Protect Mustangs comments against spaying wild mares in Wyoming


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

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

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

January 14, 2016

Dear Public Servants at the BLM:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

PM Checkerboard ROundup Sept 20 2014

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

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

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

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

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

Sincerely,
Anne Novak

.Anne Novak
Executive Director
Protect Mustangs

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

Twitter: https://twitter.com/TheAnneNovak
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www.ProtectMustangs.org
Protect Mustangs is a nonprofit organization who protects and preserves native and wild horses.





Stop experiments, sterilization and risky birth control on America’s wild horses in Wyoming

 

Take Back the Power (© Protect Mustangs with Photo © Cynthia Smalley)

Take Back the Power (© Protect Mustangs with Photo © Cynthia Smalley)

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.

Signed,

 

_________________________________________________

 

Date _________________________





Former BLM manager declares Wyoming roundup appears to be in violation of the law

LEGAL DECLARATION filed by former BLM Rock Springs and Rawlins area manager, Lloyd Eisenhauer:

IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF WYOMING

Rock Springs Grazing Association, Case No. 2:11-cv-00263-NDF Plaintiff, v. Ken Salazar, et al.,Defendants,

DECLARATION OF LLOYD EISENHAUER

I, Lloyd Eisenhauer, declare as follows:

1. I live in Cheyenne, Wyoming. I am a former Bureau of Land Management (“BLM”) official with extensive experience in the Rawlins and Rock Springs Districts in Wyoming and intimate familiarity with the public lands under BLM management in those areas.

I have reviewed the consent decree proposed by BLM and the Rock Springs Grazing Association (“RSGA”) in this case and provide this declaration based on my longstanding knowledge of, and management of, wild horses and livestock grazing in the Rock Springs and Rawlins Districts.

2. I grew up in Pine Bluffs, Wyoming with a livestock and farming background, served in the Marines for four years, and then owned a livestock business from 1952-1958. I enrolled in college in 1958, studying range management. From 1960-1961, BLM hired me to assist with collecting field data for vegetation assessments and carrying capacity surveys related to livestock and wild horses. These surveys were conducted in the Lander, Kemmerer, and Rawlins Districts. When I graduated in 1962, BLM hired me full-time to serve in the Rawlins District in Wyoming, where most of my work focused on grazing management involving sheep, cattle, and wild horses. From 1968-1972, I was Area Manager of the Baggs-Great Divide Resource Area in the Rawlins District. In 1971, the Wild Free-Roaming Horses and Burros Act was enacted, and in the spring of 1972, on behalf of BLM, I conducted the first aerial survey of wild horses in Wyoming, recording the number of horses and designating the Herd Management Areas (“HMAs”) for the Rawlins District. After a stint as an Area Manager with BLM’s Albuquerque, New Mexico office, in 1975 I took over as the Chief of Planning and Environmental Analysis in BLM’s Rock Springs District for three years. I was the lead on all planning and environmental assessments. During that time, I also served as the Acting Area Manager of the Salt Wells Resource Area, which is located in the Rock Springs District. In 1979, BLM transferred me to its Denver Service Center to serve as the Team Leader in creating the agency’s automated process for data collection. I received an excellence of service awardfrom the Secretary of the Interior commending me for my work as a Team Leader. In 1982, I became the Head of Automation in BLM’s Cheyenne office, where I managed and implemented the data collection and processing of various systems related to BLM programs. I retired from BLM in 1986, and have stayed very involved in the issue of wild horse and livestock management on BLM lands in Wyoming, and have written articles about the issue in local and other newspaper outlets. I have won various journalistic awards, including a Presidential award, for my coverage of conservation districts in Wyoming. Along with a partner, I operated a tour business (called Backcountry Tours) for six years, taking various groups into wild places in Wyoming – without a doubt wild horses were the most popular thing to see on a tour, in large part due to their cultural and historical value. I also served six years on the governor’s non-point source water quality task force.

3. Based on my longstanding knowledge of wild horse and livestock management in the Rawlins and Rock Springs Districts, and in the Wyoming Checkerboard in particular, I am very concerned about BLM’s agreement with RSGA, embodied in the proposed Consent Decree they have filed in this case, under which BLM would remove all wild horses located on RSGA’s private lands on the Wyoming Checkerboard. The Checkerboard is governed by an exchange of use agreement between the federal government and private parties such as RSGA. However, due to state laws, property lines, and intermingled lands, it is impossible to fence the lands of the Wyoming Checkerboard, which means that both the wild horses and the livestock that graze there roam freely between public and private lands on the Checkerboard without any physical barriers. For this reason, it is illogical for BLM to commit to removing wild horses that are on the “private” lands RSGA owns or leases because those same horses are likely to be on public BLM lands (for example, the Salt Wells, Adobe Town, Great Divide, and White Mountains HMAs) earlier in that same day or later that same evening. Essentially, in contrast to other areas of the country where wild horses still exist, on the Wyoming Checkerborad there is no way to distinguish between horses on “private” lands and those on public lands, and therefore it would be unprecedented, and indeed impossible for BLM to contend that it is removing all horses on RSGA’s “private” lands at any given time of the year, month, or day, considering that those horses would only be on the strictly “private” lands very temporarily and intermittently on any particular day .

