We are grateful our sucessful legal actions have stopped roundups and saved thousands of lives in the Pine Nut and Fort McDemitt areas. Protect Mustangs is creating a legal team to continue the fight for wild horse freedom in the courts. We almost didn’t find lawyers in time to help save the Pine Nut herd. We need to hire a staff lawyer
The team at Protect Mustangs feels legal action is a very important area of focus with a huge impact to save many lives.
Did you know that Academy Award-winner Michael Blake (Dances with Wolves), RIP, joined our Fort McDermitt lawsuit in 2013 to help stop two years of horrible roundups that were sending wild horses to slaughter?
Michael Blake wins Oscar for writing Dances with Wolves This is what Michael Blake wrote on August 21, 2013:
I, Michael Lennox Blake, declare and state as follows:
1. I am an author as well as a screenwriter. I have written several books and screenplays including Dances with Wolves, which was released to international acclaim in 1990. In 1991, I won every major award for my screenplay for Dances with Wolves, including an Academy Award, Golden Globe, Writer’s Guild Award, and the Silver Spur. I have also received public service awards including the Eleanor Roosevelt Award and the Americanism Award, in addition to many other awards during my life.
2. I reside in Sonoita, Arizona. I am a member of Protect Mustangs, and also am on the Advisory Board for Protect Mustangs. In a professional capacity I am an author and screenwriter. I support the work that Protect Mustangs does to protect wild horses and advocate for effective wild horse conservation on public lands.
3. I have visited Nevada for decades to see the wild horses, study them, and be inspired by them for my work. I have explored the lands of Nevada where the wild horses roam in freedom for inspiration and research for my work. I intend to return to these areas so I may continue to be inspired and do research for my work.
4. In 1992, I helped commission the first comprehensive aerial census of wild horses in Nevada. In almost every herd area, the horses were far less numerous than the BLM estimated. The final count in our survey was 8,324.
5. Protect Mustangs’ members are interested in wild horses, and I support their work to protect wild horses’ freedom and safety from cruel and harmful practices including but not limited to illegal roundups. Their mission is to educate the public about indigenous wild horses, protect and research American wild horses on the range, and help those who have lost their freedom. Protect Mustangs works to educate the public about the decisions and activities of the government that impact wild horses, and find solutions for wild horse conservation that does not include roundups and auctioning off wild horses for slaughter. Members of the public and horse advocates across the United States are interested in and support Protect Mustangs’ work to protect wild horses due to their recreational, scientific, spiritual, ecological, cultural, artistic, historical, iconic, and aesthetic values.
6. I wrote in my book Twelve the King:
“But he and hundreds of thousand like him are gone now from this beautiful land, and for that reason alone I could not stop as I traveled over four hundred miles of Nevada roads. Something evil is still afoot in this land, and it has left its imprint everywhere. In all those miles of open, free country, the mark of evil is present in what is absent. The wild horses are missing from the land.”
7. I have written extensively about the American West and find inspiration seeing and studying wild horses. If these unbranded, wild horses are rounded up and removed by the USDA Forest Service and/or the BLM on tribal land, or elsewhere by the Forest Service and/or the BLM, I will be harmed because I will no longer have the ability to study them or be inspired for my books, stories and other works.
8. Wild horses and their connection with the land in the American West inspire me to write. I have plans to spend time in the future using and enjoying these lands and studying free-roaming wild horses on public lands in the Owyhee HMAs and where the wild horses roam in the Humboldt-Toiyabe National Forest, as well as on tribal lands. The proposed gather on USDA Forest Service and tribal lands will forever remove wild and free-roaming horses that I rely upon in my professional and personal capabilities.
9. I derive significant satisfaction and happiness from the existence of native wild, free- roaming horses. Ensuring the continued existence and distribution of wildlife including wild horses in the West is of the utmost importance to me and has directly influenced my life a great deal. The West is far different than the East because the West still has wildlife—including wild horses that inspire me to write fiction and non-fiction.
10. If the Fort McDermitt Horse Gather proceeds as planned, it will prevent me and other members of Protect Mustangs from recreating, enjoying, studying, being inspired from, and writing about the wild horses in the area in the future. I am very unlikely to continue deriving benefit and inspiration concerning the wild horses in an area where they have been removed and herd numbers drastically reduced as is proposed by the Fort McDermitt Horse Gather and the 2013 Agreement between the Forest Service and Fort McDermitt Tribal Council. Our members share these views as well.
11. I have been studying and gaining inspiration from seeing wild horses in Nevada throughout my life. I have certain plans to continue visiting these wild areas of Nevada authorized for roundup, including the Humboldt-Toiyabe National Forest, throughout my lifetime. For the aforementioned reasons I would be directly harmed should the unbranded, wild horses at issue in the Fort McDermitt Horse Gather be removed and the horses rounded up and be allowed to go to holding, auction, sale, or slaughter.
[End of Michael Lennox Blake’s declaration]
HELP build the legal fund today so Protect Mustangs can continue to fight for wild horses in court. We are a unique group dedicated purely to the protection and preservation of America’s wild horses. We need to act quickly and independently to HELP SAVE wild horses with legal action. Please make a donation today and share this fundraiser: https://www.gofundme.com/MustangLaw2016 or donate via PayPal to Contact@ProtectMustangs.org
——– 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:
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?” ‘
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.
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.
URGENT: Comments against experimentation, sterilization and birth control on a nonviable herd are due by 5 pm January 14
SUBJECT: “White Mountain & Little Colorado EA Comments”
EMAIL TO: blm_wy_whitemtn_littleco_hma@blm.gov
FAX: (307) 352-0329.
BLM Rock Springs Field Office
WMLC Scoping Comment
280 Highway 191 North
Rock Springs, WY 82901
In your own words tell the BLM the following:
1.) I object to using my tax dollars to experiment on, forcibly drug with PZP and / or sterilize America’s wild horses.
2.) I do not want federally protected wild horses to be used for a research experiment using radio collars, devices in tails and spaying America’s federally protected wild mares. Sterilization is a form of harassing wild horses and against the law.
3.) The 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. There is only 1 wild horse per 6,000 acres in White Mountain. The BLM fraudulently inflates population growth (http://protectmustangs.org/?p=8551) and never performs a real headcount.
4.) I support natural selection and I am against fertility control of any kind because wild horses deserve to live on public land set aside principally but not exclusively for their use. Allowing more than 50 to 1 units of livestock to wild horses is unfair and goes against the 1971 wild horse protection act.
5.) Fertility control, such as with PZP and spaying, will destroy the herd’s genetic viability, wreck havoc on their behavior and social structure so therefore I am against it.
6.) I want to be able to come to Wyoming to see and photograph the White Mountain and Little Colorado wild horse bands with foals exhibiting natural behaviors–without radio collars and other devices–and definitely not sterilized.
7.) PZP sterilizes after multiple use and I do not want these wild horses sterilized.
I understand that your office has scheduled another roundup-and-removal operation pertaining to wild horses that allegedly have wandered outside the …
Sulphur HMA
… and that are, reportedly, posing safety-concerns along Highway 21.
I am submitting substantive comments and new information that BLM-Cedar City should consider. I urge you to cancel the gather, correct the population-estimate errors, investigate the validity of the accusations, complete an environmental assessment, fence Highway 21, and take other preventive measures.
