More PZP news regarding the Pryor herd

Cross posted from Wild in the Pryors:   Comments


I have been home now for a little over a week.  It feels good to have some time with my husband Bill and my animals.  But I do miss the Pryors and look forward to my next trip, which is coming up fast.

Even though I am not there, I know the horses are fine.  They have been fine for over 200 years (many more than that I am sure)  and I hope that they will continue to be fine.  But with the up coming PZP proposal, I am not sure this will be the case. Let’s just say I am worried.  I need to think about this proposal and meet with some others that know and care about this special herd before I make any final judgements and construct my letter to the BLM in regards to it.

I had a message on my cell phone from Jared saying this was coming out (thank you Jared for the call).  I did go on their website:  BLMWEBSITE.  On this page you can go to the lower left and see MT/DK Draft Resource Management Plans.  Under there, there is a link to the PMWHR fertility control modification.  There are several links to read, and I encourage you to read them.

A couple of days later I got my “Interested Party” letter in the mail telling me about the proposed plan.

Dear Interested Party,

United States Department of the Interior

5001 Southgate Drive
Billings, Montana 59101-4669

August 1, 2013

After consideration of public input during scoping the Pryor Mountain Wild Horse Range (PMWHR) Fertility Control Modification Preliminary Environmental Assessment (EA) DOI-BLM- MT-010-2013-0034 and unsigned Finding of No Significant Impact (FONSI) are available for a 30 day public review and comment period. The documents will be available at the Bureau of Land Management (BLM), Billings Field Office (BiFO) website at The comment period will be conducted beginning August 6, 2013 and ending on September 6, 2013

This EA is tiered to the PMWHR/Territory EA (MT-010-08-24) and Herd Management Area Plan (HMAP) May 2009. This tiered EA has been prepared to analyze the impacts associated to wild horses and other resources from modification to the current fertility control prescription. The analysis from the HMAP and the 2011 Fertility Control EA are incorporated by reference. All other impacts and affected environment are already described and analyzed in the HMAP and subsequent FONSI and Decision Record (DR). These documents are also available at the BLM web address above.

Comments about the EA or unsigned FONSI can be sent to or at the letterhead address by close of business September 6, 2013. To best ensure interested party’s comments are received, comments can be sent in a written form and mailed or hand delivered to the Billings Field Office. The BLM will consider any substantive comments and revise the EA or FONSI as appropriate. Before including your address, phone number, e-mail address, or other personal identifying information in your comment, you should be aware that your entire comment, including your personal identifying information, may be publicly available at any time. While you can 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.

Thank you for your interest in the management of the PMWHR by the Billings Field Office. If you have any questions concerning the EA or unsigned FONSI, please contact Jared Bybee, Montana/Dakotas State Wild Horse and Burro Specialist, at (406) 896-5223.

Noble and Naolin, July 2013

Noble and Naolin, July 2013

Below is the unsigned FONSI.  If I am understanding this right, this will be the proposal and will be signed if they don’t hear enough feedback suggesting other wise.

(Pryor Mountain Wild Horse Range Fertility Control Modification Preliminary Environmental Assessment
Tiered to the
Pryor Mountain Wild Horse Range/Territory Environmental Assessment And Herd Management Area Plan May 2009)

This unsigned FONSI and EA (DOI-BLM-MT-0010-2013-0034-EA) is to modify the current fertility control prescription and apply fertility control to nearly every mare on the PMWHR through 2015 in order to help maintain the appropriate management level of 90-120 wild horses and reduce the need for a large scale gather. The modification to the current prescription would begin in the fall of 2013 and last through 2015 (the life of the current prescription). The modification to the fertility control would consist of applying primer doses to in the fall to mares in the one year old age class (when they are not quite two) and any mare that has not ever been primed in the fall of 2013. Mares ages 5-10 years old that have offspring on the range that are one year old or older would be given a booster. The rest of the treatment would continue as currently is. This would continue in 2014 and 2015. Treatments would still be designed to treat mares before becoming pregnant which in the spring, however in 2014 and 2015 boosters would be applied any time of the year. The EA is available for a 30-day public review and comment period beginning on August 6, 2013, and will end on September 6, 2013. The documents are available on the Billings Field Office website at

Based on the analysis of potential environmental impacts in the attached EA and consideration of the significance criteria in 40 CFR 1508.27, I have determined that with proposed mitigating measures incorporated as part of the proposed action this would not result in significant impacts on the human environment. An environmental impact statement (EIS) is not required.

The decision to approve or deny a modification of the current fertility control prescription to mares within PMWHR, and if appropriate a signed FONSI with rationale, will be released after consideration of public comments and completion of the EA. 

