Is the Concocted Wild Horse Crisis based on Fraud?

 

Photo by BLM in public domain

Read Marybeth Devlin’s opposition to the proposed Antelope and Triple B Roundup

Via email: blm_nv_eldowellshorsegathers@blm.gov

August 21, 2017

BLM Elko District Office
3900 Idaho Street
Elko, NV 89801

Attn: Marc Jackson, Wells Field Manager

 

Project: Antelope / Triple B Complexes

Document: Environmental Assessment ( EA )

Action: 2017 Gather Plan EA — Comments to

NEPA ID: DOI-BLM-NV-E030-2017-0010-EA

 

This letter responds to your request for substantive comments and informed analysis that BLM Elko and Ely District Offices should consider regarding the subject EA. I submit my remarks as an interested party in behalf of the wild horses of the Antelope and Triple B Complexes. BLM alleges that the herds’ respective populations exceed the arbitrary management levels (AMLs).

For ease of reference, here are the respective links to the Project Summary Webpage, where the EA and other documents are posted, and to the map of Nevada’s HMAs.

https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=renderDefaultPlanOrProjectSite&projectId=84367&dctmId=0b0003e880df2fff

Please note that, in my comments, where text has been emphasized, either through bold and/or italics, the emphasis was added by me. Also, “page-number” means “screen-page” in the EA’s online version.

 

BACKGROUND

 

The Alternatives

BLM proffers four options in the EA, with Alternative A identified as BLM’s proposed action. Although not assigned a letter, the “No Action” Alternative is listed first in the EA, and it is the correct choice.

Alternative A — Cull to low-AML; PZP or GonaCon to mares; skew genders; geld 50% of studs.
Alternative B — Cull to low-AML; PZP or GonaCon to mares; skew genders.
Alternative C — Cull to low-AML.

For both Alternatives A, B, and C, the cull would drastically reduce the component herds per falsely-estimated population-levels. Page 18 of the EA states that 6,737 wild horses would be removed immediately, with the rest of the “excess” to be culled over a period of up to 10 years.

As if the cull were not bad enough, BLM would inject all released mares with pesticides — identified as either PZP-22 or GonaCon™ or “newly developed formulations.” The genders would be skewed 60:40 to favor stallions, but 50% of stallions would be gelded.

A careful review of the facts shows that the right option is the No Action Alternative. All proposed actions are contraindicated because fraud was the basis for the finding of “overpopulation.” BLM must not be rewarded for unethical, criminal behavior.

 

Wild Horses Roam — Their Presence Is Fleeting, Their Numbers Are Fluid

Just because a survey supposedly counts a particular number of wild horses in one of the Complexes on a certain day does not mean the same number are still there. Those horses may have been merely passing through per their normal free-roaming nature. They may have left the area the day after the census was conducted. Wild horses are constantly on the move. Roaming is “how they roll.” Visitor-horses are not permanent residents, but they likely get counted as such — and counted multiple times — in a census that does not take horse-movement into consideration. I refer you to my comments regarding the survey-method are why it is unsuitable for taking inventory of wild horses.

 

Not Reproduction, but Migration

BLM assumes that the Complex herds allegedly exceed the AMLs due to reproduction, and that, therefore, culling, sterilizing, and gelding must be conducted in order to save the “thriving natural ecological balance” from imminent destruction. But the EA fails to consider migration to and from nearby HMAs — such as Diamond, Diamond Hills North, Diamond Hills South, Fish Creek, Pancake, and Whistler Mountain.

 

Over-AML ≠ Over-Populated

BLM announces its intent to reduce the Complexes wild-horse herds because their numbers are — allegedly — over AML — that is, over the arbitrary management level (AML) for each herd. However, as is discussed elsewhere in my letter, the AMLs are invalid because they do not meet the minimum-viable population (MVP) as determined by the International Union for the Conservation of Nature for wild equids.

 

PRINCIPAL USE WITHIN MULTIPLE-USE APPROACH

 

Wild-Horse Habitat Must Be Managed Principally for Wild Horses

HAs and HMAs are wild-horse habitat-zones. Wild horses must enjoy principal use of their range. This requirement is stated plainly in the Wild and Free-Roaming Horses and Burros Act, which stipulates that their land is to be “devoted principally but not necessarily exclusively to their welfare ….” Thus, HAs and HMAs do not necessarily have to be managed exclusively for wild horses. However, HAs and HMAs must be managed principally for the welfare of our Federal horses.

On pages 32 and 34 of the EA, BLM disingenuously conflates “principal use” with “single use,” and claims to quote from a Senate Conference Report that single use was not intended. Who said it was? We are talking about principal use, not single use. Indeed, the WFRHBA was forward-looking for its time, anticipating the multiple-use concept while providing for principal use for wild-horses in their habitats.

Moreover, multiple-use does not mean every-conceivable-use. Incompatible uses should be excluded. Some examples of incompatible uses appear obvious — mining and off-road vehicles. HMAs should be designated “no surface occupancy” (NSO) areas — to preserve aesthetic and recreational values and to avoid disturbing the horses’ natural behavior. HMAs should also be declared “off-limits” to off-highway-vehicles (OHVs) — to protect the peace-and-quiet of the range and the cleanliness of the ambient air.

The Complexes are not being managed according to the Law because the wild horses are not allotted principal use of their habitat. The wild horses have been displaced by encroaching livestock.

This inversion must be righted, and BLM must employ the right mechanisms to do so. First, BLM needs to rescind this EA. Then, it must amend the Land-Use Plans (LUPs), Resource Management Plans (RMPs), Final Multiple-Use Decisions (FMUDs), and Herd Management Area Plans (HMAPs) to conform with the Law regarding principal use.

 

Disproportionate Allocation of Forage — Must Be Corrected

Of the 129,370 animal unit months (AUMs) — grazing slots — available in the Antelope Complex …

124,246 — AUMs — 96% — have been allotted to livestock

5,124 — AUMs — 4% — have been allotted to wild horses

Of the 93,070 animal unit months (AUMs) — grazing slots — available in the Triple B Complex …

87,406 — AUMs — 94% — have been allotted to livestock

5,664 — AUMs — 6% — have been allotted to wild horses

Question: What is wrong with that allocation? Answer: The allocation is inverted. By Law, wild horses must receive the majority of the grazing slots — the AUMs — within their HMAs in accordance with the legal requirement that they have principal use of their dedicated habitat.

 

Wild-Horses — Sparsely Populated, Widely Dispersed

The low-AML — 427 — restricts the wild-horse population-density in the 1,324,745 acres that constitute the Antelope Complex to …

1 wild horse per 3,102 acres — or about — 1 wild horse per 5 square miles.

The low-AML — 472 — restricts the wild-horse population-density in the 1,682,998 acres that constitute Triple B Complex to …

1 wild horse per 3,566 acres — or about — 1 wild horse per 5½ square miles.

Imagine if livestock were held to the same stocking-density. The sparse and widely-dispersed population imposed by the AML evidences bias. It also evidences violation of the Wild Free-Roaming Horses and Burros Act.

To grasp the enormity of the unfairness, we can see that, by converting the livestock AUMs to wild-horse equivalents, BLM allows …

Antelope Complex:

1 cow+calf pair per 128 acres — or about — 5 cow+calf pairs per 1 square mile

Triple B Complex:

1 cow+calf pair per 231 acres — or about — 3 cow+calf pairs per 1 square mile

 

Authorized v. Actual Livestock Use

BLM argues that actual livestock use is much lower than authorized or permitted use. Pages 58 through 62 feature charts that show the alleged 10-year average AUM uses by livestock in each Complex. It is curious that instead of providing recent use-figures that BLM went to the trouble of computing a 10-year average for each of the many allotments involved. What were you trying to hide?

BLM’s AUM-use charts for livestock showed 32.7% for the Antelope Complex and 46.7% for Triple B Complex. Lets assume for sake of argument that those figures are true. Then, obviously, the permittees don’t need all those authorized AUMs, and it is entirely appropriate to reassign them to whom they belong: wild horses.

But there’s more to this “use” issue. “Actual use” really means “billed use” — how many AUMs BLM billed permittees for having used. But because actual use is whatever the permit-holders self-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 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 “Actual 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.”

https://www.blm.gov/sites/blm.gov/files/uploads/Services_National-Operations-Center_Eforms_Rangeland-Resources_4130-005.pdf

http://www.gpo.gov/fdsys/pkg/FR-2014-08-22/html/2014-20049.htm

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 AUM-usage reported on Form 4130-5 is suspect.

 

Voluntary Non-Use of AUMs Reflects Price-Declines for Beef

BLM and its permit-holders protest that a lot of the livestock AUMs are in voluntary non-use. They complain loudly, blaming the seeming excess of wild horses — an illusion caused by BLM’s phony figures — for reducing their AUM-usage.

However, if permittees are not using 100% of their AUMs, it is likely because the market for their product is weak. Here is an excerpt from the most recent Cattle Report issued by Ag Center:

Cattle Futures. Price declines continued in the cattle futures market. Early week sales of cattle at lower prices discouraged any long buyers from entering the market. August, expected by some to rise to last week’s cash price, instead rolled over and continues to lead the cash market down.

http://www.agcenter.com/newcattlereport.aspx

 

Beef-Cattle Now Weigh More, So Fewer Needed — The AUM Needs to Be Reformed

In an August 2015 article titled “Cattle Weights Continue to Increase at Impressive Rates,” AgWatch Network reported:

The federally inspected steer dressed weight for the week of 8/15/15 was 900 pounds, according to USDA. This was 25 pounds heavier than a year ago, and well on track to set a new record in 2015 above the 906 pounds seen in October of 2014.

Looking back at steer dressed weights, on an annual average basis, weights increased by 0.5% per year since 1960 (they were 656 pounds in 1960). Using that percentage increase (0.5%) works through 2013, but does not capture the increased growth rate seen in 2014 and what is estimated for 2015. Looking back, 2014 experienced a 1% growth in steer dressed weights year-over-year, and 2015 is on track to be 2% higher than 2014’s.

The article goes on to predict that, because of the increase in cattle-weight, a decrease in cattle-numbers will likely ensue. It states: ” … if these weights continue to increase at a faster pace, the industry may not restock back to the previous inventory peak levels.”

The AUM was originally predicated on 1,000 pounds of live weight. However, the above article discusses the dressed weight — which is dead weight, excluding certain parts. Per Wikipedia …

Dressed weight (also known as dead weight or carcass weight) refers to the weight of an animal after being partially butchered, removing all the internal organs and oftentimes the head as well as inedible (or less desirable) portions of the tail and legs.

The new and increasing average dead weight is fast-approaching what used to be the average live weight.

The AUM for a wild horse presumes a mustang is the equivalent of a 1,000-pound saddle horse. But mustangs tend to be smaller and lighter, weighing 700 to 900 pounds. Moreover, in contrast to cattle, wild horses are “easy-keepers” that thrive on poor-quality forage.

BLM needs to revisit and reform how it assesses forage-usage for cattle versus wild horses. Cattle need an AUM surcharge; wild horses need an AUM discount that reflects less-than-one AUM per horse, giving BLM the flexibility to place more wild horses on the range.