REASONS CITED BY BLM FOR SPECIAL ROUNDUP
Overpopulation, Forage Limitations
BLM’s News Release identifies the issue as being wild horses “causing public health and safety concerns along Highway 21.” BLM lists overpopulation and forage limitations as the causes for the horses having allegedly migrated to the outer edge of the Sulphur HMA, near said highway.
The Proposed Action
BLM-Cedar City plans to round up and remove a total of 100 wild horses out of a population that BLM estimates at “approximately 830” (versus 250, the high-bound of the AML). The gather, scheduled to begin only days after issuance of the News Release and in the absence of an environmental assessment, would be accomplished via helicopter-drive. The roundup would supposedly target members of the Sulphur herd that are “encroaching on Highway 21.” But, given wild horses’ propensity to roam extensively, it is unclear how the true perpetrators would be identified.
The Issues
There are several important questions concerning the planned gather that BLM has not addressed.
What is the right solution for preventing vehicle-wildlife collisions?
What is the accurate estimate of Sulphur HMA’s wild-horse population?
Is there really an overpopulation? Has AML been exceeded?
Who has reported wild horses “along Highway 21”? Rogue ranchers?
How likely is it that 100 wild horses are encroaching on the highway?
Is the “public safety” excuse an end-run to skip an environmental assessment?
Was the snap-decision to hold a gather a strategem to avoid scrutiny of the data?
Are the pretty stories about adoptions and retirements-to-pasture just fables?
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, and
Ignorance of new studies that found herd-growth averages 10 percent — not 20.
FENCE OFF HIGHWAY 21
Outsiders — Dealing with Roving Equids
Horses will roam. It is their nature. It is management’s duty to keep them from places they should not be. Prevention is key. Removing horses that have wandered outside the boundaries of an HMA — “outsiders” — just creates a vacuum for “insider” horses to fill. Thus, removing “outsiders” is an ineffective strategy. The elimination of mustangs from an open, accessible habitat results in recolonization by other mustangs. Absent barriers, the process begins almost immediately, as horses come upon an area and see that it is attractive … and vacant. This is exactly what has happened! BLM removed 30 wild horses “from the same area” just months ago. Yet, here we go again. Thus, removal is not the solution.
Recommendations: When horses stray, BLM-Cedar City should round them back in! Encourage the outsiders to return to their proper place, then address those factors that caused the animals to leave home.
Does the HMA have perimeter fences?
Do the fences need repair?
Do the gates need to be checked frequently and closed?
Would palatable plantings draw the wild horses back inside the HMA?
Have mineral licks been placed well-inside the HMA?
Have guzzlers been installed to provide water sources within the boundaries?
And, most importantly, …
Why hasn’t Highway 21 been fenced off near the HMA?
BLM-Cedar City should specify preventive measures in this regard as its management approach. Return outsiders to the HMA. Fence the HMA’s perimeters.
Fence Off Highway 21 near Sulphur HMA, Install Wildlife-Underpasses
Highways that cross near wildlife-habitat need to be fenced off. Installing safety-fences is certainly the indicated, cost-effective, and long-term solution. By preventing horses — as well as other creatures — from crossing directly over a highway, fences keep animals from endangering themselves and motorists. Underpasses allow wildlife to migrate freely, but safely.
I urge BLM-Cedar City to install a system of fences and underpasses along Highway 21, where the road approaches the Sulphur HMA. Highway 21 has been described as “remote,” suggesting that traffic on it tends to be sparse, which should minimize inconvenience during installation of these protective features. Funding should be sought from BLM-National, BLM-Utah, your own Field-Office budget, and other state, local, and private sources.
Wildlife Underpasses — Historical Perspective
Utah can rightfully claim that it was the first state to install a wildlife-crossing in North America. In 1971, such an overpass was constructed south of Beaver.
Fast-forward to 2013, when a partnership of governmental agencies and private groups in Utah installed a system of fencing and underpasses along a 12-mile stretch of US Highway 89. The purpose of the $2.6 million-project was to protect Paunsaugunt mule-deer-herd during the animals’ seasonal migrations. The subject deer are considered trophy-caliber among sport-hunters, many of whom spend thousands of dollars to shoot one. But, prior to the installation of the fences and underpasses, an average of 100 mule-deer a year were being killed by collisions with automobiles.
What caught my attention was that the project was largely funded by … BLM — even though only 23 percent of the Paunsaugunt Plateau is on BLM-administered land.
The State’s management-objective for the mule-deer herd in the Paunsaugunt is a population of 5,200 to 6,500 wintering deer. In addition, predators — specifically, cougars — are “managed” … by hunting them … to “benefit” the deer — or is it to benefit the hunters wanting to kill the deer? Thus, the natural ecological balance is disturbed for the sport of humans.
Interestingly, the most recent data I could locate on Utah’s mule-deer population indicated that, post-harvest of 25,000-plus bucks in 2013, there were 332,900. Unlike neighboring states, Utah has a thriving mule-deer population. The International Union for Conservation of Nature (IUCN) categorizes the mule deer’s conservation-status as a species of “least concern” (LC). Mule deer have even been introduced to … Kauai, Hawaii. Yet, BLM was willing to spend millions to keep 100 of them safe. Surely, BLM will find a way to protect our precious-few-remaining wild horses. The answer is: Fence Highway 21 near the Sulphur HMA!
Not perfectly, but pretty well, according to the article linked below. Deer-deaths are down. Reportedly, it takes about three years for wildlife to become accustomed to the new funnel-structures, so results should continue to improve. One snag was cited: Opportunist-hunters set up camp near the underpasses, and shot deer passing through the funnel. Consequently, other deer, sensing danger, avoided the structures.
At the link below, you will find information and resources regarding the use of overpasses, underpasses, and crosswalks for mitigating collisions between wildlife and vehicles.
You already have the template from the Highway 89 project. Lessons have been learned — what worked, what didn’t, and how the system could be improved. Thus, implementation of a corresponding project for Highway 21 should go smoothly. Fence it, and they will cross through the underpasses.
FLAWED POPULATION ESTIMATES
Unlikely Birth-Rate
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.
718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).
This is improbable.
Population and Gather Reports — The Data
Per a review of the …
HMA and HA Statistics reports for the Sulphur herd from 2008-2014,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in BLM’s News-Release,
discrepancies are evident.
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2015
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. The beginning-of-the-year figure for 2015 — the pre-gather estimate — is per the BLM’s 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%
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%
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
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%
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%
But that 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%
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.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 Current estimate = 718+144-30-2
2015 830 Public health and safety excuse used to justify removing 100 wild horses without an EA.
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.
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 in an uproar over an “overpopulation” that BLM’s faulty figures portrayed.
Recommendations: BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must correct the record and make genuine efforts to stop this phony-story-gone-viral of a wild-horse population-explosion in Utah.
Mistakes Cost Wild Horses Their Freedom
The planned removals appear to have been hurriedly scheduled 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 faulty figures.
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 inadvertently portrayed an incorrect picture — an exaggerated picture — of the herd’s population.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER BLM METHODOLOGY
Projections per a Twenty-Percent Foal-Survival Rate
Let’s see how the population numbers should look if we used BLM’s assumption of a 20-percent foaling-rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Why 2014’s foals should be excluded: When determining animal-unit-month (AUM) use, BLM counts a cow and her calf as one unit. Likewise, a wild mare and her foal should also count as one unit. But in recent years, BLM has been counting foals as separate units. BLM has even been caught estimating wild-horse populations — and thus, AUM-use — to include newborn and even unborn foals. The correct and equitable approach is not to count foals, and certainly not to count fetuses.
