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

 

Bradshaw, Corey J.A. (2012, November 21) Essential Predators. ConservationBytes.com. Retrieved from http://conservationbytes.com/2012/11/21/essential-predators/#more-8024

Branson, David H. (no date) Current Research. USDA Agricultural Research Service Sidney, MT. Retrieved from http://www.ars.usda.gov/pandp/people/people.htm?personid=601

Bunge, Jacob. (2016, August 28) “They Shoot Horses (With Birth-Control Darts), Don’t They?” Wall Street Journal. Retrieved from http://www.wsj.com/articles/they-shoot-horses-with-birth-control-darts-dont-they-1472415126

Clabby, Catherine. (2010, January-February) A Magic Number? American Scientist. Retrieved from http://www.americanscientist.org/issues/pub/a-magic-number/

Curtis PD, Richmond ME, Miller LA, Quimby FW. (2007) Pathophysiology of white-tailed deer vaccinated with porcine zona pellucida immunocontraceptive. Vaccine. 2007 Jun 6;25(23):4623-30. Epub 2007 Apr 11. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/17475371

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

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

Federal Register Volume 79, Number 163 (Friday, August 22, 2014). Notices. Pages 49802-49803. Renewal of Approved Information Collection. AGENCY: Bureau of Land Management, Interior. Concerning a number of data-collection documents, including Form 4130-5, Actual Grazing Use Report. OMB Control Number: 1004-0041. Retrieved from https://www.gpo.gov/fdsys/pkg/FR-2014-08-22/html/2014-20049.htm

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

Information Quality Act. Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106-554, H.R. 5658). 44 USC § 3504 (d-h) and § 3516 (a-b). Retrieved from http://www.archives.gov/about/laws/fed-information-policy.html#admin — and from — http://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title44-section3516&num=0&edition=prelim

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

United States Department of the Interior. Data Quality Guidelines. Originally retrieved from this link, which has either been moved or been taken down. http://www.blm.gov/style/medialib/blm/national/national_page.Par.7549.File.dat/guidelines.pdf

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

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

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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



Brutal experiments continue on pregnant wild horses!

Did you know that right now the Bureau of Land Management, under the Department of Interior is still funding cruel experiments on wild pregnant mares for population control?

Keep in mind that the National Academy of Sciences Report from 2013 stated there is “no evidence” of overpopulation. It’s the end of 2016 and there is still no evidence of alleged overpopulation and the thugs in control won’t do a headcount. They just want to keep abusing innocent wild horses and burros who should be living in freedom. Sickos!

The brutal tubal ligation research on pregnant wild mares in Oregon was stopped due to public outrage but that’s it. All the other tax-payer funded experiments on pregnant wild mares continue. They are cruelly experimenting on them now! Did you realize that?

The Department of Interior is giving away grants totaling up to 11 million dollars for population control experiments–on pregnant wild mares. Are these experiments causing pain and suffering and do they violate the rights of wild horses and burros to live free? Yes. This a wicked violation against their freedom.

So while everyone was distracted by real threats of killing and slaughtering wild horses, the brutal Nazi-like experiments–mostly with injections–continue . . .

America’s last wild horses should never be used as “lab animals”. Never. How is this even legal to experiment on federally protected wild horses?

Wild horses have been cruelly subjected to experimentation for decades. This cruelty has been going on for so long that the Bureau of Land Management and their supporters think this is “normal”. Experimentation on federally protected wild horses must be against the law but there is so much corruption within wild horse and animal advocacy that no one is stopping this! Those organizations who support using Pesticide PZP as birth control will not fight against experimenting on wild horses because they are still involved with PZP experiments or receive funding from those that are.

2017 is the time to fight back the evil cruelty inflicted upon America’s innocent and voiceless wild horses and burros! They should be protected from experimentation, protected from being sold to slaughter, protected from being killed and protected to live freely in the wild.

We’d like to protect wild horses from this abuse. Will you join us?

 

For the Wild Ones,

Anne Novak

Volunteer Executive Director

www.ProtectMustangs.org

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




BLM Final Rule Resource Management Planning

PM Diamond Helicopter Roundup

[Federal Register Volume 81, Number 238 (Monday, December 12, 2016)]
[Rules and Regulations]
[Pages 89580-89671]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-28724]
[[Page 89579]]
Vol. 81
Monday,
No. 238
December 12, 2016
Part II
Department of the Interior
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Bureau of Land Management
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43 CFR Part 1600
Resource Management Planning; Final Rule
 
Federal Register / Vol. 81 , No. 238 / Monday, December 12, 2016 / 
Rules and Regulations
 
[[Page 89580]]
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DEPARTMENT OF THE INTERIOR
 
Bureau of Land Management
 
43 CFR Part 1600
 
[Docket ID: BLM-2016-0002; LLWO210000.17X.L16100000.PN0000]
RIN 1004-AE39

Resource Management Planning
 
AGENCY: Bureau of Land Management, Interior.
 
