BLM is handing out $11 million for sterilization-studies. The grant money is surely intended to buy loyalty and silence potential criticism from academia. Plus, BLM, a corrupt agency, gets to cloak itself in respectability by affiliating with prestigious universities.
The ugly side of PZP is humane-washed by feel-good features that describe it with humor, sweetness and light. However, the true story of PZP is one of scandal, whose deceit and danger — to both horses and humans — must be exposed. That is the story that needs to be reported.
Biased white papers have been swaying elected officials and spreading the overpopulation lie since 2011
It’s no wonder that we are fighting an uphill battle when our elected officials are working off white papers severely biased against wild horses and burros and their right to be part of the thriving natural ecological balance. Read the white paper that focuses on disposal and ignores the fact that wild horses are a native species.
Click here to read it: Wild Horses and Burros_Issues and Proposals
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.
(Photo Credit Rylee Isitt/WikiCommons)
Deadline extended to August 22, 2016 so please get your comments in. Below is what Marybeth Devlin sent in.
Postmarked or Received by:
August 15, 2016
Colorado River District Office
Kingman and Lake Havasu Field Offices
CEQ, DOI, and BLM National Office
with hard-copy via Priority Mail to:
Bureau of Land Management
Kingman Field Office
2755 Mission Boulevard
Kingman, AZ 86401
Subject: Black Mountain Wild Burros
Project: PZP Fertility-Management Pilot
Proposed by: Humane Society of the United States
Document: Environmental Assessment ( EA )
NEPA ID: DOI-BLM-AZ-C010-2016-0004-EA
This letter responds to the public-comment period currently underway regarding the management of the wild burros whose dedicated habitat is the Black Mountain Herd Management Area (HMA). I submit these substantive comments — questioning the accuracy and integrity of BLM’s analysis — and new information relevant to the analysis that should have been considered but was not — as an interested party in behalf of the Black Mountain wild burros. Please note that in all instances where text has been emphasized, either through bold and/or italics, the emphasis was added by me. For ease of reference, below are the respective links to BLM’s press release and to the Webpage where the Dear Reader letter and the EA are posted.
BLM received an unsolicited proposal from Humane Society of the United States (HSUS) to conduct a pilot study on the use of porcine zona pellucida (PZP), also known as ZonaStat-H, an EPA-registered pesticide that induces infertility, on as many as 165 wild jennies of the Black Mountain herd. HSUS would endeavor to determine the effects of PZP on individual jennies and on herd-structure following treatments. HSUS would particularly focus on whether remote “opportunistic” retreatment methods could work. HSUS would collect and maintain data-sheets, and submit them as well as an annual progress report to BLM for review.
HSUS has requested $33,695 in funding from BLM over 3 years. BLM reviewed the proposal and has now issued a preliminary EA, accepting public comments before issuing a decision.
Captured and Held — Injected and Re-Injected — Branded and Disfigured
The jennies would be captured via bait-trapping and then transported to a holding facility for injection with PZP. They would be held captive for the next several weeks in order to administer a second “booster” injection of PZP. Most (70 to 100) of the jenny-subjects would also be freeze-branded with three digits on both hips for HSUS and BLM’s convenience in identifying them. Such permanent freeze-marks are typically 3½ or 4 inches high, and the letters are wide. Following the injections and branding, the jennies would be transported back and released into the HMA.
Annual Roundups Probable
Although field-darting would be attempted for the annual retreatments, the EA acknowledges that it might be necessary to bait-trap the jennies again for that purpose as well as in order to freeze-brand them a second time or to allow veterinary treatment of abscesses at the injection-sites. Thus, program funds would be spent for rounding up the test-subjects yearly, and the costs thereof would be over-and-above the grant for which HSUS has applied to conduct its study.
CONFLICTS OF INTEREST
HSUS — PZP’s Registrant
HSUS is a leading advocacy-organization for animal-welfare. It provides leadership to advance the cause of humane treatment of animals. In response to BLM’s abusive helicopter-roundups and scandals involving wild horses and burros being sold into slaughter, HSUS sought a compassionate way to manage the mustangs on the range. It was a noble goal, and PZP was proffered as the answer.
PZP / ZonaStat-H was touted by its manufacturer as “so safe it is boring”  and its contraceptive effects, as reversible. Relying on the manufacturer’s representations, HSUS applied to the Environmental Protection Administration (EPA) to have the product approved for use on wild horses and burros, which the EPA did — as a pesticide in cases where mustangs were deemed to have become a “nuisance.” So highly respected was HSUS’ reputation, that EPA waived certain protocols that are normally required. Unfortunately, HSUS failed to fully investigate the product beforehand, has not done so subsequently, and does not seem interested in knowing about any drawbacks to its use. Consequently, HSUS is ignorant of the body of science weighing against PZP.
Now, HSUS is seeking to conduct a study of PZP on the subject herd of wild burros. But because HSUS is the registrant of the pesticide PZP, a conflict of interest is apparent. HSUS has a stake in the outcome of the proposed study, namely, to see it succeed and to ignore ill effects. Lacking scientific impartiality, HSUS must be disqualified from studying its sponsored product and from using taxpayer money to experiment on America’s underpopulated wild burros.
BLM and HSUS — Rely on PZP’s Manufacturer for Safety Information
The EA relies heavily on reports issued by PZP’s manufacturer regarding product-safety and lack of adverse effects. However, such data is suspect because the manufacturer has a stake in promoting its product. Lacking scientific impartiality and having a financial interest in the outcome, the manufacturer has an apparent conflict of interest. Therefore, independent studies should compose the majority of the references regarding the use of PZP; however, that is not the case. Indeed, as will be addressed later in this letter, numerous independent studies have been conducted, and they revealed many adverse effects of PZP.
Mandate to Practice Scientific Integrity
The Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states:
Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy. 
BLM and HSUS have ignored and BLM has suppressed independent scientific findings about PZP’s adverse effects and unintended consequences. Instead, BLM and HSUS continue to rely almost exclusively on the manufacturer’s claims regarding PZP’s safety for use on burros and horses, and for handling by humans. In fact, independent research — and even one study by the manufacturer — disclosed that PZP is hazardous to burros, horses, and humans. BLM and HSUS are thus non-compliant with the Policy and malfeasant in their responsibilities to protect staff, volunteers, and the wild burros and horses.