 

Sheep Production Continues Long Decline in the US

Not just cattle but sheep and even goats (as well as some domesticated horses) graze in the Complexes allotments. On pages 60 and 62 of the EA, BLM blames drought and “competition” with wild horses for forage causing a drop in actual-use livestock AUMs, which also include sheep. But BLM’s representation is not in accordance with the facts. Sheep-production has been in decline across the United States for decades, with herd-levels down 90% from their peak in the 1940s. [See article by Runyon in Harvest Public Media] The decline is reportedly due to a combination of factors not caused by wild horses.

Changing consumer-demand
Availability of synthetic fabrics
Competition from foreign imports
Competition from beef, chicken, pork
Scarce feed supplies for fattening
Harsh weather and drought
Price-volatility

 

Facilitation and Commensalism — Equids Enhance the Ecosystem

Some species thought to compete actually facilitate one another’s well-being. They interact positively and reduce physical stress. For instance, commensals are animals that eat “at the same table” but without competing.

BLM sees “competition” where there is really commensalism. For instance, in the EA, BLM implied that having fewer wild horses would reduce competition over not just forage but over water too. BLM alleges that wild horses drive off other creatures from watering holes. While that may happen, any such displacement lasts just minutes. Wild horses drink and leave. There is no ongoing blockade. Wild horses also expand water seeps, which is another benefit they provide.

Moreover, wild horses actually create little water-catchments. Sue McDonnell, PhD, a certified applied animal behaviorist and the founding head of the equine behavior program at the University of Pennsylvania’s School of Veterinary Medicine, explains how:

“A very interesting phenomenon in horses is the “creation” of dust bowls at the rolling sites. Repeated rolling in the same spot serves to eliminate the vegetation and erodes the surface, forming a shallow bowl. With time the bowl has a very compacted base lined with fine powdery soil. The bowl also becomes “oiled” with body residues. The drier and hotter it gets in summer, the more rolling occurs, and the deeper and more compact and oiled the bowl becomes. When it rains, these dust bowls gather water and become temporary watering sites.”

Thus, wild horses contribute to, rather than compete for, the availability of water. They enhance the ecosystem.

 

Rangeland Health Monitored Using Method Considered Less Accurate

Per the EA, rangeland disturbance response groups (DRGs) were evaluated per the Key Forage Plant (KFP) Method. However, KFP is obsolete, having been replaced by a new method — Landscape Appearance (LA) Method in 1996. Both the KFP and LA methods are qualitative assessments known as “ocular estimates.” In other words, you “eyeball” the area to judge its appearance; hence “ocular.”

Technical Reference (TR) 1734-7, Ecological Site Inventory, notes that such ocular estimates — qualitative assessments — “may result in reduced accuracy, limiting use of the data.” It is apparent that BLM chose an easy method that could be manipulated to blame the wild horses for any and every range condition not meeting standard, even though a century of overgrazing by livestock was the real culprit.

 

Rangeland Health Monitoring Proceeded As If Only Wild Horses Impacted the Range

BLM did not evaluate the impacts of the many other species present in the Complexes — species many times more numerous and others that are known to consume a greater percentage of rangeland forage. Instead, BLM proceeded as if only livestock and/or wild horses used the rangeland’s resources, listing them as “primary” users. However, wild horses were the scapegoats. The rangeland monitoring was merely a “hatchet job” — a maliciously destructive critique — on the wild horses in order to make it seem as though culling, contracepting, and gelding the herd were justified when, in reality, such actions are contraindicated.

 

Lagomorphs

Although BLM alleges “competition” between mustangs and livestock over forage, one of the dominant herbivores on the range are lagomorphs — jackrabbits, hares, and cottontails. According to Appendix VII “Species List” to the EA, all-three species are found in the project area. However, BLM has neither determined nor factored in their impact on the range.

A recent study in Utah found that jackrabbits were consuming 34% of the forage on local grazing-allotments. Evidently, the creatures reproducing like rabbits were rabbits. Ranchers immediately called for an end to shooting coyotes, which prey on rabbits.

http://www.sltrib.com/news/2080640-155/usu-study-jackrabbits-are-a-bigger?fullpage=1

http://www.hcn.org/articles/bison-cows-rabbits-utah-ranching-henry-mountains

Instead of scapegoating wild horses for forage likely eaten by a different species, BLM needs to conduct a Ecological Site Inventory to determine actual use — including trespass use. The Inventory must pro-rate actual use by each animal-species present, including rodents and insects, and even including creatures such as lagomorphs.

 

Locusts

In normal times, locusts — grasshoppers and crickets — consume 20-to-25% of the forage in areas where they are present. However, in times of outbreaks, they can eat nearly all of the green biomass.

Grasshoppers thrive on the warming Wyoming range

Below is the link to the most recent USDA map, showing areas where there is grasshopper-and-cricket infestation. Nevada — including parts of the Complexes — appears to have been affected. As the map reflects, the creatures devouring the forage like locusts probably are locusts.

http://www.sidney.ars.usda.gov/grasshopper/Extras/2016GHwMC.htm

An Ecological Site Inventory would reveal the extent of forage-consumption by insects — such as locusts — in the project area. Again, you may be surprised to learn who is eating what and how much.

I note the omission of insects from Appendix VII’s Species List.

 

BIRTH RATE AND GROWTH RATE ARE DIFFERENT

 

Birth Rate ≠ Growth Rate

Before we examine BLM’s reported herd-growth rates for these HMAs, it is important to understand the difference between the birth rate and the herd-growth rate. The birth-rate is not the same as — and should not be equated to — the population growth-rate. The birth rate will necessarily be higher than the herd-growth rate. Here’s why: Horses die.

 

Foal Mortality Rate = 50%

An independent study (Gregg, LeBlanc, and Johnston, 2014) reviewed BLM roundup-records of four representative herd management areas with a robust sample-size of 5,859 wild horses. While the researchers found an overall birth rate of just under 20 percent, they also found that half of foals perish before their first birthday. Thus, the 20% foaling rate is merely a temporary “blip” in the data. The effective foal-to-yearling survival rate is just 10%. By failing to adjust the population-estimates per expected foal mortality, BLM inflates the figures.

 

Other-than-Foal Mortality Rate = At Least 5%

Even when fed, watered, vaccinated, wormed, and protected, horses still die. BLM advises that about 5% of wild horses in short-term holding — and 8% of those in long-term holding — perish on a yearly basis. Adult horses in the wild also succumb to illness, injury, or predation. So, it is a reasonable and conservative estimate that at least 5% of wild horses other-than-foals perish annually out on the range. The actual number is probably much higher. By failing to factor in adult-wild-horse mortality, BLM further exaggerates the population-estimates.

 

Stochastic Events — Also Reduce Herd Growth

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

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

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

Imagine if such a catastrophe were to befall the subject herds. Note that the Saiga deaths involved antelope-mothers and their calves. What if these HMAs’ mares and their foals perished all of a sudden, leaving mainly stallions, geldings, and sterile elderly mares? BLM must proactively manage the herds per IUCN guidelines, if only in case of stochastic events.

 

Normative Annual Herd-Growth = At Most, 5%

The surviving-foal rate (10%) minus the adult-mortality rate (5%) equals a normal herd-growth rate of 5%. If BLM wanted a handy — and valid — way of estimating herd-growth, using 5% per year would work. Please note: At that rate, it would take 14 years for a herd to double.

 

Maximum AML Set Below Minimum Viable Population

Approximately 83 percent of wild-horse herds are “managed” below MVP, including the subject Complexes of HMAs. What is the correct MVP for wild horses? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the acreage composing each HMA in the Complexes. However, the high-AMLs — even the combined Complexes’ high-AMLs — are set below MVP.

 

FRAUDULENT POPULATION DATA

 

Lies, More LIes, and Statistics

BLM has posted herd-growth rates that far exceed the normative rate of 5%. Here are charts showing the excessive growth rates, which are not credible. They appear to be falsified birth rates used as growth rates. Mortality was evidently ignored.

 

Antelope Complex Herds

Name of HMA: Antelope

Year Population Percent Compared to
Change 5% Norm

2013  344
2014  413  20%  4 times the norm
2015  669  62%  12 times the norm
2016  861  29%  6 times the norm
2017  1,271  48%  9 times the norm per official stats
2017ea 1,033  20%  4 times the norm per the EA
2017a  1,239  20%  4 times the norm against the EA figure

 

Name of HMA: Antelope Valley

Year Population Percent Compared to
Change 5% Norm

2013  662
2014  792  20%  4 times the norm
2015  1,013  28%  5 times the norm
2016  1,100  9%  2 times the norm
2017  1,320  20%  4 times the norm
2017a  1,584  20%  4 times the norm
2017b  1,488   96 removed in May

 

Name of HMA: Goshute

Year Population Percent Compared to
Change 5% Norm

2013  198
2014  523  164%  33 times the norm
2015  668  28%  5 times the norm
2016  904  35%  7 times the norm
2017  1,015  12%  2 times the norm
2017a  1,218  20%  4 times the norm

 

Name of HMA: Spruce-Pequop

Year Population Percent Compared to
Change 5% Norm

2013  380
2014  493  30%  6 times the norm
2015  789  60%  12 times the norm
2016  1,021  29%  6 times the norm
2017  1,170  15%  3 times the norm
2017a  1,404  20%  4 times the norm

 

Triple B Complex Herds

Name of HMA: Maverick-Medicine

Year Population Percent Compared to
Change 5% Norm

2013  586
2014  763  30%  6 times the norm
2015  910  19%  4 times the norm
2016  1,155  27%  5 times the norm
2017  1,309  13%  2 times the norm
2017a  1,571  20%  4 times the norm

 

Name of HMA: Triple B

Year Population Percent Compared to
Change 5% Norm

2013  498
2014  1,107  122% 24 times the norm
2015  1,460  32% 6 times the norm
2016  1,600  10% 2 times the norm
2017  1,702  6% 1 times the norm per official stats
2017ea  1,770  11% 2 times the norm per the EA
2017a  2,124  20% 4 times the norm against the EA figure

BLM’s population-growth figures are deemed invalid. Even if the “data” represented only the birth rates, they would, in many instances be higher than the normal birth rate.

Multiple over-counts, along with normal roaming behavior, migratory flux among HMAs, and erroneous assumptions, are likely factors to blame. Nevertheless, BLM knows the numbers have to be false. Therefore, by posting false and misleading information, and by proposing to manage per that false and misleading information, BLM is perpetuating a fraud.

In light of these fictitious figures, the No Action Alternative — is and must be the correct choice.

 

Unethical Manipulation

BLM staffers cannot claim ignorance. You are college-educated professionals with degrees in science and range management. You are well-aware that wild-horse herds cannot increase at exponential rates. Yet, you willfully continue to cite them, thereby inciting local ranchers and their elected officials. Worse yet, BLM proposes to conduct drastic culls based on those fraudulent figures.

 

Is There a Mandate to Practice Scientific Integrity?

Yes. The Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states:

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy.

 

Fraud Is a Crime

BLM’s wild-horse population figures are without merit. They are false and misleading. Making false and misleading representations = fraud, which violates Title 18 USC 1001 of the Federal criminal code.

 

Fraudulent Data Emboldens Scofflaws, Costs Wild Horses Their Freedom

In many allotments throughout the West, permit-holders have refused to recognize BLM’s rules regarding season-of-use. Conditions are egregious in Nevada, where the notorious Cliven Bundy and sons, and permittees Kevin Borba and Dan Filippini, blatantly defied BLM’s authority. Yet, they were pacified with non-enforcement and concessions. BLM enables and rewards such bad behavior by caving in to it. Meanwhile, poor LaVoy Finnicum lost his life because, per precedent BLM stand-downs, he concluded that BLM and FBI would not enforce the law.