Note about birthdays: Some might argue that all horses celebrate their collective birthday on January 1. But that practice is merely a convention of breed-registries, causing their members to employ artificial means to force mares to ovulate out-of-season in order to avoid their offspring being at a physical-maturity disadvantage vis-à-vis competitors. True age is biological age, and wild foals will not be true yearlings for several more months, until spring.
Factoring in PZP’s Impact: Herd size was affected by removals and by PZP. Removals, we know. As for PZP, the picture becomes murky.
Dr. Jay Kirkpatrick, the developer of PZP, claims that PZP treatment of wild horses is greater than 95-percent effective.
A study by Turner et al. (2007), which was cited in the National Research Council’s report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, found that PZP-22 remains 85-percent effective after 22 months. Moreover, PZP is known to exert significant contraceptive effect in the third year and beyond.
However, there are too mainly unknowns for me to factor in PZP’s effect on the Sulphur herd’s growth. So, to proceed conservatively, the estimates below ignore PZP initially and, thus, overstate the population to an unknown extent in that regard. An adjustment will be applied at the end to offset this.
Deaths on the range: Finally, it is assumed — wrongly, but for sake of initial estimates — that no horses died in the past seven years. The estimates ignore fatalities and, thus, further overstate the population. An adjustment encompassing PZP and fatalities will be applied to arrive at a working-estimate.
Bottom line: Every benefit-of-the-doubt has been given.
Sulphur HMA — 20% Growth — Reflecting removals, but not PZP or deaths
2008 — 190 — BLM’s population-estimate post-gather November 2008
Year Herd-size
January 1
2009 — 190 — Foal-crop: 38. Those foals would have been born in spring.
2011 — 244 — Foal-crop: 49. PZP does not affect already-pregnant mares.
2012 — 293 — Foal-crop: 59. Even though PZP at maximum-effect.
2013 — 352 — Foal-crop: 70. Even though PZP still in effect.
2014 — 422 — Foal-crop: 84. But gather in Aug removed 30 horses.
2015 — 476 — including the 2014 foal-crop
2015 — 392 — excluding the 2014 foal-crop
It is clear that, using BLM’s own data and the “20-percent-per-year” rule, BLM’s population-estimate, with or without the 2014 foal-crop, was about double that of a properly-calculated estimate.
Conclusion: If we were to accept BLM’s thesis that the herds grow 20 percent every year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 350. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
Yes, the estimate exceeds the assigned AML. However, in this case, being “over AML” is not meaningful because the AML and the working-estimate reflect a herd-level that is …
Below minimum-viable population.
No wild horses should be removed. Complete an environmental assessment as required, and fence off Highway 21.
Planned Roundup Would Have a Devastating Impact on the Sulphur Herd
Per the working-estimate of 350, if BLM were to remove 100 horses from the Sulphur herd, it would be a sudden, drastic reduction — nearly 30 percent of the herd. In addition, the type of roundup — targeting horses near Highway 21 — would ignore bloodlines and essentially be a “gate-cut.” Thus, the herd’s genetic viability would be further impaired.
But it gets worse. Recent studies have shown BLM’s “20-percent-per-year” rule to be exaggerated by double.
TRUE HERD-GROWTH RATE, FOAL-TO-YEARLING SURVIVAL RATE = 10%
Longitudinal Study Demonstrates Growth-Rate of Five-to-Ten-Percent
The International Society for the Protection of Mustangs and Burros (ISPMB) has just completed a 14-year study of wild-horse population-growth. The ISPMB herds have been managed per the “hands-off” minimum-feasible level specified in the Wild and Free-Roaming Horses and Burros Act.
Results: The study-herds grew from 5-to-10 percent a year. During the study, there were …
No removals
No predators
No PZP
Here is the link to the letter sent in this regard from ISPMB to the Department of the Interior and Bureau of Land Management.
http://www.ispmb.org/Letter.html
The ISPMB study casts doubt on BLM’s standard “20-percent-per-year” rule for estimating herd-growth. Certainly, assumed growth-rates of 29 percent IN 2010 and, especially, the 87 percent growth-rate the BLM assumed for 2014, are implausible. Further, because subsequent estimates were based on false, inflated previous estimates, the errors compounded.
Independent Research Discloses a 10% Foal-to-Yearling Survival-Rate
A study of BLM roundup-records for a representative sample of four herd management areas was recently published (Gregg, LeBlanc, and Johnston, 2014).
The researchers found an effective foal-to-yearling survival-rate of just 10 percent. No matter the birth-rate, what counts is survival. The same pattern likely holds true for the Sulphur herd. Per this study, BLM-Cedar City’s assumed growth-rates for the Sulphur herd are deemed not credible.
HOW THE ESTIMATES SHOULD HAVE LOOKED — PER NEW RESEARCH-FINDINGS
Projections per a Ten-Percent Growth-and-Survival Rate
Let’s see how the population numbers would look if we correctly assumed a ten percent foaling or survival rate. I have run the numbers, both including 2014 foals (inequitable) and excluding 2014 foals (correct).
Sulphur HMA — Per 10% Growth — Modified by Removals, but NOT by PZP
2008 — 190 — BLM’s population-estimate post-gather Nov ’08
2011 — 200 — Foal-crop: 20. PZP does not affect already-pregnant mares.
2012 — 220 — Foal-crop: 22. Even though PZP at maximum-effect.
2013 — 242 — Foal-crop: 24. Even though PZP still in effect.
2014 — 266 — Foal-crop: 27. But gather in Aug removed 30 horses.
2015 — 263 — including 2014 foals
2015 — 236 — excluding 2014 foals
It is clear that, using BLM’s own data and the “10-percent-per-year” research-finding rule, BLM’s population-estimate, with or without the 2014 foal-crop, was more than triple the properly-calculated estimate.
Conclusion: If we were to accept the new research-findings that herds grow 10 percent a year, then a good working-estimate of the Sulphur herd excluding the 2014 foals would have been about 210. That rounded number reflects a modest 10-percent adjustment to account for the effects of PZP and for deaths-on-the-range that would have reduced the population.
However, please note that the working-estimate derived per the independent research’s findings of 10-percent growth reflects a population that is …
Below AML and
Below minimum-viable population.
It is clear that BLM should be estimating the wild-horse population according to the latest scientific knowledge. Therefore, no wild horses should be removed. Instead, complete an environmenal assessment and fence off Highway 21.
Could There Really Be 100 Wild Horses Wandering onto the Highway?
Out of a herd best-estimated at 210, it seems implausible that 100 horses — virtually half the population — would have left the 265,711 acres of the HMA and begun hanging out near Highway 21. Indeed, the public safety “concerns” appear phony — like they might well have been concocted by rogue ranchers and seditious county commissioners. The safety-complaint seems more of a ruse to push BLM into conducting a major removal-action that will inure to the benefit of permit-holders. Those parties are agitating to have the State of Utah take over Federal lands and the management of our wild horses. Getting rid of the horses is the ranchers’ goal.
Unfortunately, BLM’s previous erroneous population-figures made it seem that the ranchers were right about an overpopulation of wild horses, and that by removing just 100 of them, BLM would hardly be making a dent. Thus, it is imperative that BLM set the record straight.
