Watch a newborn wild foal near Carson City

Pine Nut Wild Horses ©Anne Novak for Protect Mustangs

Pine Nut Wild Horses ©Anne Novak for Protect Mustangs

Wild and free is their world

Without Protect Mustangs’ and FoA’s successful 2015 lawsuit protecting the Pine Nut Herd from the roundup and forced drugging with pesticide PZP, this little foal and her band would have been chased by helicopters for miles. . . If she wasn’t abandoned then she would be ripped from her home on the range forever to live and nurse in a dirty pen with no shelter.

A few months later she would be separated from her mama. This would be too early for a wild foal to be weaned. She would be separated from her mama forever at that point with no one to comfort her when she’s sad or scared.

We are very grateful she was born in the wild.

(Video by John Humphrey)

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




Marybeth Devlin comments on the Sulphur Wild Horse roundup plan

Email: blm_ut_sulphur@blm.gov

Copies: jwhitloc@blm.gov, tchristense@blm.gov, eburghar@blm.gov
January 19, 2016
Cedar City Field Office
176 E DL Sargent Drive
Cedar City, UT 84721
Project Name: Sulphur Wild Horse Gather Plan

Document: Environmental Assessment — Preliminary

NEPA ID: DOI-UT-C010-2015-0011-EA
This letter responds to your request for substantive comments and new information that BLM-Cedar City should consider regarding the subject Plan. I submit mine as an interested party in behalf of the wild horses of the Sulphur Herd Management Area (HMA).

I support the use of radio collars to track the horses and the construction of a fence along Highway 21 for the safety of both horses and humans. However, I urge you to cancel the roundup-and-removals, discontinue PZP treatments, correct the fraudulent population-estimates, and take other specified corrective actions.

I suggest the addition of another alternative: Increase the AML, collar the horses, fence the Highway but remove interior fences, conserve apex predators, and install guzzlers throughout the HMA.

As for the proposed alternative, if BLM has confidence in the WinEquus population-growth modeling, then please note that the “removals only” alternative yields a median-trial average herd-size that is nearly 24% lower than the proposed alternative — 318 versus 417. As for PZP injections, they should be abandoned because they are dangerous to the mares, to the foals (born and unborn), and to the staff and volunteers that handle the pesticide.

For ease of reference, here are the links to the documents at issue:

News Release — 2015 EA

http://www.blm.gov/ut/st/en/info/newsroom/2015/December/EAsulphurwildhorsegather.html

News Release — 2015 Public-Safety Removals

http://www.blm.gov/ut/st/en/info/newsroom/2015/february/public_safety_concerns.html

Sulphur Gather Environmental Assessment — Preliminary

http://www.blm.gov/style/medialib/blm/ut/natural_resources/wild_horses_and_burros/general.Par.73121.File.dat/Preliminary%20Sulphur%20Gather%202015%20EA_12_18_15.pdf
REASONS CITED FOR GATHER-REMOVE-CONTRACEPT PLAN
Overpopulation, Forage Limitations

BLM lists overpopulation and forage / water limitations as the need for the proposed action. The “overpopulation” in this case merely means “over AML”. And because the AML is arbitrary and unscientific, it is meaningless. Range-conditions function as natural feedback to wild horses, allowing them to self-regulate their numbers. That is how Nature works. BLM is meddling unnecessarily. The intervention that is needed would be to offset the impact of livestock-grazing — eliminating interior fences that block wild-horse movement and installation of trick-tanks (guzzlers) to capture and store precipitation.
The Proposed Action

BLM-Cedar City plans to conduct two-to-four helicopter-style roundups-and-removal operations over the next 10 years to bring the herd’s alleged overpopulation down to the low-bound of the arbitrary management level (AML) — 165 horses on 265,675 acres — and maintain it there. BLM claims there are “excess” horses but the EA does not reveal the number. Instead, the EA goes on and on about the historical numbers and removals. Not even a “ballpark” figure is listed for how many horses BLM would remove initially, some sources have mentioned “over 500.”

BLM further plans to forcibly inject all of those few mares it plans to allow back into the HMA with PZP-22, the long-acting version of the pesticide. PZP is known to sterilize after as few as three injections in mares, or after just one shot in fillies that have not yet reached puberty. And the EA states that BLM plans to administer PZP treatments to yearling fillies.

http://dataspace.princeton.edu/jspui/handle/88435/dsp01vt150j42p
Baseless and Biased Assumptions

A review of BLM’s data — its assumptions, claims, population-estimates, gather-data, and PZP-inoculations — for the Sulphur herd disclosed

Grossly-exaggerated estimates,
Failure to adjust for PZP’s contraceptive impact,
Failure to factor in wild-horse deaths on the range from natural causes,
Ignorance of the new study that found the effective birth-rate averages 10 percent,
Ignorance of the new data showing “hands-off” management results in 5-to-8 percent growth,
Failure to include studies — both old and new — that reveal PZP’s damaging impacts, and
FRAUDULENT POPULATION ESTIMATES
Birth Rate versus Herd-Growth Rate

Before we examine BLM’s reported herd-growth rates of this HMA, 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. BLM claims an average birth rate in wild-horse herds of about 20% a year. But herd-growth is unlikely to reach 20 percent a year. Here’s why: Horses die.

An independent study reviewed BLM roundup-records for a representative sample of four herd management areas and a robust sample-size 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. Cedar City’s claim that 95% of the Sulphur foals survive is not credible. It is just self-serving for administrative convenience in equating the birth rate to the growth rate. That wrong assumption has been disproved. Moreover, I note that the 2013 inventory counted 25 foals born out of season. That anomaly was likely due to the PZP treatments, which research by Ransom et al. (2013) disclosed.

http://www.ncbi.nlm.nih.gov/pubmed/23383018

However, CCFO failed to include that study as a reference; and although it did cite another Ransom et al. study (2010), it was not included in the EA’s “References” section either.

Births outside the normal parturition-pulse put the survival of both the mares and foals at risk.
Adult Wild-Horse Mortality Rate Must Be Factored

But it is not only foals that die. Adult wild horses also perish. They succumb to illness, injury, and predation. Indeed, the EA claims that 8 horses were found dead in 2015. The adult death rate must be taken into consideration. Adult mortality is at least as high as the 5% a year for horses that die in short-term holding, where they are fed, watered, and provided care.