BLM Leadership Coddles Hostile and Law Breaking Nevada Ranchers like Cliven Bundy

There are likely other permittees in Nevada emulating Bundy, Borba, and Filippini. Wild horses must not lose their freedom merely so that BLM can placate greedy and rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that elected officials and ranchers are building due to the false appearance created by fictitious herd-growth figures.

No doubt, the local cattlemen are up in arms over BLM’s seeming tolerance for what has been portrayed — via fraudulent figures — as a huge overpopulation. BLM is, in part, to blame for inciting the the permittees with false and misleading information. However, the ranchers are also, in part, to blame. Certainly, being professional stockmen, they knows full well that horses are slow to reproduce. But they apparently go along with the farce because it advances their self-interest.

 

Societal Impact of Inflated Population-Data

The population-figures for the subject HMAs are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly state and local elected officials and permittees — in an uproar over a false “overpopulation” that BLM’s faulty figures portray. BLM needs to correct these errors and, more importantly, acknowledge them to the public. You must stop this phony-story-gone-viral of a wild-horse population-explosion.

 

HELICOPTERS — INAPPROPRIATE FOR COUNTING WILD HORSES

 

But the Inventory Counted That Many Horses

When a count produces results that disagree with the known reproductive limitations of a species, the count must be deemed invalid. We know mares have a long gestation, and that they produce one foal per year. The normal annual herd-growth rate is 5% — not 122% or 164% — which are among the rates that your official data reported for herds in the Complexes. A 20% growth rate would be 4 times the norm.

 

Helicopter Inventories Produce Gross Over-Counts

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

I note that the EA also mentioned that assumptions had been used, but contended that an under-count was likely. That assumption is incorrect and opposite to the facts. When more horses are “seen” than could possibly exist, the method is faulty and likely fraudulent. Finally, I note the absence of photographs taken from a Go-Pro camera mounted on the aircraft.

 

Both the Roundup-Contractor and BLM Are Looking to “Make Their Numbers”

A glance at the map of the HMAs in question reveals that they are contiguous, and public lands are interspersed with private lands. How easy it would be for a profit-motivated helicopter-pilot to “poach” wild horses from strictly public lands by driving them into target-areas. What would stop the helicopter-pilot from capturing wild horses that never set hoof outside outside their rightful HMA?

The helicopter-pilot is looking to “make his numbers” but so is BLM. Thus, BLM has a conflict of interest in needing the contractor to remove any 6,737 horses that he can find. The wild horses are fungible — one is as good as another — to make the pilot his money and to enable BLM to spend the budget. Consequently, wild horses would lose their freedom for the private profit of the helicopter-contractor and for the administrative, job-justifying convenience of BLM. Unacceptable.

 

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. However, removing horses that have wandered outside their HMAs just creates a vacuum for other horses to fill. Thus, removing them is an ineffective population-control strategy. The elimination of mustangs from an open, accessible habitat results in repeated colonization by more mustangs. The process begins almost immediately, as horses roam into the area and see that it is attractive and vacant. Thus, removal is not a true solution — it just perpetuates the situation and leads to the elimination of more mustangs than necessary. Moreover, the wanderers may be only temporary visitors or refugees, not permanent residents. Worse yet, they may have been driven into the checkerboard by the helicopter.

Recommendations: In legitimate instances of straying, BLM should first encourage the wild horses to return to their proper place, then address those factors that caused the animals to leave home. Would palatable plantings draw the wild horses to the areas BLM wants them to use? What about siting mineral licks deep inside the HMAs, away from the outskirts? Have guzzlers been installed to provide water sources deep within the boundaries? Aversive conditioning could also be employed to shoo the wild horses into the solid-block public lands. Certainly, positive reinforcement coupled with aversive conditioning would be an effective and cost-effective solution. BLM should specify preventive and reactive measures in this regard as part of its management approach. Return outsiders to the HMAs, reward that return (hay, mineral-licks, guzzlers), and encourage their “retreat” from “outside” areas (aversive techniques).

 

HELICOPTERS — DANGEROUS TO HUMANS, HORSES,
AND THE ENVIRONMENT

 

The risks to humans, horses, and the environment posed by the use of helicopters to count and capture wild horses were fully discussed in comments I submitted to BLM-Nevada on Tuesday, June 27, 2017, when the Motorized Equipment Statewide Hearing was held. Therefore, I will not repeat them here but am linking them to these comments by reference.

 

POPULATION-CONTROL BY NATURE

 

Predators Prey on Ponies

Nature provides its own population-control for wild horses — by means of large predators. There can be no “thriving natural ecological balance” without apex predators. Mountain lions, bears, wolves, and coyotes effectively control wild-horse populations. Predators promote survival of the fittest, as Nature intends. Therefore, the best approach is for BLM to concentrate on conserving native predators to permit natural control of the wild-horse population on the range.

 

Mountain Lions Are Especially-Effective Population-Control Agents for Wild Horses

Many studies have established that mountain lions prey on wild horses more frequently than previously believed. Canadian biologists found that cougars tended to kill younger animals, especially when preying on feral horses. Nearly all of the cougars’ predation-events (86%) involved animals less than 2 years old.

http://sci-northern.ab.ca/wp-content/uploads/2010/12/CougarKillRateandPreyComposition.pdf

In an interview with the Billings Gazette, the above study’s lead researcher, Kyle Knopf, described observing a cougar that brought down a feral horse in less than 30 yards from where it attacked.

http://billingsgazette.com/lifestyles/recreation/article_d9cf046b-2c47-539f-a267-972e72e570b6.html

Other research confirms that mountain lions are quite capable, all by themselves, of keeping wild horse populations in check.

The Montgomery Pass Wild Horse Territory, on the California/Nevada border, has had its ppopulation managed by cougars alone. An eleven-year study by Turner and Morrison (2001) concluded that the growth of this herd was limited by cougar predation. In fact, the population actually decreased over the course of the research.

http://www.jstor.org/discover/10.2307/3672527?uid=2129&uid=2&uid=70&uid=4&sid=21101018535373

The Nevada Wild Horse Range (current designation) averaged negative population growth due to cougar predation from 1989 to 1998 (Greger and Romney, 1999).

https://www.sciencebase.gov/catalog/item/5053f9e6e4b097cd4fcf8fd3

Per The Cloud Foundation, the Pryor Mountain herd averaged no population growth over a four-year period due to predation by mountain lions. Only when those lions were killed — so that BLM could continue practicing management of the herd with PZP — did the wild-horse population begin to grow.

 

Healthy Predators, Healthy Ecosystems

Minimum feasible management means letting natural selection do its job. Mountain lions, wolves, bears, and coyotes should be allowed to carry out their role of population-control agents. Predators will cull the weak, and a thriving natural ecological balance will ensue. Conservation Researcher Dr. Corey Bradshaw emphasizes “… just how important predators are for healthy ecosystems. Long story short – if your predators are not doing well, chances are the rest of the ecosystem is performing poorly.”

Due to pressure from livestock and hunting interests that mistakenly view predators as pests, it has been the Federal government’s practice to exterminate native predators outright or to allow them to be hunted on a massive scale. That policy is wrong. Predators function to keep the ecosystem in balance. Without them, prey species decline, as do the forage-production species on which the prey-animals feed. Dr. Bradshaw warns: “Without predators, our feeble attempts to conserve ecosystems are doomed to fail.” Here’s the link to his timely article:

Essential predators

 

Predator Protection

HMAs should be safe-havens for predators, which will serve as wild-horse population-control agents.

There can be no true “thriving natural ecological balance” without predators. Therefore, BLM should ensure the protection of native predators, instituting a prohibition on hunting them. Conservation measures will work to enable the right number of predators to establish themselves. Large carnivores will keep the wild-horse population in check. Such an approach would keep the herd-population in equilibrium with minimal human-interference, just as the Wild and Free-Roaming Horses and Burros Act envisioned. Predators are the “no-cost” option.

Recommendations: Puma-protection, bear-introduction, wolf-reintroduction, and coyote-protection programs should be implemented. BLM should collaborate with Nevada Department of Wildlife to prohibit hunting of predators in the HMAs. Concerned livestock operators and residents of the surrounding area can be advised to use guardian-dogs to protect their animals. There are several specialty-breeds that have been developed just for this purpose, and they are reportedly effective. Protecting one’s herd is just part of the cost of doing business. The timely article linked below provides information on livestock-guardian-dogs.

https://www.hcn.org/articles/searching-for-the-best-dog-to-save-livestock-and-wildlife

 

PZP — BLM PROPOSES TO DEPLOY IT AGAINST WILD MARES

 

PZP — The Pesticide

Porcine zona pellucida — PZP aka ZonaStat-H or Native PZP — is an EPA-registered pesticide derived from the ovaries of slaughtered pigs. PZP is approved for use on wild horses “in areas where they have become a nuisance ….”

Some persons argue that, because PZP does not kill the mare, it is not really a “pesticide.” Actually, PZP does kill. As will be documented herein, PZP’s use is associated with stillborn foals. PZP is further correlated with stolen foals and out-of-season foals, who perish as neonates. In the long term, PZP tends to weaken a herd immunologically, which could swiftly lead to its extinction. So, yes, PZP is a real pesticide.

 

PZP — an Anti-Vaccine

While touted as a “vaccine,” PZP is actually a perversion of what a true vaccine is supposed to be. Instead of preventing disease, PZP causes disease — auto-immune disease. Thus, PZP could be viewed as an anti-vaccine.

 

PZP’s Mode of Action as Stated in the Pesticide Registration Is a Disproved Hypothesis

HSUS, the registrant of PZP advised the Environmental Protection Agency that, based on information from the pesticide’s researcher-manufacturer, PZP works by generating antibodies that “block sperm attachment.” This representation of PZP as a sort of chemical condom was not fact but merely an untested hypothesis, postulated three decades ago. The old hypothesis was disproved by subsequent research. PZP’s manufacturer knew, or should have known, this. The manufacturer should also have been informed and up-to-date regarding the side effects and unintended consequences of PZP. Yet, the manufacturer continued to cite the disproved hypothesis and to deny that PZP has any adverse effects. [25 and 36] HSUS is remiss in not investigating PZP beyond the manufacturer’s claims before touting it as the solution to the non-existent wild-horse overpopulation “problem.” BLM is irresponsible in ignoring research that has disclosed PZP’s risks.

 

PZP’s True Mode-of-Action

So how does PZP really work? PZP tricks the immune system into waging immunological war on the ovaries. In a meta-analysis of ZP-type contraceptives, Kaur & Prabha (2014) reported that the infertility brought on by such products is ” … a consequence of ovarian dystrophy rather than inhibition of sperm-oocyte interaction.” Thus, PZP’s antibodies “work” not by blocking sperm attachment but by destroying the ovaries. Kaur & Prabha further disclosed that ” … histological examination of ovaries of immunized animals revealed the presence of atretic follicles with degenerating oocytes.” [Atretic follicles are ovarian follicles in an undeveloped state due to immaturity, poor nutrition or systemic disease; manifested by prolonged anestrus.]

