Protect Mustangs comments against spaying wild mares in Wyoming


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

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

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

January 14, 2016

Dear Public Servants at the BLM:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

PM Checkerboard ROundup Sept 20 2014

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

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

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

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

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

Sincerely,
Anne Novak

.Anne Novak
Executive Director
Protect Mustangs

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

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





Urgent! Wyoming roundups cause environmental damage

Permission given to use to raise awareness crediting © Protect Mustangs

Permission given to use to raise awareness crediting © Protect Mustangs

Your comments are urgently needed to help Wyoming’s wild horses today!

You do not need to live in the U.S.A. to comment as we know Wyoming tourism draws people to the state from around the world to see native wild horses.

The Bureau of Land Management (BLM) released an Environmental Assessment (EA) for the roundup and removal of wild horses from the “Checkerboard” region HMAs–Adobe Town and Salt Wells Creek (ATSW) in the Red Desert of Wyoming. The EA reads:

“All wild horses on private lands and on the checkerboard lands within the ATSW Complex would be removed in accordance with the 2013 Consent Decree.”

Since wild horses move freely from public land to private land in the “Checkerboard” region, will they chase the native wild horses with helicopters on to private land to remove as many as possible from the entire public-private land region? They have chased them on to public land in the past to trap them.

Does this roundup have a back-room connection to BP America’s Continental Divide – Creston (CD-C) natural gas project that will frack 8,950 new gas wells? The massive CD-C project already has 4,400 existing oil and gas wells.

Watch GASLAND Part II on HBO July 8th to see the answer to that question.

Comments are due to BLM Wyoming by 4:30 p.m. Central Time, June 10, 2013.

We encourage you to select Alternative C, No Action Alternative, No removal  

Email your comments to Jay D’Ewart, Wild Horse and Burro Specialist, using this email address: AdobeTown_SaltWells_HMA_WY@blm.gov with “ATSW Public Comment” in the subject line.

Focus on the environmental damage because of the proposed Adobe Town Salt Wells Roundup. Oppose the roundup and request Alternative C, No Action Alternative, No removal. You can make it short. The point is to make a comment because they count how many come in. Below are some talking points:

  • Damaged and trampled plants, terrain and destruction of the fragile ecosystem from chasing wild horses with helicopters and the potential for a stampede.
  • Damaged and trampled plants, terrain and destruction of the fragile ecosystem from trucks and trailers as well as equipment trucks driving in and out.
  • Damage to riparian areas from chasing wild horses with helicopters and the potential for a stampede.
  • Damage to riparian areas and the surrounding fragile ecosystem from trucks and trailers as well as equipment trucks driving in and out.
  • Noise pollution from noisy helicopters assaults all wildlife and disturbs sage grouse.
  • Helicopters pollute the environment. They release CO2 that increases global warming and should not be allowed.
  • Fuel emissions from trucks carrying equipment and trailers for the roundup pollute. Trucks release CO2 that increases global warming and should not be allowed.
  • Dust from chasing wild horses, coupled with the stress, causes upper respiratory infections, possible permanent damage or possible death of native wild horses as well A hurting other animals in the ecosystem.
  • Dust from equipment trucks and trucks hauling captured wild horses in trailers causes possible damage to other species in the ecosystem.
  • Wild horses are a return-native species (E. caballus) and should not be removed. They are an essential piece in the native ecosystem, creating diversity and helping to reverse desertification. If native wild horses are removed the ecosystem will become more out of balance as we see happening because many predators species are being removed or killed.
  • Without proving overpopulation, this proposed roundup is in violation of NEPA.
  • Without proving overpopulation, this proposed roundup does not merit the use of risky chemical fertility control (PZP, SpayVac®) or fertility control made from pig ovaries (PZP-22, ZonaStat-H) as most pigs have become GMO animals and the risks are unknown. The “birth-control” was approved by the EPA as a “restricted use pesticide” only.
  • Without proving overpopulation, this roundup should be cancelled. Even the NAS study said the BLM fails to provide accurate data to support their overpopulation claims.
  • Native wild horses are not “pests” and should not be labelled or treated as if they are. They are an essential part of the native ecosystem.

More items will be listed later. Your suggestions below are welcome.