Given the 50% foal mortality-rate, and the 5%-or-higher average annual death rate of adult wild horses on the range, herd growth could not increase 20% a year, and a herd-population could not double in 4 years — refuting yet another BLM myth. But BLM ignores mortality — foal and adult — in its population-estimates, which exaggerates the numbers it posts.
The Herd-Growth Rate Must Necessarily Be Lower Than the Birth Rate

In light of the high foal-mortality rate and the expected adult wild-horse mortality rate, the herd-growth rate must always be lower than the average 20% birth rate. However, herd-growth rates many times higher than 20% — which would necessarily mean birth rates substantially higher still — are routinely found in BLM’s population data, including the year-to-year figures for Sulphur HMA and other HMAs under Cedar City Field Office’s jurisdiction. 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 one of the ways BLM creates the false impression of a population-explosion.
Stochastic Events Also Reduce Herd Growth

BLM also 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 Sulphur herd. Note that the Saiga deaths involved antelope-mothers and their calves. What if Sulphur’s few fertile mares and their foals perished all of a sudden, leaving mainly stallions and sterile old mares? BLM must proactively manage the herd per IUCN International Union for the Conservation of Nature guidelines, if only in case of stochastic events.
Maximum AML Set Below Minimum Viable Population

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, including Sulphur. What is the MVP? According to the International Union for the Conservation of Nature: 2500, a number which could easily be accommodated by the 265,675 acres of the Sulphur HMA.
Phony Population-Estimates

According to BLM’s 2013 population-estimate, the Sulphur herd was reported to have had 384 members. The corresponding estimate for 2014 showed 718 horses.

http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html

Let’s do the math.

718 in 2014
– 384 in 2013
——-
334 — an 87-percent increase (334 ÷ 384 = 87%).

This is improbable. Even if 87% were only the birth rate, it would be 335% higher than the 20% birth rate that BLM claims as average and which the independent study by Gregg et al. confirmed. Surely, herd growth — births minus deaths — could not be that high.

BLM attributes the impossibly-high estimate to “improved inventory methods.” But as has been pointed out to BLM previously, the “mark-resight” method, conducted by helicopter, appears to overcount the population. Indeed, as the report by the specialty-contractor who conducted the Red Desert Complex (Wyoming) census 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.

http://www.blm.gov/wy/st/en/info/NEPA/documents/rfo/red-desert.html
Population and Gather Reports — The Data

Discrepancies were evident per a review of the …

HMA and HA Statistics reports for the Sulphur herd from 2008-2015,
Completed Gathers reports from 2009-2014, and the
Population-figure referenced in CCFO’s News-Release for 2015’s public-safety gather,
Sulphur HMA — Utah — Herd Population Changes — 2008 to 2016

The following chart merges the yearly population-estimates with the gather and contraceptive data to reveal how the numbers were calculated and where errors were made initially, which caused them to compound. The beginning-of-the-year figure for 2015 — the pre-gather estimate — was per the BLM’s pre-safety-gather News Release.

Max Beginning
Year AML Estimate R-up Done Foal-Crop and Other Figures, Estimates
2008 250 435 + 87 BLM estimated foal-crop @ 20%.
Falsely equated it to the herd-growth rate.
November 522 Pre-gather estimate = 435+87
362 Rounded up
333 Removed
29 Released
160 Assumed to have evaded capture
1 Tacked on
——
190 Post-gather estimate = 29+160+1
2009 190 + 40 BLM estimated foal-crop @ 21%
Falsely equated it to the herd-growth rate.
230 End-of-year estimate = 190+40
2010 230 + 67 BLM estimated foal-crop @ 29%
Falsely equated it to the herd-growth rate.
December 297 Pre-gather estimate = 230+67
250 Planned to gather
90 Rounded up — 36% of plan
30 Removed
38 Mares vaccinated with PZP
22 Other horses also released
207 Assumed: evaded capture
—–
267 Post-gather estimate = 38+22+207

2011 267 + 53 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
PZP would not have affected mares
—– already pregnant when inoculated.
320 End-of-year estimate = 267+53
2012 320 + 64 BLM estimated foal-crop @ 20%
Falsely equated it to the herd-growth rate.
But that birth-rate estimate was wrong.
PZP was at maximum effect and
—– would have reduced the foal-crop.
384 End-of-year estimate = 320+64

2013 384 +334 BLM estimated foal-crop @ 87%
Falsely equated it to the herd-growth rate.
Not only implausible generally, but
PZP was still exerting contraceptive
—– effect, would have reduced foal-crop.
718 End-of-year estimate = 384+334
2014 718 +144 BLM estimated foal-crop @ 20%
thus compounding earlier errors.
Falsely equated it to the herd-growth rate.
August 36 Rounded up — “outside”
30 Removed
6 Released
826 Assumed: Still present in HMA
– 2 Subtracted
—–
830 End-of-year estimate = 718+144-30-2
2015 830 Public health and safety excuse used
to justify removing 100 wild horses
without an EA.
February – 101 Number removed — plus 2 horses
said to be “domestic.”
The subject EA states: “Currently there are
approximately 200 head of wild horses that
are within 6 miles of Highway 21. These
horses are continually on the highway in search
of space, forage and water.” EA pdf-page 28
My comments: So, 200 took the place of the
100? Implausible. Wild horses roam. It’s their
nature. That’s why a safety-fence is needed.
—–
729 Adjusted population estimate
2015a 729 146 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
– 8 Deaths
—–
867 End-of-year estimate = 729+146-8
2016 867 173 If BLM estimates foal-crop @ 20%
and falsely equates it to the herd-growth rate.
—–
1040 Possible pre-gather estimate = 867+173
The discrepancies identified herein cast doubt on the validity of the population-estimates. These errors must be reconciled before any decisions regarding removal-actions are considered.
Not the First Time Population-Estimates Were Found to Be Flawed

In May 2014, I submitted comments regarding the environmental assessment for Bible Spring Complex, which is also under BLM-Cedar City’s jurisdiction. For the three HMAs and the one HA that compose the Complex, major discrepancies were disclosed — one-year growth-rate-estimates of …

125 %
131 %
153 %
157 %
249 %

Thus, the errors uncovered with regard to BLM’s population-estimates for the Sulphur HMA are not isolated instances. Together with those revealed for the Bible Spring Complex, these disparities point to a systemic problem.

