Comments submitted to BLM to Protect the Pine Nut Wild Horses (Carson City, Nevada)

PM MArilyn © Eve Arnold Magnum Photos


John Axtell  (

Wild Horse and Burro Specialist

Carson City District Office

5665 Morgan Mill Road

Carson City, NV 89701

The Environmental Assessment for the Pine Nut Mountain wild horse management plan near Carson City, Nevada must take into account this herd management area (HMA) is extremely accessible to the public and international tourists with easy access from the San Francisco Bay Area as well as from the Reno International Airport and therefore the Pine Nut HMA must be preserved with the maximum level of wild horses as an educational public sanctuary on public land. The maximum level of wild horses should be determined through rigorous scientific study during a 10 year moratorium on roundups, fertility control and human intervention. Good science must prevail to ensure America’s Pine Nut wild horses–made famous in John Huston’s film THE MISFITS starring Clark Gable and Marilyn Monroe–will not be wiped out due to human intervention resulting in a lack of adaptability to survive climate change, etc.

Many photographers, poets, artists and filmmakers such as myself and our supporters rely on the Pine Nut HMA for accessibility to real wild horses on public land. We seek out wild horses to observe their natural behavior, beauty and inspiration. We don’t want to see sterile groups of wild horses nor those given pesticides ruining their bodies, natural behaviors who are part of an on the range breeding program with a “one foal” policy. We want the real deal, period

We represent thousands of supporters and ask that you do the following:

  • Halt helicopter and other removals to manage the population on the range utilizing reserve design, holistic land management with predation. Predators must not be killed but must fill their niche in the ecological balance of the Pine Nut HMA.
  • Move back into the HMA any alleged “nuisance” and other wild horses that are residing outside the HMA in areas that are not managed for wild horse habitat or that contribute to public safety concerns such as property damage and vehicle collisions. Conduct a study with a wild horse group to find and implement solutions to keep them inside the HMA.
  • Ensure that wild horses are not fenced off from water at the river.
  • Wild horses are not pests and therefore no pesticides should ever be used on native wild horses. PZP is dangerous:

“The old hypothesis — that PZP merely blocks sperm attachment — has been disproved.

Kaur & Prabha (2014) found that the infertility brought on by PZP is ” … a consequence of ovarian dystrophy rather than inhibition of sperm-oocyte interaction.” They reported thatPZP’s antibodies induce ovarian dystrophy, oophoritis (inflammation of the ovaries), destruction of oocytes in all growing follicles, and depletion of resting follicles.

Despite all the hype about PZP being non-hormonal, the manufacturer himself knew that it had an adverse hormonal effect — significantly-lowered estrogen. In 1992, he reported that ” … three consecutive years of PZP treatment may interfere with normal ovarian function as shown by markedly depressed oestrogen secretion.” Thus, PZP is an endocrine disruptor.

Worse yet, Sacco et al. (1981) found that 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. This is bad news because BLM regularly administers PZP to pregnant and lactating mares, who transfer the destructive antibodies to their filly-foals. Thus, the fillies get their first treatment with PZP in utero, while nursing, or both.

Nettles (1997) found an association between PZP and stillbirths. In 2015, the International Society for the Protection of Mustangs and Burros reported that 7 mares previously treated with PZP, when taken off it, were able to get pregnant. However, 6 of those 7 mares — that is, 86 percent — produced foals that were stillborn. All other ISPMB mares that had not been previously injected with PZP successfully birthed healthy foals. Environmental and other conditions were identical. The only variable was PZP. Meanwhile, over on the East Coast, the Corolla herd, long-managed with PZP, has recently experienced birth defects among its newborns.

Gray & Cameron (2010) questioned the supposed benefit of PZP-sterilized mares living much longer than their normal life expectancy, and and Knight & Rubenstein (2014) warned of unintended consequences of PZP’s ironic effect of extended longevity. Ultra-elderly mares take up scarce slots within AML-restricted herds. They consume resources but 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. Meanwhile, those few foals that are born have to be removed to achieve AML because they’re more adoptable.

Ransom et al. (2013) conducted a longitudinal study of three herds currently being managed by PZP — Little Book Cliffs, McCullough Peaks, and Pryor Mountain. They found that the the birthing season lasted 341 days — nearly year-round — which puts the life of mares and foals in jeopardy. Nature designed the equine birthing-season to occur in Spring, not year-round, and certainly not in the dead of Winter.