FALSE PREMISES, FRAUDULENT NUMBERS
The rationale for using birth control on the Black Mountain burros is predicated on false assumptions — “virtually no natural predators” and “herd sizes can double nearly every four years” — and fraudulent figures — reported herd-growth numbers many times over the biologically plausible. It is wrong to proceed when the premises-for-action are counterfactual and fraudulent. In the EA, BLM attempts to separate the premises from the proposal; however, the two are inextricably linked.
False Premise #1 — Lack of Predators
Contrary to BLM’s assertion, burros do have natural predators: Mountain lions and coyotes. Both species are present in Black Mountain HMA. If BLM believes that inadequate numbers of these apex predators preventing them from fulfilling their population-control function, then BLM should take action to conserve them. Collaborate with the Arizona Game & Fish Department (AGFD) to prohibit hunting of predators in the HMA, and negotiate with Wildlife Services, to stop that agency from killing them. Put some healing balm on that “trigger itch” — as Aldo Leopold called it. 
Healthy Predators, Healthy Ecosystem
To achieve a “thriving natural ecological balance,” the Black Mountain HMA should be a safe-haven for predators. Such an approach would help the burros by favoring survival-of-the-fittest and the best genetic adaptations, and by keep the herd-population in equilibrium with minimal human-interference, just as the Act envisioned. Predators are the “no-cost” option. Conservation Researcher Dr. Corey Bradshaw emphasizes just how important predators are to a healthy ecosystem:
Long story short – if your predators are not doing well, chances are the rest of the ecosystem is performing poorly.
Predators keep the ecosystem in balance. Without them, prey species decline, as do the forage-production species on which the prey-animals feed. Dr. Bradshaw warns: “Without predators, our feeble attempts to conserve ecosystems are doomed to fail.” 
Wolves also prey on burros. However, Arizona’s wolves had been intentionally exterminated by the Federal and State governments to placate livestock-ranchers and to please trophy-hunters. Both groups — ranchers and hunters — continue to oppose the wolves’ right-to-exist. However, their reasons are self-serving.
Now that wiser minds have prevailed, initiatives to reintroduce wolves are ongoing.  Mohave County does not yet appear to be participating in the Mexican Wolf Restoration Project. However, again, if BLM believes there is a dearth of apex predators in the HMA, then reintroduction of Mexican Wolves is a logical solution. Because the Federal government played a major role in the extermination of wolves, the moral imperative is for the Federal government — via BLM — to make restitution to the species. The Black Mountain HMA could be designated a wolf-recovery area (WRA). 
False Premise #2 — High Reproductive Rate
First, some background facts. Burros are a slow-growth species when it comes to reproduction. The gestation-period lasts an average of 12 months — although it can extend as long as 14 months. A jennet produces just 1 foal, and she typically reproduces in alternate years. Further, the conception-rate of jennies is lower than that of mares. Thus, in contrast to wild-horse herds, wild-burro herds grow more slowly. [1, 31 and 46]
BLM uses a standard, assumed burro birth rate — 15% — as a proxy for the herd-growth rate. However, for a herd-growth rate to be valid, the birth rate must be adjusted by the death rate. To wit, …
Herd-growth rate ≠ Birth rate
Herd-growth rate = Birth rate − Foal death rate − Adult burro death rate
As is evident, BLM incorrectly equates births with herd growth. BLM wrongly assumes that all foals survive and that all adult burros live forever.
BLM’s assumption regarding burro-foal survival has been falsified per a recent independent review of BLM records. Gregg, LeBlanc, and Johnston (2014) found a high mortality rate for newborn burro-foals. Their study concluded that, based on survival-data from birth-to-yearling status, the effective increase in a typical burro-population attributable to new foals is just 7%. 
However, adult mortality must also be taken into consideration when estimating herd-growth. Adult wild burros succumb to illness, injury, and predation. Others are shot and killed by unethical parties. Still others perish from stochastic events — random catastrophes such as an epidemic or a wildfire. Adult wild burros are believed to have a mortality rate of at least 5% a year.
So, what is a normal herd-growth rate among wild burros? A good estimate would be about 2%, probably less. Thus, a burro herd could not double in 4 years, debunking yet another false premise held by BLM.
BLM’s press release starts off by announcing that there are 5,000 wild burros in Arizona. The inescapable purpose of citing a state-level population instead of the subject herd’s population — which is the only one under analysis for the EA — is to prejudice the public against the burros, to “build a case” that the burros are seemingly “overpopulated.” Such manipulation of the numbers evidences lack of scientific integrity on the part of BLM staff.
Figure 2 of the EA purports to show, in visual format, how “unchecked herds double in size every 4 years.” Figure 2 is just another fraud perpetrated by BLM at the National level and now copied at the Field Office level. It is disinformation — propaganda, not science. Independent research and analyses have revealed that BLM falsifies its wild-horse-and-burro population-data.
A review of BLM’s population-estimates for the Black Mountain herd disclosed biologically-dubious year-to-year growth data. The figures reflect herd-growth way beyond the normative foal-survival rate, and adult mortality was evidently ignored. 
The chart below tracks BLM’s reported herd-growth estimates for the Black Mountain burros since 2013, which serves as the base, the starting point — assuming it is correct, which is probably not the case. Deviations from three norms are calculated:
(1) From BLM’s assumption of a herd-growth rate of 15%, which does not take mortality — either foal or adult — into account;
(2) From the Gregg et al. study of BLM records, which found a 7% increase in burro herds attributable to new surviving foals but which did not take adult-mortality into account; and
(3) From the Gregg et al. study’s finding of a 7% increase due to new surviving foals, but adjusted to take into account a conservative annual adult-mortality rate of 5%, which yields a net herd-growth rate of 2%.
(1) (2) (3)
from 15% from 7% from 2%
per BLMper Studyper Study
without without with 5%
Foal orAdult Adult
PopulationGrowthAdult Mortality Mortality
Year Estimate Rate Mortality
2013 800 n/a n/a n/a n/a
2014 1,000 25% 67% higher 257% higher 1,150% higher
2015 1,450 45% 200% higher 543% higher 2,150% higher
2016 1,551 7% 53% lower 0% equal 250% higher
Note that the implausible growth rates compound, as each successive year is calculated per those that preceded it. The errors compound also, leading to population-figures that are biologically impossible, given the reproductive limitations of the burro species.
Arbitrary Management Level (AML)
The AML for the Black Mountain herd was set in 1996 at 382 to 478 wild burros. Black Mountain HMA comprises 925,425 acres, or 1,446 square miles. Thus, per the AML, BLM implies that each burro needs 1,936 to 2,423 acres, or about 3 to 4 square miles per burro.
