Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Posted on January 20, 2016 by Protect Mustangs

Email: blm_ut_sulphur@blm.gov

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

Document: Environmental Assessment — Preliminary

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

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

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

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

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

News Release — 2015 EA

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

News Release — 2015 Public-Safety Removals

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

Sulphur Gather Environmental Assessment — Preliminary

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Let’s do the math.

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

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

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

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

Discrepancies were evident per a review of the …

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

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

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

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

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

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

125 %
131 %
153 %
157 %
249 %

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

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

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

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

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

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

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

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

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

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

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

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

Here are excerpts from a news report:

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

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

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

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

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

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

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

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

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

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

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

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

The EA states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Marybeth Devlin

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

Posted on January 12, 2016 by Protect Mustangs

The feds’ mustang population “data” is a fraud

By Marybeth Devlin

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

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

Fish Creek (NV)
80% increase in one year

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

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

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

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

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

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

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

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

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

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

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

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

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

Here is the tool to compute CAGR:

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

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

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

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

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

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

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

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

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

Further Insight into Calculating Population-Growth

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

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

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

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

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

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

URGENT: Petition to stop violent wild horses roundups and stop sending them to slaughter!

Posted on January 11, 2016 by Protect Mustangs

Wild horses are a native species who must be saved!

Sign and share the urgent petition

Loopholes allow the BLM to sell thousands of wild horses to slaughter middlemen known as kill buyers to dispose of alleged “excess and unadoptable” American wild horses and this must stop now! Slaughter is cruel and inhumane.

This is what cruel roundups look like:

Roundups are the first step towards slaughter.

Craig Downer published the peer reviewed paper titled The Horse and Burro as Positively Contributing Returned Natives in North America.

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

The NAS report states there is “no evidence” of overpopulation. Only tobacco science and spin backs up BLM’s population claim to justify roundups and fertility control/sterilizations. . .

PZP is an EPA approved RESTRICTED-USE PESTICIDE that sterilizes wild horses after multiple use so it’s risky for long-term herd survival. See information here: http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

Giving PZP to wild mares also results in foals being born late in the fall or winter and dying because they are too little to make it through a harsh winter.

Fertility control research trials are big business. Left unchallenged, wild horses and burros will continue to be lab rats for human fertility control research. This exploitation must stop!

We request an immediate halt to roundups for scientific population studies and studies on holistic management before it’s too late.

Wild horses are a returned-native species in America. Rounding up federally protected wild horses and burros has been documented as cruel. Warehousing them for decades is fiscally irresponsible. Sending wild horses to slaughter by selling them to middlemen is cruel and inhumane. Clearing wild horses and burros off public land–for industrialization, fracking, grazing and the water grab–goes against the 1971 Free Roaming Wild Horse and Burro Act put in place to protect the living legends of the American West. They must never go to slaughter.

We request you defund and stop the roundups immediately as well as reverse the Burns Amendment to stop unlimited sales of wild horses to slaughter.

There is no accurate census and the BLM figures do not add up. We request population studies for each herd management area (HMA) and each herd area (HA) because we are gravely concerned there are less than 18,000 wild horses and burros in the 10 western states combined. More roundups, fertility control/sterilizations and sales to slaughter will wipe them out because the majority are no longer genetically viable herds.

Wild horses are underpopulated despite spin from the forces that want to perform heinous sterilizations in the field. Humane fertility control could be looked at as an option only after scientific population studies have been conducted for each herd management area. The EPA approved restricted-use pesticides known as PZP and Gonacon have risks as do other drugs . . . Right now fertility control is premature, will destroy natural selection and could cause harm because wild horses are underpopulated in the West.

Field observers have noticed a worrisome decline in wild horse and burro populations since the BLM’s rampant roundups from 2009 to this day.

Kindly allow returned-native wild horses and burros to reverse desertification, reduce the fuel for wildfires and create biodiversity on public land, live with their families and inspire us with their spirit.

Right now America’s wild horses and burros are being managed to extinction. They need your help to stop the roundups and slaughter today.