Niobrara, June 2013

Niobrara, June 2013

While I am not opposed to using PZP, I am opposed to the overuse of it.

Last year most of the J, K and L girls got removed.  So that alone will make a huge difference to the upcoming years of foals.  This year we have begun to see the effects of PZP.  There have only been 15 (13 surviving) foals born compared to 25 last year.

Please read and please submit your comment letter.  Comments need to be in by September 6, 2013.


Ecologist Craig Downer speaks out against using PZP in the Pryors

Craig Downer

Craig Downer (Photo © Cat Kindsfather, all rights reserved.)

Protect Mustangs’ Advisory Board member offers holistic management based on Reserve Design as opposed immunocontraceptives approved by the EPA as pesticides 

April 15, 2013

Mr. James M Sparks, Billings Field Manager
BLM, Billings Field Office
5001 Southgate Drive
Billings, MT 59101-4669
Re: 4700 (MT010.JB): Scoping Notice for Increased Use of Fertility Control on Wild Horses within the Pryor Mountain Wild Horse Range

Dear Mr. Sparks and To Whom It May Concern:

Montana BLM has zeroed out six of its seven original wild horse Herd Areas. The only one that still has any wild horses left is the Pryor Mountain Wild Horse Refuge, which was established prior to the 1971 Wild Free-Roaming Horses and Burros Act (WFHBA). In fact, Montana BLM has decided to zero out 82% of the original legal acreages that should have been set aside “principally” for the wild horses in the wild. This is a greater percentage of zeroing out than any other Western state. New Mexico comes closest at 77%. Given this initial injustice, it would seem that in the remaining area still home to wild horses, they would be treated much more fairly and given the resources and the Appropriate Management Levels (AML) that would assure their long-term viability. But such has clearly not been the case in the Pryors, where the AML range of 90 to 120 falls far short of the 250 individuals that is recommended for long-term viability in the wild by the IUCN SSC Equid Specialist Group (1992).

So I take this opportunity to thank you for sending me this scoping notice. I have reviewed this and wish to oppose the intensified use of PZP on the Pryor Mountain wild horses. They have been assigned an AML that is non-viable; and the further tampering with and inhibition of their reproduction would make them even more non-viable, especially in view of their long-term future survival, as well as their ecological adaptation to the Pryor Mountain ecosystem.

As a wildlife ecologist who appreciates these animals for the returned North American natives they are, I am particularly concerned that BLM’s repeated semi-sterilization of mares (often resulting in permanent sterilization of the mares) will cause serious social disruption. The logic is this: those mares who fail to achieve pregnancy quickly become disaffected with their band stallions and go off with other stallions in their futile attempts to achieve pregnancy. Similarly the stallions become desperate in their repeated futile attempts to impregnate the mares. This leads to widespread discontent and disruption, both within and between the wild horse bands composing the Pryor Mountain – as any – herd. This results in the serious neglect by adults of their duties to educate the younger members of their bands who are not as inhibited in their breeding as before. These immature individuals attempt to breed prematurely when the social units are in disarray. If intact they would be learning the very important lessons for survival in the demanding Pryor Mountain ecosystem, with its harsh winters, etc. As the effect of PZP wanes and some mares come back into a fertile condition, many give birth out of the normal Spring and early Summer birthing season, even in the late Fall or Winter when cold and storms cause them to greatly suffer and even die, along with their offspring. This is totally opposite the true intent of the WFHBA!

The intensified PZP approach to reducing reproduction in the Pryor Mountain wild horse herd is not the correct policy to adopt. It does not adhere to the core intent of the WFHBA. It is a major step toward domesticating these wild horses and seriously compromises their true wildness and natural adaptiveness. What I am offering in place of this “quick fix drug” approach to preserving, protecting, and managing this cherished herd (and all herds should be cherished) is a major and widely employed branch of the science of wildlife conservation known as Reserve Design. If properly and conscientiously applied, this would: (a) obviate the need to drug the Pryor Mountain mustangs by creating a naturally self-stabilizing horse population that would truly become “an integral part of the natural system of public lands” (preamble of WFHBA); and (b) “achieve and maintain a thriving natural ecological balance on the public lands” and “at the minimum feasible level” of interference by man. Both of these mandates come directly from Section 3 a of the WFHBA and should be adhered to by authorities of the BLM and USFS, the two agencies charged with fulfilling the act.

To accomplish these goals, you should:
(1) Incorporate the Pryor Mountain’s natural barriers such as the steep cliffs along the eastern side of the refuge that lead down to the Bighorn River. These will limit the expansion of the herd. Where necessary they could be complemented by artificial semi-permeable barriers.