ACTION: Final Rule
 
-----------------------------------------------------------------------
 
SUMMARY: The Bureau of Land Management (BLM) is amending its 
regulations that establish the procedures used to prepare, revise, or 
amend land use plans pursuant to the Federal Land Policy and Management 
Act (FLPMA). The final rule affirms the important role of other Federal 
agencies, State and local governments, Indian tribes, and the public 
during the planning process and enhances opportunities for public 
involvement and transparency during the preparation of resource 
management plans. The final rule will enable the BLM to more readily 
address resource issues at a variety of scales, such as wildfire, 
wildlife habitat, appropriate development, or the demand for renewable 
and non-renewable energy sources, and to respond more effectively to 
change. The final rule emphasizes the role of using high quality 
information, including the best available scientific information, in 
the planning process; and the importance of evaluating the resource, 
environmental, ecological, social, and economic conditions at the onset 
of planning. Finally, the final rule makes revisions to clarify 
existing text and to improve the readability of the planning 
regulations.
 
DATES:  This final rule is effective on January 11, 2017.
 
FOR FURTHER INFORMATION CONTACT: Leah Baker, Division Chief for 
Decision Support, Planning and NEPA, at 202-912-7282, for information 
relating to the BLM's national planning program or the substance of 
this proposed rule. For information on procedural matters or the 
rulemaking process, you may contact Charles Yudson, Management Analyst 
for the Office of Regulatory Affairs, at 202-912-7437. Persons who use 
a telecommunications device for the deaf (TDD) may call the Federal 
Relay Service at 1-800-877-8339, to contact these individuals. You will 
receive a reply during normal business hours.

 

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




Mustang holding facility open for rare public tour in Fallon October 28th

pm-blm-fallon-screen-shot-2016-10-20-at-11-06-12-am

Failed adoptions result in America’s wild horses and burros becoming at-risk of ending up at slaughter

RENO, Nev. —The Bureau of Land Management (BoLM) will host two free public tours of the Indian Lakes Off-Range Wild Horse and Burro Corral in Fallon, Nevada, on Friday, October 28. The private corral is one of three in Nevada that fattens up wild horses and burros removed from the range so they are attractive to kill buyers in the end. Tour attendees will have the opportunity to view native wild horses recently rounded up from public lands in central and eastern Nevada when the federal agency could have brought them water on the range to save taxpayer dollars. Instead they rounded them up, will offer them for adoption 3 times for $125 in order to “strike them out”. Then to dispose of them, the federal agency sells them off for $25 to horse traders who eventually flip them to kill buyers for slaughter.

“The Bureau claims they don’t sell wild horses to slaughter but they don’t seem do any post sales checks to make sure the mustangs aren’t sent to Mexico or Canada to be butchered for human consumption abroad,” explains Anne Novak, executive director or Protect Mustangs. “What about all the wild horses that aren’t accurately accounted for that aren’t sold yet? What happened to them?”

The rare public tours are scheduled to begin at 10 a.m. and 1 p.m. and each will last about two hours. Each tour will accommodate up to 20 people. The public can sign up to attend and get driving directions to the facility by calling the BoLM at (775) 475-2222.

About a 90-minute drive east of Reno, the Indian Lakes Off-Range Corral is located at 5676 Indian Lakes Road, Fallon, and is privately owned and operated with a big money contract. Tour attendees will have limited access to the captives. They will be taken around the facility as a group on a wagon to learn about the facility, the wild horses and burros available for adoption, and BLM’s Wild Horse and Burro Program. These tours should be happening every weekend at least to encourage adoptions out of the Fallon facility.

The Indian Lakes corral can provide care for up to 3,200 wild horses or burros. The facility encompasses 320 acres containing 43 large holding pens, each pen measuring 70,000 square feet that will safely hold about 100 wild horses or burros. The wild horses receive a lot of feed to fatten them up, along with a constant supply of fresh water through automatic watering troughs. Free choice mineral block supplements are also provided to the wild horses and burros in each pen. A veterinarian routinely inspects the wild horses and burros and the BoLM claims they provide necessary veterinary care as needed.

The Bureau of Land Management is failing at adoptions because of lack of marketing and poor customer service.

“If the U.S. Congress only realized how hard it is to adopt wild horses and give them homes they might make the bureau change their ways,” says Novak.

For example the wild horses at the Indian Lakes facility with limited access to the public are almost impossible to adopt despite looking like they are available for adoption or sale at off-site adoption events and through BLM’s Internet Adoption program. Too many 3-Strikers are coming out of the Fallon facility so it’s proof their system is failing.

pm-investigate-count-fallon-list-meme-sept-2016-001

Sign and share the petition to investigate the head count of wild horses and burros: https://www.change.org/p/u-s-senate-investigate-the-wild-horse-burro-count-in-captivity-and-freedom

Keep in mind that the BoLM’s main focus is making money off public land the wild horses and burros are supposed to have for principle but not exclusive use. The BoLM 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 BoLM also administers 700 million acres of sub-surface mineral estate throughout the nation. In Fiscal Year 2015, the BoLM generated $4.1 billion in receipts from activities occurring on public lands. They fail at environmental stewardship and are irresponsible towards all the wild horses and burros they removed to make billions in profit. In 20 years the BoLM will make more than 200 billion dollars as long as their planned #fracking boom moves forward.

Contact Protect Mustangs (Contact@ProtectMustangs.org) if you want to adopt a pair of wild horses and save their lives. We help adopters navigate the Bureau of Land Management’s red tape to get to success.