Go to the petition on Change.org here and email it to your friends and family: https://www.change.org/p/defund-and-stop-the-wild-horse-amp-burro-roundups

Scandal Unfolds: Rare Water Canyon foals are up for adoption before the Gonacon™ experiment wrecks havoc in the herd

Posted on December 17, 2015 by Protect Mustangs

We are updating this page so check back for more information as the scandal unfolds. Updates are being posted towards the bottom.

Save the young victims of the cruel experiment!

Wild foals captured from the Water Canyon portion of the Antelope Herd Management Area in eastern Nevada are up for adoption. They are the victims of a roundup to EXPERIMENT on wild horses with GONACON™. Nine weanlings and two yearlings are being held together at the National Wild Horse and Burro Center at Palomino Valley, north of Reno, Nevada. They need to be saved now and hopefully in pairs because this is so painful for them to have lost their families!

The wild horses are available for walk-up adoption from 8 a.m. to 4 p.m., Monday through Friday, and 8 a.m. to 2 p.m., Saturdays. All of the horses have received vaccinations and their bloodwork is completed. Brand inspections will be performed and health certificates issued on all adopted horses.

Applications are available for download (.pdf) at http://on.doi.gov/1A0eAfw.

For more information, contact Jeremy Wilhelm, BLM public contact person, at (775) 475-2222.

The GONACON™ EXPERIMENT is being humane-washed by the Bureau of Land Management (BLM) and their partners. They are perpetrating the overpopulation myth when in truth America’s wild horses are underpopulated. In their experiment they are releasing only a fraction.

Alleged wild horse advocate, Jeannie Nations, is the Project Coordinator (unpaid volunteer) of the experiment. Nations was also proposing PZP experiments as a BLM RAC member in October 2014 as you see here: http://www.blm.gov/style/medialib/blm/nv/resources/racs/ne_rac/meeting_presentations.Par.34609.File.dat/14-10-16-negb-jnations-proposal.pdf

Nations says, “I wanted to mention also, that we did a quick online petition for about 6 days with American Wild Horse Preservation Campaign regarding this same proposal and we had over 19,000 people from all around the country and the world in favor of doing this pilot program.This just goes to show how badly people want a positive change in wild horse management!

Do people realize what they are signing and supporting when they sign petitions put out by the American Wild Horse Preservation Campaign? Are they reading the whole document or just reading the first paragraph and clicking quickly to add their name?

Why did the BLM take the Spin Dr.’s push for fertility control and turn it into an EXPERIMENT with GONACON™? It’s a slippery slope when “advocates” partner up with BLM for fertility control . . . American herds are becoming nonviable and will be wiped out.

GONCACON™ is an immunocontraceptive that Big Pharma calls a “vaccine“. Yet fertility is not a disease so calling it a vaccine doesn’t make sense. It is registered with the EPA as a restricted use pesticide. http://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-116800_01-Sep-09.pdf

GONACON™ like PZP is an EPA restricted use pesticide (see photo below). The BLM and their supporters are experimenting on America’s wild horses because the Feds see them as PESTS and want to dispose of them slowly . . . They hope the public won’t realize what’s happening.

Now it’s clear that some alleged “wild horse advocates” pushing fertility control, like PZP and GONACON™, are helping BLM not wild horses.

See who is involved in this experiment and know what exactly they are doing: http://www.blm.gov/nv/st/en/fo/ely_field_office/blm_programs/wild_horses_and_burros/Water_Canyon_Growth_Suppression_Pilot_Program.html

Update 5:27 pm PST: Why is the BLM’s Project Coordinator (volunteer) of the GONACON™ EXPERIMENT and BLM RAC member now raising money for her alleged Angels Acres Rescue to adopt the “Lucky 11” as she calls them? Yes she is calling the victims of this horrible GONACON™ EXPERIMENT and roundup “Lucky”.

Ask yourself if this:

Why didn’t the well funded wild horse preservation groups fight in court to stop the Water Canyon roundup?