That idea that every little burro would need 3 or 4 square miles of range is preposterous as well as unscientific. Therefore, the AML is arbitrary and capricious.
Minimum Viable Population (MVP) — IUCN Says ~ 2,500
The AML must be reformed to set a baseline — a starting point — of at least 2,500 burros. Where does this number — 2,500 — originate? It is the recommendations of the International Union for Conservation of Nature (IUCN), the world’s oldest and largest global environmental organization. The IUCN is a neutral forum for practical solutions to conservation challenges and a leading authority on the preservation of genetic diversity in wild equids, including horses and burros. The IUCN notes that the selective pressures wild equids have endured in the wild are likely shaping them genetically to be hardy stock that could prove useful as a genetic resource. 
Note that 2,500 is not a maximum but a minimum size. Higher numbers would be better. Because neither the questioned population-estimate nor the present AML reaches the minimal threshold of 2,500 individuals, the herd is under-populated. Therefore, the Black Mountain HMA needs to have its herd-size baseline expanded accordingly.
By increasing the AML, the HMA would be brought into compliance with scientific expertise concerning adequate herd size. The properly-set AML would be foundational to BLM’s best management practices (BMPs) relative to protecting and preserving this wild burro herd.
Minimum Viable Population (MVP) — Meta-Analysis Says ~ 5,000
Just when you think the answer to MVP has been found, a newer study is published. Traill, Bradshaw, and Brook (2007) conducted a meta-analysis of the scientific literature spanning the preceding 30 years on the topic of MVP.  The researchers filtered hundreds of studies and selected 141 sources covering 212 unique species whose distribution was skewed toward heavier animals, particularly mammals. The researchers found:
Across all species, the median MVP was 4,169. The “bootstrapped 95% confidence bounds” MVP for all species ranged from 3,577 to 5,129.
With regard to mammals, the median MVP was 3,876. The “bootstrapped 95% confidence bounds” MVP for mammals ranged from 2,261 to 5,095.
Their conclusions: In general, conservation practioners should aim for an MVP of approximately 5,000. Specifically, the authors state: “… we recommend the upper 95% confidence limit of MVP ….” For all species and for mammals specifically, a round number — a numerical threshold — of approximately 5,000 can be used to inform conservation management practices.
A 2010 article in American Scientist discussed the meta-analysis’ findings and provided some additional information gleaned from an interview with the lead author. 
How Would the New Levels Look?
Here are some numbers to compare and contrast.
Black Mountain HMA
Size: 925,425 total acres
Current Maximum Management Level: 478 wild burros
Acres per burro: 1,936
Current Exaggerated Population Estimate: 1,551 wild burros
Acres per burro: 597
IUCN Minimum Herd Size: 2,500 wild burros
Acres per burro: 370
Meta-Analysis Minimum Level for Mammals: 5,000 wild burros
Acres per burro: 185
Genetic Health of the Black Mountain Burros
In order to make informed decisions and to manage responsibly, BLM must have specific genetic data on each member Black Mountain burro herd. Therefore, BLM needs to conduct a 100-percent evaluation of the Black Mountain burro-herd’s genetic health. This would be accomplished by taking DNA samples and sending them in a timely manner to the Equine Genetics Lab. Per the test-results, and per guidance from Dr. Gus Cothran and other equine experts, BLM must then reform the AML and develop best management practices to restore and maintain gene-pool diversity via a robust population-level.
The AML must ensure an optimal burro-population — one that can easily self-sustain its diversity and viability, and that can bounce back from random catastrophic events.
The correct sampling approach and order are:
Sample current and continuing herd members.
Sample first, before considering any actions.
Sample large — 100 percent.
Manage per test-results and best-available science.
PZP — ADVERSE EFFECTS
PZP — The Pesticide
Porcine zona pellucida — PZP aka ZonaStat-H or Native PZP — is an EPA-registered pesticide derived from the ovaries of slaughtered pigs. PZP is approved for use on wild horses “in areas where they have become a nuisance ….” 
Some persons argue that, because PZP does not kill the mare or jenny, it is not really a “pesticide.” Actually, PZP does kill. As will be documented herein, PZP’s use is associated with stillborn foals. PZP is further correlated with stolen foals and out-of-season foals, who perish as neonates. In the long term, PZP tends to weaken a herd immunologically, which could swiftly lead to its extinction. So, yes, PZP is a real pesticide.
PZP — an Anti-Vaccine
While touted as a “vaccine,” PZP is actually a perversion of what a true vaccine is supposed to be. Instead of preventing disease, PZP causes disease — auto-immune disease. Thus, PZP could be viewed as an anti-vaccine.
PZP’s Mode of Action as Stated in the Pesticide Registration Is a Disproved Hypothesis
HSUS, the registrant of PZP advised the Environmental Protection Agency that, based on information from the pesticide’s researcher-manufacturer, PZP works by generating antibodies that “block sperm attachment.” This representation of PZP as a sort of chemical condom was not fact but merely an untested hypothesis, postulated three decades ago. The old hypothesis was disproved by subsequent research. PZP’s manufacturer knew, or should have known, this. The manufacturer should also have been informed and up-to-date regarding the side effects and unintended consequences of PZP. Yet, the manufacturer continued to cite the disproved hypothesis and to deny that PZP has any adverse effects. [11 and 19] HSUS is remiss in not investigating PZP beyond the manufacturer’s claims before touting it as the solution to the non-existent burro-overpopulation “problem.” BLM is irresponsible in ignoring research that has disclosed PZP’s risks.
PZP’s True Mode-of-Action
So how does PZP really work? PZP tricks the immune system into waging immunological war on the ovaries. In a meta-analysis of ZP-type contraceptives, Kaur & Prabha (2014) reported that the infertility brought on by such products is ” … a consequence of ovarian dystrophy rather than inhibition of sperm-oocyte interaction.” Thus, PZP’s antibodies “work” not by blocking sperm attachment but by destroying the ovaries. Kaur & Prabha further disclosed that ” … histological examination of ovaries of immunized animals revealed the presence of atretic follicles with degenerating oocytes.”  [Atretic follicles are ovarian follicles in an undeveloped state due to immaturity, poor nutrition or systemic disease; manifested by prolonged anestrus.]
Kaur & Prabha’s review concluded that PZP’s antibodies induce ovarian dystrophy, destruction of oocytes in all growing follicles, and depletion of resting follicles. The manufacturer of PZP as well as BLM should have been aware of these and other findings about the pesticide. Yet they ignored or disregarded any information that was contrary to their personally-preferred but obsolete and false description of PZP’s mode-of-action.