Read Debbie Coffey’s statement on using the fertility control agent known as PZP:

“PZP and other fertility control should not be used on non-viable herds either. Most of the remaining herds of wild horses are non-viable. The NAS and any advocacy groups that are pushing PZP and other fertility control have not carefully studied all of the caveats in Dr. Gus Cothran’s genetic analysis reports along with the remaining population of each herd of wild horses.” ~ Debbie Coffey, Director of Wild Horse Affairs at Wild Horse Freedom Federation

Read Jesica Johnston’s statement about overpopulation:

“The NAS findings clearly state that the BLM has failed to provide accurate estimates of the nation’s population of wild horses and burros. Therefore, the NAS cannot conclude that a state of over-population exists and or provide a recommendation for artificial management considerations such as ‘rigorous fertility controls’ to control populations for which the complex population dynamics are currently unknown.” ~Jesica Johnston, environmental scientist and biologist.

Here is the link to the BLM’s Environmental Assessment online:

http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/rfodocs/adobetown-saltwells.Par.74403.File.dat/ATSWEA.pdf

Here is the BLM press release explaining their side:

Release Date: 05/10/13
Contacts: Serena Baker,
307-212-0197

Adobe Town/Salt Wells Creek Wild Horse Gather EA Available

The Bureau of Land Management (BLM) Rawlins and Rock Springs field offices are launching a 30-day public comment period on an environmental assessment (EA) to gather excess wild horses from the Adobe Town and Salt Wells Creek (ATSW) Herd Management Areas (HMAs).The two HMAs are managed collectively as the ATSW Complex due to wild horse movement between the two areas. The Complex is located in the checkerboard pattern of mixed public, private, and state land ownership in Sweetwater and Carbon counties, stretching from Interstate 80 south to the Wyoming/Colorado border. The BLM respects private land owner rights while managing wild horse populations. The ATSW Complex includes approximately 510,308 acres which are privately held. This gather would reduce landowner conflicts where the wild horses stray onto private lands.Population surveys conducted in May 2012 found approximately 1,005 wild horses in the ATSW Complex. However, wild horse populations are expected to increase by approximately 20 percent with the 2012 and 2013 foaling seasons, bringing the population in the ATSW Complex to an estimated 1,447 wild horses by summer.The appropriate management level (AML) for the ATSW Complex is 861-1,165 wild horses. The gather is necessary to maintain the wild horse herds toward the lower range of the established AMLs in compliance with the 1971 Wild Free-Roaming Horse and Burro Act, and the 2003 Wyoming Consent Decree. The AML for the ATSW Complex was established through an agreement with private land owners and wild horse advocacy groups. It was confirmed in the 1997 Green River Resource Management Plan (RMP) and through the 2008 Approved Rawlins RMP. The proposed gather is anticipated in 2013.

The proposed action in the EA is also in conformance with the Consent Decree with the Rock Springs Grazing Association (RSGA) ordered by the U.S. District Court on April 3, 2013, to remove all wild horses from private lands within the checkerboard portion of the ATSW Complex in 2013. According to the Consent Decree, if the numbers are likely to exceed 200 wild horses within the checkerboard portion of the ATSW Complex, the BLM shall prepare to remove the wild horses from the private lands.

The ATSW Complex was last gathered in fall 2010. During that gather, 99 mares released back to the HMAs were administered the PZP fertility control vaccine. Fertility control is an alternative being considered in the EA.

Public comments are most helpful if they cite specific actions or impacts, and offer supporting factual information or data. Written comments should be received by June 10, and may be emailed only to AdobeTown_SaltWells_HMA_WY@blm.gov (please list “ATSW Comment” in the subject line), mailed or hand-delivered during regular business hours (7:45 a.m. to 4:30 p.m.) to: The BLM Rock Springs Field Office, ATSW Comment, 280 Highway 191 N., Rock Springs, WY 82901.

Before including your address, phone number, email address, or other personal identifying information in your comment, you should be aware that your entire comment – including your personal identifying information – may be made publicly available at any time. While you may ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so.

For more information, please contact BLM Wild Horse Specialist Jay D’Ewart at 307-352-0256.

Note to editor: A link to the EA and map of the proposed project area can be found atwww.blm.gov/wy/st/en/info/NEPA/documents/rfo/atsw-gather.html.

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. In Fiscal Year (FY) 2011, recreational and other activities on BLM-managed land contributed more than $130 billion to the U.S. economy and supported more than 600,000 American jobs. The Bureau is also one of a handful of agencies that collects more revenue than it spends. In FY 2012, nearly $5.7 billion will be generated on lands managed by the BLM, which operates on a $1.1 billion budget. The BLM’s multiple-use mission is to sustain the health and productivity of the public lands for the use and enjoyment of present and future generations. The Bureau accomplishes this by managing such activities as outdoor recreation, livestock grazing, mineral development, and energy production, and by conserving natural, historical, cultural, and other resources on public lands.
–BLM–Rock Springs Field Office   280 Highway 191 North      Rock Springs, WY 82901