Recommendations: BLM needs to correct its mathematical errors and acknowledge those mistakes to the public. Elected officials, local permittees, and ordinary taxpayers need to know that the population-estimates previously announced for the Sulphur HMA were wrong. BLM must take responsibility and inform the public that it portrayed an incorrect picture — an exaggerated picture — of the herd’s population.

Recommendations: Stop the inflammatory rhetoric. For example, the EA warns, ominously: “If horse populations were allowed to continue to double or triple throughout the HMA, wild horses would utilize all of the available AUM’s allocated for other resources.” EA pdf-page 27 Scare tactics have no place in a legitimate EA. Stop the nonsense.
Societal Impact of Inflated Population-Data

The population-estimates for the Sulphur HMA are flawed, exaggerated. The political fallout of this error has been to keep the public — particularly 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 in Utah.
County Commissions Pass Resolutions, but Commissioner Goes to Jail

The EA cited the resolutions that local county commissions have reportedly passed, demanding that BLM reduce the herd to AML. However, one of the ringleader-commissioners, Phil Lyman, was recently sentenced to jail after having been convicted of conspiring to operate off-road vehicles on public lands closed to off-road vehicles, and operation of off-road vehicles on public lands closed to off-road vehicles. He and a co-conspirator must pay their share of $96,000 in damage caused and serve 3 years probation.

Federal prosecutor Jared Bennett asked the judge to sentence Lyman to a “limited but reasonable” prison term to promote respect for the law and to deter others from committing the crime. Lyman knew the ride was illegal and he used his political office to recruit others to participate, he said.

http://www.deseretnews.com/article/865643995/Judge-sentences-San-Juan-Commissioner-Phil-Lyman-to-10-days-jail-3-years-of-probation.html?pg=all
Bogus Data Inflames Local Ranchers and Costs Wild Horses Their Freedom

The EA states that there have been requests over the past two years from land owners adjacent to the Sulphur HMA for removal of wild horses. These requests most surely came from renegade ranchers, such as LaVoy Finicum of Arizona who, inspired by Cliven Bundy, has gone public with his refusal to recognize BLM’s authority, to pay his grazing fees, and to comply with season-of-use. In Nevada, in addition to Cliven Bundy, Kevin Borba and Dan Filippini blatantly defied BLM’s authority; yet they too were pacified with concessions. BLM enables and rewards such bad behavior by caving in to it. There are likely permittees in Utah emulating Bundy, Borba, Filippini, and Finicum.

http://www.stgeorgeutah.com/news/archive/2015/11/01/mgk-finicum-blm-dispute-bundy/#.VjeBkW7ko1c

The EA’s proposed removals of wild horses and pesticide-treatments on the few allowed to remain appear designed to placate the seditious elected officials and their rogue-rancher constituents, who are making a play for taking over the Federal lands in Utah. However, the wild horses must not lose their freedom merely so that BLM can kowtow to rebellious elements in the human population. If you “come clean” and admit your errors, it will tend to deflate the “head-of-steam” that the officials and ranchers are building due to the false appearance created by fictitious figures on herd-growth.
Bundy Brothera and Finicum Lead Armed Takeover of the Malheur National Wildlife Refuge

Ammon and Ryan Bundy, along with LaVoy Finicum are the “spokesmen” who have commandeered the Malheur Wildlife Refuge. Armed for battle, they continue, as of this writing, to occupy. Using Federal vehicles and machinery, they tore down a fence built to keep trespass-livestock out. They come and go as they please, even soliciting snacks and coffee creamer (French Vanilla) from supporters. The situation is out of control. BLM and FBI appear to be kowtowing to the rebels.

Here are excerpts from a news report:

The militants occupying the Refuge asked Harney County ranchers to tear up their leases with the Bureau of Land Management and stop paying the federal government to graze cattle on public land.

“I’ve done it. Cliven Bundy’s done it,” said LaVoy Finicum, an Arizona rancher and the militants’ defacto spokesman. “Now is the day. Now is the time. Are you going to wait for tomorrow? For next week? Next month? Next year? When? When will you stand up if not now?”

Finicum invited the ranchers to cancel their leases with the BLM at a ceremony before the media at the refuge on Saturday. He said two ranchers, one from New Mexico and another from Harney County, are scheduled to void their contracts publicly.

Ryan Bundy went on to emphasize his view that breaking away from the federal government means ranchers wouldn’t have to follow federal laws, like the Endangered Species Act.

LaVoy and the Bundys also acknowledged their proposition is risky. They said any rancher who joined them would get protection from the armed militants ….

http://www.opb.org/news/article/ammon-bundy-oregon-grazing-blm-finicum-crane/
QUESTIONABLE CAWP, FALSE REASSURANCES
CAWP Condones Abuse

The Comprehensive Animal Welfare Program (CAWP) for rounding up wild horses has farcical features. For example, hitting, kicking, striking, and beating a wild horse “in an abusive manner” is prohibited. The guidelines do not define at what point such mistreatment would be deemed “abusive” and, at any rate, there are no consequences identified for violating the prohibition.

Another example: The roundup–helicopter–the CAWP okays the use of helicopters — is not allowed to hit a wild horse. (There is plenty of video-footage showing that such ramming occurs.) If the helicopter hits a wild horse, what to do? The CAWP says: Document it! Again, there are no penalties for such abuse.

Yet another example: The helicopter-pilot must not drive wild horses to the point of exhaustion. The attending veterinarian–if there is one (the CAWP requires one be present but the EA says there “may” be one)–must “check for signs of exhaustion.” And …? And, nothing. Just check. No penalties.

