Protect Mustangs comments against spaying wild mares in Wyoming


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

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

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

January 14, 2016

Dear Public Servants at the BLM:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

PM Checkerboard ROundup Sept 20 2014

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

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

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

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

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

Sincerely,
Anne Novak

.Anne Novak
Executive Director
Protect Mustangs

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





Take Action: Save 6 wild horse herds BLM wants to wipe out!

PM Craig Downer by Rona Aguilar

Wild horse expert sounds alarm

As the new Director of Ecology and Conservation at Protect Mustangs and a concerned Carson Valley resident, I attended the Bureau of Land Management’s (BLM) “Carson City District Draft Resource Management Plan (RMP) / Environmental Impact Statement (EIS)” meeting at the Spark’s Nugget hotel casino on Tuesday, January 13, from 5 to 7 pm.

I spoke with several BLM officials including John Axtell, the Wild Horse and Burro Specialist for this district, and Leon Thomas, Field Manager for the Sierra Front Field Office. I voiced my concerns that stakeholders who previously gave much input for increased numbers and resources in regard to wild horses were being ignored in the Draft Resource Management Plan.

I heard the overview explanation of the document by Colleen Sievers, RMP Project Lead, and instructions for reviewing it. I had given earlier input during the 2012 Scoping meetings in Carson City, along with many other pro-wild horse stakeholders.

It’s important to note there are two new wilderness designations that have just been passed by Congress for this area: Pine Forest and Wovoka Wilderness Areas.

Wild horses need you more than ever to stand up for them and here’s why:

There are five alternatives presented in the RMP document, one of which is No Action, or status quo, that will include improvements for Sage Grouse survival, but little else. Another is for maximizing resource exploitation that would be disaster for many natural values upon which the long term survival of life depends. Another (Alternative C) is for maximizing conservation of nature, and another is for bringing a so-called balance of these (Alternative E). This is the preferred alternative although it does not allocate enough land, water and forage for native wild horses who are needed to reduce wildfires, restore balance to the ecosystem, and reverse desertification on public land.

The Conservation Alternative would greatly reduce livestock grazing and expand wilderness designations but pro-wild horse stakeholders and native wild horses themselves appear to have been ignored. Wild horses should be regarded as native restorers of these natural ecosystems, but in the BLM’s Draft RMP there are serious errors which imply that they are non-native invasive pests with no value to the ecosystem. This, of course, is false.

In my preliminary view, and pending a more thorough analysis of this document, it’s  outrageous to see that federal officials appear to have completely neglected the wishes of stakeholders favoring wild horses. They unfairly sided with wild horse enemies to zero out herd management areas (HMAs). The BLM’s preferred alternative are plans to zero out six wild horse “herd management areas,” (HMA’s) rendering them “herd areas.” This is a twisting of language by which the original designation of a “herd area” as an area for wild populations of wild horses/burros in perpetuity, now according to BLM means an area where the wild horses/burros have been eliminated, or “zeroed out.”

John Axtell told me that there was not enough forage or water in these areas and that their numbers were too low. However, he conveniently failed to mention how cattle and sheep have been given the great majority of forage allocations in these same areas, or how the BLM has intentionally failed to exercise the wild horses and burros’ Implied Federal Water Rights that come with any major federal act of Congress in order to secure their basic survival requirements.

The areas that the BLM appears to be planning to zero out in the preferred alternative includes some HMA’s north of Reno such as Granite Peak and Flannigan that have been assigned truly ridiculous, low appropriate management levels (AML)—plus or minus 20 or so horses.

The minimum number for a genetically viable herd is 2,500 wild horses, according to the IUCN Species Survival Commission Equid Specialist Group and these levels are even a far cry from the suspect 150 individuals that BLM documents often cite as being genetically viable for a population.

BLM also wants to eliminate the historic Wassuk wild horse herd in the Wassuk HMA just north of Mt. Grant–where Axtell told me about 125 wild horses still survive.

Axtell claimed there was not enough forage for the horses here. I can’t believe this. I have repeatedly visited this wonderful spirited herd of Spanish-type mustangs and over many decades.