Ransom et al. also 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. They 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.”

PZP’s manufacturer conceded that it could take up to eight years to recover fertility after just three consecutive PZP treatments.

The study on PZP by 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.

PZP’s manufacturer was quoted describing PZP as “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 staff and volunteers believe that PZP is boringly safe, they will be less likely to protect themselves adequately from this dangerous pesticide. Indeed, many of the volunteers are women and, therefore, at risk. Accidental self-injection with PZP could cause them to suffer diseased ovaries and depressed estrogen-levels — in addition to infertility and, potentially, sterility.Consider the magnitude of the risk — the PZP-in-question is a horse-size dose.” ~ Marybeth Devlin, Wild Horse Advocate

  • PZP, GonaCon, and Sterilization would ruin natural behavior that we specifically go to the Pine Nut HMA to study and enjoy. Therefore this junk must not be forced upon wild horses. No experiments. No collars. Respect their right to true freedom.
  • We request you re-evaluate AMLs to accommodate the present wild horse population without removals, making forage adjustments, if necessary, pursuant to CFR 43 C.F.R. 4710.5(a).
  • Conduct a complete headcount and public database with individual photos of every wild horse on the Pine Nut HMA with their basic information. Follow the wild horses and note all the deaths. Do you know even how many have died since birth in the past 2 years? How many have died of natural causes including predation and how many have been shot or poisoned by humans?
  • Increase penalties for killing wild horses.
  • Include a complete identification and analysis of the various causes of land degradation — AND their corresponding degree of impact — including but not limited to motorized uses (OHV, etc.), extractive uses (mining, etc.), various recreational uses, and other uses for each area, inside and outside of HMAs, analyzed in the EA.
  • The Environmental Assessment must include a complete disclosure and analysis showing the degree of disturbance that each of the following negative impacts has on the bi-state sage grouse: renewable energy projects, extractive uses, motorized vehicle uses, recreational activities, power lines, fencing and other man-made structures have on the bi-state sage grouse behaviors and habitat–mapped and analyze for the degree and range (circumference) of impact each has on bi-state sage grouse behaviors and habitat within the HMA.
  • Analyze the HMA exclusively to be used for wild horses and other wildlife to prevent the degradation of public lands within and outside the herd management area. Expand the HMA if needed to the original acreage designated to wild horses. What would the impacts be and how would the thriving natural ecological balance and Sage Grouse flourish?

We will not allow wild horses to be scapegoated for damage caused by other species or land users.

Thank you for allowing us to participate in the public process.


Anne Novak

Executive Director

Protect Mustangs

Tel./Text: 415.531.8454

Read about native wild horses: 



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

PM Pine Nut Wild Horses ©Craig Downer

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

12 thoughts on “Comments submitted to BLM to Protect the Pine Nut Wild Horses (Carson City, Nevada)

  1. Send BLM your comment regarding their request for comments on the Pine Nut wild horse HMA. The info is here:

    BLM seeks input on plan to manage Pine Nut Wild Horses

    Carson City, Nev. – The Bureau of Land Management (BLM), Sierra Front Field Office is soliciting your input on the management of wild horses in the Pine Nut Mountains. The BLM will be developing a 10-year plan to manage wild horses in the Pine Nut Mountains that could include wild horse gathers, implementation of population growth control measures, public education and outreach, habitat improvement/restoration, and monitoring protocols. The goal is to maintain or restore a thriving natural ecological balance of wild horses and their habitat. Public comments will be accepted through July 6, 2016.

    The Pine Nut Mountains Herd Management Area (HMA), an area designated for the management of wild horses and their habitat, is located within the Pine Nut Mountains. The Pine Nut Mountains are located in Carson City, Douglas, and Lyon counties, Nevada. In April 2016, the BLM conducted an inventory of the Pine Nut Mountains and observed 536 wild horses. The appropriate management level for the HMA is 119 to 179 animals. Thirty-nine percent of the wild horses were observed outside the HMA, including in urban interface areas such as Deer Run Road, Dayton and Fish Springs. The BLM has published a Final Summary of Current Conditions for the HMA that concludes that vegetative trends and riparian functional assessments for springs demonstrate that wild horses are a causal factor in the deterioration of conditions.