Was this just another opportunity to get more donor data by sending out an online petition but do nothing to stop the roundup?

Is it because they are in with BLM, want more names on their email lists to push for fertility control?

Follow the money . . .

Photos from BLM taken by the experiment’s project coordinator (volunteer) Jeannie Nations in public domain

Elko Daily News reports on the GONACON™ EXPERIMENT: http://elkodaily.com/lifestyles/nature-notes-wild-horse-contraception-research/article_8da74080-34c0-5f7a-8ba9-65578d5254b4.html

November 08, 2015 5:45 am • LARRY HYSLOP
A research project north of Ely will look at maintaining a stable wild horse population using a contraceptive. The goal is to treat mares with Gonacon, a commercial contraceptive, and then watch them over several years to make sure the project mares do not produce foals.

Jeanne Nations is a volunteer project coordinator who lives in the area, frequently visits the horses and knows most by sight. She will handle the on-site adoptions and help Ben Noyes, in charge of the project, and the Wild Horse Specialist in the BLM Ely District Office. Jeanne said if this research is successful, she hopes it could help other areas provide a more humane way to keep wild horse populations under control.

The Northeastern Nevada Resource Advisory Council recently visited the project site, after submitting a letter to the BLM’s Wild Horse and Burro Program supporting Jeanne’s project.

The research site is north of Ely, on a narrow strip of public land 12-15 miles long between U.S. Highway 93 and the Schell Creek Range. A fairly isolated group of 66 wild horses currently live in this part of the Antelope Herd Management Area, which has 803 wild horses with an Appropriate Management Level of 324. The nearest other wild horses to this project area are over the mountains to the east.

Trapping has begun and Ben has gathered 35 horses so far. All the rest of the area horses will be trapped this fall. Ben feels he can capture all the area horses using water and bait trapping but will use other techniques if needed.

While the last few members of the Council were visiting the trap site, seven horses came into the trap to eat hay and drink water, showing they are quite comfortable with the trap.

About 30 horses will be part of the project, with the rest removed from the area. It is hoped on-site adoptions will take most of the removed horses but any remaining will be taken to holding areas. People interested in adoption can email Jeanne at jnphotography@hughes.net.

The project horses kept on the site will consist of 15 stallions and 15 mares, having an assortment of ages. After capture, mares will be treated with Gonacon and freeze branded. DNA samples will be collected from all horses. The problem then is the mares must receive a booster 30 days later, so all mares and some of the stallions will be kept in holding pens.
After the 30 days, the horses will be released back into their home range. Ben feels the horses should have no problem re-habituating to their open range after a month of daily hay and abundant water.

Ben and Jeanne will keep an eye on the mares and watch them for pregnancies. The mares will need to be gathered again in two years to receive another booster.

There is a good chance the project mares are now pregnant and will produce foals the first year. However, these treatments should keep the mares from becoming pregnant again during the length of the project. After the project ends, it is hoped the mares will then become pregnant. Other horses may cross the mountains to join this group but they will not throw off the research since only the branded mares will be watched.

Links of interest:

Read Jack Ferm’s The BLM wild horse roundup continues: follow the money for a good overview of the situation: http://suindependent.com/blm-wild-horse-roundup-continues/

and his piece Why is the BLM killing wild horses? http://suindependent.com/blm-killing-wild-horses/

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

Urgent Hay drive for WILD HORSES (WY14) rescued from the slaughterhouse

Posted on November 12, 2015 by Protect Mustangs

Help bring hay to wild horses

URGENT: They have forecasted MORE SNOW Sunday! We can’t buy a big load of hay until the WY14’s goal is met here: https://www.gofundme.com/WY14WinterHay It’s getting close to the halfway mark. Please help with a donation to FEED the Dry Creek WY14 this Winter. Your donations are tax-deductible and will make a direct impact on the lives of the youngsters rescued back from the slaughterhouse.