Kaur & Prabha’s review concluded that PZP’s antibodies induce ovarian dystrophy, destruction of oocytes in all growing follicles, and depletion of resting follicles. The manufacturer of PZP as well as BoLM should have been aware of these and other findings about the pesticide. Yet they ignored or disregarded any information that was contrary to their personally-preferred but obsolete and false description of PZP’s mode-of-action.

Kaur & Prabha warned that “… long term studies showed that immunization with zona antigens might induce immunological attack on many eggs in the ovary which might lead to premature ovarian failure.”

Included as a reference to the EA? No.

 

Study Shows PZP Elicits Ovarian Pathologies

One of the references cited in the EA was a study by Curtis et al. (2001) on the comparative effects of GnRH and PZP on white-tailed deer. However, Curtis, along with most of the same colleagues issued a newer study (2007) on PZP alone.

Curtis, Richmond, Miller, and Quimby (2007) disclosed that 75% of PZP-treated white-tailed deer — and 50% of re-treated deer — suffered eosinophilic oophoritis (inflammation of the ovaries).

Further, the re-treated deer that did not develop oophoritis instead developed a different problem — significantly fewer normal secondary follicles than control females.

The study-authors concluded that PZP “elicited ovarian pathologies in deer similar to those observed in other species.”

Included as a reference to the EA? No.

 

PZP Manufacturer’s Own Research Found Markedly Depressed Estrogen Secretion

In a telling study, Kirkpatrick, Liu, Turner, Naugle, and Keiper (1992a), the lead author and manufacturer of Native PZP, along with colleagues, reported that ” … three consecutive years of PZP treatment may interfere with normal ovarian function as shown by markedly depressed oestrogen secretion.” So, despite all the hype about PZP being non-hormonal, the manufacturer knew that ZonaStat-H has an adverse hormonal effect, causing significantly-lowered estrogen. Thus, PZP is an endocrine disruptor. [39] The plummeting estrogen-levels may also reflect the ovarian dystrophy and oophoritis now known to be caused by PZP. Despite personally discovering negative hormonal impacts 24 years ago, PZP’s manufacturer continued to cite misinformation regarding the product’s mode-of-action and hid its endocrine-disruptor side-effects.

Included as a reference to the EA? Cannot tell. A 1992 study is listed twice, but not 1992a.

 

PZP Causes Ovarian Cysts

In their 2010 meta-analysis, Gray & Cameron cited a number of studies that found ” … alterations to ovarian function, oophoritis, and cyst formation with PZP treatment (Mahi-Brown et al.1988, Sehgal et al. 1989, Rhim et al. 1992, Stoops et al. 2006, Curtis et al. 2007).” These findings support those of Kaur & Prabha while introducing yet another adverse effect: ovarian cysts. Gray & Cameron’s review also noted that increased irritability, aggression, and masculine behavior had been observed in females following PZP-treatment.

Included as a reference to the EA? No.

 

PZP → Endocrine Disruptor → Elevated Testosterone → Masculinizing Effects

Recall that PZP has endocrine-disrupting effects that result in lowered estrogen. Per the observed masculine behavior of treated mares, PZP seems to have a testosterone-elevating effect too. A deficit of estrogen alone would not necessarily manifest in the masculinization of treated females, but an excess of testosterone would. So, it appears that PZP disrupts at least two hormones: estrogen — by substantially lowering it — and testosterone — by substantially elevating it. Adverse effect: Abnormal behavior.

 

PZP → Ovarian Cysts → Elevated Testosterone → Masculinizing Effects

As discussed above, PZP correlates with abnormal masculine behavior on the part of treated females, a side-effect likely due to elevated testosterone. But in addition to the endocrine-disruption caused by PZP, there could be a second way for testosterone levels to become elevated. Recall that PZP causes ovarian cysts. An Internet search on “ovarian cysts and testosterone” yielded results for polycystic ovary syndrome (PCOS) in women. Interestingly, one of the symptoms of PCOS is high testosterone levels. The connection between ovarian cysts and elevated testosterone suggests that the ovarian cysts caused by PZP could — either alone or in combination with PZP’s endocrine-disruptor effects — lead to high testosterone levels in treated females, as evidenced by their masculinized behavior.

 

PZP Causes Additional Adverse Effects

Gray & Cameron’s review also disclosed that, when PZP was administered to the females of a herd, males lost body condition while the oft-claimed improvement in female body condition did not hold up. Further, mares remained sexually active beyond the normal breeding season and had more estrus events.

 

PZP Selects for Weak Immune Function

Gray & Cameron’s analysis raised the possibility of PZP selecting for immuno-compromised individuals. Here’s why. Because PZP stimulates the immune system, it ironically works “best” — sterilizes faster — in mares that have strong immune-function. Such mares respond to the anti-vaccine and produce quantities of PZP antibodies that destroy their ovaries. But, conversely, PZP may not work at all in mares whose immune-function is weak or depressed. Those mares fail to respond to PZP. They keep getting pregnant and producing foals who, like their dam, suffer from weak immune-function. So, the PZP pesticide works against the very horses that Nature has best equipped for survival-against-disease while favoring and selecting for the immuno-compromised. Thus, a herd being treated with PZP is undergoing selective breeding for weak immunity, which puts the population at risk for disease — and ultimately, for extinction.

 

PZP Confers Dubious “Benefit” of Increased Longevity

Gray & Cameron also cited a study that found that “… PZP treated feral horse mares lived longer, resulting in a new age class (>25 years) not present before treatment ….” Exceptionally-long life is an ironic effect of PZP treatments. PZP’s manufacturer actually boasted about it, as if the anomaly were a good thing. However, Gray & Cameron questioned the supposed benefit of mares living much longer than their normal life expectancy. Indeed, such mares take up scarce slots within size-restricted populations. The ultra-elderly mares continue to consume resources for many years, but they no longer contribute to the gene-pool. It is detrimental to a population’s genetic viability to carry significant numbers of sterile herd-members way-beyond their normal life-span.

 

Research on Wildlife Contraceptives Revealed Stillbirths and Auto-Immune Oophoritis from PZP

There was an even earlier, definitive meta-analysis on wildlife contraceptives. Nettles (1997) reviewed 75 studies available at that time on the subject. Among his findings regarding PZP-use across different species, including horses, were:

Stillbirths;
Altered ovarian structure and cyclicity;
Interference with normal ovarian function;
Permanent ovarian damage; and
Some cases of irreversible sterility due to auto-immune oophoritis, which suggested that PZP can be selective against a certain genotype in a population.

Many of these findings were confirmed by Kaur & Prabha as well as by Gray & Cameron. The focus now turns to certain of these key findings: Stillbirths, and auto-immune oophoritis. However, in discussing the correlation between stillborn foals and PZP-use, a related abnormality will be addressed: Stolen foals — abducted by barren mares treated with PZP.

Included as a reference to the EA? No.

 

Foals May Be Their Dam’s and/or Sire’s Only Offspring

In view of the fact that PZP eventually — if not immediately — causes sterility, any foal could be genetically rare and precious. In many cases, a foal may be the only offspring of a certain mare or stallion. By using PZP on the Sand Wash Basin mares en masse, BLM could endanger the herd’s genetic diversity.

 

Autoimmune Ovarian Disease — Known to Cause Premature Ovarian Failure — Induced by PZP

Tung, Agersborg, Bagavant, Garza, and Wei (2002) found that autoimmune oophoritis (ovarian inflammation) could be induced by injecting test-animals with ZP3 peptide. The researchers noted that autoimmune ovarian disease is a known cause of human premature ovarian failure. Here again, is causation of autoimmune disease by a ZP-type product. Humans and horses are both mammals. It is logical to conclude that ovarian failure also occurs in horses. This study confirms other research cited herein.

Included as a reference to the EA? No.

 

Autoimmune Oophoritis and Risk of Other Autoimmune Diseases

Varras, Anastasiadis, Panelos, Balassi, Demou, & Akrivis (2013) disclosed that, in humans, autoimmune oophoritis carries the risk of the patient developing other autoimmune diseases. The correlation between autoimmune oophoritis and subsequent other autoimmune disorders weighs against injecting the mares with PZP.

 

Prolonged Breeding Season, Unusually-late Parturition Dates with PZP

Nettles’ (1997) previously-mentioned meta-analysis on PZP disclosed additional adverse effects:

A prolonged breeding season and
Unusually-late parturition dates. (Parturition is the formal term for “giving birth.”)

These findings have recently been confirmed, as is discussed below.

 

Parturition-Season Extends to Nearly Year-Round When a Herd Is Treated with PZP

A longitudinal study by Ransom, Hobbs, and Bruemmer (2013) of three herds currently being managed by PZP — Little Book Cliffs (Colorado), McCullough Peaks (Wyoming), and Pryor Mountain (Montana) — found a prolonged parturition-season — it lasted 341 days. Ransom et al.’s finding of a nearly year-round birthing season supports the earlier finding by Nettles (1997). Thus, during its period of potential reversibility, PZP’s effects wear off unpredictably. Out-of-season births put the life of both the mare and the foal in jeopardy. Nature designed the equine birthing-season to occur in Spring, not year-round, and certainly not in the dead of Winter.

Included as a reference to the EA? Yes, but EA is dismissive of its findings.

 

Prolonged Delay in Recovery of Fertility

The same longitudinal study by Ransom et al. found that, after suspension of PZP, there was a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recovered their fertility. What this means is that it takes that long, on average, for the ovaries to heal, to clear out all those cysts, and to regain some degree of normal hormonal function.

The question is: How is the delay in recovery-of-fertility addressed by BLM management practices? Answer: BLM ignores it. For instance, BLM currently administers PZP to Pryor Mountain’s fillies and mares starting at age 1½ — whom BLM artfully described in the Environmental Assessment as fillies “becoming two year olds” — through age four. Thus, these fillies and mares receive intentional treatments for four consecutive years before being allowed the privilege of reproductive potentiality. Per Ransom et al.’s study, the Pryor Mountain fillies and mares would be expected to need 1,645.2 days (4.51 years) to regain reproductive capacity. But BLM gives the Pryor Mountain mares only 5 years off PZP before they are put back on it again — for the rest of their life. Thus, these fillies and mares might have just a 6-month window — at best — in which to conceive. Due to the unpredictable timing of PZP’s wearing off, for some mares that window of fertility will close before they get a chance to produce a foal. Those mares’ genetic contribution will be zero.

As if the above scenario were not bad enough, PZP’s manufacturer conceded that it could take up to 8 years to recover fertility after just 3 consecutive PZP treatments.

 

Ransom Advises Proceeding with Caution regarding PZP

The Ransom et al. study warned:

Humans are increasingly attempting to manage the planet’s wildlife and habitats with new tools that are often not fully understood. The transient nature of the immunocontraceptive PZP can manifest into extraordinary persistence of infertility with repeated vaccinations, and ultimately can alter birth phenology in horses. This persistence may be of benefit for managing overabundant wildlife, but also suggests caution for use in small refugia or breeding facilities maintained for repatriation of rare species.

Because BLM keeps virtually all of the herds — including those of the Antelope and Triple B Complexes — at levels below minimum-viable population (MVP) per the IUCN, these herds qualify as “small refugia.”

 

Ransom’s Exclusion of Seven Mares Evidences PZP’s Non-Effect on Immunocompromised Mares

In the “Data Collection” methodology section of the Ransom et al. report, the authors advised:

We omitted data for one female from the Little Book Cliffs and six females from McCullough Peaks because they produced offspring in every treatment year and thus were never effectively contracepted.