Kaur & Prabha warned that “… long term studies showed that immunization with zona antigens might induce immunological attack on many eggs in the ovary which might lead to premature ovarian failure.”
Included as a reference to the EA? No.
EA Lists Older PZP Study, but not Newer One by Same Scientists Showing Ovarian Pathologies
One of the references cited in the EA was a study by Curtis, Pooler, Richmond, Miller, Matfield, and Quimby (2002) on the comparative effects of GnRH and PZP on white-tailed deer. However, the HSUS proposal would only examine PZP, not GnRH; so the Curtis et al. (2002) study would not be the most appropriate reference to use, especially in view of the fact that lead-researcher Curtis, along with most of the same colleagues — Richmond, Miller, and Quimby — issued a newer study (2007) on PZP alone.
The Curtis et al. (2007) study disclosed that 75% of PZP-treated white-tailed deer — and 50% of re-treated deer — suffered eosinophilic oophoritis (inflammation of the ovaries). Further, the re-treated deer that did not develop oophoritis had a different problem — significantly fewer normal secondary follicles than control females. The study-authors concluded that PZP “elicited ovarian pathologies in deer similar to those observed in other species.” 
PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion
In a telling study, Kirkpatrick, Liu, Turner, Naugle, and Keiper (1992a), the lead author and manufacturer of Native PZP, along with colleagues, reported that ” … three consecutive years of PZP treatment may interfere with normal ovarian function as shown by markedly depressed oestrogen secretion.”  So, despite all the hype about PZP being non-hormonal, the manufacturer knew that ZonaStat-H has an adverse hormonal effect, causing significantly-lowered estrogen. Thus, PZP is an endocrine disruptor.  The plummeting estrogen-levels may also reflect the ovarian dystrophy and oophoritis now known to be caused by PZP. Despite personally discovering negative hormonal impacts 24 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and hid its endocrine-disruptor side-effects.
Included as a reference to the EA? No.
PZP Causes Ovarian Cysts
In their 2010 meta-analysis, Gray & Cameron cited a number of studies that found ” … alterations to ovarian function, oophoritis, and cyst formation with PZP treatment (Mahi-Brown et al.1988, Sehgal et al. 1989, Rhim et al. 1992, Stoops et al. 2006, Curtis et al. 2007).”  These findings support those of Kaur & Prabha while introducing yet another adverse effect: ovarian cysts. Gray & Cameron’s review also noted that increased irritability, aggression, and masculine behavior had been observed in females following PZP-treatment.
Included as a reference to the EA? No.
PZP → Endocrine Disruptor → Elevated Testosterone → Masculinizing Effects
Recall that PZP has endocrine-disrupting effects that result in lowered estrogen. Per the observed masculine behavior of treated mares, PZP seems to have a testosterone-elevating effect too. A deficit of estrogen alone would not necessarily manifest in the masculinization of treated females, but an excess of testosterone would. So, it appears that PZP disrupts at least two hormones: estrogen — by substantially lowering it — and testosterone — by substantially elevating it. Adverse effect: Abnormal behavior.
PZP → Ovarian Cysts → Elevated Testosterone → Masculinizing Effects
As discussed above, PZP correlates with abnormal masculine behavior on the part of treated females, a side-effect likely due to elevated testosterone. But in addition to the endocrine-disruption caused by PZP, there could be a second way for testosterone levels to become elevated. Recall that PZP causes ovarian cysts. An Internet search on “ovarian cysts and testosterone” yielded results for polycystic ovary syndrome (PCOS) in women. Interestingly, one of the symptoms of PCOS is high testosterone levels. [26 and 42] The connection between ovarian cysts and elevated testosterone suggests that the ovarian cysts caused by PZP could — either alone or in combination with PZP’s endocrine-disruptor effects — lead to high testosterone levels in treated females, as evidenced by their masculinized behavior.
PZP Causes Additional Adverse Effects
Gray & Cameron’s review also disclosed that, when PZP was administered to the females of a herd, males lost body condition while the oft-claimed improvement in female body condition did not hold up. Further, mares remained sexually active beyond the normal breeding season and had more estrus events.
PZP Selects for Weak Immune Function
Gray & Cameron’s analysis raised the possibility of PZP selecting for immuno-compromised individuals. Here’s why. Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function. Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries. But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed. Those mares fail to respond to PZP. They keep getting pregnant and producing foals who, like their dam, suffer from weak immune-function. So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised. Thus, a herd being treated with PZP is undergoing selective breeding for weak immunity, which puts the population at risk for disease — and ultimately, for extinction.
PZP Confers Dubious “Benefit” of Increased Longevity
Gray & Cameron also cited a study that found that “… PZP treated feral horse mares lived longer, resulting in a new age class (>25 years) not present before treatment ….” Exceptionally-long life is an ironic effect of PZP treatments. PZP’s manufacturer actually boasted about it, as if the anomaly were a good thing. However, Gray & Cameron questioned the supposed benefit of mares living much longer than their normal life expectancy. Indeed, such mares take up scarce slots within size-restricted populations. The ultra-elderly mares continue to consume resources for many years, but they no longer contribute to the gene-pool. It is detrimental to a population’s genetic viability to carry significant numbers of sterile herd-members way-beyond their normal life-span.
Research on Wildlife Contraceptives Revealed Stillbirths and Auto-Immune Oophoritis from PZP
There was an even earlier, definitive meta-analysis on wildlife contraceptives. Nettles (1997) reviewed 75 studies available at that time on the subject. Among his findings regarding PZP-use across different species, including horses, were:
Altered ovarian structure and cyclicity;
Interference with normal ovarian function;
Permanent ovarian damage; and
Some cases of irreversible sterility due to auto-immune oophoritis, which suggested that PZP can be selective against a certain genotype in a population. 
Many of these findings were confirmed by Kaur & Prabha as well as by Gray & Cameron. The focus now turns to certain of these key findings: Stillbirths, and auto-immune oophoritis. However, in discussing the correlation between stillborn foals and PZP-use, a related abnormality will be addressed: Stolen foals — abducted by barren mares treated with PZP.
Included as a reference to the EA? No.