Happy Tone, Ugly Reality
BLM’s News Release is deceptively friendly in tone — from naming a meet-up point from which BLM invites prospective observers to start the “escorted tours” to the standard feel-good language about captured horses finding “new homes with families” and pleasant-pastures-for-life for those horses not adopted. Behind the facade, the reality is another story.
Claim of exigency regarding public safety;
Claim that is unverified and reeks of maneuvering by local ranchers.
Pretense that 100 horses are “encroaching on Highway 21”;
Removing horses rather than installing fences along the Highway.
Pretense that population-estimates are reliable numbers;
Finding of huge discrepancies in those estimates.
Pretense that an environmental assessment isn’t necessary;
Reality that an EA is required.
Pretense that only 12 percent of the herd would be removed;
Reality that 50 percent of the herd would be unlawfully taken.
Feel-good stories of adoptions and wild horses peacefully living out their lives at pasture
Reality that many of them would be — as they have been — sold to slaughter
ADOPTION … OR HIGHWAY TO HELL?
Sale to Slaughter for Sulphur HMA Captives
BLM’s News Release is disingenuous where it claims that wild horses “removed from near Highway 21 will be made available for adoption through the BLM Wild Horse and Burro Adoption Program.” The News Release is also dishonest where it promises that wild horses “not adopted will be cared for in long-term pastures, where they retain their ‘wild’ status and protection under the 1971 Wild Free-Roaming Horse and Burros Act.” If only those fairy tales were true. Unfortunately, the opposite is the case. Said adoption program is conducted to bring “three strikes and you’re out” to as many horses as quickly as possible, making them eligible to be sold rather than adopted. The long-term pastures program is shrouded in secrecy. The public has no access to check on the horses’ welfare. Past scandals have revealed BLM staff involved in selling wild horses to kill-buyers.
A review of BLM records of recent “adoptions” of wild horses that were removed from the Sulphur HMA just six months ago as part of the earlier “near Highway 21” removal disclosed instances of the Adoption Program auctioning off horses online for just $25, with free delivery to sites known to be frequented by kill-buyers.
Were the mares at issue among those that the New Release reported to “have found new homes with families”? Or did BLM remove wild horses from “near Highway 21” only to send them down a “highway to Hell”?
SULPHUR HERD’S AML WAS SET AT A GENETICALLY NON-VIABLE LEVEL
AMLs Should Provide for Better Than MVP, but Must Provide for At Least MVP
BLM is required by law to manage the wild horses in self-sustaining herds. To be self-sustaining, a herd must be genetically viable. To achieve viability, sufficient population is necessary.
A scientifically-valid AML needs to comply with the recommendations of the International Union for Conservation of Nature (IUCN) regarding adequate herd-size for equids. Increasing the AML per the IUCN guidelines also comports with the results of a recent meta-analysis regarding minimum viable population (MVP). Here are the links to the IUCN discussion on equid herd-size and to the MVP meta-analysis report:
BLM needs to increase the low-bound of the Sulphur AML to at least 2,500 and the high-bound to at least 5,000. BLM does have the authority to modify AMLs, and should correct Sulphur herd’s through amendments to the Resource Management Plan (RMP) and Herd Management Area Plan (HMAP). These actions should be taken right away. The corrected AML will result in a stocking-rate of one horse per 53 to 106 acres, which compares favorably with the one cow or calf per 38 acres that BLM allows on federal lands, as shown in the analyses that follow.
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Current
AML: 165 to 250 — Below minimum-viable population
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 1,063 – 1,610 — about 1⅔ to 2½ square miles per horse
Sulphur HMA — Utah — AML, and Acres per Wild Horse — Recommended
AML: 2,500 to 5,000 — Meets minimum-viable population per IUCN
Total acres: 265,711 — which is approximately 415 square miles
Acres per wild horse: 53 – 106 — about 6 to 12 horses per square mile
BLM’s National Authorized Livestock AUMs
But can the Sulphur HMA, composed of 265,711 acres sustain up to 2,500 mustangs at 106 acres per horse? What about 5,000 mustangs at 53 acres per horse?
BLM’s approach to determining appropriate levels of livestock-grazing suggests that the answer to both questions is “Yes”.
Below are the National statistics for authorized commercial livestock-grazing on BLM lands per animal-unit months (AUMs). Note the stocking rate: One cow or calf per 38 acres.
157,000,000 acres of public lands on which BLM allows cattle
1,033,333 cow+calf pairs that BLM permits to graze = AUMs annualized
2,066,666 cow+calf pairs per typical 6-month permit = annual AUMs x 2
4,133,332 cows and calves = pairs x 2
38 acres per cow or calf
BLM may argue that actual livestock use is lower than authorized or permitted use. But because actual use is whatever the permit-holders report on Form 4130-5, and because BLM essentially takes the permit-holders’ at their word and bills accordingly … eventually … after-the-fact … maybe … or maybe not (see Bundy, Cliven), the actual-use number is unverified and likely grossly under-reported.
Actual Grazing Use Report — Form 4130-5
As alluded to above, permittees are required to submit an annual report of how many livestock they put out on their respective allotments and for how long. Form 4130-5 “Annual Grazing Use Report” is used for this purpose. It’s a one-page document that BLM estimates to take 15 minutes to complete “… including the time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form.”
Form 4130-5 is the basis on which BLM bills the permit-holders. It is also the basis for the claim of reduced-use. Thus, grazing-use is a self-reporting, self-certifying system that is rarely verified. The ease with which permittees could game the system is obvious. Consequently, the veracity of the reports is suspect.
Bundy-Supporting Permittee Grazed His Livestock beyond Authorized Use
In neighboring Nevada, permit-holder Kevin Borba, whose allotment includes land inside the Fish Creek HMA, engaged in unauthorized livestock-grazing “consistently for six months” outside the permitted use. He had his cattle out there year-round. He owes $29,410.62 in fees and fines for willful trespass, but has subsequently sued BLM over the loss of his “rights” and to stop BLM from returning any wild horses to the range following the recent gather.
Such abuses by permittees are likely widespread. Cliven Bundy and Kevin Borba are not alone in this regard. Utah has its share of rogue-ranchers too, as recent events have demonstrated.
What If There Is Not Enough Forage to Support 5,000 Horses?
Nature has its feedback mechanisms that function to right-size a herd to fit the land’s carrying capacity. Biologist Robert Bauer points out that
… density dependent inhibition plays an important role also. In this scenario, what that means is that the numbers or density of wild equine, versus competing ruminants, such as the pronghorn, each will fluctuate in response to the other based upon the carrying capacity of the land, yet always in perfect balance. In essence, the pronghorn need the presence of wild horses and burros, just as much as the wild horses need the pronghorn. Each population will have the effect of keeping the numbers of another competing population at levels that are ideal for the carrying capacity of the land.
Careless and excessive removals of wild horses can nullify preservation-efforts. Thus, the very characteristics for which this herd is known could be lost by ignorant management. BLM-Cedar City is duty-bound to conserve the Sulphur herd and manage it for a self-sustaining, genetically-viable population.
Recommendations: Perform a complete genetic study of the herd. Per test-results on DNA samples analyzed by the Equine Genetics Lab and per guidance from Dr. Gus Cothran, BLM must then develop best management practices to restore and maintain gene-pool diversity via robust population-levels. An AML is valid only if it provides for a optimal population — one that can easily self-sustain its genetic viability and bounce back from random catastrophic events. It is not scientifically valid to conduct removals blindly — without regard to the herd’s genetics. Submitting DNA samples after-the-fact has it backwards.