5. Another major concern with BLM’s agreement to remove all horses from the private lands of the Wyoming Checkerboard is that BLM is undermining the laws that apply to the Checkerboard, and wild horse management in general, which I implemented during my time as a BLM official. Traditionally, BLM officials (myself included) have understood that, pursuant to the Wild Horse Act, wild horses have a right to use BLM lands, so long as their population numbers do not cause unacceptable damage to vegetation or other resources. In stark contrast, however, livestock (sheep and cattle) have no similar right to use BLM lands; rather, livestock owners may be granted the privilege of using BLM lands for livestock grazing pursuant to a grazing permit that is granted by BLM under the Taylor Grazing Act, but that privilege can be revoked, modified, or amended by BLM for various reasons, including for damage to vegetation or other resources caused by livestock, or due to sparse forage available to sustain livestock after wild horses are accounted for. BLM’s tentative agreement here does the opposite and instead prioritizes livestock over wild horses, by proposing to remove hundreds of wild horses from the Wyoming Checkerboard without reducing livestock numbers – which, in my view, is contrary to the laws governing BLM’s actions as those mandates were explained to me and administered during the decades that I was a BLM official.

6. While I do not agree with every management action taken by BLM over the years in the Rock Springs District, I can attest – based on my longstanding employment with BLM and my active monitoring of the agency’s activities during retirement – that BLM has generally proven capable of removing wild horses in the Rock Springs District, including by responding to emergency situations when needed and removing horses when necessary due to resource damage.

7. Considering that wild horses exhibit different foraging patterns and movement patterns than sheep and cattle, and also than big game such as antelope and elk, no sound biological basis exists for permanently removing wild horses from the Wyoming Checkerboard at this time. In particular, wild horses tend to hang out in the uplands at a greater distance from water sources until they come to briefly drink water every day or two, whereas livestock congregate near water sources and riparian habitat causing concentrated damage to vegetation and soil. For this reason, the impacts of wild horses are far less noticeable on the Checkerboard than impacts from livestock.

8. In addition, because livestock tend to eat somewhat different forage than wild horses (horses tend to eat coarser vegetation such as Canadian wild rye and other bunch grasses, whereas cattle and sheep mostly eat softer grasses), there is no justification to remove wild horses on the basis that insufficient forage exists to support the current population of wild horses.

Also, because cattle and sheep have no front teeth on the front part of their upper jaws, they tend to pull and tear grasses or other forage out by the root causing some long-term damage to vegetation, whereas wild horses, which have front teeth on both their front upper and lower jaws, act more like a lawnmower and just clip the grass or forage (leaving the root uninjured), allowing the vegetation to quickly grow back. These differences are extremely significant because if there were a need to reduce the use of these BLM lands by animals to preserve these public lands, it might be cattle and sheep – not wild horses – that should be reduced to gain the most benefit for the lands, and which is why BLM, during my time as an agency official, focused on reducing livestock grazing.

9. BLM’s agreement with RSGA states that RSGA’s conservation plan limited livestock grazing, primarily by sheep, to the winter months to provide sufficient winter forage.This is a good example of “multiple use” management, since wild horses and sheep have very little competition for the forage they consume and the seasons during which they use parts of the Checkerboard. During winter, sheep use the high deserts and horses utilize the uplands and breaks (i.e., different locations) for forage and protection. During the summer, when sheep are not present, wild horses use various landscapes on the Checkerboard. This multiple use should continue for the benefit of the livestock, the wild horses, and the public and private lands involved.

10. I am also very concerned about BLM’s agreement with RSGA to permanently zero out the Salt Wells HMA and the Divide Basin HMA, leaving no wild horses in those areas that have long contained wild horses. I have been to fifteen of the sixteen HMAs in Wyoming, and to my knowledge none has ever been zeroed out by BLM. It is my view, based on everything I know about these areas and the way these public lands are used by wild horses and livestock, that BLM has no biological or ecological basis for zeroing out a herd of wild horses in an HMA that existed at the time the wild horse statute was passed in 1971, as is the case with both the Salt Wells and Divide Basin HMAs. And, again, because the wild horses have a statutory right to be there, whereas livestock only have a privilege that can be revoked at any time by BLM, there also is no authority or precedent, to my knowledge, for the agency to zero out these two longstanding wild horse herds simply to appease private livestock grazers.

11. The zeroing out of wild horses in the Salt Wells and Divide Basin HMAs is also concerning because it would mean that, in those two longstanding HMAs, there would no longer be the “multiple use” of these public lands as required by both the Wild Horse Act and the Federal Land Policy and Management Act. Currently, while there are other uses of this public land, such as by wildlife, hunters, and recreational users, the two primary uses in those HMAs are by wild horses and livestock. If BLM proceeds with its agreement with RSGA to zero out wild horses in those HMAs, the only major use remaining would be livestock use, meaning that there would be no multiple use of those BLM lands. Not only will that potentially undermine the laws that BLM officials must implement here, but it has practical adverse effects on the resources – multiple use is very beneficial for the environment, and particularly for sensitive vegetation, because different users (e.g., livestock, wild horses) use the lands and vegetation in different ways. When that is eliminated, the resources are subjected to an unnatural use of the lands which can cause severe long-term damage to the vegetation. As a result, zeroing out these herds would likely be devastating for the vegetation in these two HMAs, because livestock would be by far the predominant use in this area.

12. Turning the White Mountain HMA into a non-reproducing herd, as the agreement between BLM and RSGA proposes to do, is also a farce, and violates the meaning of a wild and free-roaming animal. This is essentially a slow-motion zeroing out of this HMA, and is inconsistent with any wild horse management approach I am familiar with that BLM has implemented on public lands.

Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is trueand correct.

Lloyd Eisenhauer