Thank you for being part of the WY14 Rescue Mission.! Protect Mustangs is 100% volunteer so every dollar counts and they all add up to help the youngsters eat and stay warm in the snow.

If you would like to make a donation by www.PayPal.com please send it to Contact@ProtectMustangs.org

Or send a check by mail to:
Protect Mustangs
PO Box 5661
Berkeley, CA. 94705

Thank you for your hay donation to feed them so they can stay warm in the freezing winter nights.

The WY14 love you and know you are helping them. They send their heartfelt gratitude and blessings.

Remember sharing is caring.

With love,
Anne

Anne Novak
Volunteer Executive Director
www.ProtectMustangs.org

Anonymous tip says wild horses are being slaughtered by the thousands

Posted on October 16, 2015 by Protect Mustangs

We are sharing this anonymous tip in hopes legal action or rescue will follow to save the thousands of horses who are still alive.

#TakeAction to demand horse slaughter stop now!

Email Secretary Sally Jewell ( Secretary_jewell@ios.doi.gov ). The Secretary of Interior oversees the Bureau of Indian Affairs. You can also write her a letter. Here is her address:

The Honorable Sally Jewell Secretary of the Interior

U.S. Department of the Interior

1849 C Street,

NW Washington,

DC 20240E

Please Contact your Congressional Rep (
http://www.contactingthecongress.org/search.html ) to request they intervene on your behalf to stop the slaughter.

Join the movement to Protect Mustangs by liking the Facebook page: www.Facebook.com/ProtectMustangs Check the page daily and invite your friends to join the movement to protect mustangs!

We are working for the wild horses on Twitter too so Join up at www.Twitter.com/ProtectMustangs You can also join our Founder and Executive Director, Anne Novak, on Twitter at www.Twitter.com/theAnneNovak There is a lot we can do together to Protect Mustangs!

Please share this video so people will learn what is going on. Then they can demand change and legal action to stop the slaughter of thousands of wild horses!

Go to www.ProtectMustangs.org for more information on wild horses.

Our non-profit mission is to protect and preserve America’s native and wild horses. www.ProtectMustangs.org

BLM Wants Input on Proposed Red Desert Wild Horse Roundup

Posted on October 3, 2015 by Protect Mustangs

BLM Press Release:

The Bureau of Land Management (BLM) Rawlins and Lander field offices announce that a preliminary environmental assessment (EA) analyzing a proposed wild horse gather in the Red Desert Wild Horse Herd Management Area (HMA) Complex is now available for review.
The Red Desert Complex, which includes the Antelope Hills, Crooks Mountain, Green Mountain, Lost Creek and Stewart Creek HMAs, is located in Sweetwater, Carbon, Fremont and Natrona counties west and south of Wyoming Highway 287.
 The proposed operation would include gathering wild horses, treating all mares to be released with the PZP-22 (porcine zona pellucida) fertility control vaccine, and removing horses to bring the population of the complex within its appropriate management level. All horses that have moved outside the HMAs would also be removed. The proposed gather may take place late this year or in 2016.
The preliminary EA analyzes three alternatives and is available by visiting the BLM website at: www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html.
 The 30 day comment period runs from September 8 through October 8, 2015.

Comments may be emailed to: RedDesertComplex_HMA_WY@blm.gov (please include “Red Desert Gather EA Comments” in the subject line). Comments may also be mailed or delivered to either field office:
Benjamin Smith, Wild Horse & Burro Specialist BLM Rawlins Field Office 1300 N. 3rd Street Rawlins, WY 82301
Jeremie Artery, Interim Wild Horse & Burro Specialist BLM Lander Field Office 1335 Main Street Lander, WY 82520
For more information, visit www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html, or contact Benjamin Smith at 307-328-4200 or Jeremie Artery at 307-332-8400.
The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In fiscal year 2013, the BLM generated $4.7 billion in receipts from public lands.
–BLM–
Rawlins and Lander Field Offices 1300 N. Third/PO Box 2407 Rawlins, WY 82301 1335 Main Street Lander, WY 82520

