Is the Concocted Wild Horse Crisis based on Fraud?

 

Photo by BLM in public domain

Read Marybeth Devlin’s opposition to the proposed Antelope and Triple B Roundup

Via email: blm_nv_eldowellshorsegathers@blm.gov

August 21, 2017

BLM Elko District Office
3900 Idaho Street
Elko, NV 89801

Attn: Marc Jackson, Wells Field Manager

 

Project: Antelope / Triple B Complexes

Document: Environmental Assessment ( EA )

Action: 2017 Gather Plan EA — Comments to

NEPA ID: DOI-BLM-NV-E030-2017-0010-EA

 

This letter responds to your request for substantive comments and informed analysis that BLM Elko and Ely District Offices should consider regarding the subject EA. I submit my remarks as an interested party in behalf of the wild horses of the Antelope and Triple B Complexes. BLM alleges that the herds’ respective populations exceed the arbitrary management levels (AMLs).

For ease of reference, here are the respective links to the Project Summary Webpage, where the EA and other documents are posted, and to the map of Nevada’s HMAs.

https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&projectId=84367&dctmId=0b0003e880df2fff

Please note that, in my comments, where text has been emphasized, either through bold and/or italics, the emphasis was added by me. Also, “page-number” means “screen-page” in the EA’s online version.

 

BACKGROUND

 

The Alternatives

BLM proffers four options in the EA, with Alternative A identified as BLM’s proposed action. Although not assigned a letter, the “No Action” Alternative is listed first in the EA, and it is the correct choice.

Alternative A — Cull to low-AML; PZP or GonaCon to mares; skew genders; geld 50% of studs.
Alternative B — Cull to low-AML; PZP or GonaCon to mares; skew genders.
Alternative C — Cull to low-AML.

For both Alternatives A, B, and C, the cull would drastically reduce the component herds per falsely-estimated population-levels. Page 18 of the EA states that 6,737 wild horses would be removed immediately, with the rest of the “excess” to be culled over a period of up to 10 years.

As if the cull were not bad enough, BLM would inject all released mares with pesticides — identified as either PZP-22 or GonaCon™ or “newly developed formulations.” The genders would be skewed 60:40 to favor stallions, but 50% of stallions would be gelded.

A careful review of the facts shows that the right option is the No Action Alternative. All proposed actions are contraindicated because fraud was the basis for the finding of “overpopulation.” BLM must not be rewarded for unethical, criminal behavior.

 

Wild Horses Roam — Their Presence Is Fleeting, Their Numbers Are Fluid

Just because a survey supposedly counts a particular number of wild horses in one of the Complexes on a certain day does not mean the same number are still there. Those horses may have been merely passing through per their normal free-roaming nature. They may have left the area the day after the census was conducted. Wild horses are constantly on the move. Roaming is “how they roll.” Visitor-horses are not permanent residents, but they likely get counted as such — and counted multiple times — in a census that does not take horse-movement into consideration. I refer you to my comments regarding the survey-method are why it is unsuitable for taking inventory of wild horses.

 

Not Reproduction, but Migration

BLM assumes that the Complex herds allegedly exceed the AMLs due to reproduction, and that, therefore, culling, sterilizing, and gelding must be conducted in order to save the “thriving natural ecological balance” from imminent destruction. But the EA fails to consider migration to and from nearby HMAs — such as Diamond, Diamond Hills North, Diamond Hills South, Fish Creek, Pancake, and Whistler Mountain.

 

Over-AML ≠ Over-Populated

BLM announces its intent to reduce the Complexes wild-horse herds because their numbers are — allegedly — over AML — that is, over the arbitrary management level (AML) for each herd. However, as is discussed elsewhere in my letter, the AMLs are invalid because they do not meet the minimum-viable population (MVP) as determined by the International Union for the Conservation of Nature for wild equids.

 

PRINCIPAL USE WITHIN MULTIPLE-USE APPROACH

 

Wild-Horse Habitat Must Be Managed Principally for Wild Horses

HAs and HMAs are wild-horse habitat-zones. Wild horses must enjoy principal use of their range. This requirement is stated plainly in the Wild and Free-Roaming Horses and Burros Act, which stipulates that their land is to be “devoted principally but not necessarily exclusively to their welfare ….” Thus, HAs and HMAs do not necessarily have to be managed exclusively for wild horses. However, HAs and HMAs must be managed principally for the welfare of our Federal horses.

On pages 32 and 34 of the EA, BLM disingenuously conflates “principal use” with “single use,” and claims to quote from a Senate Conference Report that single use was not intended. Who said it was? We are talking about principal use, not single use. Indeed, the WFRHBA was forward-looking for its time, anticipating the multiple-use concept while providing for principal use for wild-horses in their habitats.

Moreover, multiple-use does not mean every-conceivable-use. Incompatible uses should be excluded. Some examples of incompatible uses appear obvious — mining and off-road vehicles. HMAs should be designated “no surface occupancy” (NSO) areas — to preserve aesthetic and recreational values and to avoid disturbing the horses’ natural behavior. HMAs should also be declared “off-limits” to off-highway-vehicles (OHVs) — to protect the peace-and-quiet of the range and the cleanliness of the ambient air.

The Complexes are not being managed according to the Law because the wild horses are not allotted principal use of their habitat. The wild horses have been displaced by encroaching livestock.

This inversion must be righted, and BLM must employ the right mechanisms to do so. First, BLM needs to rescind this EA. Then, it must amend the Land-Use Plans (LUPs), Resource Management Plans (RMPs), Final Multiple-Use Decisions (FMUDs), and Herd Management Area Plans (HMAPs) to conform with the Law regarding principal use.

 

Disproportionate Allocation of Forage — Must Be Corrected

Of the 129,370 animal unit months (AUMs) — grazing slots — available in the Antelope Complex …

124,246 — AUMs — 96% — have been allotted to livestock

5,124 — AUMs — 4% — have been allotted to wild horses

Of the 93,070 animal unit months (AUMs) — grazing slots — available in the Triple B Complex …

87,406 — AUMs — 94% — have been allotted to livestock

5,664 — AUMs — 6% — have been allotted to wild horses

Question: What is wrong with that allocation? Answer: The allocation is inverted. By Law, wild horses must receive the majority of the grazing slots — the AUMs — within their HMAs in accordance with the legal requirement that they have principal use of their dedicated habitat.

 

Wild-Horses — Sparsely Populated, Widely Dispersed

The low-AML — 427 — restricts the wild-horse population-density in the 1,324,745 acres that constitute the Antelope Complex to …

1 wild horse per 3,102 acres — or about — 1 wild horse per 5 square miles.

The low-AML — 472 — restricts the wild-horse population-density in the 1,682,998 acres that constitute Triple B Complex to …

1 wild horse per 3,566 acres — or about — 1 wild horse per 5½ square miles.

Imagine if livestock were held to the same stocking-density. The sparse and widely-dispersed population imposed by the AML evidences bias. It also evidences violation of the Wild Free-Roaming Horses and Burros Act.

To grasp the enormity of the unfairness, we can see that, by converting the livestock AUMs to wild-horse equivalents, BLM allows …

Antelope Complex:

1 cow+calf pair per 128 acres — or about — 5 cow+calf pairs per 1 square mile

Triple B Complex:

1 cow+calf pair per 231 acres — or about — 3 cow+calf pairs per 1 square mile

 

Authorized v. Actual Livestock Use

BLM argues that actual livestock use is much lower than authorized or permitted use. Pages 58 through 62 feature charts that show the alleged 10-year average AUM uses by livestock in each Complex. It is curious that instead of providing recent use-figures that BLM went to the trouble of computing a 10-year average for each of the many allotments involved. What were you trying to hide?

BLM’s AUM-use charts for livestock showed 32.7% for the Antelope Complex and 46.7% for Triple B Complex. Lets assume for sake of argument that those figures are true. Then, obviously, the permittees don’t need all those authorized AUMs, and it is entirely appropriate to reassign them to whom they belong: wild horses.

But there’s more to this “use” issue. “Actual use” really means “billed use” — how many AUMs BLM billed permittees for having used. But because actual use is whatever the permit-holders self-report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not — see Bundy, Cliven — the actual-use number is unverified and likely under-reported.

 

Actual Grazing Use Report — Form 4130-5

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

https://www.blm.gov/sites/blm.gov/files/uploads/Services_National-Operations-Center_Eforms_Rangeland-Resources_4130-005.pdf

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

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

 

Voluntary Non-Use of AUMs Reflects Price-Declines for Beef

BLM and its permit-holders protest that a lot of the livestock AUMs are in voluntary non-use. They complain loudly, blaming the seeming excess of wild horses — an illusion caused by BLM’s phony figures — for reducing their AUM-usage.

However, if permittees are not using 100% of their AUMs, it is likely because the market for their product is weak. Here is an excerpt from the most recent Cattle Report issued by Ag Center:

Cattle Futures. Price declines continued in the cattle futures market. Early week sales of cattle at lower prices discouraged any long buyers from entering the market. August, expected by some to rise to last week’s cash price, instead rolled over and continues to lead the cash market down.

http://www.agcenter.com/newcattlereport.aspx

 

Beef-Cattle Now Weigh More, So Fewer Needed — The AUM Needs to Be Reformed

In an August 2015 article titled “Cattle Weights Continue to Increase at Impressive Rates,” AgWatch Network reported:

The federally inspected steer dressed weight for the week of 8/15/15 was 900 pounds, according to USDA. This was 25 pounds heavier than a year ago, and well on track to set a new record in 2015 above the 906 pounds seen in October of 2014.

Looking back at steer dressed weights, on an annual average basis, weights increased by 0.5% per year since 1960 (they were 656 pounds in 1960). Using that percentage increase (0.5%) works through 2013, but does not capture the increased growth rate seen in 2014 and what is estimated for 2015. Looking back, 2014 experienced a 1% growth in steer dressed weights year-over-year, and 2015 is on track to be 2% higher than 2014’s.

The article goes on to predict that, because of the increase in cattle-weight, a decrease in cattle-numbers will likely ensue. It states: ” … if these weights continue to increase at a faster pace, the industry may not restock back to the previous inventory peak levels.”

The AUM was originally predicated on 1,000 pounds of live weight. However, the above article discusses the dressed weight — which is dead weight, excluding certain parts. Per Wikipedia …

Dressed weight (also known as dead weight or carcass weight) refers to the weight of an animal after being partially butchered, removing all the internal organs and oftentimes the head as well as inedible (or less desirable) portions of the tail and legs.

The new and increasing average dead weight is fast-approaching what used to be the average live weight.

The AUM for a wild horse presumes a mustang is the equivalent of a 1,000-pound saddle horse. But mustangs tend to be smaller and lighter, weighing 700 to 900 pounds. Moreover, in contrast to cattle, wild horses are “easy-keepers” that thrive on poor-quality forage.

BLM needs to revisit and reform how it assesses forage-usage for cattle versus wild horses. Cattle need an AUM surcharge; wild horses need an AUM discount that reflects less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.

 

Sheep Production Continues Long Decline in the US

Not just cattle but sheep and even goats (as well as some domesticated horses) graze in the Complexes allotments. On pages 60 and 62 of the EA, BLM blames drought and “competition” with wild horses for forage causing a drop in actual-use livestock AUMs, which also include sheep. But BLM’s representation is not in accordance with the facts. Sheep-production has been in decline across the United States for decades, with herd-levels down 90% from their peak in the 1940s. [See article by Runyon in Harvest Public Media] The decline is reportedly due to a combination of factors not caused by wild horses.

Changing consumer-demand
Availability of synthetic fabrics
Competition from foreign imports
Competition from beef, chicken, pork
Scarce feed supplies for fattening
Harsh weather and drought
Price-volatility

 

Facilitation and Commensalism — Equids Enhance the Ecosystem

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.

BLM sees “competition” where there is really commensalism. For instance, in the EA, BLM implied that having fewer wild horses would reduce competition over not just forage but over water too. BLM alleges that wild horses drive off other creatures from watering holes. While that may happen, any such displacement lasts just minutes. Wild horses drink and leave. There is no ongoing blockade. Wild horses also expand water seeps, which is another benefit they provide.

Moreover, wild horses actually create little water-catchments. 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, explains how:

“A very interesting phenomenon in horses is the “creation” of dust bowls at the rolling sites. Repeated rolling in the same spot serves to eliminate the vegetation and erodes the surface, forming a shallow bowl. With time the bowl has a very compacted base lined with fine powdery soil. The bowl also becomes “oiled” with body residues. The drier and hotter it gets in summer, the more rolling occurs, and the deeper and more compact and oiled the bowl becomes. When it rains, these dust bowls gather water and become temporary watering sites.”