Protect Mustangs is a 501c3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org




2 special needs wild horses escape death at roundup

Day 2 of Devil's Garden Roundup courtesy Devils Garden Wild Horses FB Page

Day 2 of Devil’s Garden Roundup courtesy Devils Garden Wild Horses FB Page

Protect Mustangs will help find homes for 2 wild horses who would have been killed at Modoc Forest roundup

ALTURAS, Ca.(September 27, 2016)–Last week Anne Novak, founder and director of Protect Mustangs reached out to U.S. Forest Service staff with an offer to help find homes for any wild horses rounded up with pre-existing conditions–who would be killed–not offered a chance at adoption. Tonight Novak received the first call from Forest Service staff.

“It’s always bothered me that after wild horses heal from injuries and survive in the wild, they are chased by helicopters, rounded up and killed upon capture because they don’t seem like they would get adopted,” says Novak. “Some people don’t want a riding horse. Some people want to save a life.”

So far, two wild horses from the roundup have pre-existing conditions. One is believed to be pigeon toed due to a broken foot that healed in the wild. The other mustang’s condition is unknown at this time.

“They need to go to loving homes to become pets–not riding partners–or go to sanctuaries,” explains Novak. “They have survived in the wild and that’s a harsh life. They deserve our compassion after the roundup and they deserve to live.”

After the mustang protectors make an assessment of the wild horses with pre-existing conditions, a sanctuary might be a more suitable forever home. It’s too early to tell.

These two California wild horses from Modoc County will join their herd-mates at the Bureau of Land Management’s Litchfield holding Corrals near Susanville. There they will be prepared for adoption with the others.

Adoption applications are here: Protect-Mustangs-BLM-facility-adoption-app

    • Cost to adopt is $125.
    • Adoptions by appointment only, call (530) 254-6575.
    • Open Monday through Friday, 7 a.m. to 4 p.m. Summer hours are 6 a.m. to 3 p.m. The facilities are closed on federal holidays. Please call for current information.
    • Information is available 24 hours a day by calling 1-800-545-4256.
    • Completed adoption applications can be sent to Videll Retterath by e-mail vrettera@blm.gov or fax (530)252-6762.
    • The Corrals are located 21 miles east of Susanville , CA on US Highway 395.
    • Adopters receive title to wild horses after one year

Protect Mustangs will post photos as soon as we get them. Tax-deductible Gas donations are always needed to help us help the wild ones.

pm-ufs-devils-garden

Photo by the US Forest Service

Members of the public with questions about the BLM’s requirements for adoption, questions about the wild horses with pre-existing conditions, who want to help network homes for wild horses who would be killed for pre-existing conditions, need trainer referrals, or want some tips on how to build an inexpensive shelter are invited to email the mustang protectors at Contact@ProtectMustangs.org

“I pray we can change the trend of killing special needs wild horses at roundups,” says Novak. ‘Someone’s going to fall in love with them. After all they’re still American mustangs.”

Protect Mustangs is a 501c3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org




The Modoc National Forest starts wild horse roundup from private and tribal lands today

pm-devils-garden-meme

The Modoc National Forest started a wild horse roundup from private and tribal lands Sept. 26

According to the Forest Service, public viewing opportunities at the trap site will be available on a first come, first served basis for up to 14 people each day. Members of the public wishing to view the helicopters  chasing wild horses into traps must arrive an hour and a half prior to gather activities at Forest Headquarters, 225 W. 8th St., in Alturas, follow forest personnel to the trap site and remain at the viewing location until operations are completed for the day.

Viewers should bring plenty of water, lunch, stout footwear, hat and their own chair. There will be an approximate one-mile hike over rocky terrain from the parking area to each of the trap sites. The weather is expected to be hot and dry, and there is little shade available.

Members of the public will be asked to remain in a blind in order to avoid disrupting gather activities. Safety of visitors, gather personnel and the horses is top priority. The use of drones in the area will not be allowed due to safety concerns.

Public viewing will also be available at the temporary holding facility at Willow Creek Ranch, during the hours of 3–5 p.m. on days roundup activities occur. Operations may not occur every day, but as contractors determine.

Anyone interested in viewing roundup operations at taxpayer expense should contact Public Affairs Officer Ken Sandusky at (530) 233-5811.

Protect Mustangs is a 501c3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org




Indigenous people called area the “Smiles of the Gods” but settlers named it Devil’s Garden

Ponderosa Pines in spring on Devil's Garden.

Where the wild ones live

The Devil’s Garden lies in the heart of the Modoc Plateau, according to the Forest Service. The Modoc Plateau is a mile-high expansive prehistoric lava flow, with areas of sparse vegetation, rough broken lava rock, juniper trees, and sagebrush flats in a semi-arid region covering about a half-million acres. The plateau is thought to have been formed approximately 25 million years ago. The name Devil’s Garden was given to the area when the first European settlers traveled to this region in the 1800’s. In contrast, the Native people called the area, “The Smiles of Gods”.

While it’s dry most of the year, in the early spring the Garden often looks like the “land of lakes,” as all of the water holes fill. In the spring, after the snow melt, the rocky Devil’s Garden produces a veritable carpet of wild pink pansies, pink and red owl clover, yellow primroses and pink shooting stars. Purple lupine, yellow mules ear and the shiny green leaves of manzanita complete the rainbow of color that lasts well into the summer.  The farther north you travel, the Garden’s dryness gives way to conifer forests and is home to some of the biggest mule deer in the area.

Ducks on the water of Beeler Reservoir with treelined shore in the background aThe Devil’s Garden lies directly under the Pacific Flyway. During their migration from Alaska and Canada to Mexico, hundreds of thousands of waterfowl use the wetlands as rest stops. Several of the reservoirs on the district are stocked by the California Dept of Fish and Game with bass or trout. The Garden is also shared by Rocky Mountain elk, pronghorn antelope, sage grouse, turkeys, coyotes and wild horses.