Outrage over feds hauling Cold Creek wild horses to private facility in Utah

Posted on September 14, 2015 by Protect Mustangs

Mounting concern they will end up unadopted and go to slaughter

For immediate release:

LAS VEGAS, NV. (September 14, 2015)—Protect Mustangs, Mark Boone Junior and members of the public are outraged that the Bureau of Land Management (BLM) moved the captive Cold Creek wild horses out of Nevada to a remote private holding facility in Axtell, Utah—with limited public accessibility and allegedly owned by a BLM employee. Earlier near Las Vegas, the BLM shot and killed more than 28 wild horses who were not well enough to make the long haul to Utah when the haulers were scheduled to pick them up. The skinny roundup survivors were exhibiting complications of re-feeding syndrome and severely dehydrated. Protect Mustangs has filed a complaint requesting the the Inspector General investigate matters leading up to, during and after the Cold Creek roundup.

“It’s outrageous for the BLM to move the Cold Creek wild horses out of Nevada to a private facility—in the boondocks of Utah—without public accessibility 6 days a week,” says Anne Novak, executive director of Protect Mustangs. “We need to be able to watchdog the mustangs and help them get adopted.”

Novak is a horsewoman who has a good track record of helping American wild horses get adopted from coast to coast. She uses Facebook and works with her vast network of supporters at Protect Mustangs to find good homes for wild horses.

“Why are the feds taking the cherished Cold Creek wild horses away from the public’s eyes especially after killing 28?” asks Novak. “It’s time for the BLM to stop violating the public’s trust. There is plenty of room at Palomino Valley Wild Horse and Burro Center outside of Reno, Nevada. It’s an accessible location for potential adopters to visit and fall in love with a Cold Creek mustang. They need to be there.”

Palomino Valley Wild Horse and Burro Center near Reno currently has 941 wild horses. Their holding capacity is 1850. They are located 27 miles away from the Reno International Airport and 4 hours by car from San Francisco. The Utah facility is 780 miles from San Francisco.

Some horse advocates and environmental researchers believe the Cold Creek wild horses are showing signs of impaired immunity because they were given PZP, the pesticide for birth control several years ago. Does BLM wants to hide the long term side-effects of PZP from the public? Is this why they whisked them off to a private facility in Utah or is there another reason?

Utah congressman Chris Stewart is pushing legislation to give individual states and Indian Tribes control of federally protected wild horses and aggressively manage them as they wish. His Wild Horse Oversight Act is proposed in Congress. http://stewart.house.gov/media-center/press-releases/rep-chris-stewart-introduces-bill-giving-states-the-ability-to-manage

“Utah is notorious for being a pro-slaughter state and we must ensure the Cold Creek wild horses are safe forever,” states Novak. “Horse slaughter for human consumption is inhumane and barbaric. Just because horse meat sells on the foreign market doesn’t mean that the United States of America should allow our icons of freedom to be eaten abroad.”

After 3 failed attempts at adoption—live or internet—the BLM can legally sell wild horses by the truckload to middlemen who claim they won’t sell wild horses to slaughter. . . According to the Burns Amendment of the free Roaming Wild Horse and Burro Protection Act, the BLM can also get rid of all wild horses over the age of 10 the same way.

“We won’t sit by and watch America’s wild horses fall through the cracks,” says Hollywood actor Mark Boone Junior a member of Protect Mustangs. “I spent a lot of time in Vegas and I’m mad as hell 28 Cold Creek wild horses were killed by the feds. The herd was managed poorly because BLM isn’t doing their job.”