Stillborn Foals — Recent Stillbirths Correlated with PZP
There is recent evidence confirming Nettles’ finding of a correlation between PZP treatments and subsequent stillbirths. In June 2015, Karen Sussman, President of the International Society for the Protection of Mustangs and Burros (ISPMB), reported that 7 mares previously treated with PZP at ISPMB, when taken off PZP, were able to get pregnant. However, 6 of those 7 mares — that is, 86 percent — produced foals that were stillborn. All other ISPMB mares that had not been injected with PZP successfully birthed healthy foals. Thus, given that environmental and other conditions were identical, the only variable was PZP. The dead foals have been sent to a university pathology department for autopsy. 
Included as a reference to the EA? No.
Stolen Foals — Dominant Mares Treated with PZP Steal Foals from Young Mares
Ms. Sussman of ISPMB further reported that several mares that are barren due to PZP treatments have stolen — and continue to steal — foals from first-time-mother mares.  Although the kidnappers do care for the foals tenderly, they have no milk. Consequently, the foals starve unless ISPMB discovers the “crime” and can intervene in time to save them. However, when such stealing occurs on public lands, there is no one to rescue the foals. So, it is likely that PZP kills foals indirectly — by their being kidnapped by barren PZP-treated mares, further confirming its status as a pesticide. We can also infer that PZP’s population-reduction effect is probably due, in part, to foal deaths.
Included as a reference to the EA? No.
Why Do PZP-Treated Mares Steal Foals?
Ms. Sussman has observed that the PZP-treated mares appear to suffer psychologically from their barrenness. They seem unhappy and frustrated that they don’t have foals of their own. So, they steal foals to fulfill that unmet maternal need.
Foal-stealing is yet another behavioral abnormality associated with PZP-use. Thus, PZP wreaks havoc beyond just the individual mares treated with it, disrupting the life of non-treated mares and threatening the life of innocent new foals. It is likely that the apparent “contraceptive” effect of PZP is due, in part, to the death of stolen foals on the range, where no one is there to save them.
Foal-Stealing — Hormonal Hypothesis
In the literature, it is noted that foal-stealing is not as common among horses as in some other species. However, when foal-stealing does occur, Waring (2003)  — citing Crowell-Davis and Houpt (1986)  — reported that foal-stealing typically correlates with a mare …
Who is close to giving birth or
Who is separated from her own neonate or
Whose foal has recently died.
Sue McDonnell, PhD, a certified applied animal behaviorist and the founding head of the equine behavior program at the University of Pennsylvania’s School of Veterinary Medicine, states:
The explanation proposed (but not known for sure) for this in a mare just before she foals is that her hormones might be a bit misaligned, such that the hormones of bonding prevail a bit earlier than they should and maternal interest and bonding occur prematurely. 
However, the kidnapper-mares in question are neither pregnant, nor separated from a neonate, nor grieving the death of a foal. If the unusual behavior is hormonally-induced, then it would seem that PZP has another endocrine-disrupting effect — and additional unintended consequences — causing social disruption and foal deaths.
Foals May Be Their Dam’s and/or Sire’s Only Offspring
In view of the fact that PZP eventually — if not immediately — causes sterility, any foal could be genetically rare and precious. In many cases, a foal may be the only offspring of a certain jenny or jack. By using PZP on the Black Mountain burros en masse, BLM could endanger the herd’s genetic diversity.
Autoimmune Ovarian Disease — Known to Cause Premature Ovarian Failure — Induced by PZP
Tung, Agersborg, Bagavant, Garza, and Wei (2002) found that autoimmune oophoritis (ovarian inflammation) could be induced by injecting test-animals with ZP3 peptide.  The researchers noted that autoimmune ovarian disease is a known cause of human premature ovarian failure. Here again, is causation of autoimmune disease by a ZP-type product. Humans and horses are both mammals. It is logical to conclude that ovarian failure also occurs in horses. This study confirms other research cited herein.
Included as a reference to the EA? No.
Autoimmune Oophoritis and Risk of Other Autoimmune Diseases
Varras, Anastasiadis, Panelos, Balassi, Demou, & Akrivis (2013) disclosed that, in humans, autoimmune oophoritis carries the risk of the patient developing other autoimmune diseases.  The correlation between autoimmune oophoritis and subsequent other autoimmune disorders weighs against injecting 165 jennies with PZP.
Prolonged Breeding Season, Unusually-late Parturition Dates with PZP
Nettles’ (1997) previously-mentioned meta-analysis on PZP disclosed additional adverse effects:
A prolonged breeding season and
Unusually-late parturition dates. (Parturition is the formal term for “giving birth.”)
These findings have recently been confirmed, as is discussed below.
Parturition-Season Extends to Nearly Year-Round When a Herd Is Treated with PZP
A longitudinal study by Ransom, Hobbs, Bruemmer (2013) of three herds currently being managed by PZP — Little Book Cliffs, McCullough Peaks, and Pryor Mountain — found a prolonged parturition-season — it lasted 341 days.  Ransom et al.’s finding of a nearly year-round birthing season supports the earlier finding by Nettles (1997). Thus, during its period of potential reversibility, PZP’s effects wear off unpredictably. Out-of-season births put the life of both the mare and the foal in jeopardy. Nature designed the equine birthing-season to occur in Spring, not year-round, and certainly not in the dead of Winter.
Included as a reference to the EA? No.
Prolonged Delay in Recovery of Fertility
The same longitudinal study by Ransom et al. found that, after suspension of PZP, there was a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recovered their fertility. What this means is that it takes that long, on average, for the ovaries to heal, to clear out all those cysts, and to regain some degree of normal hormonal function.
The question is: How is the delay in recovery-of-fertility addressed by BLM management practices? Answer: BLM ignores it. For instance, BLM currently administers PZP to Pryor Mountain’s fillies and mares starting at age 1½ — whom BLM artfully described in the Environmental Assessment as fillies “becoming two year olds” — through age four. Thus, these fillies and mares receive intentional treatments for four consecutive years before being allowed the privilege of reproductive potentiality. Per Ransom et al.’s study, the Pryor Mountain fillies and mares would be expected to need 1,645.2 days (4.51 years) to regain reproductive capacity. But BLM gives the Pryor Mountain mares only 5 years off PZP before they are put back on it again — for the rest of their life. Thus, these fillies and mares might have just a 6-month window — at best — in which to conceive. Due to the unpredictable timing of PZP’s wearing off, for some mares that window of fertility will close before they get a chance to produce a foal. Those mares’ genetic contribution will be zero.
As if the above scenario were not bad enough, PZP’s manufacturer conceded that it could take up to 8 years to recover fertility after just 3 consecutive PZP treatments. 