A herd of mares and foals graze the dry, late summer grass.

The Devil’s Garden Plateau Wild Horse Territory is well known across the US for the wild horses it produces. Historically, horses have run on the plateau for more than 140 years. Many of the early horses escaped from settlers or were released when their usefulness as domestic animals ended. In later years, like many areas throughout the west, local area ranchers released their domestic horses out to graze, and then gathered them as they were needed. Not all were ever captured. Learn more about Devil’s Garden wild horses at http://bit.ly/2aGcCsu.

With the passage of the 1971 Wild Horse and Burro Act (PL 92-195), private horse roundups ended. In 1974, as an initial step toward management, the Forest Service inventoried the Devil’s Garden Wild Horse population for the first time. The Devil’s Garden Plateau Wild Horse Territory Management Plan, completed in 2013, set an Appropriate Management Level (AML) of a maximum of 402 total horses.

Four of the five developed campgrounds on the Devil’s Garden charge no fees for camping, day use or boat launching. Even so, these facilities rarely fill to capacity and are considered the perfect getaway by the few who venture there.

Information provided by the Forest Service.

Protect Mustangs is a 501c3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org




In January we offered to help adopt hundreds of wild horses and the Department of Interior blew us off

PM Oct 2014 PVC Mirror
The Honorable Sally Jewell Secretary of the Interior
U.S. Department of the Interior 1849 C Street, NW Washington, DC 20240
Friday January 29, 2016
 
RE: Official request to stop using federally protected American wild horses in cruel experiments, offer all the wild horses at the closed door Indian Lakes holding facility for adoption and provide transparency with public access, etc.
Dear Secretary Jewell,
Pregnant mares were moved Friday January 22, 2016 from Palomino Valley Center (PVC) outside of Reno to the closed door, privately owned and operated, facility called Indian Lakes aka Broken Arrow, located at 5676 Indian Lakes Road, Fallon, Nevada.
Does the Bureau of Land Management (BLM) intend on using the pregnant mares from Beatys Butte, Oregon and other herds in the horrible Nazi-type sterilization experiments in Oregon, Kentucky or elsewhere?
The Beaty’s Butte pregnant mares and members of their herd seem to have been rounded up because Country Natural Beef, a supplier of Whole Foods Market, was pushing for the roundup. Do they want the federally protected wild horses gone so they can use the public grazing land for more grass fed beef?
 
Protect Mustangs officially requests the mares from Beatys Butte, Oregon, as well as all the other wild horses (male and female) at the Indian Lakes facility, be immediately put up for adoption–not experimented on. Wild horses over 10 years old must be offered to the public as well. They are not yours to engage in animal testing. This cruelty must stop now.
 
We also request you immediately create transparency for the public, show good faith and therefore request you:
  1. Halt transporting American wild horses out of the closed door Fallon facility called Indian Lakes (aka Broken Arrow). The public wants to save all these wild horses–including the pregnant mares–through adoption or purchase.
  2. Provide all identification numbers and descriptions all the wild horses as well as a headcount of unbranded, untagged wild horses and foals at Indian Lakes as of today January 29, 2016.
  3. Provide a separate list of all identification numbers and descriptions of all the wild horses as well as a headcount of unbranded wild horses and foals at Indian Lakes from January 20 to today.
  4. Provide a list of identification numbers of all the wild horses who have transported out of Indian Lakes since January 1, 2016 and show exactly where they have gone and where they are now.
  5. Grant immediate visitation to members of Protect Mustangs, elected officials and their staff, as well as other members of the public to the closed door facility known as Indian Lakes (aka Broken Arrow) to witness, document, photograph and video all the wild horses for as many days as needed at the facility to help them get adopted in order to keep them safe from cruel experiments, dubious sales or worse.
How many wild horses have been sold or given away to be used in research projects, “studies” or experimentation since 2009? How many wild horses have been used in research projects, “studies” or experimentation since 2009 and then later offered for adoption, moved to long-term holding or sold?
Sterilization and “fertility control” experiments are cruel and unjustified
 