One more example: The CAWP allows electric prods to be used on the horses “no more than three times during a procedure … except in extreme cases with approval ….” Who’s counting? Who is able to supervise properly in the chaotic conditions of a wild-horse roundup? Hotshots are abusive and should never be used. Ever.
BLM Lies about Impact of Abusive Roundup

The EA’s standard wording disinforms the reader that virtually all negative impacts of roundups disappear within hours to several days of when wild horses are released back into the HMA. That is false. Please refer to the report linked below. I recommend BLM add it to the “References” section after studying it and reforming your methods accordingly.

http://thecloudfoundation.files.wordpress.com/2010/04/bruce-nock-report-final.pdf
BLM Fails to Address Results of Helicopter Hearing

The EA states:

As required by regulation [43 CFR 4740.1(b)], a public hearing was held in Price, Utah on December 8, 2015 and will be held in subsequent years to discuss the use of helicopters and motorized vehicles in the management of Utah BLM’s wild horses and burros. … Comments received from the Preliminary Environmental Assessment (EA) and at those public meetings will be considered and, if applicable, will be addressed in management actions, NEPA documents, and decision documents using the most current direction from the National Wild Horse and Burro Program. EA pdf-page 44

I submitted detailed, substantive comments for the hearing. By now, BLM should have acted upon them and made reforms.
BLM Lies about Foal Weaning

In more standard wording, the EA states: “Nearly all foals that would be gathered would be over four months of age and some would be ready for weaning from their mothers. In private industry, domestic horses are normally weaned between four and six months of age.” EA pdf-page 37

Please note that in “private industry,” foals receive special feed and supplements, and they would be sheltered from the elements. In the wild, foals nurse for many months longer than in domestic settings, where the profit-motive leads breeders to wean early — a traumatic event for both foals and their dams.
Increased Foaling Rates?

BLM claims to need to reduce the wild-horse population. Yet the EA states: “Achieving the AML and improving the overall health and fitness of wild horses could also increase foaling and foaling survival rates over the current conditions.” EA pdf-page 36 This is an example of BLM’s eagerness to justify the unjustifiable. But in so doing, BLM belies its own contentions.
BLM Lies about Population Growth

In looking for every reason not to adopt any alternative but the proposed one, BLM insists repeatedly that unless mass-removals and PZP treatments are conducted, “… wild horse populations may increase at a faster rate and exceed the high end of the AML ….” EA pdf-page 38 However, that contradicts the WinEquus population-projections, which show a higher median-trial population for the proposed action.
BLM Lies about PZP Safety

The EA claims PZP injections would not affect unborn foals. That is false.

Sacco et al. 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. Yet, PZP is regularly administered to pregnant and lactating mares, who transfer the destructive antibodies to their fetus, via the placenta, and to their foal, via mother’s milk.

If mares are injected with PZP while pregnant or nursing, these fillies will already have PZP antibodies cross-reacted with and bound to their zonae. Therefore, when such fillies are injected as yearlings, it will be their second treatment, or potentially even their third. In fact, they could already have been sterilized in utero or while nursing.

http://www.ncbi.nlm.nih.gov/pubmed/7328557
BLM Lies about Gender Ratio

The EA warns that gender-ratios could become lopsided if the proposed action were not taken: “Near normal populations exhibit a 1:1 sex ratio. Population shifts favoring males could occur as males are better adapted to compete for resources during changing environmental conditions.” EA pdf-page 41

But BLM also advises that, for the WinEquus population-modeling trials, one of the assumptions employed was: “Sex ratio at birth: 58% males.” EA pdf-page 90 Further, I note that following the 2008 gather, 12 females and 17 males were returned to the range, giving males a 59:41 percent advantage to the males. Finally, bachelor-stallions are more successful in escaping from helicopter-roundups. They have no mares and foals to protect. So, the roundup-method itself creates a post-gather herd skewed to more males than females.
BLM Uses Obsolete Range Assessment Technique

The EA states that the “Key Forage” method was used to evaluate range-conditions. The full title of that approach is the “Key Forage Plant” (KFP) method. However, KFP is obsolete, having been replaced by the Landscape Appearance method as far back as 1996. Moreover, per Technical Reference 1734-7, Ecological Site Inventory, such qualitative assessments “may result in reduced accuracy, limiting use of the data.” If for only this reason, I cannot rely on the EA’s representations regarding conditions in the Sulphur HMA.
BLM Lies about Year-Round Wild-Horse Presence

The EA states that wild horses do more damage because they are present year-round as opposed to livestock, which supposedly are not. However, inspection of the Active-Use chart EA pdf-page 20 reveals that nearly 49% of the livestock allotments are used year-round, and 67% are used 8-to-12 months. Further, actual-use is whatever the permit-holders self-report. Going back to the rogue ranchers in open rebellion against BLM, it is likely that real use is much higher than “actual.”
BLM Hauls Water but Fails to Install Guzzlers

BLM states that water is the limiting factor for wild-horse populations, and claims to have hauled 160,000 galllons of water into the HMA last summer for the wild horses. EA pdf-page 20 What this points to is the need for guzzlers — trick-tanks — to capture and store whatever precipitation there is.
BLM Falsely Blames Wild Horses for Damage to Riparian Areas

In its zeal to condemn the wild horses, BLM lumps wild horses in with livestock as responsible for damage to riparian areas. Yet, the EA also notes that it “is not the nature of wild horses to rest exceedingly at water sources.” EA pdf-page 53 Stop the false accusations. Your bias is showing.
BLM Plans to Use Barbed Wire for Safety Fence

Horses and barbed wire do not mix. Yet, the EA states that barbed wire will be used for the fence along Highway 21. That is not good enough. You need to use appropriate materials that pose less risk of injuring the horses.

Here are some links to information on the various types of fences and their price-ranges. Note: I have no connection whatsoever with any of these groups.

http://horseandrider.com/article/field-guide-to-horse-fences-13317

http://www.progressivecattle.com/topics/facilities-equipment/4793-building-fence-a-yearly-job-on-every-ranch

http://www.extension.iastate.edu/agdm/livestock/html/b1-75.html

http://www.rammfence.com/fence/coated-wire-fence/coated-wire-fence-rolls/high-impact-raceline-coated-wire.html
BLM Notes Interior Fences Block Wild Horses

The EA admits, without further explanation: “Construction of fences within Sulphur HMA boundaries could inhibit the free-roaming nature of wild horses.” EA pdf-page 42 It is time to remove interior fences, not to install more. This matter needs to be resolved.
Finally, Some Truth-Telling

It was refreshing to encounter at least some truthfulness in the EA:

At the turn of the century, large herds of livestock grazed on unreserved public domain in uncontrolled open range. Eventually, the range was stocked beyond its capacity, causing changes in plant, soil and water relationships. Some speculate that the changes were permanent and irreversible, turning plant communities from grass and herbaceous species to brush and trees. EA pdf-page 43

BLM needs to stick to the facts and cease blaming wild horses for what livestock already did.
——————————————-

Please consider these substantive comments and new information — new to BLM — and make the necessary course-corrections and reforms.
Sincerely,

Marybeth Devlin





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%).

