To:  Jacob Bunge, Wall Street Journal

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Sincerely,

Marybeth Devlin