The BLM’s overpopulation claims are fraudulent and any action such as experimentation for population control, fertility control, or other actions taken that are based on fraudulent information is wrongful.
There are no “excess” wild horses on public land. Roundups have been based on fraudulent data. Read more about that here: http://protectmustangs.org/?p=8551
There exists no accurate head counts of America’s wild horse populations and many herd management areas have no wild horses left on them.
The BLM’s horrible customer service, lack of problem solving and poor marketing are the reasons wild horse adoption has dropped. The public wants to adopt wild horses but the BLM is making it impossible for adopters to get the wild horses they want. It’s as if the BLM wants their adoption program to fail.
Americans do not want their tax dollars funding cruel experiments reminiscent of the notorious Nazi–Dr. Joseph Mengele. The rights of American wild horses are being violated. This is animal cruelty at its worse. All wild horses–especially pregnant mares–must never be used in sterilization or other experiments.
To sum things up:
  1. There is no overpopulation of wild horses. They are underpopulated on the vast acreage of public land in the West. Even the National Academy of Sciences said in 2013 that there is “no evidence of overpopulation”.
  2. BLM’s harvesting model based management via roundups is disrupting herd structure and increasing the birthrate.
  3. BLM’s allegations of overpopulation are fraudulent based on false data. Besides no head counts, they don’t even account for the correct mortality rates in the wild for example.
  4. Predators should not be killed off and if there are none left then they need to be reintroduced for the thriving natural ecological balance for the herd management area.
  5. Wild horses are a return-native species who help reduce catastrophic wildfires, create biodiversity, etc. We need the herds to reverse desertification. Read more about native wild horses here: http://protectmustangs.org/?page_id=562
  6. The BLM is creating a false overpopulation crisis to cash in on wild horses as laboratory animals for fertility control experiments while reducing the herds to nonviable levels.
  7. GonaCon™, PZP, SpayVac® are all pesticides that classify wild horses erroneously as pests–ultimately sterilize them and are not needed because wild horses are underpopulated. There are no “excess” wild horses in America.
  8. Experimenting on wild horses to sterilize them is animal cruelty funded by tax dollars and must stop now.
  9. The BLM is trying to manage America’s wild horses to extinction.
Federally protected wild horses and burros are to be protected from harassment according to the law. You can read about the Wild and Free Roaming Horses and Burros Act of 1971 here: https://en.wikipedia.org/wiki/Wild_and_Free-Roaming_Horses_and_Burros_Act_of_1971
The public is outraged the BLM, the federal agency put in charge of managing and protecting wild horses and burros, would engage in animal cruelty and try to use America’s icons of freedom in population control experiments.
Any and all experimentation, “research” or harassment of a federally protected wild horse or burro–based on the overpopulation myth, decreased adoptions or any other excuse must stop now.
Sincerely,
Anne Novak
 
Links of interest:
 
Anne Novak
Executive Director
Tel./Text: 415.531.8454
Read about native wild horses: http://protectmustangs.org/?page_id=562  
Then on June 22, 2016 the subcommittee hearing on wild horses and burros was held in the House of Representatives and this is what the elected officials said:
On September 9, 2016, the Bureau of Land Management’s Wild Horse & Burro Advisory Board voted to kill the alleged 45,000 wild horses in taxpayer funded holding facilities and pastures. Do they want to cover-up the fraud that has been going on for years by killing the evidence?

Don’t Let Them Kill 45,000 Wild Horses and Burros! Sign and Share the Petition: http://www.thepetitionsite.com/907/592/301/demand-nokill-45000-wild-horses-burros-in-holding

 

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.




Demand an Urgent Congressional Investigation and Head Count of all Wild Horses and Burros in Captivity and in Freedom

 

This Change.org petition is going to the US Senate, the US House of Representative and the President of the United States

On September 9, 2016, the Bureau of Land Management’s Wild Horse & Burro Advisory Board voted to kill the alleged 45,000 wild horses in tax-payer funded holding facilities and pastures. Do they want to cover-up the fraud that has been going on for years by killing the evidence?

Taxpayers and the general public want to know:

  • How much fraud has been committed regarding the wild horse and burro count on public land and in corrals?
  • How many budgets were approved using fraudulent information?
  • How many wild horses have gone to slaughter?
  • How many wild horses and burros have been shot and killed?
  • How many unbranded foals did the kill-buyers get to sell overseas?

We request an immediate Congressional investigation and independent head count, with photo IDs, of the alleged 45,000 wild horses and burros rounded up and held in captivity–at taxpayer expense.

In addition, we call for an immediate moratorium on roundups, transport and removals for a precise independent count, with photo ID, of all the federally protected wild horses and burros in the wild. This must occur before any more wild horses or burros are rounded up and/or transported, trapped, chipped, collared, removed, sterilized, given pesticide PZP, GonaCon®, SpayVac®, IUDs, etc., researched or experimented on in any manner to prevent further fraud against taxpayers as well as prevent abuse against wild horses and burros who should be protected from harassment and abuse by law.
We request a complete inventory of the wild horses and burros at the following locations:

  1. Every Herd Management Area
  2. Every Herd Area
  3. Every “Complex”
  4. Every temporary holding facility
  5. Every short-term holding facility
  6. Every long-term holding facility, pasture, eco-sanctuary, etc.
  7. Mustang Heritage Foundation facilities and all equids in their program
  8. TIP Trainers’ facilities
  9. All private contractors’ facilities
  10. Research facilities
  11. Any other locations where wild horses and burros are held in captivity and/or live on public land.

The public, voters of America and taxpayers are outraged and demand immediate action. Thank you.

Sign and share the Change.org petition

Link to the petition: https://www.change.org/p/u-s-senate-investigate-the-wild-horse-burro-count-in-captivity-and-freedom

Help fight the killing!

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.




Comments against the Wyoming checkerboard roundup and removal

Via email:  blm_wy_checkerboard_hmas@blm.gov

    September 9, 2016

BLM Rock Springs Field Office

280 Highway 191 North

Rock Springs, WY 82901

Attn: Wild Horse and Burro Specialist

Subject: Checkerboard EA Comments

Project: Roundup-and-Removal — Announced

Document: Environmental Assessment ( EA )

NEPA ID: DOI-BLM-WY-D040-2016-0135-EA

This letter responds to your request for substantive comments and informed analysis that BoLM Rock Springs Field Office (RSFO) should consider regarding the subject EA.  I submit my comments as an interested party in behalf of the wild horses of the Adobe Town (AT), Great Divide Basin (GDB), and Salt Wells Creek (SWC) Herd Management Areas (HMAs) who are deemed to have roamed into the “checkerboard lands” — those where Federal and private property sections alternate in a checkerboard-like pattern — in numbers that exceed the arbitrary levels established by the Consent Decree.  Please note that in all instances where text has been emphasized, either through bold and/or italics, the emphasis was added by me.