Ransom Advises Proceeding with Caution regarding PZP
The Ransom et al. study warned:
Humans are increasingly attempting to manage the planet’s wildlife and habitats with new tools that are often not fully understood. The transient nature of the immunocontraceptive PZP can manifest into extraordinary persistence of infertility with repeated vaccinations, and ultimately can alter birth phenology in horses. This persistence may be of benefit for managing overabundant wildlife, but also suggests caution for use in small refugia or breeding facilities maintained for repatriation of rare species.
Because BLM keeps over 80 percent of the herds — including the Black Mountain burros — at levels below minimum-viable population (MVP) per the IUCN, most herds qualify as “small refugia.”
Ransom’s Exclusion of Seven Mares Evidences PZP’s Non-Effect on Immunocompromised Mares
In the “Data Collection” methodology section of the Ransom et al. report, the authors advised:
We omitted data for one female from the Little Book Cliffs and six females from McCullough Peaks because they produced offspring in every treatment year and thus were never effectively contracepted.
This fact is important because it evidences PZP’s lack-of-efficacy on immunocompromised fillies and mares.
To review: Because PZP activates the immune system, mares with naturally-low or depressed immune function do not “respond” to the treatment. It’s as if they had been injected with saline — their immune system is so weak that it does not react to the PZP by producing antibodies. The good news is such mares’ ovaries are saved from PZP’s destructive effects. The bad news is that these mares continue to become pregnant year after year, producing foals that will also tend to inherit low immune-function. Over time, the herd will become populated with more such low-immune horses because those with strong immunity get sterilized. Thus, PZP selects for horses with low immune function, which is bad for a herd in the long term. Even a routine infection could spread quickly and wipe out a population of horses or burros with weak immune-function. If the goal is to preserve a herd, the use of PZP constitutes a worst management-practice.
BLM Was Fully-Aware of the Ransom et al. (2013) Study but Suppressed the Findings
In their report, the authors of the Ransom et al. study gave a shout-out to BLM “for administrative and technical support throughout this project.” Thus, BLM was fully aware of the multi-year study while it was in progress and even lent support to it administratively and technically. Yet, in the case of the Pryor Mountain herd, BLM omitted this important report as a reference for the 2015 Environmental Assessment, which proposed intensifying the PZP “prescription.” Thus, BLM pretended that there was no such report and unethicallly suppressed it. Consequently, the public could not comment knowledgeably and appropriately on the continued use of — let alone the accelerated application of — PZP.
I note that the Black Mountain EA also omitted the Ransom et al. (2013) study as a reference but did include an earlier study by Ransom, Cade, and Hobbs (2010) on PZP’s influence on issues of lesser importance: Time budgets, social behavior, and body condition. The 2013 study is certainly more relevant in terms of PZP’s potential impact to the very existence of the Black Mountain burros than was the 2010 report. The 2013 study’s important scientific findings should inform the decision-making process, but were left out. Thus, BLM did not use the best-available research.
Three PZP Injections Can Trigger Sterility in Mares, or Just One Shot in Fillies Before Puberty
Disturbingly, another recent study on PZP (Knight & Rubenstein, 2014) found that ” … three or more consecutive years of treatment or administration of the first dose before sexual maturity may have triggered infertility in some mares. 
These findings are particularly troubling. They suggest that, actually, only two consecutive PZP-treatments may be reversible. Except, that is, in the case of fillies who have not yet reached puberty — they could be sterilized by just one injection. Recall the Pryor Mountain fillies, whose PZP treatments begin when they are just 1½ years old. They may not have reached puberty when they are initially treated.  And as we shall see later in this report, that first shot of PZP may not be their first shot of PZP.
Included as a reference to the EA? Yes, but the EA said: “However, Knight and Rubenstein (2014) speculated that three consecutive years may trigger infertility in some mares.” (pdf-page 35)
Black Mountain’s EA Lifted Passages Wholesale from Another Fertility-Control EA
When I read the sentence referenced immediately above — that Knight and Rubenstein had “speculated” about PZP triggering infertility in as few as 3 years — it had a déjà vu quality. I knew I had encountered just that same dismissive-to-science word-choice before. Indeed I had. The 2015 Pryor Mountain Wild Horse Range Fertility Control Environmental Assessment DOI-BLM-MT-0010-2015-0006-EA contained that same sentence, word-for-word, on pdf-page 14.  In fact, the entire paragraph that ends in that sentence was lifted directly from the Pryor Mountain EA. What’s more, most of the paragraph preceding that one was taken directly from the Pryor Mountain EA. Continuing on, I found example after example of such copying, with minor additions and modifications here and there referencing jacks and jennies instead of stallions and mares.
Questions as to scientific integrity: The fact that the team of 9 BLM-Arizona staffers who prepared the EA copied extensively and word-for-word from another EA suggests that no true analysis was conducted. I wonder: Did they even read the studies they cited? Probably not.
More questions as to scientific integrity: Pdf-page 48 of the Black Mountain EA identifies the BLM National Office staff who reviewed it. One of the reviewers is the former Wild Horse Specialist for the Pryor Mountain Wild Horse Range, and held that position at the time that the 2015 fertility-control EA was issued. Did the W. O. Senior Wild Horse and Burro Representative supply his old EA for the convenience of BLM-Arizona staff? Did he essentially approve his own EA, modified slightly to reference Black Mountain wild burros instead of Pryor Mountain wild horses?
Researchers Again Express Concerns about the Abnormal Life-Spans of Sterilized Mares
Returning to the subject Knight & Rubenstein study, the researchers warned:
Inducing sterility, while relieving the mares from the energetic costs of lactation and reducing the stress from harem switching, may have unintended consequences on population dynamics by increasing longevity and eliminating the mares’ ability to contribute genetically.
Knight & Rubenstein’s concerns support those of Gray & Cameron, who also questioned the supposed benefit of sterile mares’ extended life-spans. The abnormal numbers of aged, sterile mares count for census-purposes; but their presence disadvantages the younger horses, who become tageted for removal in order for BLM to achieve arbitrary management levels. Further, such mares no longer belong to the viable gene-pool. The same concern should be taken seriously with regard to jennies, especially in light of their lower fertility and alternating-year breeding cycle.
PZP’s Destructive Antibodies Are Transmitted via the Placenta and Mother’s Milk
It gets worse. Sacco, Subramanian, Yurewicz (1981) reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. 
These findings were disclosed in 1981 — 35 years ago. PZP’s manufacturer must have known about this dangerous effect, and certainly BLM should have investigated on its own whether there was any risk to the unborn or the nursing foal. Yet, the manufacturer continued to insist that there was no danger to the foal, whether born or unborn.  And in fact, BLM regularly administers PZP to pregnant and lactating mares, who transfer the destructive antibodies to their fetus, via the placenta, and to their foal, via mother’s milk.