    The purpose of the proposed plan would be to address the following issues:

    · Prevent the degradation of public lands within and outside the herd management area;
    · Address nuisance and other wild horses that are residing outside the HMA in areas that are not managed for wild horse habitat or that contribute to public safety concerns such as property damage and vehicle collisions;
    · Address long-term population trends within and outside the herd management area; and
    · Manage wild horses in a manner that supports meeting Bi-State sage-grouse habitat objectives.

    For this plan, the BLM will be preparing an environmental assessment (EA) to comply with the National Environmental Policy Act. The draft environmental assessment would assess the direct, indirect and cumulative effects from the proposed plan and alternatives.

    For more information, maps and a copy of the Final Summary of Current Conditions, please go to the project website at

    Send comments to: John Axtell, Wild Horse and Burro Specialist, 5665 Morgan Mill Rd, Carson City, Nevada 89701 or email at: Comments can also be faxed to: 775-885-6147 Attn: John Axtell. For more information contact John at: 775-885-6000.

    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 sustain the health, diversity, and productivity of AmericaÂ’s public lands for the use and enjoyment of present and future generations. In Fiscal Year 2015, the BLM generated $4.1 billion in receipts from activities occurring on public lands.
    Carson City District Office 5665 Morgan Mill Road Carson City, NV 89701

  2. To: John Axtell

    I have reviewed the BLM and Natural Resources Committee meeting video and after review it has become crystal clear that our wild horses/equines will be EXTINCT imminently if this plan that has been approved and that is Government sanctioned is NOT stopped immediately.

    As an American Citizen I demand that the illegal round-up; capture; inhumane and torturous imprisonment of our wild horses STOP NOW! These precious equines lack even the basic of needs, such as proper shelter, food and water. The imprisonment of wild horses ultimately amounts to cruelty beyond description for them. The ultimate travesty and miscarriage of justice is that the laws that already exist and that are supposed to be in effect to protect these wild horses/equines have instead been trampled on and ignored which has led to their betrayal and destruction with many ending up on a hellish transport to Mexico and Canada for slaughter.

    The American people have NO say in what happens to our Nations Wild Horses which are our Country’s National Treasures and Icons and they should be protected as such, but instead of protection they are being decimated to near extinction as the true numbers of wild herds have been covered up and lied about for years.

    Further: I also demand the immediate cessation of the inhumane and barbaric sterilization procedures and the systemic monstrous poisoning of the wild mares by PZP, GONACON, or any other toxic poison that the BLM uses to supposedly sterilize these helpless mares.

    The systematic and cruel extinction of wild horses is taking place with the knowledge, cooperation and facilitation of the every Government powers enabled to protect them. Our wild horses/equines will be EXTINCT if these plans are permitted to continue.

    I am one of mighty army of horse warriors that will hold the blood of our precious wild horses on the hands of all who perpetrated and fostered the unabated slaughter and extinction of our wild horses/equines.

    signed.Jackie Farquhar

  3. The pine nut horses should remain on public land where they are at home,without any PZP experimenting or any other pesticides.The BLM insane experimenting is causing more damaged then good,we will lose the wild horses if this continues.Please no more round ups,PZP experimenting,no more splitting them from their family/herd.BLM I thought your job was to protect the wild horses , not destroyed them.Please live up to what your job duty are,and listen to the million of people who want the Wild horses to remained Wild on public land.Lets show them we can Co-Exist with them.Just Because the horses are not needed for our own selfish uses does not mean they are not needed to for our Earth/Their Earth.Please leave them Free and alone, Unmolested by our humans hands.We need to remember all species are Priceless.

  4. The Wild Horse in the wild ,Natural .Horse ,very important to the Horse Industry ,and the Ecosystem ,, we must protect our Wild Horses ,,

  5. Way to go in standing up for our wonderful wild horses and their right to live free in a world not overrun and messed up by benighted people!