For ease of reference, here are the links to the Dear Reader letter and to the Webpage where the EA is posted:

https://eplanning.blm.gov/epl-front-office/projects/nepa/59563/78510/89493/Dear_Reader_Letter_Public_Review_Checckerboard_EA_8-11-16.pdf

http://bit.ly/2bj4PzJ

Background

BoLM unwisely and unethically committed itself to reducing wild-horse numbers at harshly-low levels in the Checkerboard sections of three HMAs at issue.  Per the Consent Decree, once it was determined — or projected — that more than 100 wild horses were present (or might be) at some point in time in GDB, and/or that more than a combined total of 200 wild horses were (or might be) present at some point in time in AT and SWC, then RSFO would have them all removed.

Here are the number of horses that, BLM alleges that, per April 2016 surveys, were present in the checkerboard area of the following herd management areas (HMAs):

  25 Adobe Town

272 Great Divide Basin

187 Salt Wells Creek

——————————————

484 Total

RSFO proposes to remove not just the 484, but an additional 16, for an even 500.  RSFO acknowledges that it would not be removing “excess” wild horses.  RSFO further admits that the proposed removals would drop the population below the low-bound of the established arbitrary management level (AML).

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

Just because RSFO’s survey allegedly counted 484 wild horses in the Checkerboard does not mean that 484 are still there or were there the day after the census was conducted.  Wild horses are constantly on the move.  Just because they visit an area on certain days does not make them permanent residents.

Public Lands Commandeered by Private Interests

The Checkerboard area encompasses 2,427,220 acres, or 3,793 square miles.  Public lands total 1,695,517 acres — 2,649 square miles — and privately-held lands total 731,703 acres –1,143 square miles.  Thus, public lands constitute 70%, and private lands comprise 30%, of the Checkerboard.

Per the EA, the Rock Springs Grazing Association (RSGA) owns or “controls” the “majority” of the 30% of the privately-held Checkerboard area.  The EA does not reveal how significant that majority is, but it would have to be 51% or more, by definition, to be a majority.  If it were a “great” majority, then surely that point would have been made.  Thus, the conservative inference would be around 51%.  But to make the computations easier, and to give the benefit to the doubt, 60% will be used.

So, 60% x 30% = 18%.  What results is a minor percentage of private-profiteers calling the shots for how public lands are managed.  Unacceptable.

Wild-Horse Population-Density — Even If All 484 Were Only on Private Land

Let’s assume for the moment that 484 wild horses have established permanent residence in the 731,703 acres — 1,143 square miles — of privately-held checkerboard land.  The resultant population-density would be:

1 wild horse per 1,512 acres = 1 wild horse per 2.4 square miles.

Public Corruption — Appearance of

According to the Website of the American Wild Horse Preservation Campaign, the Rock Springs Field Manager has stated publicly:

For all intents and purposes, we consider all of the checkerboard private.”

If this direct quotation is accurate, then the Field Manager appears to be encouraging the private takeover of public lands.  No wonder the Bundy brothers and company felt emboldened by such BoLM “dog whistles” to seize control of the Malheur Wildlife Refuge.  Announcements like that suggest public corruption — abuse of public office to benefit private interests.

FRAUDULENT POPULATION ESTIMATES

Birth Rate versus Herd-Growth Rate

Before we examine BLM’s reported herd-growth rates of 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.  BLM claims an average birth rate of about 20% a year in wild-horse herds.  But the herd growth rate is unlikely to be that high.  Here’s why: Horses and burros die.

An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records for a representative sample of four herd management areas and 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 in their first year of life.  Thus, the effective foal-to-yearling survival rate is just 10 percent.  It is wrong for RSFO to use 20% as the growth rates.  It may be administratively convenient to equate the birth rate to the growth rate, but it is not valid.   

Adult Wild-Horse-and-Burro Mortality Rates Must Be Factored

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

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

The Herd-Growth Rate Must Necessarily Be Lower Than the Birth Rate

In light of the high foal-mortality rate and the expected adult wild-horse mortality rate, the herd-growth rate must always be lower than the birth rate.  When BLM reports alleged herd-growth rates many times higher than 20% (horses) — that would necessarily mean birth rates substantially higher still.  Such implausible rates are routinely found in BLM’s population data, including the year-to-year figures for the subject HMAs.  Stealthily inserting bogus birth-rates into the data, wrongly conflating birth-rates with population growth-rates, and failing to factor in mortality-rates — those are just some of the ways BLM creates the false impression of a population-explosion.

Stochastic Events Also Reduce Herd Growth

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

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

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

Imagine if such a catastrophe were to befall the 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 and sterile elderly mares?  BLM must proactively manage the herds per IUCN guidelines, if only in case of stochastic events.

Maximum AML Set Below Minimum Viable Population

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

Fraudulent Population Figures

BLM-RSFO’s data reports that the herds-in-question grew at biologically-impossible reproduction-rates.  Further, BLM-RSFO asserts that 484 of these imaginary horses were spotted in the checkerboard, thereby triggering their removal.