Fillies whose dams were injected with PZP while pregnant or nursing will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when those same fillies are injected later, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized in utero or while nursing, the treatment having been received prior to puberty, about which Knight & Rubenstein warned.
Likewise, if the Black Mountain jennies were injected while pregnant and / or nursing, their filly-foals would have PZP antibodies inflaming their little ovaries. Subsequent injections could easily sterilize them in one shot, especially if given prior to puberty.
Included as a reference to the EA? No.
PZP Weakens Herd-Immunity, Posing Risk of Stochastic Events Leading to Herd-Extinction
To be self-sustaining, a herd needs to possess good immunity to withstand random catastrophes — known as stochastic events — such as contagious infections. There was such an event recently in Kazakhstan, where 120,000 endangered Saiga antelope — half the world’s population — died off suddenly and inexplicably within a two-week period. Scientists think a common bacterial infection was the cause of this mass-mortality event, but are unsure why the antelope were unable to fight off the disease immunologically. 
Imagine if such a catastrophe were to befall the Black Mountain burros, whose herd-immunity would be eroded by PZP. Note that the Saiga deaths involved antelope-mothers and their calves. If Black Mountain’s few fertile jennies and their foals perished all of a sudden, that would leave just jacks and sterile old jennies. The herd would be composed of the living dead, reproductively speaking, its rare alleles extinguished. BLM would be failing to proactively manage the Black Mountain herd with stochastic events taken into consideration. That would constitute malfeasance. PZP is a tool of immunological destruction, not of proper management.
PZP Continues the Use of Roundups and Removals
If the promise of PZP were true — if PZP really did eliminate the need to roundup and remove “excess” wild horses from the range — gathers and removals would have ended long ago in the Pryor Mountain Wild Horse Range, where PZP has been in use for approximately two decades. Yet removals are scheduled there with regularity every 3 years, the latest one in 2015.
But evidently every 3 years, in BLM’s mind, wasn’t often-enough. BLM announced plans to conduct removals every year in the Pryor Mountains despite recently-intensified PZP-treatments. Friends of Animals, a reknowned animal-advocacy organization that opposes PZP, sued to prevent BLM from initiating the accelerated schedule of gathers. Friends of Animals prevailed, and the annual removals were blocked. The Court directed BLM to fulfill its commitments to reevaluate the Pryor Mountain AML. [11 and 15]
As the EA acknowledges, the Black Mountain herd would likely also be subject to annual roundups in order to re-inject the jennies, to re-brand them, and to render veterinary treatment of injection-site abscesses. What the EA refers to as “opportunistic” field-darting would probably not be adequate to “re-booster” enough of the test-subjects. Roundups are stressful on burros and costly to taxpayers. The better and no-cost population-control method is predation by mountain lions, coyotes, and perhaps even reintroduced wolves.
Risks to Humans Who Administer PZP Injections
For BLM and HSUS staff and volunteers who inject wild horses with PZP, EPA’s Pesticide Fact Sheet advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility. 
However, EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …
Pregnant women of the reason why it is so important that they strictly avoid PZP — because PZP’s antibodies cross the placenta and cross-react with and bind to an unborn female child’s own little zonae pellucidae. The baby-girl could be “anti-vaccinated” with PZP and even sterilized before birth;
EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …
Lactating women to avoid PZP and why — because PZP’s destructive antibodies would be passed along to a nursing female child via mother’s milk. The baby-girl could be “anti-vaccinated” with PZP and possibly sterilized simply from nursing.
EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …
All women of the reason why to avoid PZP — due to the risk of ovarian dystrophy, oophoritis, ovarian cysts, depressed estrogen and elevated testosterone-levels — in addition to infertility and, potentially, sterility — from unintentional self-injection.
EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures further fail to emphasize the magnitude of the risk — the PZP-in-question is a dose meant for a horse — or, in this case, a burro.
Mandate to Practice Scientific Integrity
Let us return to the Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct, which applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states:
Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy. 
In the EA, BLM has omitted independent scientific findings about PZP’s adverse effects and unintended consequences. Instead, BLM continues to rely almost exclusively on the manufacturer’s claims regarding PZP’s safety for use on horses or burros and for handling by humans. BLM and HSUS are thus non-compliant with the Policy and malfeasant in their responsibilities to protect staff, volunteers, and the wild horses and burros.
PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct
The manufacturer of PZP — a partner to BLM — misrepresented the pesticide as safe for use on animals by humans. The manufacturer knew or should have known that the former hypothesis regarding PZP’s mode-of-action had been disproved, and that PZP has dangerous side effects, safety-issues, and unintended consequences. Yet he hid and denied that information and failed to warn about PZP’s adverse effects. The manufacturer cited his own research as if it were definitive, and aggressively criticized wild-horse-and-burro advocacy groups that oppose PZP, such as Friends of Animals and Protect Mustangs, and independent researchers whose findings did not fully support his claims. Indeed, he submitted an Op-ed to The Salt Lake Tribune wherein he accused Friends of Animals and Protect Mustangs of citing “dubious and distorted” data about PZP. He belittled the research of fellow scientists whose studies on PZP yielded results somewhat different from his own.  His accusations were so unreasonable that the scientists felt it necessary to submit an Op-ed in response to defend the integrity and validity of their work.  The manufacturer also disparaged members of the public — one of whom was appointed to the Pennsylvania Game Commission — that expressed concerns about PZP. He dismissively accused them of “an attempt to mislead,” of “hyperbole,” of “knowingly manipulating information,” of “attempts to frighten people,” and of indulging in an “anti-intellectual approach to debates.”  By these actions, the manufacturer violated the DOI Code of Scientific and Scholarly Conduct.
PZP Manufacturer Misled Trainees into Believing that PZP Was Safe
BLM and HSUS staff and volunteers receive their training from PZP’s manufacturer in how to handle and administer the pesticide. BLM and HSUS are remiss in delegating the training to the manufacturer without verifying the adequacy of the instruction and the truthfulness of it. Two comments recorded recently in the media suggest that PZP’s manufacturer misled not just the public-at-large but those who received training therefrom in how to administer PZP.