This fact is important because it evidences PZP’s lack-of-efficacy on immunocompromised fillies and mares.

To review: Because PZP activates the immune system, mares with naturally-low or depressed immune function do not “respond” to the treatment. It’s as if they had been injected with saline — their immune system is so weak that it does not react to the PZP by producing antibodies. The good news is such mares’ ovaries are saved from PZP’s destructive effects. The bad news is that these mares continue to become pregnant year after year, producing foals that will also tend to inherit low immune-function. Over time, the herd will become populated with more such low-immune horses because those with strong immunity get sterilized. Thus, PZP selects for horses with low immune function, which is bad for a herd in the long term. Even a routine infection could spread quickly and wipe out a population of horses or burros with weak immune-function. If the goal is to preserve a herd, the use of PZP constitutes a worst management-practice.

 

Three PZP Injections Can Trigger Sterility in Mares, or Just One Shot in Fillies Before Puberty

Disturbingly, another recent study on PZP (Knight & Rubenstein, 2014) found that ” … three or more consecutive years of treatment or administration of the first dose before sexual maturity may have triggered infertility in some mares.

These findings are particularly troubling. They suggest that, actually, only two consecutive PZP-treatments may be reversible. Except, that is, in the case of fillies who have not yet reached puberty — they could be sterilized by just one injection. For instance, the Pryor Mountain fillies’ PZP treatments begin when they are just 1½ years old. They may not have reached puberty when they are initially treated. And as we shall see later in this report, that first shot of PZP may not be their first shot of PZP.

Included as a reference to the EA? No.

 

Researchers Again Express Concerns about the Abnormal Life-Spans of Sterilized Mares

Returning to the subject Knight & Rubenstein study, the researchers warned:

Inducing sterility, while relieving the mares from the energetic costs of lactation and reducing the stress from harem switching, may have unintended consequences on population dynamics by increasing longevity and eliminating the mares’ ability to contribute genetically.

Knight & Rubenstein’s concerns support those of Gray & Cameron, who also questioned the supposed benefit of sterile mares’ extended life-spans. The abnormal numbers of aged, sterile mares count for census-purposes; but their presence disadvantages the younger horses, who become targeted for removal in order for BoLM to achieve arbitrary management levels. Further, such mares no longer belong to the viable gene-pool.

 

PZP’s Destructive Antibodies Are Transmitted via the Placenta and Mother’s Milk

It gets worse. Sacco, Subramanian, Yurewicz (1981) reported that, per radioimmunoassay, PZP antibodies are transferred from mother to young via the placenta and milk. The transferred antibodies cross-react with and bind to the zonae pellucidae of female offspring, as demonstrated by immunofluorescent techniques.

These findings were disclosed in 1981 — 35 years ago. PZP’s manufacturer must have known about this dangerous effect, and certainly BLM should have investigated on its own whether there was any risk to the unborn or the nursing foal. Yet, the manufacturer continued to insist that there was no danger to the foal, whether born or unborn. Indeed, the EA recites the manufacturer’s claim in that regard. And in fact, BLM regularly administers PZP to lactating mares, who transfer the destructive antibodies to their foal via mother’s milk.

Fillies whose dams were injected with PZP while nursing will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when those same fillies are injected later, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized while nursing, the treatment having been received prior to puberty, about which Knight & Rubenstein warned.

Likewise, if the Antelope and Triple B mares were to be injected while nursing, their filly-foals would have PZP antibodies inflaming their little ovaries. Subsequent injections could easily sterilize them in one shot, especially if given prior to puberty.

Included as a reference to the EA? Yes, but findings discounted.

 

PZP Continues the Use of Roundups and Removals

If the promise of PZP were true — if PZP really did eliminate the need to roundup and remove “excess” wild horses from the range — gathers and removals would have ended long ago in the Pryor Mountain Wild Horse Range, where PZP has been in use for approximately two decades. Yet removals are scheduled there with regularity every 3 years, the latest one in 2015.

But evidently every 3 years, in BLM’s mind, wasn’t often-enough. BLM announced plans to conduct removals every year in the Pryor Mountains despite recently-intensified PZP-treatments. Friends of Animals, a renowned animal-advocacy organization that opposes PZP, sued to prevent BLM from initiating the accelerated schedule of gathers. Friends of Animals prevailed, and the annual removals were blocked. The Court directed BLM to fulfill its commitments to reevaluate the Pryor Mountain AML. [25 and 32]

As the EA proposes, the Antelope and Triple B Complexes’ herd would be rounded up in order to inject / re-inject the mares. Roundups are stressful on wild horses and costly to taxpayers. The better and no-cost population-control method is predation by mountain lions, bears, coyotes, and perhaps even reintroduced wolves.

Risks to Humans Who Administer PZP Injections

For BLM staff, contractors, and volunteers who inject wild horses with PZP, EPA’s Pesticide Fact Sheet advises that Personal Protective Equipment requirements include long sleeved shirt and long pants, gloves and shoes plus socks to mitigate occupational exposure. EPA specifically warns that pregnant women must not be involved in handling or injecting ZonaStat-H, and that all women should be aware that accidental self-injection may cause infertility.

However, EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …

Pregnant women of the reason why it is so important that they strictly avoid PZP — because PZP’s antibodies cross the placenta and cross-react with and bind to an unborn female child’s own little zonae pellucidae. The baby-girl could be “anti-vaccinated” with PZP and even sterilized before birth;

EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …

Lactating women to avoid PZP and why — because PZP’s destructive antibodies would be passed along to a nursing female child via mother’s milk. The baby-girl could be “anti-vaccinated” with PZP and possibly sterilized simply from nursing.

EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures fail to inform …

All women of the reason why to avoid PZP — due to the risk of ovarian dystrophy, oophoritis, ovarian cysts, depressed estrogen and elevated testosterone-levels — in addition to infertility and, potentially, sterility — from unintentional self-injection.

EPA’s Fact Sheet, the manufacturer’s training, and BLM’s operating procedures further fail to emphasize the magnitude of the risk — the PZP-in-question is a dose meant for a horse.

 

Mandate to Practice Scientific Integrity

Let us return to the Department of the Interior’s (DOI) Code of Scientific and Scholarly Conduct, which applies to all staff members as well as to contractors, partners, permittees, and volunteers. The Code states:

Scholarly information considered in Departmental decision making must be robust, of the highest quality, and the result of as rigorous scientific and scholarly processes as can be achieved. Most importantly, it must be trustworthy.

In the EA, BoLM has omitted independent scientific findings about PZP’s adverse effects and unintended consequences. Instead, BLM continues to rely almost exclusively on the manufacturer’s claims regarding PZP’s safety for use on horses or burros and for handling by humans. BLM is thus non-compliant with the Policy and malfeasant in its responsibilities to protect staff, contractors, volunteers, and the wild horses.

 

PZP Manufacturer Violated the DOI Code of Scientific and Scholarly Conduct

The manufacturer of PZP — a partner to BLM, but since deceased — misrepresented the pesticide as safe for use on animals by humans. The manufacturer knew or should have known that the former hypothesis regarding PZP’s mode-of-action had been disproved, and that PZP has dangerous side effects, safety-issues, and unintended consequences. Yet he hid and denied that information and failed to warn about PZP’s adverse effects. The manufacturer cited his own research as if it were definitive, and aggressively criticized wild-horse-and-burro advocacy groups that oppose PZP, such as Friends of Animals and Protect Mustangs, and independent researchers whose findings did not fully support his claims. Indeed, he submitted an Op-ed to The Salt Lake Tribune wherein he accused Friends of Animals and Protect Mustangs of citing “dubious and distorted” data about PZP. He belittled the research of fellow scientists whose studies on PZP yielded results somewhat different from his own. His accusations were so unreasonable that the scientists felt it necessary to submit an Op-ed in response to defend the integrity and validity of their work. The manufacturer also disparaged members of the public — one of whom was appointed to the Pennsylvania Game Commission — that expressed concerns about PZP. He dismissively accused them of “an attempt to mislead,” of “hyperbole,” of “knowingly manipulating information,” of “attempts to frighten people,” and of indulging in an “anti-intellectual approach to debates.” [35] By these actions, the manufacturer violated the DOI Code of Scientific and Scholarly Conduct.

 

PZP Manufacturer Misled Trainees into Believing that PZP Was Safe

BoLM and HSUS staff and volunteers receive their training from PZP’s manufacturer in how to handle and administer the pesticide. BoLM and HSUS are remiss in delegating the training to the manufacturer without verifying the adequacy of the instruction and the truthfulness of it. Two comments recorded recently in the media suggest that PZP’s manufacturer misled not just the public-at-large but those who received training therefrom in how to administer PZP.

Recall that the manufacturer claimed PZP is “so safe it is boring.” Independent research shows otherwise — that PZP is a powerful hormone disruptor that could sterilize a female with just one injection. If trainees believe that PZP is boringly safe, they will be less likely to protect themselves adequately from this dangerous pesticide. Indeed, many of the trainees are women and, therefore, particularly at risk. It is worrisome that the volunteers may be conducting their darting under the impression that it is perfectly safe. As evidence that such is the case, in a photograph that accompanied a recent article on PZP, a volunteer-darter is shown not wearing the required protective garb.

Another PZP supporter, who self-identified at the time as a recent completer of the PZP-darting training program conducted by the manufacturer, said in a comment posted to a news article:

I just received my FDA certification to handle and administer Native PZP. Would you be so kind to provide a link to the study you keep referencing? To my knowledge, and those teaching the Native PZP certification class, there are no side effects of the PZP produced by Dr. Kirkpatrick and his team, which is Native PZP.”

Key words: “no side effects.” It is disturbing that a person who was, no doubt, motivated by a desire to help the wild horses and burros has been disinformed regarding PZP’s safety-hazards to humans as well as to horses and burros.

Likewise, wild-horse-and-burro advocates are lulled into complacency, trusting that PZP is harmless. Of course, that is not true.

 

PZP — Conclusions about

PZP is appropriately categorized as a pesticide by the EPA. PZP “works” by tricking the immune system into attacking and destroying the ovaries. PZP has many adverse effects as well as unintended consequences. PZP presents safety-hazards to humans who handle it. PZP is a dangerous pesticide whose use is antithetical to the spirit and intent of the Wild and Free-Roaming Horses and Burros Act.

 

GONACON™ — BLM CONSIDERS DEPLOYING IT AGAINST THE HERDS

 

Gonacon™ — Yet Another Immuno-Pesticide

GonaCon™ is an EPA-registered, immuno-contraceptive pesticide. Its classification is “restricted-use” due to “non-target injection hazard.” EPA warns that “pregnant women should not be involved in handling or injecting GonaCon and that all women should be aware that accidental self-injection may cause infertility.” Children are not allowed in areas where the product is used. Please keep in mind that the GonaCon™ dose-in-question is meant for a horse.

 

GonaCon™ — Mechanism of Action

GonaCon™ causes an auto-immune disorder. Behaving like a perverted vaccine, GonaCon™ tricks the immune system into producing antibodies that destroy a female’s gonadotropin-releasing hormone (GnRH). Without GnRH, a female does not produce sex hormones, does not come into estrus, and is thus infertile. Behaviorally, courtship-rituals cease. Thus, GonaCon™ is a hormone-disruptor.