Name of HMA Population Population Percent

National OfcNational OfcIncrease

March 2015 March 2016

Adobe Town      602     1,030     71.0%

Great Divide Basin      199       670   236.7%

Salt Wells Creek      117       728   522.2%

BLM’s population-growth figures are fraudulent.  They are biologically impossible.  Even if the “data” represented only the birth rates, they would be as much as 100 times the normal birth rate.  Moreover, the bogus birth rates have been conflated with herd-growth rates.  The mortality rates were not factored.  Consider how such errors will compound and magnify over time.

In light of these fictitious figures, no action is the appropriate alternative.  BoLM-RSFO should be subjected to a forensic audit to determine who is behind the phony data.  Those staffers must be held accountable.

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.”

BLM-RSFO’s wild-horse population estimates are without merit.

Societal Impact of Inflated Population-Data

The population-estimates 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.

Fraudulent Data Emboldens Scofflaw Ranchers, Costs Wild Horses Their Freedom

In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use.  The notorious Cliven Bundy 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.

There are likely permittees in Wyoming emulating Bundy, Borba, and Filippini.  Certainly RSGA has no respect for the Act that was meant to protect America’s mustangs.  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.    

Voluntary Non-Use of AUMs Reflects Lowered Demand for Beef

BLM and its permit-holders protest that a lot of the livestock AUMs are in non-use, sometimes mandatorily, other times voluntarily.  They complain loudly, pointing to the seeming excess of wild horses — an illusion caused by BLM’s phony figures.

Bloomberg News published an article recently concerning the state of the beef market.  In the US, consumer-demand for beef is down to levels not seen in 40 years.  The US cattle-herd population is at a 60-year low and is expected to drop further.  The article explored why this situation exists.

Bloomberg noted that beef is a premium product, with a significantly higher price-point.  US consumers are turning to lower-cost meats, such as pork and chicken.  Further, the strength of the dollar makes US beef exports less competitive in the global marketplace.  Thus, it does not make economic sense for a rancher to produce more beef, given current conditions.  So, reduced demand and lowered cattle-population are important reasons why AUM-usage is down.  It has nothing to do with wild horses.

http://www.bloomberg.com/news/articles/2015-10-04/beef-isn-t-for-dinner-anymore-as-americans-devour-cheaper-pork

Authorized v. Actual Livestock Use

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

Actual Grazing Use Report — Form 4130-5

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

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

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

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

USDA Reports Beef-Cattle Now Weigh More — AUM Calculations Need to Be Reformed

The same Bloomberg article noted that the average weight of a beef-cattle animal has increased to 1,385 pounds, up 32 pounds from just the previous year.  Please note that the AUM was originally set per a weight of 1,000 pounds.  But, in the meantime, what the industry refers to as “genetics” — technologically-advanced selective breeding — has increased average weight by 38½ percent, with better-than two percent of that increase coming in the past year alone.  BLM needs to charge more AUMs for cattle — as well as charge more per AUM — in accordance with true market-rates.

On the other hand, the AUM for a horse presumes a 1,000-pound saddle horse.  But mustangs tend to be smaller and lighter, weighing 700 to 800 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 the less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.

HELICOPTERS — Inappropriate for Counting Wild Horses

Aerial 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 Red Desert Complex (also in Wyoming) census emphasized, there are assumptions and caveats that must be considered when evaluating the numbers, including the potential for having double-counted due to “horse activity (moving).”  The method itself exaggerates the numbers.  See pdf-pages 84-87 at the link below.

http://www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html

I note that the 2015 Checkerboard Census Report also mentioned that assumptions had been used but contended that an under-count was likely.  That assumption is not only incorrect but opposite to the facts.  When more horses are “seen” than could possibly exist, the method is faulty and likely fraudulent, given the “cooperation” of RGSA.  Finally, I note the absence of photographs.

Both the Roundup-Contractor and BoLM 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 the target-area.  What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?

In its response to this topic, which was raised during scoping, BoLM said that it would monitor the helicopter’s flight-path to keep this from happening.  But BoLM’s purpose in conducting equid cleansing is to please the permittees.  BoLM has committed to removing 500 wild horses to comply with the Consent Decree, and the roundup-contractor expects to earn the amount that corresponds to 500 captured wild horses.  The helicopter-pilot is looking to “make his numbers” but so is BoLM.  Thus, BoLM has a conflict of interest in needing the contractor to remove any 500 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 BoLM to fulfill its agreement with the arbitrary Consent Decree.  Consequently, wild horses would lose their freedom for the private profit of RSGA and the helicopter-contractor, and for the administrative convenience of BoLM.  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 into the checkerboard area 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.  RSFO acknowledges as much in the EA, but still pursues the removal-without-return alternative.

Recommendations:  In legitimate instances of straying, RSFO 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 RSFO wants them to use?  What about siting mineral licks deep inside the HMAs, away from the Checkerboard?  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.  RSFO should specify preventive and reactive measures in this regard as part of its management approach.  Return outsiders to the solid-block public-lands areas of the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from the Checkerboard (aversive techniques).

HELICOPTERS — Dangerous to Humans

Scheduled Airliners — Safe; Helicopters — Crash-Prone

As cited in my scoping comments but reiterated here out of concern for staff-wellbeing, the American public considers travel-by-air to be safe, even routine.  Crashes are rare, and fatalities, few.  Thus, it is easy to assume that all flight is safe, which is not the case.