Recall that the manufacturer claimed PZP is “so safe it is boring.”  Independent research shows otherwise — that PZP is a powerful hormone disruptor that could sterilize a female with just one injection. If trainees believe that PZP is boringly safe, they will be less likely to protect themselves adequately from this dangerous pesticide. Indeed, many of the trainees are women and, therefore, particularly at risk. Likewise, wild-horse-and-burro advocates are lulled into complacency, trusting that PZP is harmless. Of course, none of that is true.
Second, a PZP supporter, who self-identified as a recent completer of the PZP-darting training program conducted by the manufacturer, said in a comment posted to a news article: “I just received my FDA certification to handle and administer Native PZP. Would you be so kind to provide a link to the study you keep referencing? To my knowledge, and those teaching the Native PZP certification class, there are no side effects of the PZP produced by Dr. Kirkpatrick and his team, which is Native PZP.”  Key words: “no side effects.” It is disturbing that a person who was, no doubt, motivated by a desire to help the wild horses and burros has been disinformed regarding PZP’s safety-hazards to humans as well as to horses and burros.
PZP — Conclusions about
PZP is appropriately categorized as a pesticide by the EPA. PZP “works” by tricking the immune system into attacking and destroying the ovaries. PZP has many adverse effects as well as unintended consequences. PZP presents safety-hazards to humans who handle it. PZP is a dangerous pesticide whose use is antithetical to the spirit and intent of the Wild and Free-Roaming Horses and Burros Act.
ADDITIONAL CONCERNS AND INFORMATION
EA Includes a Reference that Cannot Be Verified and that Perpetrates a Fraud
The APA Publication Manual “contains the complete guidelines on how to cite research in text as well as formatting of material for publication. It is a set of style rules that codifies the components of scientific writing in order to deliver concise and bias free information to the reader.” 
One of the references BLM cited in the EA is listed thusly:
Cothran. 2010. Personal Communication. Conversation regarding genetics and related testing.
This citation does not comply with APA standards for a proper scientific reference because a conversation is not “findable” or “retrievable” or “recoverable.”  Thus, the above personal communication cannot be verified. It should have been mentioned only in text, not in References. It was also odd that, in the intervening 6 years, a better reference was not secured.
Evidently, the citation was intended in support of the following sentence, found on pdf-page 38.
Extended length between generations provides for lengthening generation time and slows the rate of genetic loss (Cothran, personal communication 2010).
But this sentence, too, had a déjà vu feeling to it. Sure enough, it was taken directly, word-for-word, from pdf-page 16 of the 2015 Pryor Mountain Fertility Control EA. In fact, the entire paragraph that contains the above sentence was lifted from the 2015 EA.
What is more troubling is that the reader is led to believe that someone from BLM-Arizona actually had a personal communication with Dr. Cothran back 6 years ago. Surely, no such conversation happened. Thus, a fraud is being perpetrated against the reader in violation of scholarly-integrity principles.
Bighorn Sheep — Study Shows No True Competition from Burros
Black Mountain is home to bighorn sheep, prized trophy-targets for hunters. Extraordinary efforts have been made to translocate sheep into suitable habitat in the state and to augment their numbers. On pdf-page 25 of the EA, BLM implies that burros compete with bighorn:
Over the very long-term (20 years or longer), if the results of the project are found to be effective in reducing jenny fertility rates (through extrapolation), there could be the potential for a reduction in competition for forage resources between ungulates (desert bighorn sheep, cattle, and burros).
BLM assumes — incorrectly — that burros disadvantage bighorn (and cattle). That false assumption has been debunked. Wehausen (1998) concluded that “a negative influence of burros on bighorn sheep demography has not been shown as support for true competition.”  As to the alleged competition with cattle, that false assumption has been debunked too.
Facilitation and Commensalism — Equids Enhance Livestock Production
Some species thought to compete actually facilitate one another’s well-being. They interact positively and reduce physical stress.  For instance, commensals are animals that eat “at the same table” but without competing. Such is the case for burros and bovids. Counter-intuitive but true, research has shown that cattle gain more weight when grazed with donkeys. 
BLM neds to stop the range-war, pitting burros against bovids. Forage-grazing is not a zero-sum game.
Symbiosis — Burros Graze Old Growth — Cattle Prefer New Growth
Wild burros utilize coarse, old-growth forage. They are like lawn mowers. They take off the top growth — the dry, unpalatable layer. This grazing method enables the plants to put down deeper roots, and it prevents weeds from maturing to produce seeds. Grasses are encouraged by the burros’ frequent “mowing.” In addition, the fuel-load is reduced, helping to prevent wildfires.
Livestock, in contrast, prefer tender new growth. They will even return to patches previously grazed — not rested — to get at that new growth.  Thus, by consuming the old growth and making available the new growth, wild burros make conditions better for the range and better for livestock. Arizona needs more burros, not fewer.
ESTHETICS UGLIFIED → VISITOR-EXPERIENCE RUINED
BLM procedures would call for the 165 jennies treated with PZP to be freeze-marked with three letters on both sides of their hips — left and right. Each of the letters would be 3½-4 inches in size. The purpose of these huge brands is to make it easy for HSUS researchers to spot and dart the jennies from a distance.
First, please note that the Act prohibits the branding of wild horses and burros. The Act provides no exemption for BLM or HSUS. The disfigurement of burros is unacceptable. Surely, no jennies uglified with such blemishes would ever be adopted. Their marred appearance would also spoil the wilderness experience of eco-tourists who come to see the lovely burros in their natural habitat. Like Hester Prynne, the Black Mountain jennies would wear their prominent “scarlet letters” to announce their shameful status for the rest of their life, their only “sin” being their fertility, for which they would be punished.
With regard to tracking and locating wild horses, BLM should employ inconspicuous electronic devices, such as tracking tags. The use of disfiguring freeze-marks must be prohibited. It should be noted that electronic tracking can also provide a record of each burro’s personal data for longitudinal studies. It is time for BLM to use modern methods instead of destroying the jennies’ beauty.
Recreation and Wild Burro Viewing
As it is, most wildlife-tour visitors have to search long and hard to find any wild burros to view in the Black Mountain HMA. So, with 165 of the jennies injected with PZP, there would be fewer families, and especially, fewer darling “babies” frolicking on the range. The presence of foals delights recreational visitors; the absence of foals disappoints them. Forelorn, childless jennies disfigured with huge freeze brands on their rumps would be repulsive, and not what the public wants to see. Esthetics count, and recreation is fast-becoming the predominant use of our public lands. Please don’t ruin it for us.
Protect Mustangs is an organization who protects and preserves native and wild horses.
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Protect Mustangs is an organization who protects and preserves native and wild horses.