# # #

Media Contacts:

Anne Novak, Anne@ProtectMustangs.org, 415-531-8454

Kerry Becklund, Kerry@ProtectMustangs.org, 510-502-1913

Links of interest™:

Nevada: Federal Inquiry Is Sought After Starving Horses Are Euthanized (New York Times): http://www.nytimes.com/2015/09/10/us/nevada-federal-inquiry-is-sought-after-starving-horses-are-euthanized.html?smid=fb-share&_r=0

Horse advocates want review; 28 Nevada mustangs euthanized (Associated Press article went viral) http://www.nevadaappeal.com/news/18109922-113/horse-advocates-want-review-28-nevada-mustangs-euthanized

Horse Advocates Call For Investigation After BLM Euthanizes 28 Emaciated Mustangs http://sanfrancisco.cbslocal.com/2015/09/09/horse-advocates-call-for-investigation-after-blm-euthanizes-28-emaciated-mustangs/#.VfD_tm8dYN8.facebook

Horse advocates seek probe of mustang killings: http://www.kezi.com/news/Horse_Advocates_Seek_Probe_of_Mustang_Killings.html

PZP proposal for research on Cold Creek wild horses (2013): http://nyecounty.granicus.com/MetaViewer.php?view_id=3&clip_id=576&meta_id=31471

Federal horse, burro adoption event designed to help manage population (Washington Post August 2014): https://www.washingtonpost.com/local/federal-horse-burro-adoption-event-designed-to-help-manage-population/2015/08/14/cdc3f3f6-4205-11e5-846d-02792f854297_story.html

Palomino Valley Wild Horse & Burro Center: http://www.blm.gov/nv/st/en/prog/wh_b/palomino_valley_national.html

Chris Stewart WHOA bill: http://stewart.house.gov/media-center/press-releases/rep-chris-stewart-introduces-bill-giving-states-the-ability-to-manage

Mark Boone Junior on IMDB: http://www.imdb.com/name/nm0095478/

Protect Mustangs on the web: www.ProtectMustangs.org

Protect Mustangs on Facebook: https://www.facebook.com/ProtectMustangs

Anne Novak on Twitter: https://twitter.com/TheAnneNovak

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

Complaint to the Office of the Inspector General regarding BLM killing 28 wild horses near Las Vegas

Posted on September 9, 2015 by Protect Mustangs

To the Office of the Inspector General at the United States Department of Interior

Dear Sirs,

We officially request a full investigation into the management of wild horses and land use planning 6 years before the roundup, the roundup itself, feeding, veterinary care and killing of the 28 Cold Creek wild horses who had become skinny.

Why didn’t the BLM help these federally protected wild horses get the forage they needed earlier?
Why didn’t the BLM move the native wild horses up to areas with more forage?
What happened to their forage?
What about the livestock grazing permits? (see attached)
What organizations were pushing for BLM to use PZP, a controversial EPA restricted use pesticide for “birth control”–made from slaughterhouse pig ovaries–that sterilizes after multiple use? http://www.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf
Are the wild horses getting pushed out and killed as part of the New Energy Frontier–to put massive solar farms on fragile desert land and therefore impacting wildlife? https://eplanning.blm.gov/epl-front-office/projects/lup/2900/49868/54310/LV-RMP_Poster_Renewable_Energy.pdf
Why aren’t the Cold Creek wild horses getting their fair share of the land that is for their principal but not exclusive use according to the 1971 Free Roaming Wild Horse & Burro Protection Act?
Why is the agency appointed “appropriate management level” (AML) for wild horses so low when a genetically viable herd needs more members?
Why is the BLM limiting access to the public to bare witness to this cruel roundup?
Was euthanasia chosen for convenience and the bottom line, pure and simple?
Did they look at the feed and labor involved vs adoptability and take the cheap and easy way out?

Rescues and members of the public would have helped bring the Cold Creek wild horses back to health if manpower was an issue. Adoption would have been simple once they healed because people know about them and cherish them.

Tourists from around the world, visiting Las Vegas, love the wild horses of the American West.

The BLM continues to roundup more beloved Cold Creek wild horses and we pray they will not kill any more but nurse them back to health.

The public is outraged.

We thank you for investigating into the wrongdoings surrounding the management, roundup and killing of 28 Cold Creek wild horses, provide transparency and shine the light of truth.