 





Marybeth Devlin speaks out against PZP

Pm PZP Darts

Marybeth Devlin responds to PZP SPIN in High Country News titled: PZP: Where hope, science and mustangs meet http://www.hcn.org/articles/pzp-where-hope-science-and-mustangs-meet

Ms. Wilder is disinformed. PZP does not “cause eggs to reject sperm.” That hypothesis has been disproved. PZP is a registered pesticide whose mechanism-of-action is to cause auto-immune disease. PZP tricks the immune system into producing antibodies that target and attack the ovaries. PZP’s antibodies cause the mare to suffer ovarian dystrophy, oophoritis (inflammation of the ovaries), ovarian cysts, destruction of oocytes in growing follicles, and depletion of resting follicles. Not surprisingly, estrogen levels drop markedly as the ovaries are slowly destroyed. But PZP’s adverse effects are not limited to the individual animal. As a recent study — which included the Little Book Cliffs, Colorado herd and the McCullough Peaks, Wyoming herd — found, PZP extends the birthing season to nearly year-round. Out-of-season births put the life of the foals and the mares at risk. Further, the same study disclosed that the pesticide causes a delay lasting 411.3 days (1.13 years) per each year-of-treatment before mares recover their fertility after suspension of PZP. However, some mares never recover — they are left permanently sterile, and quickly too. Indeed, yet another study found that sterility could occur in some mares from just three years of PZP injections or from just one treatment if the pesticide were given to a filly before she reached puberty. Because PZP messes with the immune system, it ironically works “best” — sterilizes faster — if the mare has a strong immune system. But, conversely, PZP may not work at all in mares whose immune function is weak or depressed. So, the pesticide discriminates against the very horses that Nature has best equipped for survival against disease while favoring and selecting for the immuno-compromised. Worse yet, tests performed via radioimmunoassay indicated 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, as demonstrated by immunofluorescent techniques.

But there is no need for PZP or any other population-reduction measures. BLM’s wild-horse overpopulation “data” is a fraud. Reviews of BLM’s year-to-year growth-estimates for various herds disclosed biologically-impossible growth-rates. For instance, just recently in Oregon, BLM claimed that the famous Kiger herd’s population grew from 21 horses to 156 horses in just four years — an increase of 643%. Stealthily inserting bogus birth-rates into the data, then wrongly equating the birth-rate with the population growth-rate, and failing to factor in the mortality-rate — that is how BLM creates the false impression of a population-explosion. Another ruse BLM employs is restricting maximum herd-size below minimum-viable herd-size. Then, whenever a herd is made to appear — via false 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% of the herds are “managed” below minimum-viable size, including Spring Creek Basin.

Scandal Unfolds: Rare Water Canyon foals are up for adoption before the Gonacon™ experiment wrecks havoc in the herd

We are updating this page so check back for more information as the scandal unfolds. Updates are being posted towards the bottom.

Save the young victims of the cruel experiment!

Wild foals captured from the Water Canyon portion of the Antelope Herd Management Area in eastern Nevada are up for adoption. They are the victims of a roundup to EXPERIMENT on wild horses with GONACON™. Nine weanlings and two yearlings are being held together at the National Wild Horse and Burro Center at Palomino Valley, north of Reno, Nevada. They need to be saved now and hopefully in pairs because this is so painful for them to have lost their families!

The wild horses are available for walk-up adoption from 8 a.m. to 4 p.m., Monday through Friday, and 8 a.m. to 2 p.m., Saturdays. All of the horses have received vaccinations and their bloodwork is completed. Brand inspections will be performed and health certificates issued on all adopted horses.

Applications are available for download (.pdf) at http://on.doi.gov/1A0eAfw.

For more information, contact Jeremy Wilhelm, BLM public contact person, at (775) 475-2222.

The GONACON™ EXPERIMENT is being humane-washed by the Bureau of Land Management (BLM) and their partners. They are perpetrating the overpopulation myth when in truth America’s wild horses are underpopulated. In their experiment they are releasing only a fraction.

Alleged wild horse advocate, Jeannie Nations, is the Project Coordinator (unpaid volunteer) of the experiment. Nations was also proposing PZP experiments as a BLM RAC member in October 2014 as you see here: http://www.blm.gov/style/medialib/blm/nv/resources/racs/ne_rac/meeting_presentations.Par.34609.File.dat/14-10-16-negb-jnations-proposal.pdf

Nations says, “I wanted to mention also, that we did a quick online petition for about 6 days with American Wild Horse Preservation Campaign regarding this same proposal and we had over 19,000 people from all around the country and the world in favor of doing this pilot program.This just goes to show how badly people want a positive change in wild horse management!

Do people realize what they are signing and supporting when they sign petitions put out by the American Wild Horse Preservation Campaign? Are they reading the whole document or just reading the first paragraph and clicking quickly to add their name?

Why did the BLM take the Spin Dr.’s push for fertility control and turn it into an EXPERIMENT with GONACON™?  It’s a slippery slope when “advocates” partner up with BLM for fertility control . . . American herds are becoming nonviable and will be wiped out.

GONCACON™ is an immunocontraceptive that Big Pharma calls a “vaccine“. Yet fertility is not a disease so calling it a vaccine doesn’t make sense. It is registered with the EPA as a restricted use pesticide. http://www3.epa.gov/pesticides/chem_search/reg_actions/registration/fs_PC-116800_01-Sep-09.pdf 

GONACON™ like PZP is an EPA  restricted use pesticide (see photo below). The BLM and their supporters are experimenting on America’s wild horses because the Feds see them as PESTS and want to dispose of them slowly . . . They hope the public won’t realize what’s happening.

Now it’s clear that some alleged “wild horse advocates” pushing fertility control, like PZP and GONACON™, are helping BLM not wild horses.