The correct order is:
Sample first.
Sample complete — 100 percent.
Test samples.
Manage per test-results.
There should be no removals or contraceptions without knowing and managing per the genetic data for each herd-member.
Drastic Limitation of Herd-Size Leads to a Non-Viable Gene Pool
I would urge the BLM-Cedar City to study the topic of “genetic drift.” An excellent resource is linked below. Please note that stochastic events — random, chance happenings — can eliminate important survival-supporting, adaptive genes from a population. BLM’s currently-inadequate AML, enforced through sudden, draconian removals and mass contraceptive vaccinations, could randomly wipe out certain traits that are valuable and well-worth conserving.
Please study the danger of creating a “population bottleneck,” which is especially risky when a population is small, as is the case with the mustang-herd in question. Please also review the topic of the “founder effect” — which occurs when a new colony is started by a few members of the original population. It too would apply to previous removals. Refreshing your understanding of these evolutionary impacts will surely make it clear that the proposed intensification of PZP treatment is contraindicated. Here is that link:
Removal of Young Horses that May Be Their Sire or Dam’s Only Offspring
Captured horses would likely consist predominantly of mares and their foals, along with band-stallions. Bachelor-stallions escape more easily, resulting in a gender-ratio imbalance post-gather. Too few mares and too many studs is bad for the gene-pool. BLM-Cedar City must be careful in this regard. Because the Sulphur herd’s current population is below MVP, and because mares have been contracepted, certain bloodlines could be extinguished by mass-removals.
A HELICOPTER-ROUNDUP IS ILL-ADVISED FOR SEVERAL REASONS
Helicopters Are Not Safe
BLM-Cedar City has been informed, in previous comments, that helicopters crash a lot. For that reason, helicopter-use should be restricted to functions in service of a higher good, such as saving lives or fighting fires.
Peculiar Way of Addressing Safety Concerns
Please note the irony of using a helicopter-stampede — a dangerous method — to deal with an alleged public-safety concern. Rather than increasing safety, this approach decreases it.
Helicopter-Drive — an Inhumane Roundup Method
Using helicopters to round up wild horses is inhumane. There is no way to make it humane. Helicopter-roundups are examples of worst management practices. It is a national scandal that they still continue, bringing disgrace to the Agency and reflecting poorly on the Administration.
Abusive Behavior by Helicopter Pilots during Gathers
As has been documented on video, helicopter-pilots conducting roundups become frustrated by the wild horses’ lack of cooperation. Impatient to get the horses moving faster, the pilots ram the horses with the aircrafts’ landing skids, in some cases even flipping the animals into a somersault. There is video documentation of such abuses, and a court found that they had indeed occurred. Worse yet, much of the abuse goes undetected because the roundup-pilot generally flies solo.
There has also been documentation of contractor-wranglers whipping wild horses in the face, kicking them in the head, dragging them by the neck with ropes, using electric prods on them.
No Horse Left Behind
The helicopter contractors are incentivized to leave no horse ungathered. In addition to the flat-fee-for-service, they earn a per-horse-fee. Thus, they have reason to go after every last horse in order to “make their numbers.” Indeed, during the November 2012 Wassuk (NV) HMA roundup, we saw how determined the contractors were to get their per-horse payment. We also observed how the attending USDA veterinarian and the BLM officials present did nothing to stop the abuse.
An Angry Contractor May Be Headed Your Way
In case BLM-Cedar City were planning to employ the same helicopter-contractor who just worked the Fish Creek gather in Nevada, here is information you need to know.
Because that roundup was called off about 75 horses short of the planned number, the contractor was not happy. In fact, he tried to confront one of the humane-observers to make his displeasure known. She wisely refused to be provoked and just walked away.
Because the contractor’s profit-pump is primed, he could likely be more aggressive than usual. He could take out his frustrations on the horses.
Some Observers May Be Pumped-Up Too
Roundup-observers are bound to include anti-wild-horse parties — local ranchers, local elected officials. They are likely to be eager to bring a lawsuit against BLM on any pretext in sympathy with the Bundy-supporting, trespass-permittee in Nevada who, along with Eureka County Commissioners, just filed an IBLA appeal with regard to the Fish Creek gather.
The political weather is unstable. That is another good reason to call off the roundup.
Easy for Helicopter-Pilot to “Poach” Wild Horses from Neighboring HMAs
A glance at the map of the Sulphur HMA shows that Highway 21 approaches its boundary at one point before veering off again. The map also shows that Highway 21 passes by Blawn Wash, which is not-that-far east of the Sulphur HMA. Blawn Wash is associated with the Bible Spring Complex. However, having been downgraded to an HA, Blawn Wash is officially “off limits” to wild horses.
How easy it would be for a disgruntled and therefore highly-motivated helicopter-pilot to “poach” wild horses from the Bible Spring Complex by driving them into Blawn Wash. What would stop him from capturing wild horses that never set hoof near Highway 21? BLM needs to ask itself: Are we honestly trying to catch the Highway 21 trespassers, or are we allowing permittees to bully us into removing any 100 wild horses that the helicopter can find? The horses thus-captured might not even include the few that are — allegedly — “encroaching” on the Highway.
Possible Collusion with Permit-Holders
Perhaps, as you read this, permit-holding ranchers are in the HMA, pushing wild horses toward the Highway.
SUMMARY OF CONCLUSIONS AND RECOMMENDATIONS
1. Stop action. Cancel gather.
2. Complete environmental assessment.
3. Correct errors in the population-estimates.
4. Fence off Highway 21. Install wildlife-underpasses as needed. Apply the funds you would have used for this gather to begin construction of fences and underpasses.
5. Bring ’em back home. In the meantime, if a few wild horses really are straying onto Highway 21 — and the claim seems suspiciously-like a self-serving story that ranchers would invent — then BLM staff on horseback should be out on the scene “shooing” the mustangs back into the HMA. How else will the horses learn where they can and cannot roam? In short order, they will get the message.
6. Make it so they want to stay home. BLM should install multiple guzzlers deep within the HMA so that the wild horses will have water-sources available. That will reduce their dependency on stock-tanks operated by permit-holders. BLM should also entice the horses to stay home by placing treats such as mineral licks well-inside the HMA. BLM must remediate conditions that prompted the wild horses to wander. However, if the horses are following a seasonal migration route, then a wildlife corridor for them must be established. Regardless of these good measures, it is still essential to fence off Highway 21.
7. Amend the RMP and HMAP now to provide for a genetically-viable herd. The current AML and the actual wild-horse population of the Sulphur HMA are below mininum-viable population (MVP).
8. Increase the low-bound of the AML to 2,500 and the high-bound to 5,000.
9. Conduct a 100-percent evaluation of the Sulphur HMA herd’s genetic status.
BLM refused to hear public comments at “public” meeting
MINDEN, NV (January 22, 2015)—Edita Birnkrant, Campaigns Director for Friends of Animals (FoA) flew out from New York City with FoA correspondent Nicole Rivard to give public comments at the Bureau of Land Management (BLM) public meeting about the Carson City District Draft Resource Management Plan which calls to zero out 6 treasured herds of wild horses. After being denied her rights at the public meeting, held at the Carson Valley Inn in Minden, Nevada this afternoon, Birnkrant took over the microphone at the BLM meeting and held up yellow crime scene tape while Rivard filmed the protest against censorship and managing wild horses to extinction. Birnkrant was threatened with arrest by Nevada Sheriffs while holding up her banner. The hotel manager made Rivard stop filming and told the advocates they were being thrown out of the hotel, even though they had booked rooms there that night.