Nevadan biologist and teacher Steven Pelligrini studied the Wassuk herd for his Master’s Degree in biology at the University of Nevada-Reno. His thesis was presented to the public and to the Congress in support of the passage of the Wild Free-Roaming Horses and Burros Act of 1971, when he went to testify together with Wild Horse Annie and his professor Dr. John Pontrelli of UNR.

The Carson City BLM’s RMP is targeting our wild horses for removal yet it is mandated to protect them. There exists large-scale public support for them both among the local public, nationally and internationally.

We must stand up and fight for the Wassuk wild horses and for the other venerable wild horse herds that are being dishonestly used as scapegoats for abuses attributable to uncaring people.

I noticed that at the meeting leaders of the Toiyabe Sierra Club and long time wild horse enemies, were present, and engaged with the BLM wild horse specialists and other officials. It appears they have been working to undermine the wild horse presence on public lands for many years, and I am very disturbed about this.

In the “Toiyabe Trails” publication that goes out to many thousands as a free quarterly publication, their President, Tina Nappe seems to be given carte blanche to badmouth wild horses, while those who used to be afforded the opportunity to reply, such as myself, no longer are given this basic right, even in the form of a short letter to the editor.

In spite of the horrible news in the RMP, I was urged to make a strong statement concerning my reasons against the proposed “zeroings out”. These would include how the wild horses are not getting fair grazing allocations compared to livestock in their legal areas, failure to develop or fend for watering sources for the animals and illegal fencing prohibiting their “free-roaming” lifestyle, an inherent part of the Wild Free-Roaming Horses and Burros Act.

Protect Mustangs is calling all wild horse supporters to speak out strongly in an informed and intelligent manner, for the wild horses and burros of the Carson City BLM District. This RMP/EIS revision will govern land use policy for the next 15-20 years and we must not allow it to be a death sentence for the wild horses and burros, which it largely appears to be.

This is the public’s chance to improve the treatment of the wild horses and burros, and we cannot allow another act of subterfuge.

The proposal can be viewed online at http://on.doi.gov/1uYBNGT and more information can be found here: http://www.blm.gov/nv/st/en/fo/carson_city_field.html

Here are some talking points:

1.) Both horse and burro evolution originate and have immense multi-million year duration in North America.

2.) As post-gastric digesters, different from ruminant digesters, the equids truly restore balance to the North American ecosystem. There is a lopsided preponderance of ruminants today, encouraged by established rancher, hunter, and other linked interests.

3.) Natural predators must not continue to be persecuted and eliminated, such as puma and wolf, natural predators of the wild equids.

4.) PZP and other tamperings with basic biology and social structure of wild horses and burros is contrary to the “minimum feasible” management tenet of the WFHBA as stated in Section 3 a. See my 19 points of law on pages xi to xiii of The Wild Horse Conspiracy. See sections on PZP  in the Index as well

5.) Also look up “Pine Nut wild horse herd area” in the Index of my book for more specific information http://www.amazon.com/Wild-Horse-Conspiracy-Craig-Downer/dp/1461068983

To be most effective, please make your own personal analysis of the pertinent sections of this document about which you are knowledgeable and/or concerned, especially the wild horses and burros. You can submit your comments electronically by email to:  BLM_NV_CCDO_RMP@blm.gov  or by US mail to: BLM Carson City District, Attn: CCD RMP, 5665 Morgan Mill Road, Carson City, NV 89701.

Send a copy of your comments to your two senators and your representative asking them to intervene.

The deadline for these comments is March 27th, 2015. Questions can be addressed to Colleen Sievers, Carson City District RMP Project Lead. Tel. 775-885-6000

Examples of what BLM consider to be substantive and nonsubstantive comments can be found at  http://www.blm.gov/wo/st/en/prog/planning/nepa/webguide/document_pages/6_9_2_1__examples.html 

Thank you for standing up for the wild ones!

Craig
Craig C. Downer
Wildlife Ecologist
Director of Ecology and Conservation at Protect Mustangs
Author of The Wild Horse Conspiracy http://www.amazon.com/Wild-Horse-Conspiracy-Craig-Downer/dp/1461068983
and The Horse and Burro as Positively Contributing Returned Natives in North America (American Journal of Life Science) http://www.sciencepublishinggroup.com/journal/paperinfo.aspx?journalid=118&doi=10.11648/j.ajls.20140201.12

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