To:

John Axtell  (PineNutHorses@blm.gov)

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: http://protectmustangs.org/?p=8749

“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.

Sincerely,

Anne Novak

Executive Director

Protect Mustangs

Tel./Text: 415.531.8454

Anne@ProtectMustangs.org

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

Twitter: https://twitter.com/TheAnneNovak

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www.ProtectMustangs.org

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