Thus, wild horses contribute to, rather than compete for, the availability of water. They enhance the ecosystem.

 

Rangeland Health Monitored Using Method Considered Less Accurate

Per the EA, rangeland disturbance response groups (DRGs) were evaluated per the Key Forage Plant (KFP) Method. However, KFP is obsolete, having been replaced by a new method — Landscape Appearance (LA) Method in 1996. Both the KFP and LA methods are qualitative assessments known as “ocular estimates.” In other words, you “eyeball” the area to judge its appearance; hence “ocular.”

Technical Reference (TR) 1734-7, Ecological Site Inventory, notes that such ocular estimates — qualitative assessments — “may result in reduced accuracy, limiting use of the data.” It is apparent that BLM chose an easy method that could be manipulated to blame the wild horses for any and every range condition not meeting standard, even though a century of overgrazing by livestock was the real culprit.

 

Rangeland Health Monitoring Proceeded As If Only Wild Horses Impacted the Range

BLM did not evaluate the impacts of the many other species present in the Complexes — species many times more numerous and others that are known to consume a greater percentage of rangeland forage. Instead, BLM proceeded as if only livestock and/or wild horses used the rangeland’s resources, listing them as “primary” users. However, wild horses were the scapegoats. The rangeland monitoring was merely a “hatchet job” — a maliciously destructive critique — on the wild horses in order to make it seem as though culling, contracepting, and gelding the herd were justified when, in reality, such actions are contraindicated.

 

Lagomorphs

Although BLM alleges “competition” between mustangs and livestock over forage, one of the dominant herbivores on the range are lagomorphs — jackrabbits, hares, and cottontails. According to Appendix VII “Species List” to the EA, all-three species are found in the project area. However, BLM has neither determined nor factored in their impact on the range.

A recent study in Utah found that jackrabbits were consuming 34% of the forage on local grazing-allotments. Evidently, the creatures reproducing like rabbits were rabbits. Ranchers immediately called for an end to shooting coyotes, which prey on rabbits.

http://www.sltrib.com/news/2080640-155/usu-study-jackrabbits-are-a-bigger?fullpage=1

http://www.hcn.org/articles/bison-cows-rabbits-utah-ranching-henry-mountains

Instead of scapegoating wild horses for forage likely eaten by a different species, BLM needs to conduct a Ecological Site Inventory to determine actual use — including trespass use. The Inventory must pro-rate actual use by each animal-species present, including rodents and insects, and even including creatures such as lagomorphs.

 

Locusts

In normal times, locusts — grasshoppers and crickets — consume 20-to-25% of the forage in areas where they are present. However, in times of outbreaks, they can eat nearly all of the green biomass.

Grasshoppers thrive on the warming Wyoming range

Below is the link to the most recent USDA map, showing areas where there is grasshopper-and-cricket infestation. Nevada — including parts of the Complexes — appears to have been affected. As the map reflects, the creatures devouring the forage like locusts probably are locusts.

http://www.sidney.ars.usda.gov/grasshopper/Extras/2016GHwMC.htm

An Ecological Site Inventory would reveal the extent of forage-consumption by insects — such as locusts — in the project area. Again, you may be surprised to learn who is eating what and how much.

I note the omission of insects from Appendix VII’s Species List.

 

BIRTH RATE AND GROWTH RATE ARE DIFFERENT

 

Birth Rate ≠ Growth Rate

Before we examine BLM’s reported herd-growth rates for these HMAs, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. The birth rate will necessarily be higher than the herd-growth rate. Here’s why: Horses die.

 

Foal Mortality Rate = 50%

An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records of four representative herd management areas with a robust sample-size of 5,859 wild horses. While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish before their first birthday. Thus, the 20% foaling rate is merely a temporary “blip” in the data. The effective foal-to-yearling survival rate is just 10%. By failing to adjust the population-estimates per expected foal mortality, BLM inflates the figures.

 

Other-than-Foal Mortality Rate = At Least 5%

Even when fed, watered, vaccinated, wormed, and protected, horses still die. BLM advises that about 5% of wild horses in short-term holding — and 8% of those in long-term holding — perish on a yearly basis. Adult horses in the wild also succumb to illness, injury, or predation. So, it is a reasonable and conservative estimate that at least 5% of wild horses other-than-foals perish annually out on the range. The actual number is probably much higher. By failing to factor in adult-wild-horse mortality, BLM further exaggerates the population-estimates.

 

Stochastic Events — Also Reduce Herd Growth

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

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

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

Imagine if such a catastrophe were to befall the subject herds. Note that the Saiga deaths involved antelope-mothers and their calves. What if these HMAs’ mares and their foals perished all of a sudden, leaving mainly stallions, geldings, and sterile elderly mares? BLM must proactively manage the herds per IUCN guidelines, if only in case of stochastic events.

 

Normative Annual Herd-Growth = At Most, 5%

The surviving-foal rate (10%) minus the adult-mortality rate (5%) equals a normal herd-growth rate of 5%. If BLM wanted a handy — and valid — way of estimating herd-growth, using 5% per year would work. Please note: At that rate, it would take 14 years for a herd to double.

 

Maximum AML Set Below Minimum Viable Population

Approximately 83 percent of wild-horse herds are “managed” below MVP, including the subject Complexes of HMAs. What is the correct MVP for wild horses? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the acreage composing each HMA in the Complexes. However, the high-AMLs — even the combined Complexes’ high-AMLs — are set below MVP.

 

FRAUDULENT POPULATION DATA

 

Lies, More LIes, and Statistics

BLM has posted herd-growth rates that far exceed the normative rate of 5%. Here are charts showing the excessive growth rates, which are not credible. They appear to be falsified birth rates used as growth rates. Mortality was evidently ignored.

 

Antelope Complex Herds

Name of HMA: Antelope

Year Population Percent Compared to
Change 5% Norm

2013  344
2014  413  20%  4 times the norm
2015  669  62%  12 times the norm
2016  861  29%  6 times the norm
2017  1,271  48%  9 times the norm per official stats
2017ea 1,033  20%  4 times the norm per the EA
2017a  1,239  20%  4 times the norm against the EA figure

 

Name of HMA: Antelope Valley

Year Population Percent Compared to
Change 5% Norm

2013  662
2014  792  20%  4 times the norm
2015  1,013  28%  5 times the norm
2016  1,100  9%  2 times the norm
2017  1,320  20%  4 times the norm
2017a  1,584  20%  4 times the norm
2017b  1,488   96 removed in May

 

Name of HMA: Goshute

Year Population Percent Compared to
Change 5% Norm

2013  198
2014  523  164%  33 times the norm
2015  668  28%  5 times the norm
2016  904  35%  7 times the norm
2017  1,015  12%  2 times the norm
2017a  1,218  20%  4 times the norm

 

Name of HMA: Spruce-Pequop

Year Population Percent Compared to
Change 5% Norm

2013  380
2014  493  30%  6 times the norm
2015  789  60%  12 times the norm
2016  1,021  29%  6 times the norm
2017  1,170  15%  3 times the norm
2017a  1,404  20%  4 times the norm

 

Triple B Complex Herds

Name of HMA: Maverick-Medicine

Year Population Percent Compared to
Change 5% Norm

2013  586
2014  763  30%  6 times the norm
2015  910  19%  4 times the norm
2016  1,155  27%  5 times the norm
2017  1,309  13%  2 times the norm
2017a  1,571  20%  4 times the norm

 

Name of HMA: Triple B

Year Population Percent Compared to
Change 5% Norm

2013  498
2014  1,107  122% 24 times the norm
2015  1,460  32% 6 times the norm
2016  1,600  10% 2 times the norm
2017  1,702  6% 1 times the norm per official stats
2017ea  1,770  11% 2 times the norm per the EA
2017a  2,124  20% 4 times the norm against the EA figure

BLM’s population-growth figures are deemed invalid. Even if the “data” represented only the birth rates, they would, in many instances be higher than the normal birth rate.

Multiple over-counts, along with normal roaming behavior, migratory flux among HMAs, and erroneous assumptions, are likely factors to blame. Nevertheless, BLM knows the numbers have to be false. Therefore, by posting false and misleading information, and by proposing to manage per that false and misleading information, BLM is perpetuating a fraud.

In light of these fictitious figures, the No Action Alternative — is and must be the correct choice.

 

Unethical Manipulation

BLM staffers cannot claim ignorance. You are college-educated professionals with degrees in science and range management. You are well-aware that wild-horse herds cannot increase at exponential rates. Yet, you willfully continue to cite them, thereby inciting local ranchers and their elected officials. Worse yet, BLM proposes to conduct drastic culls based on those fraudulent figures.

 

Is There a Mandate to Practice Scientific Integrity?

Yes. 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.

 

Fraud Is a Crime

BLM’s wild-horse population figures are without merit. They are false and misleading. Making false and misleading representations = fraud, which violates Title 18 USC 1001 of the Federal criminal code.

 

Fraudulent Data Emboldens Scofflaws, Costs Wild Horses Their Freedom

In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use. Conditions are egregious in Nevada, where the notorious Cliven Bundy and sons, and permittees Kevin Borba and Dan Filippini, blatantly defied BLM’s authority. Yet, they were pacified with non-enforcement and concessions. BLM enables and rewards such bad behavior by caving in to it. Meanwhile, poor LaVoy Finnicum lost his life because, per precedent BLM stand-downs, he concluded that BLM and FBI would not enforce the law.

BLM Leadership Coddles Hostile and Law Breaking Nevada Ranchers like Cliven Bundy

There are likely other permittees in Nevada emulating Bundy, Borba, and Filippini. Wild horses must not lose their freedom merely so that BLM can placate greedy and rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that elected officials and ranchers are building due to the false appearance created by fictitious herd-growth figures.

No doubt, the local cattlemen are up in arms over BLM’s seeming tolerance for what has been portrayed — via fraudulent figures — as a huge overpopulation. BLM is, in part, to blame for inciting the the permittees with false and misleading information. However, the ranchers are also, in part, to blame. Certainly, being professional stockmen, they knows full well that horses are slow to reproduce. But they apparently go along with the farce because it advances their self-interest.

 

Societal Impact of Inflated Population-Data

The population-figures for the subject HMAs are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly state and local elected officials and permittees — in an uproar over a false “overpopulation” that BLM’s faulty figures portray. BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must stop this phony-story-gone-viral of a wild-horse population-explosion.

 

HELICOPTERS — INAPPROPRIATE FOR COUNTING WILD HORSES

 

But the Inventory Counted That Many Horses

When a count produces results that disagree with the known reproductive limitations of a species, the count must be deemed invalid. We know mares have a long gestation, and that they produce one foal per year. The normal annual herd-growth rate is 5% — not 122% or 164% — which are among the rates that your official data reported for herds in the Complexes. A 20% growth rate would be 4 times the norm.

 

Helicopter Inventories Produce Gross Over-Counts

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

I note that the EA also mentioned that assumptions had been used, but contended that an under-count was likely. That assumption is incorrect and opposite to the facts. When more horses are “seen” than could possibly exist, the method is faulty and likely fraudulent. Finally, I note the absence of photographs taken from a Go-Pro camera mounted on the aircraft.

 

Both the Roundup-Contractor and BLM Are Looking to “Make Their Numbers”

A glance at the map of the HMAs in question reveals that they are contiguous, and public lands are interspersed with private lands. How easy it would be for a profit-motivated helicopter-pilot to “poach” wild horses from strictly public lands by driving them into target-areas. What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?

The helicopter-pilot is looking to “make his numbers” but so is BLM. Thus, BLM has a conflict of interest in needing the contractor to remove any 6,737 horses that he can find. The wild horses are fungible — one is as good as another — to make the pilot his money and to enable BLM to spend the budget. Consequently, wild horses would lose their freedom for the private profit of the helicopter-contractor and for the administrative, job-justifying convenience of BLM. Unacceptable.

 

Dealing with Roving Equids

Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. However, removing horses that have wandered outside their HMAs just creates a vacuum for other horses to fill. Thus, removing them is an ineffective population-control strategy. The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs. The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant. Thus, removal is not a true solution — it just perpetuates the situation and leads to the elimination of more mustangs than necessary. Moreover, the wanderers may be only temporary visitors or refugees, not permanent residents. Worse yet, they may have been driven into the checkerboard by the helicopter.