Statement from Edita Birnkrant:
“While we were waiting to go into the meeting a man told a BLM staffer “I wanna open up a horse butcher shop”. Then a few other guys started making jokes about how tender horse meat is. The BLM guy just chuckled but didn’t tell them it was inappropriate.
I was outraged that the BLM dared to hold a “public ” meeting and forbid the public from speaking. I took over the microphone to call out the sham of a BLM meeting, that shut out the public, and I said that Friends of Animals was there tonight to oppose the BLM’s extinction plan for wild horses in Nevada. I said the BLM is managing wild horses to extinction through roundups and PZP and we are outraged and demand it stop. I held our banner that said “Stop the BLM’s Criminal Reign of Terror. Protect Wild Horses Under the Endangered Species Act” The sheriffs were surrounding me at that point threatening to arrest me unless I left. I still had the banner and was shouting “the BLM is charged with crimes against wild horses”.
Then the hotel manager at the Carson Valley Inn in Minden, Nevada—Phil Dohrn–started bullying us and got in Nicole’s face. He pushed against her—blocking the camera and told her she had to shut her video off and we were getting thrown out.
Three extremely hostile sheriffs and the Carson Valley Inn manager escorted us to our rooms and waited outside while we packed our bags. They pounded on the door to hurry us or they’d arrest us. They called additional sheriffs to the hotel during all this. We left the hotel shocked that the Carson Valley Inn treats paying guests who exercise their First Amendment rights in their meeting room like this.”
The federal plan for public land in the Reno/Carson area is of interest to all Americans from coast to coast. Citizens care about public land and want federally protected wild horses protected by the law that allows them to roam freely without harassment.
Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org
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Friends of Animals’ public comments that advocates were not allowed to read and were given to Collen Sievers the BLM BLM Project Manager for Carson City District at the public hearing on the draft resource management plan for Carson City District
Edita Birnkrant, FoA’s campaigns director 917-940-2725
The opinion of the American public, as declared through Congress is clear: “wild free-roaming horses and burros are living symbols of the historic and pioneer spirit of the West; they contribute to the diversity of life forms within the Nation and enrich the lives of the American people.” BLM has an obligation to consider wild horses as an integral part of the natural system of public lands.
It appears from the Carson City’s Draft Resource Management Plan (RMP) and Environmental Impact Statement that the BLM failed to take into consideration critical information about wild horses and failed to consider any alternatives that promote a free and viable wild horse population.
Friends of Animal is here to urge BLM to reevaluate its Resource Management Plan.
We ask that BLM consider an alternative that: (1) maintains all wild horse herd management areas; (2) prohibits conflicting uses on herd management areas; and (3) prohibits efforts to eradicate wild horses, such as round-ups, fertility control and sterilization. BLM must take into consideration the small population of wild horses and the potential that they will be listed as a threatened or endangered species under the Federal Endangered Species Act. From a scientific perspective, wild horses on our public lands are at risk of extinction if BLM does not change its management plans.
BLM does not provide adequate area for wild horses. Under the current RMP, approximately 4.8 million acres of public lands covered by the plan are open for private ranchers to graze cattle and sheep while only 1.2 million acres are reserved for wild horses. In the preferred alternative the ratio or area available for cattle and sheep grazing is also more than 4 times that available for wild horses.
Moreover, under no alternative, are cattle and sheep prohibited from grazing on wild horse herd management areas. BLM must consider an alternative that provides contiguous habitat for wild horses to roam freely.
Second, all alternatives for the proposed Resource Management Plan allows BLM to continue managing horses at artificially low populations, or appropriate management levels. This results in expensive, and cruel round-ups that tear the wild horses from their homes and families and place them in tax funded holding facilities. This is one of the largest threat to wild horses on U.S. lands. Experts have warned that the “majority of wild equid populations managed by the BLM are kept at population sizes that are small enough for the loss of genetic variation to be a real concern.”
The Equid Specialist Group of IUCN Species Survival Commission recommends minimum populations of 2,500 individuals for the conservation of genetic diversity. Others have warned that populations managed with a target size of fewer than 500 horses are at some risk of losing more than 90 percent of selective neutral genetic variation over a period of 200 years.
There are no herds that have a large enough population to meet the recommendation of the IUCN Species Survival Commission – 2,500 animals—and only 1 out of 17 of the herd management areas in this planning area has an appropriate management level set to 500 or more. Limiting horses to an artificially low number is short-sighted and ineffective because it could prompt short-term population growth.
Finally, Friends of Animals submitted a petition to the US Fish and Wildlife Service asking it to recognize wild horses as threatened or endangered. The Endangered Species Act requires the government to make final determination on the petition within 12 months – which would be this June. The BLM should not undermine this legal process by allowing BLM to round-up and remove wild horses from Carson City herd management areas. Not only would such actions undermine the Endangered Species Act, but they would also put the viability of the horses here at risk. Instead the plan should recommend BLM halt all efforts to remove wild horses, and allow Fish and Wildlife Service to review the law and facts in regards to wild horses. Nicole Rivard, correspondent, FoA 203-910-1217
As my colleague just pointed out, all but one of the 17 herd management areas in the Carson City District has an appropriate management level set to 500 or more. Everywhere else the loss of genetic viability is a real concern. So additional roundups, which destroy social structure that can lead to population spikes, as well as consideration of administering fertility control, should be removed from this Carson City District Plan immediately if not sooner.
While some wild horse advocates may claim fertility control drugs, such as PZP, is the lesser of two evils, we at FoA believe birth control is equally harmful and inhumane as roundups. In most cases—even the BLM admits this—wild horses would still have to be captured to be treated with the pesticide before being released.
The widespread use of PZP is really very contrary to the true core intent of the Wild Horse and Burro Act of 1971, which was to restore wild horses as naturally, integrated, harmonious components of the public land ecosystem who are not overly tampered with. Deciding which animal should give birth or not is a very invasive, unacceptable thing to do to these wild animals.
Studies have revealed adverse effects of PZP— that it sterilizes wild horses after multiple uses and results in risky foal birth out of season and significant behavioral changes that can affect the health of the herd.
BLM’s discussion regarding a population control program in the EIS is inaccurate and unsupported. They claim fertility control limits the stress of pregnancy on mares, and helps stallions as they will not be exerting extra energy fighting to control mares or raising foals.
What about the stress on mares of not being able to get pregnant as nature intended!
We urge the BLM to look beyond data provided by the Humane Society of the United States, which has a vested interest in PZP as it is the registrant of the pesticide, and Jay Kirkpatrick, the director of the Science and Conservation Center, which produces the active ingredient in PZP. For instance a 2009 Princeton University study of the horses on Shackleford Banks in North Carolina, who began getting PZP in 2000, showed that prolonged infertility has significant consequences on social behavior.
Researchers found that females who were receiving contraception were much more likely to change groups. Normally bands are really very stable, said researcher Cassandra Nunez, and mares will stay with males much if not all of their lives. That stability is really important for the health of the group members. Foal mortality increases when there are a bunch of different changes, and parasite load of animals in the group can go up because they are getting more stressed.
In a later study in 2010, Nunez found that recipients of PZP also extend the receptive breeding period into what is normally the non-breeding season, resulting in foal birth out of season.