 

Gonacon™ — Link to PZP

Wild-horse-and-burro advocates who oppose the other immuno-contraceptive — PZP — will be disturbed to learn the following from the USDA-APHIS “Questions and Answers” sheet regarding GonaCon™:

After evaluating GonaCon™, the Food and Drug Administration (FDA) … approved the slaughter of pigs vaccinated with GonaCon™. Similar injectable hormone-altering products are used routinely in livestock applications.

Good grief. So, the slaughterhouse pig ovaries used to manufacture PZP may very well come from animals who were previously injected with GonaCon™ to destroy their GnRH hormone — without which the ovaries cannot produce estrogen. Those poor pigs may also have been “routinely” injected with other similar “hormone-altering products.” Then our wild horses and burros are injected with PZP, which itself causes a marked drop in estrogen after just three treatments. Surely, these hormonal atrocities constitute animal abuse.

 

Gonacon™ — Causes Long-Term Infertility

GonaCon™ is long-acting. The treatment-protocol, consisting of two injections administered 30 to 60 days apart, can cause infertility for as long as four-to-five years without the need for booster shots. However, mares would still need to be rounded up and held captive for those 30 to 60 days to administer the injections properly. If all females in a small herd were treated per the multi-year plan, it could result in an unintended consequence — a huge gap in the herd’s age-structure, because very few if any foals would have been born during that period.

 

Gonacon™ — Adverse Side-Effects, Chance of Sterilization

Although the pesticide’s effectiveness was expected to diminish over time, a 3-year study of GonaCon-treated elk revealed that the percentage of infertile females actually increased each year, finally reaching 100%. It was also noted that every one of the treated elk suffered an abscess at the injection-site. [1]

Because GonaCon™ stimulates the immune-system, it will elicit the greatest reaction — the greatest output of destructive antibodies — if a mare is blessed with healthy immune-function. Such a mare will react strongly and be contracepted quickly. But she could just as easily be sterilized. In fact, GonaCon’s™ “application instructions” warn of the chance of sterilization.

On the other hand, GonaCon™ may not work at all if a mare suffers from weak immune-function. That mare’s immune system will fail to react to GonaCon™, and she will get pregnant in spite of it. Thus, over time, there is the risk of another unintended consequence ؅— selection for immuno-compromised horses.

Jenny Powers, a National Park Service wildlife veterinarian and one of three lead scientists who participated in the elk research referenced above commented:

“Some things are meant to be wild,” Powers says. “At some point, do we not want to treat them like domestic animals and be handling them? I think it’s important to point out that this is no silver bullet so that we don’t have to kill wild animals. Any time we’re manipulative with wild animals, we’re messing with natural selection.

 

GELDING — BLM WANTS TO STERILIZE HALF OF THE STALLIONS

 

Geldings Are Not Normal in Nature

Surgical sterilization would effect a permanent change in character for a wild horse. That is not natural or normal. But BLM is itching to geld, even though the EA admits that the study it cites — by Garrott and Siniff — says “not effective” unless 85% of the males are castrated, and even then, within 2 years, a new crop of males is born.

 

Gelding Would Severely Impact Genetic Diversity

No problem, BLM says. The agency would solve that by trucking in new stallions, mares, or both. Don’t be ridiculous. Herds are, by Law, to be self-sustaining, free from BLM-meddling.

 

CONCLUSIONS

 

1. BLM must make the right decision by choosing the No Action Alternative.

2. BLM must post scientific, truthful data regarding wild horses’ herd-growth rates.

3. BLM must take responsibility to provide water-sources — guzzlers — for the herds.

4. BLM needs to conduct Ecological Site Inventories to determine actual use by species.

5. BLM must conserve predators in the HMAs for a thriving, natural, ecological balance.

 

———————————————-

Sincerely,

Marybeth Devlin

———————————————-

 

REFERENCES

 

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Clabby, Catherine. (2010, January-February) A Magic Number? American Scientist. Retrieved from http://www.americanscientist.org/issues/pub/a-magic-number/

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Dayton, Kelsey. (2016, March 18) Grasshoppers thrive on the warming Wyoming range. WyoFile. Retrieved from http://www.wyofile.com/column/grasshoppers-thrive-warming-wyoming-range/?utm_source=newsletter&utm_medium=email&utm_campaign=weeklynewsletter

Duncan, Patrick (Editor). 1992. Zebras, Asses, and Horses: An Action Plan for the Conservation of Wild Equids. International Union for the Conservation of Nature and Natural Resources. Retrieved from http://data.iucn.org/dbtw-wpd/edocs/1992-043.pdf

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Ferguson, Mike. (2015, June 4) “Police called as group protests wild horse contraceptives.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/montana/police-called-as-group-protests-wild-horse-contraceptives/article_81462303-e128-5ee8-a7ef-2c8b098450f6.html

Goldfarb, Ben. (2015, April 23) Searching for the best dog to save livestock — and wildlife. High Country News. Retrieved from https://www.hcn.org/articles/searching-for-the-best-dog-to-save-livestock-and-wildlife

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Gregg, Kathleen, LeBlanc, Lisa, and Johnston, Jesica. (2014) Wild Horse Population Growth. Retrieved from http://protectmustangs.org/wp-content/uploads/2014/04/PM-Population-Growth-4.25.14-FINAL.pdf

Hanselka CW, Lyons R, and Teague R. (2002, October) Patch Grazing and Sustainable Rangeland Production. AgriLIfe Communications and Marketing, Texas A&M University System. Retrieved from http://www1.foragebeef.ca/$Foragebeef/frgebeef.nsf/all/frg30/$FILE/rangedistributionpatch.pdf

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Johnson, Clair. (2016, August 4) “Judge rules for wild horse advocacy group in BLM suit.” The Billings Gazette. Retrieved from http://billingsgazette.com/news/state-and-regional/judge-rules-for-wild-horse-advocacy-group-in-blm-suit/article_08c938df-2723-5d87-8d40-8ef4814a6be8.html

Kaur, Kiranjeet and Prabha, Vijay. (2014) “Immunocontraceptives: New Approaches to Fertility Control,” BioMed Research International, vol. 2014, Article ID 868196, 15 pages, 2014. doi:10.1155/2014/868196. Retrieved from http://downloads.hindawi.com/journals/bmri/2014/868196.pdf

Keller, Larry. (2011, May 17) To shoot, or not to shoot, at Rocky Mountain NP. High Country News. Retrieved from http://www.hcn.org/blogs/range/to-shoot-or-not-to-shoot-at-rocky-mountain-np

Kirkpatrick, J. F., I. K. M. Liu, J. W. Turner, Jr., R. Naugle, and R. Keiper. 1992a. Long-term effects of porcine zonae pellucidae immunocontraception on ovarian function of feral horses (Equus caballus). J. Reprod. Fert. 94:437-444. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/1317449

Kirkpatrick, Jay. 2007. “Response to PA [Pennsylvania] Game Commission.” Posted on PNC’s Wildlife Forever Home Page. Retrieved from http://www.pzpinfo.org/home.html

Kirkpatrick, Jay F. (2015, May 16). Op-ed: Wild-horse contraceptives are based on sound science. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2517266-155/op-ed-wild-horse-contraceptives-are-based-on?fullpage=1

Knight, Colleen M., Rubenstein, Daniel I. 2014. The Effects of Porcine Zona Pellucida Immunocontraception on Health and Behavior of Feral Horses (Equus caballus). Princeton University Thesis, Ecology and Evolutionary Biology. Retrieved from http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p

McDonnell, Sue. (No date) “Rolling Along. Why Do Horses Roll?” Havemeyer Equine Behavior Lab, Penn Vet / New Bolton Center, School of Veterinary Medicine, University of Pennsylvania. Retrieved from http://research.vet.upenn.edu/HavemeyerEquineBehaviorLabHomePage/HavemeyerEquineBehaviorClinic/FrequentlyAskedBehaviorQuestions/WhydoHorsesRoll/tabid/2988/Default.aspx

McGrath, Matt. (2011, September 1) “Deer ‘pill’ curbs aggressive mating.” BBC News. Retrieved from http://www.bbc.com/news/science-environment-14744811

McNamee, Gregory. 2015. “Wolves in Arizona: The Return of El Lobo Southwestern Wolves Make Their Troubled Way Home.” DesertUSA. Retrieved from http://www.desertusa.com/desert-arizona/wolf-arizona.html

Nettles, Victor F. (1997) Potential consequences and problems with wildlife contraceptives. Reproduction, Fertility and Development 9(1) 137 – 144. Accessed full pdf text via purchase of a copy from Csiro Publishing. Retrieved from http://www.publish.csiro.au/paper/R96054.htm

Nuñez, Cassandra, Jim Adelman and Dan Rubenstein. (2015, July 3). Op-ed: Wild horse contraception not without unintended consequences. The Salt Lake Tribune. Retrieved from http://www.sltrib.com/opinion/2653298-155/op-ed-wild-horse-contraception-not-without

PCOS Foundation. (2015) What Causes PCOS? Retrieved from http://www.pcosfoundation.org/what-is-pcos

PNC, Inc. (Pity Not Cruelty). PZP FAQs. (2006) “Frequently Asked Questions on Immunocontraception.” (Special thanks to Jay Kirkpatrick and Rick Naugle for additions and corrections). Retrieved from http://www.pzpinfo.org/pzp_faqs.html

Prettyman, Brett. (2015, January 26) “Jackrabbits are a bigger problem for cattle than bison in Utah’s Henry Mountains, USU study says.” The Salt Lake Tribune. Retrieved from http://www.sltrib.com/news/2080640-155/usu-study-jackrabbits-are-a-bigger?fullpage=1

Raab. Lauren. (2015, May 31) “120,000 endangered saiga antelopes die mysteriously in Kazakhstan.” Los Angeles Times. Retrieved from http://www.latimes.com/science/sciencenow/la-sci-sn-saiga-antelope-die-off-20150531-story.html

Ranglack, Dustin H., Durham, Susan, du Toit, Johan T. (April 2015) Competition on the range: science vs. perception in a bison–cattle conflict in the western USA. Journal of Applied Ecology. Retrieved from http://onlinelibrary.wiley.com/doi/10.1111/1365-2664.12386/full

Ransom JI, Hobbs NT, Bruemmer J (2013) Contraception Can Lead to Trophic Asynchrony between Birth Pulse and Resources. PLoS ONE 8(1): e54972. doi:10.1371/journal.pone.0054972. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/23383018

Runyon, Luke. (2013, October 8) The long, slow decline of the U.S. sheep industry. Harvest Public Media. Retrieved from http://harvestpublicmedia.org/article/long-slow-decline-us-sheep-industry

Sacco AG, Subramanian MG, Yurewicz EC. (1981) Passage of zona antibodies via placenta and milk following active immunization of female mice with porcine zonae pellucidae. J Reprod Immunol. 1981 Dec;3(6):313-22. Retrieved from http://www.ncbi.nlm.nih.gov/pubmed/7328557

Stachowicz, John J. (2001) Mutualism, Facilitation, and the Structure of Ecological Communities. BioScience (2001) 51 (3): 235-246. doi: 10.1641/0006-3568(2001)051[0235:MFATSO]2.0.CO;2. Retrieved from http://bioscience.oxfordjournals.org/content/51/3/235.full