Recommendations: In legitimate instances of straying, BLM should first encourage the wild horses to return to their proper place, then address those factors that caused the animals to leave home. Would palatable plantings draw the wild horses to the areas BLM wants them to use? What about siting mineral licks deep inside the HMAs, away from the outskirts? Have guzzlers been installed to provide water sources deep within the boundaries? Aversive conditioning could also be employed to shoo the wild horses into the solid-block public lands. Certainly, positive reinforcement coupled with aversive conditioning would be an effective and cost-effective solution. BLM should specify preventive and reactive measures in this regard as part of its management approach. Return outsiders to the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from “outside” areas (aversive techniques).

 

HELICOPTERS — DANGEROUS TO HUMANS, HORSES,
AND THE ENVIRONMENT

 

The risks to humans, horses, and the environment posed by the use of helicopters to count and capture wild horses were fully discussed in comments I submitted to BLM-Nevada on Tuesday, June 27, 2017, when the Motorized Equipment Statewide Hearing was held. Therefore, I will not repeat them here but am linking them to these comments by reference.

 

POPULATION-CONTROL BY NATURE

 

Predators Prey on Ponies

Nature provides its own population-control for wild horses — by means of large predators. There can be no “thriving natural ecological balance” without apex predators. Mountain lions, bears, wolves, and coyotes effectively control wild-horse populations. Predators promote survival of the fittest, as Nature intends. Therefore, the best approach is for BLM to concentrate on conserving native predators to permit natural control of the wild-horse population on the range.

 

Mountain Lions Are Especially-Effective Population-Control Agents for Wild Horses

Many studies have established that mountain lions prey on wild horses more frequently than previously believed. Canadian biologists found that cougars tended to kill younger animals, especially when preying on feral horses. Nearly all of the cougars’ predation-events (86%) involved animals less than 2 years old.

http://sci-northern.ab.ca/wp-content/uploads/2010/12/CougarKillRateandPreyComposition.pdf

In an interview with the Billings Gazette, the above study’s lead researcher, Kyle Knopf, described observing a cougar that brought down a feral horse in less than 30 yards from where it attacked.

http://billingsgazette.com/lifestyles/recreation/article_d9cf046b-2c47-539f-a267-972e72e570b6.html

Other research confirms that mountain lions are quite capable, all by themselves, of keeping wild horse populations in check.

The Montgomery Pass Wild Horse Territory, on the California/Nevada border, has had its ppopulation managed by cougars alone. An eleven-year study by Turner and Morrison (2001) concluded that the growth of this herd was limited by cougar predation. In fact, the population actually decreased over the course of the research.

http://www.jstor.org/discover/10.2307/3672527?uid=2129&uid=2&uid=70&uid=4&sid=21101018535373

The Nevada Wild Horse Range (current designation) averaged negative population growth due to cougar predation from 1989 to 1998 (Greger and Romney, 1999).

https://www.sciencebase.gov/catalog/item/5053f9e6e4b097cd4fcf8fd3

Per The Cloud Foundation, the Pryor Mountain herd averaged no population growth over a four-year period due to predation by mountain lions. Only when those lions were killed — so that BLM could continue practicing management of the herd with PZP — did the wild-horse population begin to grow.

 

Healthy Predators, Healthy Ecosystems

Minimum feasible management means letting natural selection do its job. Mountain lions, wolves, bears, and coyotes should be allowed to carry out their role of population-control agents. Predators will cull the weak, and a thriving natural ecological balance will ensue. Conservation Researcher Dr. Corey Bradshaw emphasizes “… just how important predators are for healthy ecosystems. Long story short – if your predators are not doing well, chances are the rest of the ecosystem is performing poorly.”

Due to pressure from livestock and hunting interests that mistakenly view predators as pests, it has been the Federal government’s practice to exterminate native predators outright or to allow them to be hunted on a massive scale. That policy is wrong. Predators function to 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.” Here’s the link to his timely article:

Essential predators

 

Predator Protection

HMAs should be safe-havens for predators, which will serve as wild-horse population-control agents.

There can be no true “thriving natural ecological balance” without predators. Therefore, BLM should ensure the protection of native predators, instituting a prohibition on hunting them. Conservation measures will work to enable the right number of predators to establish themselves. Large carnivores will keep the wild-horse population in check. Such an approach would keep the herd-population in equilibrium with minimal human-interference, just as the Wild and Free-Roaming Horses and Burros Act envisioned. Predators are the “no-cost” option.

Recommendations: Puma-protection, bear-introduction, wolf-reintroduction, and coyote-protection programs should be implemented. BLM should collaborate with Nevada Department of Wildlife to prohibit hunting of predators in the HMAs. Concerned livestock operators and residents of the surrounding area can be advised to use guardian-dogs to protect their animals. There are several specialty-breeds that have been developed just for this purpose, and they are reportedly effective. Protecting one’s herd is just part of the cost of doing business. The timely article linked below provides information on livestock-guardian-dogs.

https://www.hcn.org/articles/searching-for-the-best-dog-to-save-livestock-and-wildlife

 

PZP — BLM PROPOSES TO DEPLOY IT AGAINST WILD MARES

 

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, 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. [25 and 36] HSUS is remiss in not investigating PZP beyond the manufacturer’s claims before touting it as the solution to the non-existent wild-horse 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 BoLM 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.

 

Study Shows PZP Elicits Ovarian Pathologies

One of the references cited in the EA was a study by Curtis et al. (2001) on the comparative effects of GnRH and PZP on white-tailed deer. However, Curtis, along with most of the same colleagues issued a newer study (2007) on PZP alone.

Curtis, Richmond, Miller, and Quimby (2007) 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 instead developed 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.”

Included as a reference to the EA? No.

 

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. [39] The plummeting estrogen-levels may also reflect the ovarian dystrophy and oophoritis now known to be caused by PZP. Despite personally discovering negative hormonal impacts 24 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and hid its endocrine-disruptor side-effects.

Included as a reference to the EA? Cannot tell. A 1992 study is listed twice, but not 1992a.

 

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. The connection between ovarian cysts and elevated testosterone suggests that the ovarian cysts caused by PZP could — either alone or in combination with PZP’s endocrine-disruptor effects — lead to high testosterone levels in treated females, as evidenced by their masculinized behavior.

 

PZP Causes Additional Adverse Effects

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

 

PZP Selects for Weak Immune Function

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

 

PZP Confers Dubious “Benefit” of Increased Longevity

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

 

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

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

Stillbirths;
Altered ovarian structure and cyclicity;
Interference with normal ovarian function;
Permanent ovarian damage; and
Some cases of irreversible sterility due to auto-immune oophoritis, which suggested that PZP can be selective against a certain genotype in a population.

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.

 

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 mare or stallion. By using PZP on the Sand Wash Basin mares 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 the mares 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, and Bruemmer (2013) of three herds currently being managed by PZP — Little Book Cliffs (Colorado), McCullough Peaks (Wyoming), and Pryor Mountain (Montana) — 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? Yes, but EA is dismissive of its findings.

 

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 virtually all of the herds — including those of the Antelope and Triple B Complexes — at levels below minimum-viable population (MVP) per the IUCN, these 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.

 

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. For instance, the Pryor Mountain fillies’ 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? No.

 

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 targeted for removal in order for BoLM to achieve arbitrary management levels. Further, such mares no longer belong to the viable gene-pool.

 

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. Indeed, the EA recites the manufacturer’s claim in that regard. And in fact, BLM regularly administers PZP to lactating mares, who transfer the destructive antibodies to their foal via mother’s milk.

Fillies whose dams were injected with PZP while 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 while nursing, the treatment having been received prior to puberty, about which Knight & Rubenstein warned.

Likewise, if the Antelope and Triple B mares were to be injected while 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? Yes, but findings discounted.

 

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 renowned 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. [25 and 32]

As the EA proposes, the Antelope and Triple B Complexes’ herd would be rounded up in order to inject / re-inject the mares. Roundups are stressful on wild horses and costly to taxpayers. The better and no-cost population-control method is predation by mountain lions, bears, coyotes, and perhaps even reintroduced wolves.

Risks to Humans Who Administer PZP Injections

For BLM staff, contractors, 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.

 

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, BoLM 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 is thus non-compliant with the Policy and malfeasant in its responsibilities to protect staff, contractors, volunteers, and the wild horses.

 

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

The manufacturer of PZP — a partner to BLM, but since deceased — 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.” [35] By these actions, the manufacturer violated the DOI Code of Scientific and Scholarly Conduct.

 

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

BoLM and HSUS staff and volunteers receive their training from PZP’s manufacturer in how to handle and administer the pesticide. BoLM 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. It is worrisome that the volunteers may be conducting their darting under the impression that it is perfectly safe. As evidence that such is the case, in a photograph that accompanied a recent article on PZP, a volunteer-darter is shown not wearing the required protective garb.

Another PZP supporter, who self-identified at the time 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.

Likewise, wild-horse-and-burro advocates are lulled into complacency, trusting that PZP is harmless. Of course, that is not true.

 

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.

 

GONACON™ — BLM CONSIDERS DEPLOYING IT AGAINST THE HERDS

 

Gonacon™ — Yet Another Immuno-Pesticide

GonaCon™ is an EPA-registered, immuno-contraceptive pesticide. Its classification is “restricted-use” due to “non-target injection hazard.” EPA warns that “pregnant women should not be involved in handling or injecting GonaCon and that all women should be aware that accidental self-injection may cause infertility.” Children are not allowed in areas where the product is used. Please keep in mind that the GonaCon™ dose-in-question is meant for a horse.

 

GonaCon™ — Mechanism of Action

GonaCon™ causes an auto-immune disorder. Behaving like a perverted vaccine, GonaCon™ tricks the immune system into producing antibodies that destroy a female’s gonadotropin-releasing hormone (GnRH). Without GnRH, a female does not produce sex hormones, does not come into estrus, and is thus infertile. Behaviorally, courtship-rituals cease. Thus, GonaCon™ is a hormone-disruptor.

 

Gonacon™ — Link to PZP

Wild-horse-and-burro advocates who oppose the other immuno-contraceptive — PZP — will be disturbed to learn the following from the USDA-APHIS “Questions and Answers” sheet regarding GonaCon™:

After evaluating GonaCon™, the Food and Drug Administration (FDA) … approved the slaughter of pigs vaccinated with GonaCon™. Similar injectable hormone-altering products are used routinely in livestock applications.

Good grief. So, the slaughterhouse pig ovaries used to manufacture PZP may very well come from animals who were previously injected with GonaCon™ to destroy their GnRH hormone — without which the ovaries cannot produce estrogen. Those poor pigs may also have been “routinely” injected with other similar “hormone-altering products.” Then our wild horses and burros are injected with PZP, which itself causes a marked drop in estrogen after just three treatments. Surely, these hormonal atrocities constitute animal abuse.

 

Gonacon™ — Causes Long-Term Infertility

GonaCon™ is long-acting. The treatment-protocol, consisting of two injections administered 30 to 60 days apart, can cause infertility for as long as four-to-five years without the need for booster shots. However, mares would still need to be rounded up and held captive for those 30 to 60 days to administer the injections properly. If all females in a small herd were treated per the multi-year plan, it could result in an unintended consequence — a huge gap in the herd’s age-structure, because very few if any foals would have been born during that period.

 

Gonacon™ — Adverse Side-Effects, Chance of Sterilization

Although the pesticide’s effectiveness was expected to diminish over time, a 3-year study of GonaCon-treated elk revealed that the percentage of infertile females actually increased each year, finally reaching 100%. It was also noted that every one of the treated elk suffered an abscess at the injection-site. [1]

Because GonaCon™ stimulates the immune-system, it will elicit the greatest reaction — the greatest output of destructive antibodies — if a mare is blessed with healthy immune-function. Such a mare will react strongly and be contracepted quickly. But she could just as easily be sterilized. In fact, GonaCon’s™ “application instructions” warn of the chance of sterilization.

On the other hand, GonaCon™ may not work at all if a mare suffers from weak immune-function. That mare’s immune system will fail to react to GonaCon™, and she will get pregnant in spite of it. Thus, over time, there is the risk of another unintended consequence ؅— selection for immuno-compromised horses.