Normally the winter is spent eating as much as they can, and everyone is more relaxed. Males tend to let females roam farther, which is good because food is patchier. So all of this is changing because of extended cycling.
Nunez also noted it’s taking a while for the contracepted mares, who were taken off PZP in 2009, to respond physiologically. So that flexibility that you think you have with PZP…it’s not really that flexible.”
It is imperative that BLM reduce the number of cattle and sheep allowed to graze on public lands, as well as consider holistic resource management plan, such as reserve design, which is described in detail in Craig Downer’s Book the Wild Horse Conspiracy. Both options would adequately protect these majestic animals so that they can persist for future generations.
Friends of Animals, an international animal protection organization founded in 1957, advocates for the rights of animals, free-living and domestic around the world. www.friendsofanimals.org
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BLM Nevada News CARSON CITY DISTRICT OFFICE NO. CCDO 2015-11 FOR RELEASE: November 28, 2014
CONTACT: Lisa Ross, 775-885-6107, lross@blm.gov
Draft Resource Management Plan Environmental Impact Statement Available for
BLM Carson City District
Carson City, Nev. – The Bureau of Land Management (BLM) is asking the public to review and comment on a Draft Resource Management Plan (RMP) and Environmental Impact Statement (EIS) for the Carson City District. The draft plan will affect approximately 4.8 million acres of public land. The comment period opened with the publication of a notice of availability in the Federal Register on November 28, 2014. Comments will be accepted during a 120-day period which closes March 27, 2015.
Public meetings to review and comment on the draft EIS will be announced at least 15 days in advance in local newspapers and on the BLM website.
The plan will address: Areas of Critical Environmental Concern, lands and realty, utility corridors, wind energy, travel management, recreation, fish and wildlife, minerals, wild and scenic rivers, public health and safety, and visual resource management.
Public meetings on the Draft RMP/Draft EIS are currently scheduled for 5:00 to 7:00 p.m.; on January 13, at the John Ascuaga’s Nugget (1100 Nugget Ave.) in Sparks, Nev.; on January 15, at the Fallon Convention Center (100 Campus Way) in Fallon, Nev.; on January 20, at the Mineral County Library (First & A Street) in Hawthorne, Nev.; on January 22, at the Carson Valley Inn (1627 US Hwy 395 N) in Minden, Nev.; and on January 29, at the Yerington Elementary School (112 N. California St.) in Yerington, Nev. An additional public meeting will be held from 2:00 to 4:00 p.m., on January 24, at the Carson City Plaza Hotel and Event Center (801 South Carson Street) in Carson City, Nev. Additional public meetings are anticipated in coordination with local County Commissions and Boards of Supervisors.
Written comments related to the Carson City District Draft RMP/Draft EIS may be submitted by any of the following methods:
• Website: http://on.doi.gov/1uYBNGT• E-mail: BLM_NV_CCDO_RMP@blm.gov
• Fax: 775-885-6147
• Mail: BLM Carson City District, Attn: CCD RMP, 5665 Morgan Mill Rd., Carson City, NV 89701.
Copies of the Carson City District Draft RMP/Draft EIS are available in the Carson City District Office at the above address or on the following website: http://on.doi.gov/1uYBNGT
“The state of Wyoming is attacking wild horses, painting them as pests that are destroying the environment while the real culprits act with impunity in their own best interest,” states Mark Boone Junior.
Wild horses are quickly being wiped out in Wyoming. Governor Mead encourages roundups and removals at federal taxpayer expense. Mead seems to be owned by the oil and gas industry so it’s no surprise he’s getting rid of their environmental obstacles.
By: Matt Mead
Date: Aug. 23, 2013
Location: Cheyenne, WY
Governor Matt Mead expressed that he is proud of Wyoming’s record of effective regulation of the oil and gas industry in his comments on the Bureau of Land Management’s proposed rule for hydraulic fracturing. Governor Mead wrote to Secretary of the Interior Sally Jewell to say that the BLM should reject the duplicative regulation and defer to states like Wyoming.
“As a leading energy producer, Wyoming continues to set the standard for development and environmental stewardship,” Governor Mead wrote. He pointed to Wyoming’s first-in-the-nation hydraulic fracturing rules, updated well bore integrity standards, air standards for natural gas production and wells that are hydraulically fractured, and Wyoming’s recently released energy strategy. “Guided by this energy strategy, Wyoming is establishing baseline groundwater sampling, analysis and monitoring regulations.”
Given state leadership is already in place in Wyoming, Governor Mead expressed concern that the new BLM rule would add to existing delays and undercapitalization of federal permitting. Another area of concern is the BLM’s effort to grant variances to allow compliance with state or tribal requirements when those meet or exceed the federal rule or standard. What is troubling is that the ability to acquire variance is given to operators, not states or tribes. “Despite BLM’s contention that states will be afforded opportunity to work with the BLM to craft a variance, the mechanism in the rule only allows operators to pursue a variance,” Governor Mead wrote.
BREAKING NEWS: Call for Wyoming boycott and protests against roundups to frack the land for oil and gas
Native wild horses are facing destruction in the face of climate change with no evidence of overpopulation to justify BLM roundups
Rock Springs, WY. (September 21, 2014)–-The public is outraged more indigenous wild horses are being rounded up and permanently removed from public land for the water and fracking land grab. Protect Mustangs is calling for protests to stand up for American wild horses and for a tourism boycott targeted at Wyoming who promotes “Roam Free” in their marketing yet ignores wild horses in their state. More than 800 Divide Basin, Adobe Town and Salt Wells wild horses are being rounded up from the public-private land known as the “Checkerboard” in southwest Wyoming. The Rock Springs Grazing Association (RSGA) took the Bureau of Land Management (BLM) to court to push the roundup through. Wild horses are terrified by choppers, their families ripped apart, forced into inhumane captivity, be at-risk for going to slaughter and forever lose their freedom to roam and contribute to the ecosystem. Several wild horses have already died brutal deaths in the roundup–some victims were only a few months old.
“Fracking for oil and gas is polluting the environment and wiping out America’s wild horses,” states Anne Novak, executive director of Protect Mustangs. “The BLM must leave at least 150 wild horses in each herd to maintain genetic variability so they can adapt to the effects of climate change. It’s time for clean energy that can coexist with wildlife.”
BLM describes one large fracking project, Continental Divide-Creston, in saying, “The project is located on 1.1 million acres in the checkerboard pattern of mixed land ownership comprised of 59 percent federal, 37 percent private and 4 percent state-owned land. The eastern boundary of the project is approximately 25 miles west of Rawlins, Wyo. with the western boundary approximately 50 miles east of the city of Rock Springs.”
Field reports allege the BLM has inflated the population guesstimates to justify removals requested by the RSGA.
“Native wild horses are a vanishing natural resource,” states Novak. “People need to stand up for what’s right. Innocent foals are dying in this roundup and that’s wrong.”
Protect Mustangs is calling for an immediate moratorium on roundups and removals for scientific population studies and holistic management. Advocates want to see genetically viable herds on public land but the BLM prefers to cater to the extractive industry who wants number so low wild horses will die off.
“Tourists come to Wyoming to observe wild horse families in their native habitat, so why are they going to decimate these herds?” asks Novak. “The tag line at the Wyoming tourism office is ‘Roam Free‘ but they are taking away native wild horses’ freedom forever. The public is angry and wants to boycott Wyoming tourism.”