Traill LW, Bradshaw CJA, Brook BW. (2007) Minimum viable population size: A meta-analysis of 30 years of published estimates. Elsevier Ltd. Retrieved from https://coreybradshaw.files.wordpress.com/2011/03/traill-et-al-2007-biol-conserv.pdf

Tung K, Agersborg S, Bagavant H, Garza K, Wei K. (2002) Autoimmune ovarian disease induced by immunization with zona pellucida (ZP3) peptide. Curr Protoc Immunol. 2002 Aug;Chapter 15:Unit 15.17. doi:10.1002/0471142735.im1517s49. Retrieved from http://www.ncbi.nlm.nih.gove/pubmed/18432873

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USDA-APHIS. (2007, February). “GonaCon™—Birth Control for Deer: Questions and Answers.” Retrieved from https://www.aphis.usda.gov/wildlife_damage/nwrc/downloads/faq_gonacon_07.pdf

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United States Department of the Interior. (2015) Review of Ungulate Fertility Control in the National Park Service. Retrieved from https://www.nature.nps.gov/biology/wildlifehealth/Documents/Ungulate%20Fertility%20Report_09242015.pdf — and then —
https://www.nps.gov/orgs/1103/upload/Ungulate-Fertility-Report_09242015.pdf

United States Environmental Protection Agency. (2009) Pesticide Fact Sheet. Mammalian Gonadotropin Releasing Hormone (GnRH). Retrieved from http://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-116800_01-Sep-09.pdf

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http://www3.epa.gov/pesticides/chem_search/reg_actions/pending/fs_PC-176603_01-Jan-12.pdf

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U.S. National Library of Medicine. National Institutes of Health. Ovarian overproduction of androgens. Retrieved from https://www.nlm.nih.gov/medlineplus/ency/article/001165.htm

Varras M, Anastasiadis A, Panelos J, Balassi E, Demou A, Akrivis CH. (2013) Autoimmune oophoritis: Clinical presentation of an unusual clinical entity. OA Case Reports 2013 Jan 31;2(1):7. Retrieved from http://www.oapublishinglondon.com/article/369#

 

Protect Mustangs is a 501(c)3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org



Urgent: Take action now to stop the proposed extermination of 45,000 wild horses and burros

While everyone is distracted, committee members in the U.S. Senate are making life and death decisions for wild horses and burros on your behalf.

You can use your voice for the voiceless before it’s too late! Read the sample letter below to help you with phone calls, faxes and emails:

Dear Senator Feinstein, Senator Murkowski ,Senator Blunt and Senator Udall:

We realize you are about to decide on the Bureau of Land Management (BLM) wild horse and burro budget for 2017 on behalf of the American people.  The BLM has been influenced by the livestock, oil and gas and other mining interests stating that Herd Areas are designated for multiple use, conveniently and illegally ignoring the fact that wild horses and burros under Sec. C get ‘devoted principal presence of their range areas’. We ask that you stand up for them.

Will the BLM use Americans’ tax dollars to kill off our wild horse and burro herds since the BLM’s own Advisory Board has recommended that 45,000 wild horses and burros be destroyed?  This suggestion is disgusting and against the law and against the Wild Free Roaming Horse and Burro Act of 1971 passed to protect these incredible national treasures.

Therefore we ask that all BLM monies be specifically utilized for the following usages.

1.)  First, American tax dollars be allocated to maintain, feed and care for all the wild horses and burro’s in holding.

 2.) Get an independent headcount of all wild horses and burro’s in holding and on public land with public and press participation to insure that the head count is accurate as requested in this petition (https://www.change.org/p/u-s-senate-investigate-the-wild-horse-burro-count-in-captivity-and-freedom) This will insure BLM cannot skew their numbers for more BLM monies.

3.) BLM is required to start implementing a return wild horse and burro policy to their Herd Areas with a drop food and water program when necessary. This will greatly reduce spending five dollars a day on feeding the more than 13,000 wild horses and burros warehoused in feedlot settings known as short-term holding.

4.)  BLM must return the 22 million acres to the Herd Area’s of the original 53 million acres designated to them which they have removed without any congressional approval.  The BLM is blatantly lying to the public saying they have not removed any Herd Areas.   Removing thousands of wild horses while removing their Herd Areas and allowing for livestock grazing beyond their legal limits puts undo pressures upon the land that would otherwise not exist were the wild horses and burros management program being followed as the original law intended.

5.) Do not transfer federally protected wild horses to states, cities and counties. It would result in them being sold into the slaughter pipeline when the WILD horses don’t do well as “work horses”. We see the cruel fiasco looming in South Dakota when wild horses have been impounded by the state. They are planning on selling them at a livestock auction with kill-buyers licking their chops.

6.) Stop the BLM propaganda machine to fool Americans paid for with tax dollars. The BLM has misinformed the American public about wild horses and burros saying they are overpopulated and destructive to the environment when in fact they are nature’s top soil enhancer and are designed to protect the plants they need for survival. Keep in mind that wild horses are indigenous to the Americas.

7.) Due to the BLM’s illegal selling off at least 1,700 healthy wild horses to a private kill buyer who made thousand of dollars at the expense of taxpayers losing thousands of dollars, we feel you need to take charge and protect the lives of innocent captive wild horses and burros.

Below is the contact information for those who hold the fate of America’s wild horses and burros in their hands right now:
Senator Feinstein seems to welcome contact

Here’s information about how to contact her:

  • Contact her Washington, DC office.
  • Contact one of her four state offices.
  • Send her an e-mail message.
  • Please note:  If you are having difficulty with a government agency and you need casework assistance, please fill out a casework authorization form and send it to her San Francisco office, or call the San Francisco office for additional help at (415) 393-0707.
Senator Murkowski provides this link: https://www.murkowski.senate.gov/contact

Her office in WASHINGTON, D.C.

709 Hart Senate Office Building
Washington, DC 20510
Phone: (202)-224-6665
Fax: (202)-224-5301

His office in Washington, D.C.

260 Russell Senate Office Building
Washington, DC 20510
Phone: (202) 224-5721
Fax: (202) 224-8149

Senator Udall provides this link: https://www.tomudall.senate.gov/?p=contact
His office in Washington, DC
531 Hart Senate Office Building
Washington DC, 20510
(202) 224-6621

Protect Mustangs is a 501(c)3 nonprofit organization dedicated to the protection and preservation of native and wild horses. www.ProtectMustangs.org




Save GAIA (#8402) beauty of the West

PM IA GAIA #8402 Carson July 2016

Elegant wild mare with at least one strike facing a second

GAIA (#8402) is available through the internet adoption only at this time. This means BoLM  could ship her out closer to you and you pick her up from the BoLM location or you can pick her up in Nevada should you be close. GAIA has spent most of her life in captivity so with love and patience you can build trust using gentle training techniques. She is sensitive and delicate with a floaty trot. GAIA is not halter-gentled. She’s untrained but with a very kind eye.

This is what the Bureau of Land Management says:

Sex: Mare Age: 4 Years   Height (in hands): 13.0

Necktag #: 8402   Date Captured: 06/10/12

Freezemark: 12618402   Signalment Key: HF1AAAAAB

Color: Bay   Captured: Jackson Mountains (NV)

Notes:

This is an untouched mare with no training.

NOTE: This mare is only available through the Internet Adoption. She is not available for advanced viewing and can not be adopted directly from the Northern Nevada Correctional Center.

This horse is currently at the Northern Nevada Correctional Center in Carson City, NV. For more information please contact Jenny Lesieutre at jlesieut@blm.gov or call 775-861-6594.

Pick up options (by appt): Palomino Valley, NV; Delta, UT; Elm Creek, NE; Pauls Valley, OK; Ewing, IL.

Other pick up options: Waterloo, IA (October 21); Unadilla, GA (November 4).

Please share her page and ask your friends to do the same so together we can find a loving home for GAIA (#8402)

Watch GAIA’s video

Don’t let shipping hinder adopting GAIA (#8402). You have options. There are groups like Fleet of Angels who help hauling rescued horses for a low cost. GoFundMe or YouCaring are Crowd-Funding sites that can help you raise the money for GAIA’s haul to her new home in California or New York with a rescue or traditional hauler.

It’s generally cheaper to haul 2 horses so please consider adopting a second wild horse so GAIA would have a wild cousin with her forever.

America’s mustangs are going to stop being rounded up at some point soon. The Congressional sell outs to fracking, the TPP, etc. want them managed to extinction and quickly! We all saw them in action in the shamefully biased House subcomittee meeting on Wild Horses and Burros on June 22, 2016.

This is your chance to welcome a pair into your life forever and protect them from a horrible fate.

Remember sharing is caring

 

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




Get your applications in to save 3-Strikes wild horses and burros!

PM 3-Strike Nellie Diamond 10620484 for Sale

Help save them from ending up at slaughter!

The first step is to get your applications in and approved to purchase 3-Strike wild horses. You can download the application below:

PM Application to Purchase BLM WH&B

Send by it to wildhorse@blm.gov, fax to 202-912-7182 or mail it to BLM Wild Horse Sales P.O. Box 3270, Sparks, Nevada 89432 Be sure to keep a copy for your records. 

Each wild horse costs $25. after the feds have spent thousands on each one–rounding them up, removing them from their freedom and families–only to end up with 3-Strikes and at risk like this.

 

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




RED ALERT: Sage Creek (#1478) from Sarge’s herd has 3-Strikes, is miserable and needs to get to sanctuary not slaughter!

PM SAGE CREEK #1487 6 yr mare Fish Creek

Was Sage Creek (#1478) given Pesticide PZP like so many of the Fish Creek mares from Sarge’s herd who were rounded up, forcibly drugged but never released?

Look how the Bureau of Land Management inflates population numbers to justify roundups and the need for Pesticide PZP:

Fish Creek (NV)
256 = Population-estimate 2013
461 = Population-estimate 2014, before foaling season (January)
80.1% = Percentage increase in one year? Looks like some funny numbers!

Here are some Fish Creek mares at the BLM’s facility in Fallon, Nevada in 2015. They were going to be given Pesticide PZP and returned to the range but many were never returned. How many were slammed with 3-Strikes and where are they?

Can you find Sage Creek in with her relations?

Fish Creek Mares Indian Lakes aka Broken Arrow 2015

The BoLM doesn’t want to use widespread PZP they want a one-shot quick way to sterilize America’s wild horses based on the false premise that wild horses are overpopulated and need fertility control. . . when the truth is they are being managed to extinction!

Supporting PZP only supports the BLM’s divide and conquer game to ruin a united force to protect America’s wild horses. It’s time to focus on the wild horses not pesticides.

Now Sage Creek looks horrible and should be honored with a life in sanctuary away from those who brutally ripped her from her family and freedom when they rounded up the Fish Creek wild mares for Pesticide PZP–made from slaughterhouse pig ovaries.

PM SAGE CREEK #1487 6 yr mare Fish Creek Skinny

Here is what the Bureau of Land Management says about Sage Creek (#1478):

Sex: Mare Age: 6 Years   Height (in hands): 14

Necktag #: 1478   Date Captured: 02/19/15

Freezemark: 10621478   Signalment Key: HF1AAAAFJ

Color: Red Roan   Captured: Fish Creek (NV)

Notes:

Tag-#1478. 6 year old red roan mare gathered from the Fish Creek Herd Area in Nevada in February of 2015.