Jenny Powers, a National Park Service wildlife veterinarian and one of three lead scientists who participated in the elk research referenced above commented:

“Some things are meant to be wild,” Powers says. “At some point, do we not want to treat them like domestic animals and be handling them? I think it’s important to point out that this is no silver bullet so that we don’t have to kill wild animals. Any time we’re manipulative with wild animals, we’re messing with natural selection.

 

GELDING — BLM WANTS TO STERILIZE HALF OF THE STALLIONS

 

Geldings Are Not Normal in Nature

Surgical sterilization would effect a permanent change in character for a wild horse. That is not natural or normal. But BLM is itching to geld, even though the EA admits that the study it cites — by Garrott and Siniff — says “not effective” unless 85% of the males are castrated, and even then, within 2 years, a new crop of males is born.

 

Gelding Would Severely Impact Genetic Diversity

No problem, BLM says. The agency would solve that by trucking in new stallions, mares, or both. Don’t be ridiculous. Herds are, by Law, to be self-sustaining, free from BLM-meddling.

 

CONCLUSIONS

 

1. BLM must make the right decision by choosing the No Action Alternative.

2. BLM must post scientific, truthful data regarding wild horses’ herd-growth rates.

3. BLM must take responsibility to provide water-sources — guzzlers — for the herds.

4. BLM needs to conduct Ecological Site Inventories to determine actual use by species.

5. BLM must conserve predators in the HMAs for a thriving, natural, ecological balance.

 

———————————————-

Sincerely,

Marybeth Devlin

———————————————-

 

REFERENCES

 

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Dayton, Kelsey. (2016, March 18) Grasshoppers thrive on the warming Wyoming range. WyoFile. Retrieved from http://www.wyofile.com/column/grasshoppers-thrive-warming-wyoming-range/?utm_source=newsletter&utm_medium=email&utm_campaign=weeklynewsletter

Duncan, Patrick (Editor). 1992. Zebras, Asses, and Horses: An Action Plan for the Conservation of Wild Equids. International Union for the Conservation of Nature and Natural Resources. Retrieved from http://data.iucn.org/dbtw-wpd/edocs/1992-043.pdf

EquiMed staff. (2010, March 13) Equine Reproductive Maturity in Mares and Stallions. Puberty in Equines. Retrieved from http://equimed.com/health-centers/reproductive-care/articles/equine-reproductive-maturity-in-mares-and-stallions

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Ferguson, Mike. (2015, June 4) “Police called as group protests wild horse contraceptives.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/montana/police-called-as-group-protests-wild-horse-contraceptives/article_81462303-e128-5ee8-a7ef-2c8b098450f6.html

Goldfarb, Ben. (2015, April 23) Searching for the best dog to save livestock — and wildlife. High Country News. Retrieved from https://www.hcn.org/articles/searching-for-the-best-dog-to-save-livestock-and-wildlife

Gray, M.E. and Cameron, E.Z. (2010) Does contraceptive treatment in wildlife result in side effects? A review of quantitative and anecdotal evidence. Reproduction 139, 45-55. Online publication date: 1-Jan-2010. Retrieved from http://www.reproduction-online.org/content/139/1/45.full

Gregg, Kathleen, LeBlanc, Lisa, and Johnston, Jesica. (2014) Wild Horse Population Growth. Retrieved from http://protectmustangs.org/wp-content/uploads/2014/04/PM-Population-Growth-4.25.14-FINAL.pdf

Hanselka CW, Lyons R, and Teague R. (2002, October) Patch Grazing and Sustainable Rangeland Production. AgriLIfe Communications and Marketing, Texas A&M University System. Retrieved from http://www1.foragebeef.ca/$Foragebeef/frgebeef.nsf/all/frg30/$FILE/rangedistributionpatch.pdf

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Johnson, Clair. (2016, August 4) “Judge rules for wild horse advocacy group in BLM suit.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/judge-rules-for-wild-horse-advocacy-group-in-blm-suit/article_08c938df-2723-5d87-8d40-8ef4814a6be8.html

Kaur, Kiranjeet and Prabha, Vijay. (2014) “Immunocontraceptives: New Approaches to Fertility Control,” BioMed Research International, vol. 2014, Article ID 868196, 15 pages, 2014. doi:10.1155/2014/868196. Retrieved from http://downloads.hindawi.com/journals/bmri/2014/868196.pdf

Keller, Larry. (2011, May 17) To shoot, or not to shoot, at Rocky Mountain NP. High Country News. Retrieved from http://www.hcn.org/blogs/range/to-shoot-or-not-to-shoot-at-rocky-mountain-np

Kirkpatrick, J. F., I. K. M. Liu, J. W. Turner, Jr., R. Naugle, and R. Keiper. 1992a. Long-term effects of porcine zonae pellucidae immunocontraception on ovarian function of feral horses (Equus caballus). J. Reprod. Fert. 94:437-444. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/1317449

Kirkpatrick, Jay. 2007. “Response to PA [Pennsylvania] Game Commission.” Posted on PNC’s Wildlife Forever Home Page. Retrieved from http://www.pzpinfo.org/home.html

Kirkpatrick, Jay F. (2015, May 16). Op-ed: Wild-horse contraceptives are based on sound science. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2517266-155/op-ed-wild-horse-contraceptives-are-based-on?fullpage=1

Knight, Colleen M., Rubenstein, Daniel I. 2014. The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus). Princeton University Thesis, Ecology and Evolutionary Biology. Retrieved from http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p

McDonnell, Sue. (No date) “Rolling Along. Why Do Horses Roll?” Havemeyer Equine Behavior Lab, Penn Vet / New Bolton Center, School of Veterinary Medicine, University of Pennsylvania. Retrieved from http://research.vet.upenn.edu/HavemeyerEquineBehaviorLabHomePage/HavemeyerEquineBehaviorClinic/FrequentlyAskedBehaviorQuestions/WhydoHorsesRoll/tabid/2988/Default.aspx

McGrath, Matt. (2011, September 1) “Deer ‘pill’ curbs aggressive mating.” BBC News. Retrieved from http://www.bbc.com/news/science-environment-14744811

McNamee, Gregory. 2015. “Wolves in Arizona: The Return of El Lobo Southwestern Wolves Make Their Troubled Way Home.” DesertUSA. Retrieved from http://www.desertusa.com/desert-arizona/wolf-arizona.html

Nettles, Victor F. (1997) Potential consequences and problems with wildlife contraceptives. Reproduction, Fertility and Development 9(1) 137 – 144. Accessed full pdf text via purchase of a copy from Csiro Publishing. Retrieved from http://www.publish.csiro.au/paper/R96054.htm

Nuñez, Cassandra, Jim Adelman and Dan Rubenstein. (2015, July 3). Op-ed: Wild horse contraception not without unintended consequences. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2653298-155/op-ed-wild-horse-contraception-not-without

PCOS Foundation. (2015) What Causes PCOS? Retrieved from http://www.pcosfoundation.org/what-is-pcos

PNC, Inc. (Pity Not Cruelty). PZP FAQs. (2006) “Frequently Asked Questions on Immunocontraception.” (Special thanks to Jay Kirkpatrick and Rick Naugle for additions and corrections). Retrieved from http://www.pzpinfo.org/pzp_faqs.html

Prettyman, Brett. (2015, January 26) “Jackrabbits are a bigger problem for cattle than bison in Utah’s Henry Mountains, USU study says.” The Salt Lake Tribune. Retrieved from http://www.sltrib.com/news/2080640-155/usu-study-jackrabbits-are-a-bigger?fullpage=1

Raab. Lauren. (2015, May 31) “120,000 endangered saiga antelopes die mysteriously in Kazakhstan.” Los Angeles Times. Retrieved from http://www.latimes.com/science/sciencenow/la-sci-sn-saiga-antelope-die-off-20150531-story.html

Ranglack, Dustin H., Durham, Susan, du Toit, Johan T. (April 2015) Competition on the range: science vs. perception in a bison–cattle conflict in the western USA. Journal of Applied Ecology. Retrieved from http://onlinelibrary.wiley.com/doi/10.1111/1365-2664.12386/full

Ransom JI, Hobbs NT, Bruemmer J (2013) Contraception Can Lead to Trophic Asynchrony between Birth Pulse and Resources. PLoS ONE 8(1): e54972. doi:10.1371/journal.pone.0054972. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/23383018

Runyon, Luke. (2013, October 8) The long, slow decline of the U.S. sheep industry. Harvest Public Media. Retrieved from http://harvestpublicmedia.org/article/long-slow-decline-us-sheep-industry

Sacco AG, Subramanian MG, Yurewicz EC. (1981) Passage of zona antibodies via placenta and milk following active immunization of female mice with porcine zonae pellucidae. J Reprod Immunol. 1981 Dec;3(6):313-22. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/7328557

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

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

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

United States Department of Agriculture. 2016 Rangeland Grasshopper Hazard. Map. Retrieved from http://www.sidney.ars.usda.gov/grasshopper/Extras/map16.htm

United States Department of Agriculture. 2016 Rangeland Grasshopper Hazard with Mormon Cricket Presence. Map. Retrieved from http://www.sidney.ars.usda.gov/grasshopper/Extras/2016GHwMC.htm

USDA-APHIS. (2007, February). “GonaCon™—Birth Control for Deer: Questions and Answers.” Retrieved from https://www.aphis.usda.gov/wildlife_damage/nwrc/downloads/faq_gonacon_07.pdf

United States Department of the Interior. Bureau of Land Management. Actual Grazing Use Report. Form 4130-5. OMB NO.1004-0041. Expires October 31, 2017. Retrieved from http://www.blm.gov/style/medialib/blm/noc/business/eforms.Par.2064.File.dat/4130-005.pdf

United States Department of the Interior. Bureau of Land Management. Technical Reference TR 1734-03. Utilization Studies and Residual Measurements. Retrieved from http://www.ntc.blm.gov/krc/viewresource.php?courseID=286

United States Department of the Interior. Bureau of Land Management. Technical Reference TR 1734-7, Ecological Site Inventory. Retrieved from http://www.blm.gov/nstc/library/1734-7direct.html

U.S. Department of the Interior. Bureau of Land Management. Wild Horse and Burro Program Data. Retrieved from https://www.blm.gov/programs/wild-horse-and-burro

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United States Department of the Interior. (2015) Review of Ungulate Fertility Control in the National Park Service. Retrieved from https://www.nature.nps.gov/biology/wildlifehealth/Documents/Ungulate%20Fertility%20Report_09242015.pdf — and then —
https://www.nps.gov/orgs/1103/upload/Ungulate-Fertility-Report_09242015.pdf

United States Environmental Protection Agency. (2009) Pesticide Fact Sheet. Mammalian Gonadotropin Releasing Hormone (GnRH). Retrieved from http://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-116800_01-Sep-09.pdf

United States Environmental Protection Agency. Office of Chemical Safety and Pollution Prevention. Pesticide Fact Sheet. Porcine Zona Pellucida (PZP). New Chemical. Nonfood Use. January 2012. Retrieved from
http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

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

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

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

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

 

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



Who are the traitors in wild horse advocacy?

Who is exploiting wild horses now? 

CLUE: FOIA the contracts, the agreements and their emails with BLM

Do you realize who has betrayed America’s wild horses? Do you know who is who? Do you know who are the BLM supporters and partners now? Do you know who is pretending to work for “solutions” but is really working for the livestock industry? Do you know who is making back-room deals pushing pesticides for birth control, experiments and slaughter on underpopulated wild horses and burros?

Do you know who is really for the wild horses and burros now?

FACT SHEET: The Truth about PZP

PM PZP Dr liu

 

EXPANDED SUMMARY OF PZP’S ADVERSE EFFECTS, INCLUDING REFERENCES

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 ….” [20]

Some persons argue that, because PZP does not kill the mare, it is not really a “pesticide.” Actually, PZP does kill. As will be documented in this report, its use is associated with stillborn foals. In the long term, PZP will 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 is an anti-vaccine.

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

The registrant of PZP advised the Environmental Protection Agency (EPA) 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. [7 and 13]

PZP’s True Mode-of-Action

So how does PZP really work? PZP tricks the immune system into waging 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.” [5] [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, oophoritis (inflammation of the ovaries), destruction of oocytes in all growing follicles, and depletion of resting follicles. The manufacturer of PZP as well as Bureau of Land Management (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.

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

In a telling study published back in 1992, the 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.” [6] Thus, 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. [21] 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 23 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and endocrine-disruptor side-effects.

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).” [4] 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.