See who is involved in this experiment and know what exactly they are doing: http://www.blm.gov/nv/st/en/fo/ely_field_office/blm_programs/wild_horses_and_burros/Water_Canyon_Growth_Suppression_Pilot_Program.html

Update 5:27 pm PST: Why is the BLM’s Project Coordinator (volunteer) of the GONACON™ EXPERIMENT and BLM RAC member now raising money for her alleged Angels Acres Rescue to adopt the “Lucky 11” as she calls them? Yes she is calling the victims of this horrible GONACON™ EXPERIMENT and roundup “Lucky”.

PM Nations Screen Shot 2015-12-17 at 5.27.38 PM

 

Ask yourself if this:

Why didn’t the well funded wild horse preservation groups fight in court to stop the Water Canyon roundup?  

Was this just another opportunity to get more donor data by sending out an online petition but do nothing to stop the roundup?

Is it because they are in with BLM, want more names on their email lists to push for fertility control?

Follow the money . . .

 

PM Water Canyon Foal 2 2015

 

Photos from BLM taken by the experiment’s project coordinator (volunteer) Jeannie Nations in public domain

Elko Daily News reports on the GONACON™ EXPERIMENT: http://elkodaily.com/lifestyles/nature-notes-wild-horse-contraception-research/article_8da74080-34c0-5f7a-8ba9-65578d5254b4.html

November 08, 2015 5:45 am • LARRY HYSLOP
A research project north of Ely will look at maintaining a stable wild horse population using a contraceptive. The goal is to treat mares with Gonacon, a commercial contraceptive, and then watch them over several years to make sure the project mares do not produce foals.

Jeanne Nations is a volunteer project coordinator who lives in the area, frequently visits the horses and knows most by sight. She will handle the on-site adoptions and help Ben Noyes, in charge of the project, and the Wild Horse Specialist in the BLM Ely District Office. Jeanne said if this research is successful, she hopes it could help other areas provide a more humane way to keep wild horse populations under control.

The Northeastern Nevada Resource Advisory Council recently visited the project site, after submitting a letter to the BLM’s Wild Horse and Burro Program supporting Jeanne’s project.

The research site is north of Ely, on a narrow strip of public land 12-15 miles long between U.S. Highway 93 and the Schell Creek Range. A fairly isolated group of 66 wild horses currently live in this part of the Antelope Herd Management Area, which has 803 wild horses with an Appropriate Management Level of 324. The nearest other wild horses to this project area are over the mountains to the east.

Trapping has begun and Ben has gathered 35 horses so far. All the rest of the area horses will be trapped this fall. Ben feels he can capture all the area horses using water and bait trapping but will use other techniques if needed.

While the last few members of the Council were visiting the trap site, seven horses came into the trap to eat hay and drink water, showing they are quite comfortable with the trap.

About 30 horses will be part of the project, with the rest removed from the area. It is hoped on-site adoptions will take most of the removed horses but any remaining will be taken to holding areas. People interested in adoption can email Jeanne at jnphotography@hughes.net.

The project horses kept on the site will consist of 15 stallions and 15 mares, having an assortment of ages. After capture, mares will be treated with Gonacon and freeze branded. DNA samples will be collected from all horses. The problem then is the mares must receive a booster 30 days later, so all mares and some of the stallions will be kept in holding pens.
After the 30 days, the horses will be released back into their home range. Ben feels the horses should have no problem re-habituating to their open range after a month of daily hay and abundant water.

Ben and Jeanne will keep an eye on the mares and watch them for pregnancies. The mares will need to be gathered again in two years to receive another booster.

There is a good chance the project mares are now pregnant and will produce foals the first year. However, these treatments should keep the mares from becoming pregnant again during the length of the project. After the project ends, it is hoped the mares will then become pregnant. Other horses may cross the mountains to join this group but they will not throw off the research since only the branded mares will be watched.

Links of interest:

Read Jack Ferm’s The BLM wild horse roundup continues: follow the money for a good overview of the situation: http://suindependent.com/blm-wild-horse-roundup-continues/

and his piece Why is the BLM killing wild horses? http://suindependent.com/blm-killing-wild-horses/

 

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




Dry Creek Partnership Successes Continue with Treatment of Noxious Weeds

 

A partnership that began in 2012 among the Bureau of Land Management Cody Field Office, Marathon Oil Corporation and Friends of a Legacy (FOAL) continues to achieve successes toward its goal of improving water sources for the benefit of wild horses, wildlife and livestock inside the McCullough Peaks Wild Horse Herd Management Area (HMA) east of Cody, Wyoming.

Saltcedar is removed along Dry Creek.
Russian olive and
saltcedar were recently treated on 900 acres of public land along Dry
Creek east of Cody.

Most recently, the group partnered with Park County and Big Horn County weed and pest districts to treat Russian olive and saltcedar on 900 acres of public land along Dry Creek. The invasive plants were sprayed with herbicide, beginning at the bridge where U.S. Highway 14/16/20 crosses Dry Creek approximately 21 miles east of Cody, and continuing downstream to the east.Russian olive and saltcedar, both designated as noxious weeds by the Wyoming Weed and Pest Council, create numerous negative impacts on river function, native plant and wildlife species, wildlife habitat, and water quality and quantity. By removing these water-loving plants, wild horses, wildlife and livestock will benefit from more water in the creek and the space created for native vegetation to flourish.

“We are so appreciative of FOAL and Marathon Oil for the progress we continue to make along the Dry Creek drainage,” said BLM Assistant Field Manager Delissa Minnick. “And the recent Russian olive and saltcedar treatments would not have been possible without the additional contributions of herbicides and work crews from Park County and Big Horn County weed and pest districts.”

Treatments are expected to continue this spring, and re-treatments to spray re-growths will be needed in future years. In addition, tall, mature tamarisk in the area will be mulched using a skidsteer with a masticator attachment.

“FOAL is dedicated to and honored to be a partner in reducing the impact of invasive species in the HMA for the benefit of all of the flora and fauna that depend on the Dry Creek drainage,” said Warren Murphy, president of FOAL.

Projects completed by the Dry Creek Water Augmentation partners over the past few years include the identification of viable water supply alternatives; installation and testing of two shallow water supply wells along Dry Creek; purchase and installation of solar powered pumps; construction of a 2.5-mile long water delivery system; and the improvement of several reservoirs in the HMA, which are critical for capturing spring snow melt.