  6. .r. AXTELL, As a life-long horse gazer and horse lover, I would like to put forth these commets on Blm horse roundups on public lands. This is a cruel and inhuman way to crontrol horse population. Thisvhas not worked to your advantage because nature is stronger than the Cattle Association and the Blm. We, the people do not want this to go on. The horses are suffering from being corralled and wharehoused and lack of space. They have been starved, sexually altered, taken away from family herds and sent to slaughter Now you want to do experiments on them to keep them from breeding and then send them to market because your holding pens are overcrowded. This whole discrimination of horses has gone way to far! This is like the war in Europe with the Jewish people and the Gestopo, the horses being the prisoners and the Blm and the United States Government being the tormentors. This is sickening and makes me sick everyday that I hear about another roundup. All involved should be ashamed to be a part of this holocaust for horses.

  7. We need to keep our wild in the west! For future generations to see! Iam not writing to beat the BLM down. We need to keep what wild ones are left on the range! Remove the thousands of cattle ruining our public lands!

  8. Anne Novak you have once again proposed a clear, concise and humane way to manage and maintain all our wild horses, donkeys, burros and mules. I just don’t understand why your plan can’t be put into place.

    We have plenty of land available for herds to run free and be with their families and not interfere with ranchers.

    Horses have existed for ages and will continue to do if managed properly and humanely.

    We thought nothing of taking farmers horses during the wars. They were invaluable; only to be paid for their loyalty by being slaughtered after the war. Typical of how we treat our war heroes.

    Our horses , like our war heroes, should be given our utmost respect. Given them land, where they will have freedom, food, water, shelter to protect them no matter what the weather. They deserve freedom from inhumane and frankly needless round-up and PZP experiment s.

    They our our national and natural treasures and should be treated as such.

    We repair and maintain our national monument. We should do the same for our wild horses, donkeys, mules an burros. Thank you.

  9. There is no overpowering necessity for limiting the Pine Nut HMA wild horse population. The Pine Nut HMA is severely underpopulated now compared to the recent historic past, and especially compared to the deeper background past. Further, human interference through PZP administration is detrimental to any possible future for herd genetic viability as demonstrated through peer reviewed science.

  10. America’s wild horses are known all over the world through literature, film, media and history as thought at billions of schools. They belong to all the citizens of our great country, as they are our historical icons, spirit of freedom, and symbol of the West. Their management should have to do with care to allow them the free range, access to water, and support of their lives as wild animals they have been for centuries. I and a great number of citizens believe that our government should not be involved in cruelly capturing and holding, and disposing of them through sale to slaughter in Mexico and Canada, neither should it fill them up with harmful chemicals to stop their procreation, and thus destroy them in yet another way. Their rangelands should not be grazed by cattle and other stock, they should not be used for fracking, they should not be sold, or be given over to individual states to do with as they wish. They should remain theirs to graze and migrate as is their nature. A great many actions taken to allegedly help the wild horses have been an inhumane disgrace, from helicopter round ups to use of experimental birth methods on them. Such cruelty has to stop. We must preserve this living monument of wild horses as live and free.

  11. The American people DEMAND that our wild horses and burro’s be protected. We DEMAND IMMEDIATELY CESSATION OF ROUNDUOS AND EXTERMINATION OF OUR NATIONS LIVING HERITAGE. We the PEOPLE will no longer stand idly by while our wild equines are systematically cruelly removed and tortured in BLM Nazi like experiments, inhumane holding pens, and sold for pennies on the dollar to kill buyers and hide no contempt for our Nation’s treasures as pests that are to be zeroed out as per BLM ‘s own words. We the people will no longer be silent while the agonizing cries of these precious sentient beings go unanswered . We hear their terrified screams as stallions are inhumanely gelded and mares are experimented on with Nazi like cruelty. While they leave them inhumanely corralled together to fight and die and to suffer from the intense heat of summer and the bitter cold of winter without proper shekter. We will raise our voices to the highest levels of government and we will not stop until this extermination of our wild horses ends and they are protected as they are legally supposed to be protected right now under the WFHBA passed info law. You the BLM are wicked law breakers. We know you have lied and deceived the legislature and the American people. We will not stop until you are stopped. We the PEOPLE have a voice now and we will use it. STOP KILLING OUR HORSES AND BURRO’S. NOW.

  12. I’m appalled that this has been allowed. Obama lifted this and many horses have died. Praying they will be protected again and soon.

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