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: Unnatural 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. [12 and 22] 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 boasts about it, as if the anomaly were a good thing. However, Gray & Cameron questioned the supposed benefit of mares living much longer than their normal life expectancy. Indeed, such mares take up scarce slots within size-restricted populations. The ultra-elderly mares continue to consume resources for many years, but they no longer contribute to the gene-pool. It is detrimental to a population’s genetic viability to carry significant numbers of sterile herd-members way-beyond their normal life-span.

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

There was an even earlier, definitive meta-analysis on wildlife contraceptives. Nettles (1997) reviewed 75 studies available at that time on the subject. Among his findings regarding PZP-use across different species, including horses, were: Stillbirths; altered ovarian structure and cyclicity; interference with normal ovarian function; permanent ovarian damage; and some cases of irreversible sterility due to auto-immune oophoritis, which suggested that PZP can be selective against a certain genotype in a population. [10] Many of these findings were confirmed by Kaur & Prabha as well as by Gray & Cameron. Please keep in mind these key findings: Stillbirths, and auto-immune oophoritis.

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, 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. [18]

Autoimmune Oophoritis Induced by PZP

Research by the Rose-Cihakova-Caturegli Laboratory at Johns Hopkins Pathology found: “Automimmune oophoritis can be induced by immunization with testis and ovarian antigen murine human zona pellucida 3 peptide (pZP3) in adjuvant.” [16] Here again, is causation of autoimmune disease by a ZP-type product. This finding confirms other research cited herein.

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

A study by Varras et al. disclosed that, in humans, autoimmune oophoritis carries the risk of the patient developing other autoimmune diseases. [23] The correlation between autoimmune oophoritis and subsequent other autoimmune disorders weighs against injecting fillies and mares with PZP repeatedly and en masse.

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

Nettles’ meta-analysis on PZP disclosed other 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 (Ransom et al. 2013) of three herds currently being managed by PZP — Little Book Cliffs, McCullough Peaks, and Pryor Mountain — found that the the parturition season lasted 341 days. [15] Ransom et al.’s finding of a nearly year-round birthing season supports the earlier finding by Nettles. 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.

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 describes 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 six-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 eight years to recover fertility after just three consecutive PZP treatments. [13]

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.” [15]

Because BLM keeps over 70 percent of the herds at levels below minimum-viable population (MVP), most herds qualify as “small refugia.” Pryor Mountain WHR is a small, isolated refuge, and its wild horses carry genes with rare alleles.

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 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 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.

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. [9]

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. [1] And as we shall see later in this report, that first shot of PZP may not be their first shot of PZP.

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

Knight & Rubenstein 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.

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

It gets worse. Sacco et al. reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques. [17] These findings were disclosed in 1981. 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. [7 and 13] 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.

Recall again the Pryor Mountain fillies. If their dams were injected with PZP while pregnant or nursing, such fillies will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when those same fillies are injected at age 1½, 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.

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. [14]

Imagine if such a catastrophe were to befall the Pryor Mountain horses, whose herd-immunity is being eroded by PZP. Note that the Saiga deaths involved antelope-mothers and their calves. If Pryor Mountain’s few fertile mares and their foals perished all of a sudden, that would leave just stallions and sterile old mares. The herd would be composed of the living dead, reproductively speaking, its rare alleles extinguished. BLM is failing to proactively manage the Pryor Mountain herd with stochastic events taken into consideration. That is 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 remove “excess” wild horses from the range — 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 three years, the latest one in 2015.

Risks to Humans Who Administer PZP Injections

For 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. [20]

However, EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform pregnant women 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 warn 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 warn all women of the risk of ovarian dystrophy, oophoritis, ovarian cysts, 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 fail to emphasize the magnitude of the risk — the PZP-in-question is a horse-size dose.

But Is There a Mandate to Practice Scientific Integrity?

Yes. 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.” [19]

BLM has ignored and suppressed independent scientific findings about PZP’s adverse effects and unintended consequences. Instead, BLM continues to rely almost exclusively on the manufacturer’s claims — shown and known to be false — regarding PZP’s safety for use on horses and for handling by humans. BLM is thus non-compliant with the Policy and malfeasant in its responsibilities to protect staff, volunteers, and the wild horses under its jurisdiction. BLM is also misleading and disinforming Congress and the American public about the PZP pesticide.

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 independent researchers whose findings did not fully support his claims. Indeed, he recently submitted an Op-ed to The Salt Lake Tribune wherein he belittled the research of fellow scientists whose studies on PZP yielded results somewhat different from his own. [8] 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. [11] The manufacturer also disparaged members of the public — one of whom was a member of the Pennsylvania Game Commission — who 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.” [7] By these actions, the manufacturer violated the DOI’s Code of Scientific and Scholarly Conduct.

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

BLM staff and volunteers receive their training from PZP’s manufacturer in how to handle and administer the pesticide. BLM is 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.

First, the manufacturer has been quoted as saying that PZP is “so safe it is boring.” [3] 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 advocates are lulled into complacency, trusting that PZP is harmless to the Pryor Mountain horses and their rare genetic alleles. 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.” [2] Key words: “no side effects.” It is disturbing that a person who was, no doubt, motivated by a desire to help the horses has been disinformed regarding PZP’s safety-hazards to humans as well as to horses.

BLM Fails to Maintain Proper Supervision of the PZP Volunteers

The issue of safety is not the only concern. As BLM has admitted, volunteers darted the wrong mares on Pryor Mountain. These errors evidence that BLM has failed to maintain supervisory control over the volunteer-inoculators, allowing them to conduct the PZP-darting by themselves. The mistakes further evidence that the volunteers do not understand what is expected of them. Who can say whether other procedures were not complied with either. The fact that mares were darted who were ineligible for PZP per the then-current protocol, but who would be eligible under the proposed-but-not-yet-promulgated new “prescription,” suggests that the volunteers may have concluded — from BLM’s open contempt for the Constitution and disrespect for the NEPA process — that was okay for them to start darting otherwise-ineligible mares right away. Not surprisingly, BLM blames the volunteers for these mistakes, but probably has not informed them that they are being made to take the rap for management’s shortcomings.

Conclusions

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. BLM’s continuing to use PZP while ignoring and suppressing the evidence of its harmful effects constitutes malfeasance.

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This report was completed by Marybeth Devlin on December 24, 2015. Copyright Marybeth Devlin and Protect Mustangs 2015.

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References:
1. EquiMed staff. (2010, March 13) Equine Reproductive Maturity in Mares and Stallions. Puberty in Equines. Retrieved from http://equimed.com/health-centers/reproductive-care/articles/equine-reproductive-maturity-in-mares-and-stallions

2. EWCS. (2015, November 10). Re: “Contraceptive could reduce taxpayer costs for wild horses.” Retrieved from http://wyomingpublicmedia.org/post/contraceptive-could-reduce-taxpayer-costs-wild-horses#comment-2352628323

3. Ferguson, Mike. (2015, June 4) “Police called as group protests wild horse contraceptives.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/montana/police-called-as-group-protests-wild-horse-contraceptives/article_81462303-e128-5ee8-a7ef-2c8b098450f6.html

4. Gray, M.E. and Cameron, E.Z. (2010) Does contraceptive treatment in wildlife result in side effects? A review of quantitative and anecdotal evidence. Reproduction 139, 45-55. Online publication date: 1-Jan-2010. Retrieved at http://www.reproduction-online.org/content/139/1/45.full

5. Kaur, Kiranjeet and Prabha, Vijay. (2014) “Immunocontraceptives: New Approaches to Fertility Control,” BioMed Research International, vol. 2014, Article ID 868196, 15 pages, 2014. doi:10.1155/2014/868196. Retrieved from http://downloads.hindawi.com/journals/bmri/2014/868196.pdf

6. Kirkpatrick, J. F., I. K. M. Liu, J. W. Turner, Jr., R. Naugle, and R. Keiper. 1992a. Long-term effects of porcine zonae pellucidae immunocontraception on ovarian function of feral horses (Equus caballus). J. Reprod. Fert. 94:437-444. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/1317449

7. Kirkpatrick, Jay. 2007. “Response to PA [Pennsylvania] Game Commission.” Posted on PNC’s Wildlife Forever Home Page. Retrieved from http://www.pzpinfo.org/home.html

8. Kirkpatrick, Jay F. (2015, May 16). Op-ed: Wild-horse contraceptives are based on sound science. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2517266-155/op-ed-wild-horse-contraceptives-are-based-on?fullpage=1

9. Knight, Colleen M., Rubenstein, Daniel I. 2014. The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus). Princeton University Thesis, Ecology and Evolutionary Biology. Retrieved from http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p

10. Nettles, Victor F. (1997) Potential consequences and problems with wildlife contraceptives. Reproduction, Fertility and Development 9(1) 137 – 144. Retrieved from http://www.publish.csiro.au/paper/R96054.htm Accessed full pdf text via purchase of a copy from Csiro Publishing.

11. Nuñez, Cassandra, Jim Adelman and Dan Rubenstein. (2015, July 3). Op-ed: Wild horse contraception not without unintended consequences. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2653298-155/op-ed-wild-horse-contraception-not-without

12. PCOS Foundation. (2015) What Causes PCOS? Retrieved from http://www.pcosfoundation.org/what-is-pcos

13. PNC, Inc. (Pity Not Cruelty). PZP FAQs. (2006) “Frequently Asked Questions on Immunocontraception.” (Special thanks to Jay Kirkpatrick and Rick Naugle for additions and corrections). Retrieved from http://www.pzpinfo.org/pzp_faqs.html

14. Raab. Lauren. (2015, May 31) “120,000 endangered saiga antelopes die mysteriously in Kazakhstan.” Los Angeles Times. Retrieved from http://www.latimes.com/science/sciencenow/la-sci-sn-saiga-antelope-die-off-20150531-story.html

15. Ransom JI, Hobbs NT, Bruemmer J (2013) Contraception Can Lead to Trophic Asynchrony between Birth Pulse and Resources. PLoS ONE 8(1): e54972. doi:10.1371/journal.pone.0054972. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/23383018

16. Rose-Cihakova-Caturegli Laboratory. (n.d.) Autoimmune Oophoritis. Johns Hopkins Pathology. Retrieved from http://pathology.jhu.edu/department/RCCLab/Oophoritis.cfm

17. Sacco AG, Subramanian MG, Yurewicz EC. (1981) Passage of zona antibodies via placenta and milk following active immunization of female mice with porcine zonae pellucidae. J Reprod Immunol. 1981 Dec;3(6):313-22. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/7328557

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

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

20. United States Environmental Protection Agency. Office of Chemical Safety and Pollution Prevention. Pesticide Fact Sheet. Porcine Zona Pellucida (PZP). New Chemical. Nonfood Use. January 2012. Retrieved from
http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

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

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

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

Pm PZP Darts

 

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




Protect Mustangs comments against spaying wild mares in Wyoming


——– Original Message ——–
Subject: IMPORTANT White Mountain & Little Colorado EA Comments
From: <X@protectmustangs.org>
Date: Thu, January 14, 2016 4:02 pm
To: blm_wy_whitemtn_littleco_hma@blm.gov

BLM Rock Springs Field Office
WMLC Scoping Comment
280 Highway 191 North
Rock Springs, WY 82901

Email to: blm_wy_whitemtn_littleco_hma@blm.gov
Fax: (307) 352-0329

January 14, 2016

Dear Public Servants at the BLM:

We represent thousands of supporters who love America’s wild horses in Wyoming and request you halt your plans to spay wild mares for the following reasons and others:

1.)  We object to using tax dollars to experiment on, forcibly drug with PZP, SpayVac® or Gonacon™ and / or sterilize America’s wild horses on the White Mountain herd management area located in Wyoming (http://www.blm.gov/wy/st/en/field_offices/Rock_Springs/wildhorses/whitemtn.html) or elsewhere.

2.)  We do not want federally protected wild horses to be used for research experiments using radio collars, devices in tails and spaying America’s federally protected wild mares. Research and Sterilization is a form of harassing wild horses. This is heinous and cruel. The public is outraged and they are calling for nationwide protests to bring awareness to this wrongful act against American wild horses.

3.)  Wild horses found in the White Mountain and Little Colorado HMA’s are not “excess” according to the Wild and Free-Roaming Horses and Burros Act of 1971. For example, there is only 1 wild horse per 6,000 acres in White Mountain. The BLM fraudulently inflates population growth (see: http://protectmustangs.org/?p=8551) and never performs a real headcount.