Helicopters are notorious for crashing.  Please compare and contrast Wyoming’s aviation crash-records of scheduled air carriers versus helicopters during the 10-year period from January 1, 2006 to December 31, 2015 — per the National Transportation Safety Board (NTSB):

Scheduled Air Carriers (“Part 121”)

    1  — Accidents (minor events excluded)

    0  — Accidents that resulted in fatalities

Helicopters

  13  — Accidents (minor events excluded)

    1  — Accident that resulted in a fatality

    1  — Number of persons that died in that accident

In Wyoming, for the period in question, there has been 1 accident involving a scheduled air carrier.  Nobody died.  Helicopters, in contrast, have had 13 accidents — 13 times more — including 1 that involved a fatality.  At the link below, you can replicate the searches to verify these data.

http://www.ntsb.gov/_layouts/ntsb.aviation/index.aspx

Helicopter Census Method Puts BLM Personnel at Risk

BLM’s environmental assessments often allude to the use of “multiple experienced observers” (presumedly BLM staffers) to count and photograph wild horses — or what they think are wild horses — while being flown in grid patterns over the range.

Given the crash-proneness of helicopters, BoLM could face a tragedy — with the loss of key personnel, friends, and colleagues in an accident.  Counting wild horses does not justify this risky method.

HELICOPTERS — Dangerous to Horses

Inhumane Roundup Method

BoLM’s use of helicopters to round up the wild horses is inhumane.  The horses are terrified by the thunderous, high-intensity noise as they are pursued by the low-flying helicopter.  They are blasted with sand, dirt, and gravel from the rotor wash.  Panicked by the chaos, they stampede, injure themselves, and become separated from their babies and bandmates.  Mares miscarry.  Foals become orphans.  Many horses die from stress, even more have to be euthanized.  Helicopter-style roundups are abusive, especially to foals, older horses, and pregnant mares.  This is unacceptable.

Recommendations:  Helicopter-style roundups must be abolished.  Roundups in extreme temperatures — either the summer heat or the winter cold — must end.  Stampeding horses for countless miles — causing them to lather with sweat and then bringing them to an abrupt halt — must be prohibited.  Forcing the horses to run long distances over rough terrain, thereby wrecking the delicate hooves of the newborns and resulting in lameness and even death — must never happen again.

BoLM should institute the kind approach to gathering wild horses.  Roundups should be done slowly, quietly, and gently using the bait-and-water trapping approach.  This method also tends to preserve family unity, which is essential to wild-horse social structure.

Abusive Behavior by Helicopter Pilots during Gathers

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

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

No Horse Left Behind

Helicopter-contractors are incentivized to leave no horse ungathered.  In addition to the flat fee-for-service, they earn a per-horse-fee.  Thus, they have reason to go after every last horse in order to “make their numbers.”  Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment.  We also observed how the attending USDA veterinarian and the BoLM officials present did nothing to stop the abuse.  What’s more, this cruelty took place in plain view of observers holding video cameras.  Imagine what went on out of sight and off camera.

HELICOPTERS — Dangerous to the Environment

Possibility of a Post-Crash Fire’s Leading to a Wildfire

The crash of a roundup-helicopter could result in a fuel-spill.  Especially in these times of drought, when there is an abundance of dry brush, a wildfire could be sparked.  Thus, even the environment is at risk from the use of helicopters to round up wild horses.  It bears repeating that, because herd management areas are typically in remote locations, it would be difficult to put out a post-crash fire and keep it from getting out of control.

CONCLUSIONS

1.  RSFO should repudiate the arbitrary and corrupt Consent Decree.

2.  RSFO’s Field Manager should stop making seditious announcements, leading rogue ranchers to believe that public lands are private and emboldening them to break the law, putting public safety at risk.

3.  RSFO should select either Alternative A — No Action, or Alternative C — Removal-and-Return.

———————————————-

Sincerely,

Marybeth Devlin

6880 SW 27th ST

Miami, FL 33155-2916

marybethdevlin@bellsouth.net

305  665-1727

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References:

§ 1334. Private maintenance; numerical approximation; strays on private lands; removal; destruction by agents THE WILD FREE-ROAMING HORSES AND BURROS ACT OF 1971 (PUBLIC LAW 92-195) Retrieved from

18 U.S. Code § 2383 – Rebellion or insurrection.  Cornell University Law School.  Retrieved from https://www.law.cornell.edu/uscode/text/18/2383

18 U.S. Code § 2384 – Seditious conspiracy.  Cornell University Law School.  Retrieved from https://www.law.cornell.edu/uscode/text/18/2384

American Wild Horse Preservation Campaign.  (2016, August-September)  BLM Wyoming Wild Horse Wipeout Continues – Action Needed Today!  Retrieved from http://act.wildhorsepreservation.org/p/dia/action3/common/public/?action_KEY=23543

Public corruption.  Definition.  Cornell University Law School.  Retrieved from https://www.law.cornell.edu/wex/public_corruption

Romboy, Dennis.  (2015, December 18)  “Judge sentences San Juan Commissioner Phil Lyman to 10 days in jail, 3 years of probation.”  Deseret News.  Deseret Digital Media.  Retrieved from http://www.deseretnews.com/article/865643995/Judge-sentences-San-Juan-Commissioner-Phil-Lyman-to-10-days-jail-3-years-of-probation.html?pg=all

Protect Mustangs is a 501c3 nonprofit organization who protects and preserves native and wild horses.