Sincerely,
Anne Novak

Anne Novak
Executive Director
Protect Mustangs
Tel./Text: 415.531.8454
Anne@ProtectMustangs.org

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

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

Protect Mustangs demands a full investigation into the BLM killing 28 Cold Creek wild horses near Las Vegas

Posted on September 8, 2015 by Protect Mustangs

Did poor horse management result in killing wild horses after rounding them up or was the BLM just too lazy to give them the care they needed?

For immediate release:

LAS VEGAS, NV. (September 8, 2015)–Protect Mustangs demands the Office of the Inspector General conduct a full investigation into the management, roundup, feeding, veterinary care and killing of the 28 Cold Creek wild horses who had become skinny. The preservation organization also demands immediate full public disclosure of the death of more than 75 wild horses who were moved to a holding facility in Kansas in 2014. Allegations of wild horses becoming skinny and dying who were not able to access the feed troughs have been circulating the Internet for a year.

“The BLM roundup was supposed to save wild horses not kill them,” states Anne Novak, executive director of Protect Mustangs, a preservation organization based in California.

“I was told by BLM staff that wild horses would be euthanized only if they could not step up into the trailer to be hauled away,” states Alynn Dalton, photographer and Las Vegas area resident who attended the roundup. “They killed the very horses they said they were there to help. Why aren’t they giving them a real chance at life?”

“Last year in Kansas the BLM’s deplorable horse management resulted in the deaths of more than 75 wild horses and that now requires full public disclosure,” explains Novak. “Today we demand an investigation into the Cold Creek killings. These federally protected wild horses were living on the range not dropping dead. The BLM should know that feeding severely skinny wild horses takes special care to nurse them back to health. . . I wonder if they thought this was an easy way to dispose of them. The truth needs to come out.”

Out of 202 Cold Creek wild horses rounded up near Las Vegas, BLM killed 28 wild horses on September 3rd and 4th, before Labor Day weekend, according to their website update. They list a “poor prognosis for recovery” as the reason for killing them but BLM’s track record speaks for itself regarding the 2014 Kansas fiasco.

“How many mares and foals have been killed or did the BLM just kill off the mares instead of helping them?” asks Novak. “If so, now what will happen to the orphans? Did the BLM kill the old mustangs too? People would have adopted these mustangs once they were well. Volunteers and rescues would have helped them recover. Killing them without giving them a fighting chance at recovery is a heinous misuse of tax dollars.”

The Cold Creek herd is the last wild herd in southern Nevada and dearly loved by the community in the Las Vegas area.

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

# # #

Thursday,
September 3

Summary: Gather operations have been suspended
Animals gathered: 0
Animals shipped: 49

Acute related animal deaths: 0
Cause: none
Chronic/pre-existing related animal deaths: 11
Cause: Eleven (11) horses, 3 studs and 8 mares, body condition score 1.5 or less were euthanized due to “poor prognosis for recovery or improvement” as identified within BLM’s Animal Health, Maintenance, Evaluation and Response Instruction Memorandum 2015-070.

Friday,
September 4

Summary: Gather operations have been suspended
Animals gathered: 0
Animals shipped: 37

Acute related animal deaths: 0
Cause: none
Chronic/pre-existing related animal deaths: 16
Cause: Sixteen (16) horses, 3 studs and 13 mares, body condition score 1.5 or less were euthanized due to “poor prognosis for recovery or improvement” as identified within BLM’s Animal Health, Maintenance, Evaluation and Response Instruction Memorandum 2015-070.

Media Contacts:

Anne Novak, Anne@ProtectMustangs.org, 415-531-8454

Kerry Becklund, Kerry@ProtectMustangs.org, 510-502-1913

Links of interest™:

28 Cold Creek horses euthanized by BLM: http://bit.ly/1Ow5Pgl

BLM roundup and death report: http://on.doi.gov/1JRx6Xm

BLM roundup press release: http://on.doi.gov/1PJ6onj

Wild horses relocated by the Bureau of Land Management occupy a corral and die in Kansas: http://bit.ly/1UEPNT1