4.)  We support natural selection and we are against fertility control especially before reintroducing the natural balance of predation because America’s wild horses deserve to live on public land set aside principally but not exclusively for their use according to the law. Allowing more than 50 to 1 units of livestock to wild horses is unfair and goes against the 1971 wild horse protection act. We request you follow the law and give America’s wild horses and burros back all the public land you have taken from them since 1971.

5.)  Fertility control, such as spaying and/or PZP, will destroy the beloved White Mountain herd’s genetic viability, wreck havoc on their behavior and social structure–so therefore we are against it.

6.)  PZP sterilizes after multiple use and we do not want these wild horses sterilized by way of PZP either

7.)  Spaying to sterilize a wild mare can cause complications, infections and death. Even petMD advises against it. Below is an except from their article:
Why You Don’t Spay When the Animal Eats Hay
by Dr. Anna O’Brien

“Spaying a mare is a more complicated medical procedure than gelding, involving entering the abdominal cavity. Although there is more than one way to spay a mare, each resulting in the removal of the ovaries, the procedure tends to be painful and there can be scary complications, such as bleeding from the ovarian artery, which can be difficult to control.

More recently, many veterinarians elect to spay mares using laproscopic methods, which means using small incisions and inserting small cameras on the ends of lasers to view the ovaries and remove them. . .

. . . Then comes the question of population control, since I feel this is the strongest argument to spay and neuter dogs and cats. Although there is the problem of unwanted horses in the United States, you simply don’t have the hoards of stray horses roaming the streets as you do cats and dogs. Rare is the kid who comes in saying, “Mommy, look what followed me home. Can we keep this horse?” ‘

(From: http://www.petmd.com/blogs/thedailyvet/aobriendvm/2014/august/why-you-dont-spay-when-animal-eats-hay-31930)

8.)  BLM has been inflating wild horse population estimates to justify removals and appears to be fleecing the American taxpayer. The Appropriate Management Level (AML) is a biased number favoring the livestock industry and does not represent the true carrying capacity for wild horses on public land. AML needs to be updated and management needs to be revamped to utilize the wild herds to reverse desertification. They are an asset.

9.)  Where is the accurate and detailed headcount to justify BLM’s claims of excess? Where are the videos and/or facial recognition photographs cataloguing each individual wild horse in the herd management areas to ensure no double counting occurs?

10.)  Tourists come to Wyoming from around the world to see the wild horses at White Mountain. They are easily accessible and inspiring. Experimenting on this herd or any other herd is wrongful, cruel and against the majority of the public’s wishes. Any claims you may eventually produce stating that you have not received thousands of hands off comments is a direct result of your poorly publicized proposal on a national and international level.

11.)  In 2011, we sent one of our founding board members to Wyoming to study the White Mountain wild horses because we are interested in this treasured and accessible herd. Here is a slide-show on YouTube of the White Mountain Herd before the 2011 roundup:

12.)  We want to be able to come to Wyoming to see, photograph, study and film the White Mountain and Little Colorado wild horse herds with foals exhibiting natural behaviors–without radio collars and other devices–and definitely not sterilized.

13.)  We are also against radio collars because they are dangerous for wild horses for various reasons including but not limited to hooves getting stuck in collars causing injury or death, EMF related sickness, stress inflicted on federally protected wild horses which lowers their immune system and makes them more susceptible to disease, etc. The public will hold BLM accountable for any injuries or deaths related to radio collars or any other assault on the bodies of America’s wild horses during experimentation that is being white-washed as “research” or “studies”.

14.)  I am making a documentary on wild horses and want to film the White Mountain and Little Colorado wild horses exhibiting authentic natural behavior. My documentary might end up being a series so I want to be able to come back to the White Mountain and Little Colorado herds to film them years later and document how the foals have grown up and joined their own family bands with foals of their own, etc. The public likes these sort of nature films.

PM Checkerboard ROundup Sept 20 2014

15.)  The proposed roundups for your proposed spay research / experiment would contribute to global warming with all the motorized vehicles used. The environmental cost is too great for this proposed research. The Bureau of Land Management must take actions to reduce global warming–not contribute to it.

16.)  America’s wild horses are a native species having been returned to their native lands–if they ever all died out in the ice age. Fossil findings are pushing back the die out date. Now the theory of wild horses going extinct is being questioned. These are exciting times.

17.)  Wild horses contribute to the ecosystem, heal the land and reverse desertification. They must not be sterilized. America’s wild horses are a resource who must be protected in genetically viable numbers to ensure survival–especially with environmental challenges ahead of them.

18.)  The public is outraged about the BLM’s proposal to research and experiment on the White Mountain herd using Little Colorado as a control group. It’s clear the American taxpayers don’t want their tax-dollars to be used for cruel roundups destroying family bands, engaging in experimentation, sterilization and birth control assaulting their right to freedom. More than 20,000 people have signed our petition against the roundups and more are signing every day. (https://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups)

We officially ask you to immediately stop your proposal to spay the White Mountain herd which you allege is research. Americans and citizens of the world do not want iconic wild horses of the West to be used as laboratory test animals.

Sincerely,
Anne Novak

.Anne Novak
Executive Director
Protect Mustangs

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

Twitter: https://twitter.com/TheAnneNovak
Facebook: https://www.facebook.com/ProtectMustangs
In the news: https://newsle.com/AnneNovak

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





BREAKING NEWS: Sudden protest against BLM censorship, wild horse roundups and using PZP (pesticide) to manage wild horses to extinction

PM Edita Cat

 

BLM refused to hear public comments at “public” meeting

MINDEN, NV (January 22, 2015)—Edita Birnkrant, Campaigns Director for Friends of Animals (FoA) flew out from New York City with FoA correspondent Nicole Rivard to give public comments at the Bureau of Land Management (BLM) public meeting about the Carson City District Draft Resource Management Plan which calls to zero out 6 treasured herds of wild horses. After being denied her rights at the public meeting, held at the Carson Valley Inn in Minden, Nevada this afternoon, Birnkrant took over the microphone at the BLM meeting and held up yellow crime scene tape while Rivard filmed the protest against censorship and managing wild horses to extinction. Birnkrant was threatened with arrest by Nevada Sheriffs while holding up her banner. The hotel manager made Rivard stop filming and told the advocates they were being thrown out of the hotel, even though they had booked rooms there that night.

 

Statement from Edita Birnkrant:

“While we were waiting to go into the meeting a man told a BLM staffer “I wanna open up a horse butcher shop”. Then a few other guys started making jokes about how tender horse meat is. The BLM guy just chuckled but didn’t tell them it was inappropriate.

I was outraged that the BLM dared to hold a “public ” meeting and forbid the public from speaking. I took over the microphone to call out the sham of a BLM meeting, that shut out the public, and I said that Friends of Animals was there tonight to oppose the BLM’s extinction plan for wild horses in Nevada. I said the BLM is managing wild horses to extinction through roundups and PZP and we are outraged and demand it stop. I held our banner that said “Stop the BLM’s Criminal Reign of Terror. Protect Wild Horses Under the Endangered Species Act” The sheriffs were surrounding me at that point threatening to arrest me unless I left. I still had the banner and was shouting “the BLM is charged with crimes against wild horses”.

Then the hotel manager at the Carson Valley Inn in Minden, Nevada—Phil Dohrn–started bullying us and got in Nicole’s face. He pushed against her—blocking the camera and told her she had to shut her video off and we were getting thrown out.

Three extremely hostile sheriffs and the Carson Valley Inn manager escorted us to our rooms and waited outside while we packed our bags. They pounded on the door to hurry us or they’d arrest us. They called additional sheriffs to the hotel during all this. We left the hotel shocked that the Carson Valley Inn treats paying guests who exercise their First Amendment rights in their meeting room like this.”

The federal plan for public land in the Reno/Carson area is of interest to all Americans from coast to coast. Citizens care about public land and want federally protected wild horses protected by the law that allows them to roam freely without harassment.

PZP is an EPA approved restricted-use pesticide (http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf) that sterilizes wild mares after multiple use. Americans are learning about the dangers of PZP and are outraged the BLM would allow this to be used on wild horses.

Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org

# # #

Friends of Animals’ public comments that advocates were not allowed to read and were given to Collen Sievers the BLM BLM Project Manager for Carson City District at the public hearing on the draft resource management plan for Carson City District

Edita Birnkrant, FoA’s campaigns director 917-940-2725

The opinion of the American public, as declared through Congress is clear: “wild free-roaming horses and burros are living symbols of the historic and pioneer spirit of the West; they contribute to the diversity of life forms within the Nation and enrich the lives of the American people.” BLM has an obligation to consider wild horses as an integral part of the natural system of public lands.

It appears from the Carson City’s Draft Resource Management Plan (RMP) and Environmental Impact Statement that the BLM failed to take into consideration critical information about wild horses and failed to consider any alternatives that promote a free and viable wild horse population.

Friends of Animal is here to urge BLM to reevaluate its Resource Management Plan.

We ask that BLM consider an alternative that: (1) maintains all wild horse herd management areas; (2) prohibits conflicting uses on herd management areas; and (3) prohibits efforts to eradicate wild horses, such as round-ups, fertility control and sterilization. BLM must take into consideration the small population of wild horses and the potential that they will be listed as a threatened or endangered species under the Federal Endangered Species Act. From a scientific perspective, wild horses on our public lands are at risk of extinction if BLM does not change its management plans.

BLM does not provide adequate area for wild horses. Under the current RMP, approximately 4.8 million acres of public lands covered by the plan are open for private ranchers to graze cattle and sheep while only 1.2 million acres are reserved for wild horses. In the preferred alternative the ratio or area available for cattle and sheep grazing is also more than 4 times that available for wild horses.

Moreover, under no alternative, are cattle and sheep prohibited from grazing on wild horse herd management areas. BLM must consider an alternative that provides contiguous habitat for wild horses to roam freely.

Second, all alternatives for the proposed Resource Management Plan allows BLM to continue managing horses at artificially low populations, or appropriate management levels. This results in expensive, and cruel round-ups that tear the wild horses from their homes and families and place them in tax funded holding facilities. This is one of the largest threat to wild horses on U.S. lands. Experts have warned that the “majority of wild equid populations managed by the BLM are kept at population sizes that are small enough for the loss of genetic variation to be a real concern.”

The Equid Specialist Group of IUCN Species Survival Commission recommends minimum populations of 2,500 individuals for the conservation of genetic diversity. Others have warned that populations managed with a target size of fewer than 500 horses are at some risk of losing more than 90 percent of selective neutral genetic variation over a period of 200 years.

There are no herds that have a large enough population to meet the recommendation of the IUCN Species Survival Commission – 2,500 animals—and only 1 out of 17 of the herd management areas in this planning area has an appropriate management level set to 500 or more. Limiting horses to an artificially low number is short-sighted and ineffective because it could prompt short-term population growth.

Finally, Friends of Animals submitted a petition to the US Fish and Wildlife Service asking it to recognize wild horses as threatened or endangered. The Endangered Species Act requires the government to make final determination on the petition within 12 months – which would be this June. The BLM should not undermine this legal process by allowing BLM to round-up and remove wild horses from Carson City herd management areas. Not only would such actions undermine the Endangered Species Act, but they would also put the viability of the horses here at risk. Instead the plan should recommend BLM halt all efforts to remove wild horses, and allow Fish and Wildlife Service to review the law and facts in regards to wild horses.
Nicole Rivard, correspondent, FoA 203-910-1217

As my colleague just pointed out, all but one of the 17 herd management areas in the Carson City District has an appropriate management level set to 500 or more. Everywhere else the loss of genetic viability is a real concern. So additional roundups, which destroy social structure that can lead to population spikes, as well as consideration of administering fertility control, should be removed from this Carson City District Plan immediately if not sooner.
While some wild horse advocates may claim fertility control drugs, such as PZP, is the lesser of two evils, we at FoA believe birth control is equally harmful and inhumane as roundups. In most cases—even the BLM admits this—wild horses would still have to be captured to be treated with the pesticide before being released.

The widespread use of PZP is really very contrary to the true core intent of the Wild Horse and Burro Act of 1971, which was to restore wild horses as naturally, integrated, harmonious components of the public land ecosystem who are not overly tampered with. Deciding which animal should give birth or not is a very invasive, unacceptable thing to do to these wild animals.

Studies have revealed adverse effects of PZP— that it sterilizes wild horses after multiple uses and results in risky foal birth out of season and significant behavioral changes that can affect the health of the herd.