Future plans include the construction of a second pipeline and installation of various points of use for the delivered water including guzzlers, reservoirs, watering basins and wetlands along the pipelines for water storage and distribution to wildlife.

Marathon Oil has operated in this area since 1917 and has partnered with the BLM on numerous resource improvement projects. To ensure the success of the Dry Creek Water Augmentation Project, Marathon Oil has secured grants and provided funding to the National Wild Turkey Federation to implement fieldwork and construction projects.

“We’re grateful for the partnerships we have with these groups,” said Environmental Professional Mike Williams with Marathon Oil’s Wyoming Asset Team. “Such successful water augmentation in the Dry Creek drainage wouldn’t have been possible without the significant collaborative input and commitment that each organization brings to the project.”

FOAL is a non-profit wild horse advocacy organization that has been partnering with the BLM under a separate MOU since 2006 to coordinate and cooperate on opportunities for public education, to enhance habitat for all creatures living within the McCullough Peaks HMA and to assist the BLM in managing the McCullough Peaks wild horses.

FOAL has received grants from the Wyoming Wildlife and Natural Resource Trust and the Park County Winter Recreation Coalition Fund (held by the Wyoming Community Foundation) that have contributed to the success of the Dry Creekheld by the Wyoming Community Foundation Water Augmentation Project.

“On-going collaboration focused on improving the habitat and the availability of water resources is very important,” said FOAL Executive Director Marion Morrison. “We’re seeing great results due to the significant contributions of expertise, resources, and passion from every member of this partnership.”

It is hoped the partnership will continue to grow with the addition of new participants and public involvement. The partners hope to enlist volunteers in the future to plant native species along Dry Creek to further improve habitat. For more information, or to participate in Dry Creek habitat enhancement work, please contact BLM Wild Horse Specialist Tricia Hatle at 307-578-5900.

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–Cody Field Office   1002 Blackburn Street      Cody, WY 82414

Save wild horses in Oregon from getting more strikes

Please help network these wild horses to a good home. They received a STRIKE against them from the last Internet Adoption because they were passed over. 

PM Mary in Foal #08022753

MARY in foal #08022753

Sex: Mare Age: 7 Years Height (in hands): 14.1

Necktag #: 2753 Date Captured: 10/14/14

Color: Bay Captured: Palomino Buttes (OR)

Notes:
Tag#-2753. This is a 7 year-old bay mare gathered from the Palomino Buttes HMA in OR in October 2014. Freezemark: 08022753

There is a likely possibility that this mare is currently carrying a foal. By the time the internet adoption closes and shipping arrangements are made, this horse will be too far along in her pregnancy to travel healthily via livestock truck hauling. Therefore…this horse MUST BE PICKED UP directly from Oregon’s Wild Horse Corral Facility in Hines, OR.

PM Mary in Foal 3

 

There were no bids placed on MARY during the last Internet Adoption so she received another STRIKE.

 

PM Mary in Foal #08022753

 

Mary needs someone to care for her and her foal. If she gets 3 STRIKES the BLM can legally sell her to slaughter according to the Burns Amendment. Please contact us if you run into BLM red tape. Our email is Contact@ProtectMustangs.org

 

PM Sam #13022735

SAM is only 2 years old and he received another STRIKE

Sex: Gelding Age: 2 Years Height (in hands): 14.1

Necktag #: 2735 Date Captured: 10/14/14

Color: Bay Captured: Palomino Buttes (OR)

Notes:
Tag#: 2735. This is a 2 year old bay gelding gathered from the Palomino Buttes HMA in OR in October 2014. Freezemark: 13022735

This horse is currently located at the Corral Facility in Hines, Oregon. For more information, contact Patti Wilson at email pwilson@blm.gov or Tara at tmartina@blm.gov.

Pick up options (by appt): Burns, OR; Delta, UT; Elm Creek, NE; Pauls Valley, OK; Piney Woods, MS.

Other pick up options: Ewing, IL (march 20); Montgomery, AL (March 27).
Adoption confirmation for this animal must be finalized no later than Noon Mountain February 12, 2015. After this date, all unclaimed animals will be available for in-person walk up adoption ONLY.

There were no bids placed on SAM during the Internet Adoption so he received another dangerous STRIKE

PM Sam #13022735 Trot

 

Equine reproductive immunology Ph.D speaks out in 2010 against using PZP on wild horses

PM President Obama Listen to the Science

November 27, 2010

Jared Bybee, Wild Horse and Burro Specialist

Department of the Interior

Bureau of Land Management

Billings Field Office

5001 Southgate Drive

Billings, Montana 59101-4669

VIA FAX: 406-896-5281

RE: Pryor Mountain Wild Horse Range Fertility Control Preliminary Environmental
Assessment Tiered to the Pryor Mountain Wild Horse Range Environmental Assessment and Herd Management Area Plan May 2009 EA DOI-BLM-MT-0010-2011-0004-EA

Dear Jared Bybee:

Background

I appreciate the opportunity to submit comments on the Pryor Mountain Wild Horse Range
Fertility Control Preliminary Environmental Assessment Tiered to the Pryor Mountain Wild
Horse Range Environmental Assessment and Herd Management Area Plan May 2009 EA DOI-BLM-MT-0010-2011-0004-EA. My background is in equine reproductive immunology and wildlife conservation. I applaud the Billings Field Office of the Bureau of Land Management (BLM) for a thoughtful approach to this issue. Cover letter 4700 (010.JB) dated November 2010 and signed by James M. Sparks, Field Manager states that the BLM would consider comments and revision to the EA or unsigned FONSI as appropriate. I urge a “no action alternative” as outlined on page 7 and 8 of the EA. This request is based on two pieces of new scientific evidence about effects of current immuno-contraception use.

Porcine Zona Pellucida (PZP) Contraception

The proposed action as stated on page 7 of this EA would exempt “mares ages 5-10 unless they have produced foals, or are part of a large bloodline.” This is reminiscent of the approach taken with the Assateague Island wild horse population. It is a compromise approach to this issue, in comparison to placing all mares on PZP. However a recent study shows that mitochondrial DNA diversity is low in the Assateague Island horse herd (Eggert et al. 2010). Since mitochondrial DNA is inherited from the mother (mare), this is evidence that female inherited genetics on Assateague Island wild horses is under represented. It is imperative that this be assessed before rolling out a similar management plan for the Pryor Mountain wild horses.