(2) Restore natural horse predators such as the puma and wolf whose effect upon the wild horses would accord with natural selection and produce a more fit and well-adapted population in the Pryor Mountains. It has been a mistake to have puma hunting season reopened in the Pryors, and this should be rescinded in collaboration with Montana’s wildlife department.

(3) Avail yourself of options provided by Section 4 and 6 of the WFHAB in order to secure truly long-term-viable habitat for a truly long-term-viable wild horse population that is not subject to inbreeding and decline. Section 4 allows private landowners whose properties lie adjacent to the Pryor Mountain wild horse refuge to maintain wild, free-roaming horses on their private lands or on land leased from the government provided they protect them from harassment and have not willfully removed or enticed them from public lands. This is an outstanding opportunity for the public to help in preserving and protecting the wild horse herds at healthy population levels, i.e. to complement federal Herd Areas (BLM) and Territories (USFS). Section 6 of the WFHBA authorizes cooperative agreement with landowners and state and local governments to better accomplish the goals of the WFHBA. This allows for providing complete and unimpeded habitat for long-term viable wild horse populations. BLM should invoke Section 6 to establish cooperative agreements with both the National Parks Service (USDI, same as BLM) re: McCullough Peak national monument (which I believe already has such an agreement) and Bighorn Canyon National Recreation Area, as well as the Custer National Forest (USDA) in order to expand available habitat for the Pryor mustangs. As concerns the Custer National Forest, the USFS officials should not be allowed to get away with the fence they have erected and that restricts the wild horses’ traditional access to summer grazing meadows. This is on the west side of East Pryor Mountain and consists of a two-mile long buck and pole fence. This area was occupied by the wild horses in 1971 and should be a recognized legal area for them, as was documented by Dr. Ron Hall who did his study of the Pryor Mountain wild horses. It is also a prime public viewing area with great scenic visits, as I recall from my visit there in June of 2003. By erecting this fence, Custer National Forest officials defied their mandate to protect and preserve wild horses under the WFHAB; this is subject of an ongoing legal suit. BLM officials must insist this fence be taken down!

(4) Once a complete viable habitat is secured with adequate forage, water, minerals, shelter, wintering and summering habitat components, etc., the Pryor Mountain wild horses should be allowed to fill their ecological niche here and to naturally self-stabilize. This they will do as ecological climax species, as species belonging to the mature ecological sere, if only given the time and the space and the requisite non-interference by man. Thus, the socially and ecologically disruptive roundups will come to a halt; and the wild horses will harmonize with all the unique and fascinating animal and plant community that is found here. Given the opportunity, the wild horses will enhance the Pryor Mountain ecosystem and people will come to appreciate the virtue of a wild-horse-containing ecosystem.
(5) Semi-permeable fences could be constructed along the refuge’s peripheries but only where necessary. Buffer zones around the Pryor Mountain wild horse refuge should be established in order to contain the wild horses and keep them out of harm’s way. Within this buffer zone, mild forms of adverse conditioning techniques could be employed to keep the horses within their refuge. Win-win cooperative agreements with local people whereby they benefit from the wild horses as through giving paid eco-tours, providing lodging and meals, participating in monitoring and protection of the horses, etc., should be stressed. These positive opportunities should be expanded in order to make Reserve Design a success.

I go into greater detail as to how Reserve Design can be successfully applied in my recently published book: The Wild Horse Conspiracy, where I also describe the Pryor Mountain situation. I hope that you can get a copy and read it with an open mind. Look under Reserve Design in the Index. Let me know if you want a copy.

Hoping you will give serious consideration to the points here raised. Anxiously awaiting your response.

Craig Downer

Craig C. Downer
P.O. Box 456
Minden, NV 89423

Craig C. Downer is a wildlife ecologist (UCalifBerk, UNevReno, UKanLawr, UDurhamUK) who has extensively studies both the wild horses of the West and the endagered mountain tapirs of the northern Andes. He has given speeches and written many articles, including encyclopedic, and several books. His works are both popular and scientific, in English, Spanish and translated to German. Several of these concern wild horses, their ecological contribution, their North American evolutionary roots, their great natural and social value and their survival plight. Downer is an Advisory Board member for Protect Mustangs, a member of the World Conservation Union, Species Survival Commission, a Board member of The Cloud Foundation and has written the Action Plan for the mountain tapir (1997). Downer’s current book, “The Wild Horse Conspiracy” points directly to the root cause of the disappearance of America’s wild horses. The book is on sale at Amazon