BLM’s discussion regarding a population control program in the EIS is inaccurate and unsupported. They claim fertility control limits the stress of pregnancy on mares, and helps stallions as they will not be exerting extra energy fighting to control mares or raising foals.

What about the stress on mares of not being able to get pregnant as nature intended!

We urge the BLM to look beyond data provided by the Humane Society of the United States, which has a vested interest in PZP as it is the registrant of the pesticide, and Jay Kirkpatrick, the director of the Science and Conservation Center, which produces the active ingredient in PZP. For instance a 2009 Princeton University study of the horses on Shackleford Banks in North Carolina, who began getting PZP in 2000, showed that prolonged infertility has significant consequences on social behavior.

Researchers found that females who were receiving contraception were much more likely to change groups. Normally bands are really very stable, said researcher Cassandra Nunez, and mares will stay with males much if not all of their lives. That stability is really important for the health of the group members. Foal mortality increases when there are a bunch of different changes, and parasite load of animals in the group can go up because they are getting more stressed.

In a later study in 2010, Nunez found that recipients of PZP also extend the receptive breeding period into what is normally the non-breeding season, resulting in foal birth out of season.

Normally the winter is spent eating as much as they can, and everyone is more relaxed. Males tend to let females roam farther, which is good because food is patchier. So all of this is changing because of extended cycling.
Nunez also noted it’s taking a while for the contracepted mares, who were taken off PZP in 2009, to respond physiologically. So that flexibility that you think you have with PZP…it’s not really that flexible.”

It is imperative that BLM reduce the number of cattle and sheep allowed to graze on public lands, as well as consider holistic resource management plan, such as reserve design, which is described in detail in Craig Downer’s Book the Wild Horse Conspiracy. Both options would adequately protect these majestic animals so that they can persist for future generations.

Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org

# # #

BLM Nevada News
CARSON CITY DISTRICT OFFICE NO. CCDO 2015-11
FOR RELEASE: November 28, 2014
CONTACT: Lisa Ross, 775-885-6107, lross@blm.gov

Draft Resource Management Plan Environmental Impact Statement Available for
BLM Carson City District

Carson City, Nev. – The Bureau of Land Management (BLM) is asking the public to review and comment on a Draft Resource Management Plan (RMP) and Environmental Impact Statement (EIS) for the Carson City District. The draft plan will affect approximately 4.8 million acres of public land. The comment period opened with the publication of a notice of availability in the Federal Register on November 28, 2014. Comments will be accepted during a 120-day period which closes March 27, 2015.

Public meetings to review and comment on the draft EIS will be announced at least 15 days in advance in local newspapers and on the BLM website.

The plan will address: Areas of Critical Environmental Concern, lands and realty, utility corridors, wind energy, travel management, recreation, fish and wildlife, minerals, wild and scenic rivers, public health and safety, and visual resource management.

Public meetings on the Draft RMP/Draft EIS are currently scheduled for 5:00 to 7:00 p.m.; on January 13, at the John Ascuaga’s Nugget (1100 Nugget Ave.) in Sparks, Nev.; on January 15, at the Fallon Convention Center (100 Campus Way) in Fallon, Nev.; on January 20, at the Mineral County Library (First & A Street) in Hawthorne, Nev.; on January 22, at the Carson Valley Inn (1627 US Hwy 395 N) in Minden, Nev.; and on January 29, at the Yerington Elementary School (112 N. California St.) in Yerington, Nev. An additional public meeting will be held from 2:00 to 4:00 p.m., on January 24, at the Carson City Plaza Hotel and Event Center (801 South Carson Street) in Carson City, Nev. Additional public meetings are anticipated in coordination with local County Commissions and Boards of Supervisors.

Written comments related to the Carson City District Draft RMP/Draft EIS may be submitted by any of the following methods:
• Website: http://on.doi.gov/1uYBNGT• E-mail: BLM_NV_CCDO_RMP@blm.gov
• Fax: 775-885-6147
• Mail: BLM Carson City District, Attn: CCD RMP, 5665 Morgan Mill Rd., Carson City, NV 89701.

Copies of the Carson City District Draft RMP/Draft EIS are available in the Carson City District Office at the above address or on the following website: http://on.doi.gov/1uYBNGT

Visit The Facebook Forum on PZP for more https://www.facebook.com/groups/ForumPZPWildHorsesBurros

#horses #animals #AnimalCruelty #FreeSpeech #Nevada #Tourism #WildHorses #mustangs #Tesla #money #energy #mining #water #yelp #hotel #travel #Reno #Tahoe #Sheriff #Carson #PZP #EPA #roundup #America

Pinenuts wild horses featured in French TV documentary ~ STOP the ROUNDUP

 

La chasse au mustangs (2010)

 

“I’m grateful to have worked on this film together with the French director and cinematographer and thankful we were able to get such revealing footage. Thank you to Barbara Clarke at DreamCatcher Sanctuary and Laura Leigh who stood in for Craig Downer who was unreachable and out in the field the day we shot this. All the scenes in the wild were shot in the Pinenut Herd Management Area (HMA) near Carson City and close to Reno/Tahoe. These horrible roundups must be stopped. Contact your senators and representative and request they stop this tragedy paid for with tax dollars.” –Anne Novak, Executive Director of Protect Mustangs  (Video ©2010 TF1)

Now the BLM and the PZP Advocates want to roundup the Pine Nut Herd and give them the EPA restricted-use pesticide known as PZP-22 which sterilizes after multiple us. Protect Mustangs is against PZP and roundups. America’s wild horses deserve to be forever wild and free.

BLM Press Release Date: 01/20/15
Contacts: 775-885-6107
News Release No. 2015-15

BLM to Host Tour of Pine Nut Herd Management Area Gather

Carson City, Nev. – The Carson City District, Sierra Front Field Office is holding a public pre-gather tour on Friday, January 23, 2015. The public will meet at the Dayton Valley Dog Park (located at Old Como and Dayton Valley Road) in Dayton, Nevada, at 10:00 a.m. The tour is expected to last approximately three hours. Because of road conditions a four wheel-drive high clearance vehicle is required. Visitors must RSVP by calling the Gather Information Hotline at 775-861-6700, option 2 and leave a message, or call Lisa Ross, Public Affairs Specialist, at 775-885-6107, email lross@blm.gov.

“This pre-gather tour is being offered to provide an opportunity for the interested public to obtain information about the Pine Nut Gather, by interacting with BLM staff as they provide an overview of gather operations,” said Sierra Front Field Manager Leon Thomas.

The BLM will gather approximately 332 wild horses and remove approximately 200 excess wild horses within and outside the Pine Nut Herd Management Area (HMA). As many as 132 wild horses will be released back to the range following the gather. The gather area is located south of Dayton and east of Carson City and Gardnerville, Nevada within Lyon, Douglas, and Carson City Counties. The gather is scheduled to begin late January 2015.

A population inventory completed in August 2014 documented 332 wild horses. The Appropriate Management Level (AML) for the HMA is 119-179 wild horses. Based on the inventory, and monitoring data showing impacts from an over-population of the HMA, BLM has determined that removal of the excess wild horses is necessary to achieve a thriving natural ecological balance.
Protect Mustangs is against the BLM’s false comment here: Excessive grazing from wild horses has not only degraded the sage-grouse habitat, but has also reduced the availability of native forage grasses within the HMA, thereby decreasing the number of wild horses that can be supported by current range conditions. Wild horses are not the source of habitat degradation but off road vehicles are. It’s time for the BLM to tell the truth.
Of the approximately 132 wild horses released back to the range, an estimated 66 mares will receive a 22-month Porcine Zona Pellucida (PZP-22) immunocontraceptive vaccine treatment prior to release. This vaccine will extend the time between gathers, and reduce the number of excess wild horses that would need to be removed in the future. The sex ratio of the released animals will be dependent on the sex ratio of the gathered wild horses. [PZP is an EPA approved restricted-use pesticide as seen here: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf  For more information, facts and public discussion about PZP visit the PZP Forum on Facebook here: https://www.facebook.com/groups/ForumPZPWildHorsesBurros]
For more information contact Lisa Ross at 775-885-6107.

The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2013, the BLM generated $4.7 billion in receipts from public lands.
–BLM–
Carson City District 5665 Morgan Mill Road Carson City, NV 89703 http://www.blm.gov/nv/st/en/info/newsroom/2015/january/blm_to_host_tour_of.html

 

What is “Native PZP” ?

PM PZP Syringe FB

We are against using anything as a pesticide on native wild horses and burros. The EPA passed PZP as a restricted-use pesticide for wild horses and burros in 2012. This gave wild horses and burros the designation of PESTS and must be reversed.

We asked Jay Kirkpatrick, Ph.D to define “Native PZP” and this is what he said.

“Native PZP is the family of glycoproteins extracted from porcine zona pellucida and administered without any alterations, such as “PZP-22″, in which the PZP is encased in a biodegradable, non-toxic material so that it has a longer duration of action (and which doesn’t work!). Research is ongoing elsewhere to find out why it doesn’t work. SpayVac is a proprietary product made in Canada and the effects of this formulation cause both uterine edema and ovarian damage. Native PZP does neither – based on a 28 year data base.” ~ Jay Kirkpatrick, Ph.D

The Science and Conservation Center
2100 S. Shiloh Road
Billings, MT 59106

Join the open forum: Using PZP on federally protected wild horses and burros, is it safe?

PM PZP Syringe Yearling Meme

 

The open forum on PZP for federally protected equids is held on Facebook here and everyone is welcome: https://www.facebook.com/groups/ForumPZPWildHorsesBurros/

Statement:

“If the good people of Nevada choose to use PZP to manage their wild horses on state land it’s up to them because that is a state issue. Americans across the country are concerned PZP isn’t safe and don’t want their wild horses and burros on federal land to be given the restricted-use pesticide hailed as “birth control” but known to sterilize after multiple use. If PZP advocates can prove PZP is 100% safe for native wild horse and burro herds, won’t sterilize them, ruin genetic variability or cause behavioral abnormalities then it could be considered as a management tool. Until then other holistic management tools must be examined. It’s time for a freeze on roundups, drugging and removals for scientific reevaluation. We need to get it right for our icons of American freedom.” ~ Anne Novak, Executive Director of Protect Mustangs

PZP advocates put wild horses at risk of sterilization after roundup

Stop the Roundups!

Protect Mustangs calls for a freeze on roundups for scientific reevaluation

Tonopah, NV (October 31, 2014)–The Battle Mountain District, Tonopah Field Office is rounding up about 120 wild horses from within the Reveille Allotment and Herd Management Area (HMA) located approximately 50 miles east of Tonopah, NV to remove alleged excess wild horses on 600,000 acres of public land.

“The BLM is wiping out America’s wild horses and taxpayers are paying for the abuse,” states Anne Novak, executive director of Protect Mustangs. “We need to stop the roundups and protect our native wild horses.”

The roundup will stampede native wild horse families by helicopter over a fragile ecosystem and possible sage grouse habitat in the Great Basin Desert. Often wild horses are injured and die in roundups. The treacherous roundup is paid for with tax dollars, and began October 30, 2014. Most herds need to be rounded up before given PZP.

After the roundup, approximately 70 wild horses will be permanently removed, 60 wild horses will be sent to holding facilities in Ridgecrest, California and about 10 horses will be offered for adoption after the roundup in Tonopah, NV on November 8. The remaining 50 wild horses will be released back into the HMA for a post roundup population of 98 wild horses, putting the survivors at risk. The minimum number for genetic variability is 150 wild horses.

Often the BLM returns wild horses with conformation defects to the range, instead of placing them in adoptive homes or long-term holding where they will not breed. Apparently the agency doesn’t realize that by returning wild horses with defects they will ruin the breeding pool. The BLM claims mares selected to maintain herd characteristics will be released back to the HMA. The public must watchdog the agency to ensure wild horses with defects are pulled from the breeding pool and rehomed. Euthanizing them is not an option supported by the American public.

The informed public is outraged over an EPA approved restricted use pesticide called PZP, made from pigs ovaries, to be used on native wild horses. PZP advocates campaign rigorously to treat mares with the Porcine Zona Pellucidae (PZP-22) in order to temporarily sterilize mares. PZP advocates hail the use of PZP in spite of the fact that wild horses are underpopulated on millions of acres of public land.