There is a recent Princeton University study on PZP effects. Consecutive PZP applications, analogous to the proposed action plan in this EA, showed that mares gave birth later in the season, and were cycling into the fall months (Nunez et al. 2010). In a state like Montana where freezing temperatures are found in the fall, this can have serious and long term effects on foal survivorship.

I must include a statement on long term consecutive use of PZP. Any form of PZP contraception is not completely reversible in mares depending on the length of use of PZP. Contraception can only be reversed when the antibody titer decreases to 50-60% of the positive reference sera (Liu et al. 2005). Mares treated for 7 consecutive years do not return to viable fertility (Kirkpatrick and Turner 2002; Kirkpatrick et al. 2009). The issue of reversible contraception is very important to be able to maintain wild equines in the United States. Long term treatment with PZP has inherent negative potential for this herd.

I am requesting a new look at the proposed fertility control action for the Pryor Mountain wild horses.

Sincerely,

Christine DeCarlo, Ph.D.

Lori S. Eggert, David M. Powell, et al. (2010). “Pedigrees and the Study of the Wild Horse
Population of Assateague Island National Seashore.” Journal of Wildlife Management
74(5): 963-973.

J. F. Kirkpatrick, A. Rowan, et al. (2009). “The practical side of immunocontraception: zona
proteins and wildlife.” J Reprod Immunol 83(1-2): 151-7.

J. F. Kirkpatrick and A. Turner (2002). “Reversibility of action and safety during pregnancy of immunization against porcine zona pellucida in wild mares (Equus caballus).” Reprod
Suppl 60: 197-202.

I. K. Liu, J. W. Turner, Jr., et al. (2005). “Persistence of anti-zonae pellucidae antibodies
following a single inoculation of porcine zonae pellucidae in the domestic equine.”
Reproduction 129(2): 181-90.

Cassandra M. V. Nunez, James S. Adelman, et al. (2010). “Immunoctraception in Wild Horses (Equus caballus) Extends Reproductive Cycling Beyond the Normal Breeding Season.” PLos ONE 5(10): 1-10.

(Posted for educational purposes)

 

More foals die at taxpayer funded roundup #StopWyRoundup

PM WY  s.noll : Foter : CC BY-NC-SA

Photo: s.noll : Foter : CC BY-NC-SA

The stress and terror of the BLM’s cruel helicopter roundup is taking it’s toll on very young wild horses. Take action against this atrocity and contact your elected officials to request an immediate moratorium to all roundups. These deaths are a red flag. Now 3 native wild horses have died. Get active before more wild horses die in BLM’s roundup.

BLM reports:

One helicopter gathered 23 mares, 29 studs and 12 colts at the Black Rock Trap in the Divide Basin Herd Management Area.

Animals gathered and removed: 64

Removal related animal deaths: 2

Cause: A three-and-a-half month old black filly was found dead in a short-term holding pen. A necropsy was performed but the cause of death is undetermined. Cause: A six-month-old brown colt collapsed in a horse trailer. The necropsy revealed that the colt had scar tissue and nodules on its lungs, indicating that it likely had pneumonia previously. Tissue has been sent for testing with results expected in several weeks.

Request for federal accountability and transparency for captive wild horses in Nevada facilities

 

——– Original Message ——–
Subject: Carson & Fallon
From: <anne>
Date: Tue, April 01, 2014 5:17 pm
To: “Peters, Stacy” <skpeters@blm.gov>, ““James (Jeb) Beck””
<j1beck@blm.gov>, “Deborah Collins” <dacollin@blm.gov>, “Dean Bolstad”
<dbolstad@blm.gov>

Dear Jeb,

The public is concerned about captive wild horses being moved from place to place because of a lack of transparency.

Thank you for having Stacy email the answers to our questions about the wild horses who have been moved out of Palomino Valley as seen here: http://protectmustangs.org/?p=6656

The public has been contacting us with questions about the large numbers of wild horses going to NVF83 Northern Nevada Correctional Center, Carson City and WOF56 Fallon Maintenance Facility. They would like transparent answers.

How many wild horses have shipped out of NVF83 Northern Nevada Correctional Center, Carson City from January 1, 2014 to April 2, 2014?

Kindly explain exactly where they went, how many have left for each destination, and how many remain at the Northern Nevada Correctional Center as of April 2, 2014.

How many horses have left the Northern Nevada Correctional Center under “sale authority” since January 1, 2014? Where did they go?

How many wild horses have left the Correctional Center under “sale authority” from January 1, 2013 to December 31, 2013? Where did they go?

How many pregnant mares are at the correctional facility?  How many foals?

How many deaths have been documented from January 1, 2014 to April 2, 2014? How many undocumented deaths (before being branded or other)?

How many births at the correctional facility?

How many mares miscarried or foals were born dead?  What is the correctional facility manager’s definition of live foal?

and

How many wild horses have shipped out of WOF56 Fallon Maintenance Facility, Fallon Nevada from January 1, 2014 to April 2, 2014?

Kindly explain exactly where they went, how many have left for each destination, and how many remain at the WOF56 Fallon Maintenance Facility as of April 2, 2014.

How many wild horses have left the Fallon Facility under “sale authority” since January 1, 2014? Where did they go?

How many wild horses have left the Fallon Facility under “sale authority” from January 1, 2013 to December 31, 2013? Where did they go?

How many pregnant mares are at the Fallon facility?  How many foals?

How many deaths have been documented from January 1, 2014 to April 2, 2014? How many undocumented deaths (before being branded and other)?

How many births at the Fallon facility?

How many mares miscarried or foals were born dead? What is the Fallon facility manager’s definition of live foal?

and

Who is in charge of authorizing wild horses become sale authority horses in Nevada?  Who is in charge at the national level?

How many horses may someone buy at a time?

If I want to buy a truckload of 3-Strike wild horses how do I go about doing that?

How many horses may someone adopt at a time?

The public wants accountability and transparency. Thank you for answering the public’s questions.

Sincerely,
Anne Novak
Executive Director
Protect Mustangs

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

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www.ProtectMustangs.org
Protect Mustangs educates, protects and preserves native and wild horses. The nonprofit conservation group strives for a 10 year moratorium on roundups and science-based holistic land management to reduce global warming.