This horse is currently located in Palomino Valley, NV.  For more information, please contact Jeb Beck at (775) 475-2222 or e-mail: j1beck@blm.gov

For more about the sale program, go to:

http://www.blm.gov/wo/st/en/prog/whbprogram/adoption_program/sales.html

Update August 10: BLM said, “If no bids were placed on an animal in the last internet and a bidder that didn’t get the horse they choose as first pick didn’t decide to take a horse with no bid then those horses with no bids are available for pickup at PVC till August 22. After that date any remaining horses will be put on the next internet adoption. . . horses are available for pick up FROM PVC ONLY we will not ship as the truck is full at this point.”

From Protect Mustangs:

You can help by sharing Sage Creek’s (#1478) post to find a sanctuary who will give her a safe forever life and help her improve her body condition. Sage Creek never deserved to be forcibly drugged with Pesticide PZP under the false promise of returning to the wild, get 3-Strikes and become at-risk of ending up at slaughter. Share to help save her now!

Together we can turn this around.

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




BoLM Utah Press Release about their proposed wild horse and burro research

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 Protect Mustangs is against cruel research on wild horses and burros. Population ecology can be done through noninvasive observation of the herds without harassing the wild horses and burros with roundups and radio collars. The BoLM is either too lazy to do this or just enjoys torturing our icons of freedom to “experiment” on them. Wild horses and burros need to be left alone, period.

Here is one research proposal surely there are others: http://on.doi.gov/2aF2iCb

The following is from a BoLM press release:

Salt Lake City, Utah—Bureau of Land Management (BLM), Utah Wild Horse and Burro Program will be working collaboratively with scientists at the United States Geological Survey (USGS) Fort Collins Science Center to conduct several wild horse and burro research projects. The research is being done partly in response to the 2013 National Academies of Science (NAS) report that recommended science-based management of free-roaming equids within the BLM Wild Horse and Burro Program.
The NAS report recommended acquiring population ecology information on wild burros to better understand their demographic parameters and improve their management, since there is remarkably little published literature on wild burros. Two research proposals include the Sinbad wild burro Herd Management Area (HMA) managed by the Price Field Office. The first study, which has been approved, would test population survey techniques for burros and identify and develop new techniques that can be applied across wild burro ranges of western rangelands. The second proposed study would study the demography of free-roaming burros to provide data for population modeling, to improve management of wild burros, and to contribute to a better understanding of the ecology of wild burros.
The NAS report also recommended research be done on wild horse demography and ecology, and highlighted the utility of statistical models for improved management. Studies to support this approach are being proposed for the Frisco HMA, managed by Cedar City Field Office, and the Conger HMA, managed by Fillmore Field Office. Specific questions approved in the research for the Conger HMA include quantifying the impacts of sterilizing a portion of male horses in the population and how treatment impacts their behavior and ecology.
Research on both wild horse and wild burro HMAs may include looking at the fertility, fecundity (reproductive rate), recruitment rate, age-specific survival and mortality, habitat selection, movements, habitat range; and their behavior and ecology at the scale of both the individual and population levels. We expect these studies to support and contribute to the management of wild horses and burros.
Price, Cedar City, and Fillmore Field Offices have begun initiating the National Environmental Policy Act (NEPA) analysis of the research proposals. The public review and scoping period for these proposals are anticipated to begin early in the fall of 2015.

To learn more about the program, visit the BLM National Wild Horse and Burro website at www.wildhorseandburro.blm.gov. 

Follow us on Twitter @BLMUtah

The BLM manages more than 245 million acres of public land, the most of any federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In fiscal year 2014, the BLM generated $5.2 billion in receipts from public lands.
–BLM–Utah State Office   440 West 200 South, Suite 500      Salt Lake City, Utah 84101

 

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




Captives are at risk of being used in experiments!

Feb 16, 2016 — When wild horses and burros are held captive in holding facilities with no shade or shelter they are at risk of being used as lab animals for experiments.

We have just started a new Forum on Facebook for education and awareness about experimenting on America’s federally protected will horses and burros. You are welcome to join it here https://www.facebook.com/groups/ExperimentsOnWildHorsesAndBurros

Together we will research what’s going on and learn the truth about the horrible experiments. Then armed with knowledge and facts we can contact our elected officials, etc. and stop the cruel experiments.

Surely the Wild and Free-Roaming Horses and Burros Act of 19 never intended for our icons of freedom to be used as lab animals for experiments.

Together we can turn this around.

Best wishes,
Anne

Anne Novak
Volunteer Executive Director
Contact@ProtectMustangs.org
www.ProtectMustangs.org

PROTECT MUSTANGS
PO Box 5661
Berkeley, CA 94705

 

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




URGENT: Comments due February 3 against wild horse mare sterilization experiment

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There is no overpopulation of wild horses. BLM’s harvesting model based management via roundups is disrupting herd dynamics and increasing the birthrate. Even so BLM’s allegations of overpopulation are fraudulent based on false data. They don’t even account for the correct mortality rates in the wild. Predators need to be reintroduced if anything. Wild horses are a return-native species that help reduce catastrophic wildfires and create biodiversity. The BLM is trying to manage America’s wild horses to extinction. The bottom line is America’s federally protected wild horses are underpopulated today. The BLM is creating a false crisis to cash in on wild horses as laboratory animals for fertility control experiments.

The content below is a BLM Press Release and does not reflect the views of Protect Mustangs:

 

Hines, Ore. – The Bureau of Land Management (BLM) Burns District announces the availability of a draft Environmental Assessment (EA) for Mare Sterilization Research at Oregon’s Wild Horse Corral Facility in Hines. In cooperation with Oregon State University, the BLM is proposing to investigate the safety and efficacy of three separate methods of surgical sterilization of wild horse mares: ovariectomy via colpotomy, tubal ligation, and hysteroscopically-guided laser ablation of the oviduct papilla.

A 30-day public comment period on the EA is set for January 5 through February 3, 2016. Comments can be mailed or faxed to the BLM Burns Office at the address below, or submitted by email to: blm_or_bu_mareresearchea@blm.gov. Entire comments – including personal identifying information – may be published as part of the EA and Decision Record process. Copies of the draft EA are available for review at the BLM Burns District Office during regular business hours, or online at https://eplanning.blm.gov/epl-front-office. This link takes you to BLM’s new ePlanning website. To search for the EA and unsigned FONSI you can either use the map to locate Burns District or click on the “Text Search” tab and search by state, document type, year, and program.

Mail or deliver to:

Mare Sterilization Research Project Lead
BLM Burns District Office
28910 Highway 20 West, Hines, Oregon 97738

Fax:

(541) 573-4411
Attention: Mare Sterilization Research Project Lead

The BLM is investing in a diverse portfolio of research projects to develop new, modern technologies and methods for wild horse and burro management.

Research is aimed at finding safe and effective ways to slow the population growth rate and reduce the need to remove animals from public lands. The studies are in response to a 2013 recommendation from the National Academy of

Science to develop new or improve existing population grown suppression methods for wild horses and is in accordance with The Wild Free-Roaming Horses and Burros Act of 1971. Utah, Wyoming and Oregon have current or upcoming research projects.

For further information about Oregon’s Mare Sterilization Research project or to have your name added to the project mailing list, contact the Project Lead at (541) 573-4400.

The BLM manages more than 245 million acres of public land, the most of any Federal agency. This land, known as the National System of Public Lands, is primarily located in 12 Western states, including Alaska. The BLM also administers 700 million acres of sub-surface mineral estate throughout the nation. The BLM’s mission is to manage and conserve the public lands for the use and enjoyment of present and future generations under our mandate of multiple-use and sustained yield. In Fiscal Year 2014, the BLM generated $5.2 billion in receipts from public lands.

-BLM

The above is from a BLM Press Release and not reflecting the views of Protect Mustangs. The BLM is trying to manage America’s wild horses to extinction.


Conversation about fertility control with Brett Hass, retired biologist previously with NSA (part 1)

Don’t let pesticides like Gonacon™, PZP or SpayVac® manage native wild horses to extinction. The Spin Dr.’s and some ignorant horse advocates are pushing fertility control on underpopulated wild horses. Know the truth and expose those spewing the spin.

PM Gonacon Pesticide Fact Sheet

Read the entire Gonacon™ Pesticide Fact Sheet

Interview

John Cox: Brett, you’re a retired biologist, previously with the NSA for how many years?

Brett Hass: 46 long years John. We met in Vietnam, when we a lot younger my friend (smiles). We were doing wildlife and vegetation studies in your AO (area of operations). That was my first assignment with the NSA, as a matter of fact.

John Cox: Let’s cut through all of that. What do you think of Gonacon™ and some of the other fertility controls BLM is using?

Brett Hass: As usual, and as government agencies do and BLM and DOI are extremely guilty, they pretend that science guides its wild horse and burro management strategies. So the agencies involved go forth and resolve issues, supposedly, with experimental drugs–in this case GonaCon™. The question is, in reality, does it resolve anything at all, or is it simply to further experimentations with this drug and the wild horses the most expendable of situations currently?

The problem is very obvious, with the first-time use of an experimental drug, they act like children with a new toy–but this toy is extremely dangerous, to not only the horses and actually lead them to extinction, but the environmental consequences are apparently neglected entirely? (shakes his head negatively). . .

But let’s get real, the very absence of science contradicts any time of sound reasoning for its use whatsoever. So once again we have a government agency, using a Nazi-Type experimental fertility drug on horses and other wildlife–without knowing, or even acknowledging for that matter, what the long-term consequences are–or in perception–the problems that will arise in its actual use.

There is no resolution, as I reviewed the population situation and see first hand there is no over-population if wild horses just within the BLM numbers alone; but livestock, that is a completely different matter, in reality.

John Cox: In your appraisal of the information you’ve read, would you, as a tenured Wildlife Biologist for over 50 years, use this drug?

Brett Hass: Absolutely not! There is no pertinent reasoning to use it right now and especially on wild horses or much of anything else for that matter. Our wildlife and environment is simply too important to be so frivolous with such activity, especially an unknown situation, as fertility drugs used in our natural environment. But as you say, ignorance is quite something, and our government seems to portray ignorance quite well, and frankly the only situation they seem to be competent to accomplish.

Much more on this discussion with Brett Hass later . . .

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Below is the original PZP Pesticide Fact Sheet before HSUS seems to have lobbied the EPA to make changes to the chemical class. It’s still only approved as a pesticide to manage pests. PZP is made from slaughterhouse pig ovaries mixed with modified freund’s complete adjuvant.

PM PZP Test mares

(American wild horses used in fertility control experiments)

© John Cox, printed with permission

John Cox is a Vietnam Vet, living in the mountains of the Pacific Northwest who writes about the environment. He’s passionate about saving America’s wild horse herds and wolves. 

Read John Cox’s blog at: https://prophoto7journal.wordpress.com

Have you read about the Gonacon™ Experiment on the Water Canyon herd and the UNLUCKY 11 orphans? It all started as a PZP proposal and went down the slippery slope. . .  Read about it here: http://protectmustangs.org/?p=8488





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

The feds’ mustang population “data” is a fraud 

By Marybeth Devlin

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

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

Fish Creek (NV)
80% increase in one year

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

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

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

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

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

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

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

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

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

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

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

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

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

Here is the tool to compute CAGR:

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

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

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

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

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

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

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

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

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

Further Insight into Calculating Population-Growth

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

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

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

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

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

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