Experimental research on ovary damage in mares given the immunocontraceptive PZP is used to hone the drug for eventual human use. This could be where the “follow the money” piece fits in. Wild horse advocates are furious America’s herds are being used as lab rats. Science has proven the drug sterilizes wild horses after multiple use. PZP advocates are pushing for BLM to manage wild horses “in the wild” using these risky drugs.

The devastation of wild horses in the Reveille Allotment appears to be subject to a 1987 District Court Order and two orders issued by the Interior Board of Land Appeals (IBLA) in 2001 and 2002, requiring BLM conduct an annual inventory of wild horses in the Reveille Allotment and initiate a roundup to remove alleged excess native horses from the Allotment when the inventory shows that population numbers exceed the out of date Appropriate Management Level (AML) of 138 horses.

Current AML does not represent healthy herd populations and lacks scientific merit. AML must be updated to ensure healthy herds remain on public land. The herd census must never fall below 150 wild horses to maintain genetic variability.

The current estimated population, based on previous inventory flights is 168 wild horses, according to BLM. This is the low end of the genetic viability scale. The orders need to be challenged based on scientific reevaluation of wild horses benefiting the ecosystem as a native species, livestock causing range damage and the minimum number of wild horses needed for genetic variability.

“We must ensure native wild horses can survive upcoming environmental changes,” states Anne Novak, executive director of Protect Mustangs. “The minimum population for a genetically variable herd is 150. Why are PZP advocates and the BLM allowing wild horse herds to fall below safe numbers?”

According to a press release from National Academy of Sciences (NAS) released June 5, 2013, “The U.S. Bureau of Land Management’s (BLM) current practice of removing free-ranging horses from public lands promotes a high population growth rate, and maintaining them in long-term holding facilities is both economically unsustainable and incongruent with public expectations,” says a new report by the National Research Council.

The NAS report states there is “no evidence” of overpopulation. Only tobacco science and spin backs up BLM’s population claim to justify roundups and fertility control/sterilizations. PZP advocates lobbied NAS to have fertility control recommended even though the herds are underpopulated.

Roundup activities within the Reveille HMA were analyzed in the 2010 Reveille HMA Wild Horse Gather Plan and Environmental Assessment (EA) and the 2014 Reveille Wild Horse Gather Determination of NEPA Adequacy (DNA). The EA, DNA, and Decision Record can be accessed on the Reveille Wild Horse Gather website: http://on.doi.gov/10qLBlh.

Members of the public are encouraged to witness the helicopter stampede and document America’s icons losing their freedom to spread awareness that cruel roundups must stop. Observation protocols and visitor information are available at http://on.doi.gov/1xAMeTp. The BLM will post updates, photos and other information about the roundup on the Reveille website and on the hotline at 775-861-6700 throughout the course of the roundup.

The BLM is wiping out wild horses for the extractive industry and New Energy Frontier in the West. The agency manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM focuses on their mandate of multiple-use and sustained yield. In Fiscal Year 2013, the BLM generated $4.7 billion in receipts from public lands.

BLM’s roundups disturb the thriving natural ecological balance by disturbing habitat dynamics. This crime against nature causes abnormally high birthrate and puts native wild horses at risk of inbreeding.

“We are calling for an immediate freeze on roundups and removals for scientific reevaluation,” states Novak. “Right now native wild horses are at risk of being ruined by bad policy.”

Protect Mustangs is a nonprofit organization dedicated to the conservation of native and wild horses. The group is against using PZP in the wild. Today most wild herds are threatened with low numbers and a lack of genetic variability. Using PZP in a sanctuary setting where acreage is limited is a different situation. Wild horses must not be managed in the wild as if they were a zoo exhibit.

# # #

Links of interest™:

Info on PZP sterilizing mares: The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus), Princeton http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p

Princeton study on the pros and cons of adoption and immunocontraception: http://www.equinewelfarealliance.org/uploads/IEC.Rubenstein.pdf Not sure about EWA’s position on PZP now they might have embraced it like some others have.

Jamie Jackson’s piece on PZP: http://protectmustangs.org/wp-content/uploads/2013/06/PM-Jamie-Jackson-Using_Science_to_Improve_the_BLM_Wild_Horse_and_Burro_Program.pdf

Management of Wild Horses with Porcinezona Pellucida Pellucide: History, Consequences and Future Strategies, Cassandra M.V. Nuñez, Princeton: http://bit.ly/1rJywKl

Restricted use pesticide info: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-de info: Jan-12.pdf

Injection-Site Reactions in Wild Horses (Equus caballus) Receiving an Immunocontraceptive Vaccine, By James E. Roelle and Jason I. Ransom, http://pubs.usgs.gov/sir/2009/5038/

Pilot project to treat wild horses in Fish Springs communityhttp://www.blm.gov/nv/st/en/info/newsroom/2014/april/blm_approves_pilot.html

and http://www.wildhorsepreservation.org/media/pzp-pilot-project-treat-wild-horses-fish-springs-community

BLM Nevada Advisory Council Endorses Fertility Control Plan (Oct. 20, 2014) http://www.returntofreedom.org/blm-nevada-advisory-council-endorses-fertility-control-plan-october20-2014/

BLM partners with The Cloud Foundation in the Pryorshttp://www.blm.gov/pgdata/etc/medialib/blm/mt/main_story.Par.31432.File.dat/TopStoryHorse.pdf

Why end natural selection in the Pryors? http://protectmustangs.org/?p=4941

Are wild horses at risk of being sterilized due to an advocacy campaign? http://protectmustangs.org/?p=6356

Ecologist Craig Downer speaks out against using PZP in the Pryorshttp://protectmustangs.org/?p=4178

Horse contraceptive study raises concerns  Horsetalk, NZ: http://www.horsetalk.co.nz/news/2010/10/220.shtml#ixzz3Hti8ioCv

Appeal to stop the wild horse wipe outhttp://protectmustangs.org/?p=6527

The Horse and Burro as Positively Contributing Returned Natives in North America by Craig Downer PhD candidate: http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12

Wild Horse Conspiracy by Craig Downer:  www.amazon.com/dp/1461068983

Conformation defectshttp://www.thehorse.com/articles/10115/conformation-in-horses

Genetic viabilityhttp://en.wikipedia.org/wiki/Genetic_viability

Genetic variabilityhttp://en.wikipedia.org/wiki/Genetic_variability

J. Kirkpatrick team get $100K for wild horse fertility control drug PZPhttp://tuesdayshorse.wordpress.com/2012/04/17/jay-kirkpatrick-team-get-100k-for-wild-horse-fertility-control-drug-pzp/

Making PZP at The Science and Conservation Centerhttp://www.sccpzp.org

Native wild horseshttp://protectmustangs.org/?page_id=562

Petition for shelter and shade for captive wild horses and burroshttp://www.change.org/p/bring-emergency-shelter-and-shade-to-captive-wild-horses-and-burros

Petition for 10 year moratorium on wild horse roundups for recovery and studieshttps://www.change.org/p/sally-jewell-urgent-grant-a-10-year-moratorium-on-wild-horse-roundups-for-recovery-and-studies

Petition to defund and stop the wild horse roundupshttp://www.change.org/p/defund-and-stop-the-wild-horse-burro-roundups

Join the Walking Billboard Campaign to STOP THE ROUNDUPS in Nevadahttps://www.booster.com/protect-mustangs-nevada

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Controversy over PZP

nt B:W

 

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Ken Salazar’s Wild Horse Plan Fuels Accusations That He’s In The Pocket Of Ranchers, Associated Press, 2010: http://www.huffingtonpost.com/2009/10/17/ken-salazars-wild-horse-p_n_324799.html

Wildlife ecologist Craig Downer of Nevada accused Salazar, a former rancher, of acting on behalf of those who view mustangs as taking scarce forage away from their cattle herds. Downer contends cattle are more destructive to the range because they concentrate in high numbers around water sources instead of grazing over a wider area as wild horses do.

“Both the Forest Service and the Bureau of Land Management have the right to remove livestock to ensure viable, healthy populations of wild horses. But they refuse to exercise that,” Downer said. “Their master is primarily these traditional ranching interests.”

Opposition grows to Salazar’s plan to move wild horses to Midwest preserves, Associated Press 2009http://www.oregonlive.com/news/index.ssf/2009/12/opposition_grows_to_salazars_p.html

Horse defenders have stepped up their efforts in recent weeks, suing to block a proposed roundup of 2,700 horses in northern Nevada and lining up the support of celebrities such as Sheryl Crow, Lily Tomlin, Bill Maher and Ed Harris.

Crow took her concerns directly to Salazar in a telephone call this past week.

One of the first things he said was something must be done because the horses are starving. We (advocates) don’t believe it,” Crow said in an interview with The Associated Press.”

7 Preserves Envisioned to Manage Wild Horses, New York Times, 2009http://www.nytimes.com/2009/10/08/us/08horses.html?_r=0

“HELENA, Mont. — Interior Secretary Ken Salazar said Wednesday that he was proposing to create seven new wild-horse preserves, including one in the East and one in the Midwest, to address the problem of a growing population crowding the Western range.

The program, which also applies to wild burros, would expand the use of contraceptives and would geld more herds on public lands in the West, Mr. Salazar said.”

. . . ”

Yet the proposal quickly drew criticism from wild-horse advocates. Ginger Kathrens of Colorado Springs, a maker of documentary films who has chronicled the lives of a wild-horse herd in Montana, said that blocking reproduction could alter the animals’ behavior.

“It takes the wild out of wild-horse herds,” she said. “They’re families in sophisticated societies. Creating gelding herds and preventing them from reproducing is managing them toward extinction.”

But ranchers, who see wild horses as competing with cattle for grasses and water, welcomed the proposal. Jeff Eisenberg, executive director for the Public Lands Council, a group that works on public lands issues for ranchers, said Mr. Salazar’s proposal was a big step toward a solution.”

Sheryl Crow Slams Salazar’s Wild Horse Plan, Huffington Post 2010http://www.huffingtonpost.com/2009/11/22/sheryl-crow-slams-salazar_n_366809.html

With one voice we are insisting that our government stop managing these beautiful and important animals to extinction,” Crow said in a statement released by the Cloud Foundation, a Colorado Springs, Colo.-based horse advocacy group”. . .

It’s time for all of us to speak up for our wild horses and burros so we do not lose these living legends and inspiring symbols of our freedom in America,” she said.

Madeleine Pickens praises Salazar wild horse plan, Horsetalk, 2009http://www.horsetalk.co.nz/news/2009/10/077.shtml#axzz3HKN0uSuY

“Interior Secretary Ken Salazar announced wide-ranging proposals this week in which horses taken from the Western rangelands would be relocated to new preservation areas further east, utilising better quality grassland.

His plan includes the aggressive use of reproduction controls to manage numbers. Salazar hoped the new herd areas would provide tourism opportunities for nearby communities” . . .

Pickens said she would support Secretary Salazar’s efforts, and would gladly compete to offer the wild horse sanctuary that she has planned to the bureau as one of the facilities proposed by Secretary Salazar.”

 

MANAGEMENT OF WILD HORSES WITH PORCINEZONA PELLUCIDA: HISTORY, CONSEQUENCES, AND FUTURE STRATEGIES, Cassandra M.V. Nuñez, Princeton: http://bit.ly/1rJywKl

“However, recent research in other populations has revealed behavioral and physiological side effects of long-term PZP use.”

 

Injection-Site Reactions in Wild Horses (Equus caballus) Receiving an Immunocontraceptive Vaccine, By James E. Roelle and Jason I. Ransom, http://pubs.usgs.gov/sir/2009/5038/

“Abnormal dart trauma included cases where the dart hit bone or the needle broke off. We found strong evidence (odds ratio = 5.023, P = 0.001) for a higher probability of occurrence of swelling when darts were delivered by blowgun. We found some evidence (odds ratio = 8.729, P = 0.07) that abnormal dart trauma led to a higher frequency of nodule formation. Nodules were the most common reactions observed and often persisted for a year or more, but in our observations they did not appear to change any animal’s range of movement or locomotor patterns and in most cases did not appear to differ in magnitude from naturally occurring injuries or scars. We were unable to perform histological examinations of these nodules, but they may be similar to granulomas reported by other investigators following administration of Freund’s adjuvant.”

Ecologist Craig Downer speaks out against using PZP in the Pryors http://protectmustangs.org/?p=4178

Why end natural selection in the Pryors? Should humans run a wild horse breeding program or does nature know best? http://protectmustangs.org/?p=4941

The Horse and Burro as Positively Contributing Returned Natives in North America, Craig Downer  http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12 2014