The Great Divide Basin, Adobe Town and Salt Wells Creek herd management areas (HMAs) total approximately 2,427,220 acres with approximately 1,2427,220 acres in the Checkerboard. The roundup held up in court recently due to the Rock Springs Grazing Association (RSGA) Consent Decree 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 complex in 2013. The RSGA appears to be heavily involved with energy development.
Members of the public are encouraged to watch GASLAND 2, contact their elected officials, peacefully protest the roundup and join America’s growing anti-fracking movement to stop the devastation of native wild horse habitat.
Protect Mustangs is a grassroots conservation nonprofit devoted to protecting native wild horses. Their mission is to educate the public about the indigenous wild horse, protect and research American wild horses on the range and help those who have lost their freedom.
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Media Contacts:
Anne Novak, 415-531-8454, Anne@ProtectMustangs.org
Three actions to take before Congress goes on summer break July 31st.
1.) Call and fax your county commissioners to request they stop supporting the resolution pushed through the national NACO meeting to give the states the ability to manage federally protected wild horses and “dispose” of them . Politely let them know you will hold them accountable if wild horses are killed or slaughtered and the states have a heinous history of “taking care of wild horses.” Explain that livestock is causing range damage because cattle and sheep outnumber wild horses more than 50 to 1. Let them know people in all states across the country enjoy wild horses and as a federally protected animal–they belong to everyone. Request a written response from your county commissioners.
2.) Call and fax your representative to politely insist they stop Chris Stewart’s (R-UT) Wild Horse Oversight Act of 2014, H.R. 5058 from gaining any momentum in the House. Explain to them that the Act is misleading and would allow states to dispose of federally protected wild horses by killing them or selling them to slaughter. Request a written response from your representative.
3.) Call and Fax your 2 senators and representative the Declaration by Llyod Eisenhauer, former BLM manager, who states the pending Wyoming Checkerboard Roundup appears to be in violation of the law. Ask your elected officials to stop the Checkerboard Roundup scheduled to begin August 20th. Request a written response from your elected officials.
Contact us with any questions via email to Contact@ProtectMustangs.org
TAKE ACTION! Call and email your senators and rep ASAP. Demand the American wild horses be returned to the American public! http://www.contactingthecongress.org/
Free Roaming Wyoming Horses Rounded up by BLM and sold to Canadian Slaughterhouse by Wyoming Livestock Board
No public comment period and no transparency
COLORADO SPRINGS, CO. (March 31, 2014) – On March 24, The Cloud Foundation received an anonymous tip that BLM had rounded up and removed 41 free-roaming horses from public lands in northern Wyoming. Further investigation revealed that BLM conducted a helicopter roundup of the horses and turned them over to the Wyoming Livestock Board who sold the horses directly to the Canadian Bouvry Slaughterhouse. The taxpayer-funded roundup was conducted with no notice of sale after the horses were impounded, giving no one the opportunity to step in and negotiate a deal to purchase any of the horses. Even Bighorn County Sheriff, Kenneth Blackburn, was surprised that he received no notification of the roundup, which was conducted in his jurisdiction. The horses were driven to Shelby, Montana, to the Bouvry-owned feedlot, the jumping off point to their Canadian slaughterhouse, the largest slaughterhouse in Canada.
“These were colorful wild horses I spotted several years ago while driving to the Pryor Mountains,” stated Ginger Kathrens Executive Director of the Cloud Foundation. “They lived on what we’ve been told was a wild horse Herd Area southeast of the Pryors.” The small, remnant herd roamed a starkly beautiful landscape east of US 310 between Lovell and Greybull, WY. ‘”We stopped to admire them on March 10th on our way back to Colorado.” Kathrens adds. “The sight of these lovely, free-spirited animals, some with their newborn foals, against the backdrop of the snow-covered Bighorn Mountains was glorious. It’s hard to think about the horror they suffered just days later.”
On March 18, only eight days after Kathrens last spotted the horses, the BLM Field Office in Cody, WY supervised their roundup and removal. A BLM spokesperson told a Cloud Foundation representative that the horses would be held at the Worland Livestock Auction for 10 days and then sold. However, later investigation revealed that the 41 horses rounded up by Cattoor Livestock Company on March 18-19 were delivered to the Worland Livestock Auction for brand inspection. Just a few hours later, once the brand inspection was completed, 37 horses were loaded onto a truck paid for by the Wyoming Department of Agriculture and hauled to the Canadian border.
“According to Wyoming, Statute, Title 11, Chapter 24 entitled Agriculture, Livestock and Other Animals, ‘Estray horses rounded up must be held for not more than 10 days before going to auction,'” reported Paula Todd King, Communications Director for the Cloud Foundation. “These horses were rounded up and within hours they were on their way to the border. We found no notice announcing the roundup.”
The history of these horses is debatable. The BLM contends they are not wild, stating that they once belonged to an area rancher who died and his horses have only been in the area for 40 years. However, the Wild Horse and Burro Act (WHB Act) defines a wild horses as an “unclaimed, unbranded horse on federal lands in the United States.” Wyoming brand inspector, Frank Barrett, verified there were no brands of any kind on any of the animals.
Less than a mile from where Kathrens had been observing the horses is the boundary of the “zeroed out” Foster Gulch/Dry Creek Herd Area, designated for wild horse use after the passage of the WHB Act in 1971. “As they have done over a hundred times, the BLM decided not to manage wild horses in the area in 1987,” explains Kathrens. “If the horses have lived in the area for 40 years as BLM states, it is entirely possible that these horses were descendants of the herd eliminated from management in 1987.”
It is clear that these horses have survived for many years on their own, living in wild family bands, and thriving without human intervention. Conflicting reasons have been given for the timing of this BLM roundup when the horses had newborn foals. BLM indicated that private landowners in the area have complained about horses trespassing on their land. Sarah Beckwith, BLM spokesperson said that the horses were a threat to public safety – vehicles had killed two horses. However, after further investigation, TCF found that a train struck one horse 6-8 years ago, and a private vehicle struck another around 5 years ago. Jack Mononi, Supervisory Rangeland Management Specialist for Cody BLM, told Todd-King that if the Agency did not spend the federal dollars by the end of March, the funds would no longer be available.
Kathrens called the Bouvry Exports Shelby facility in an attempt to negotiate purchase of the 37 horses. The woman who answered the phone would not confirm that the horses had arrived in Shelby and told Kathrens that “these horses were rounded up and removed for slaughter and that is where they are going.” Kathrens offered to pay more than the going price and was told that this was not possible. “I was shaking when I got off the phone,” Kathrens said. “To think that this could be happening sickens me.”
Kim Michels of Red Lodge, MT, purchased all that appears to have survived of the small herd, four tiny foals born this year. “We will do all we can to see that these babies not only survive but thrive as a fitting legacy to their lost freedom and their families,” said Michels. The foals were rescued by Stacey Newby, co-owner of the Worland Livestock Auction, who fed and cared for the foals, bottle-feeding the tiniest, a 3-week-old filly. The foals are now in the care of equine veterinarian, Lisa Jacobson, in Colorado.
TCF continues to investigate the legality of what appears to be a carefully planned and executed operation at taxpayer expense. “Was it legal?” Kathrens questions. “It is clear to me that it was not moral and certainly inhumane. I do not believe that American taxpayers want their money spent to roundup and send horses to slaughter.”
