Friends of Animals’ Comments for Wild Horse and Burro Advisory Board Meeting, April 13, 2016

Friends of Animals’ Comments for Wild Horse and Burro Advisory Board Meeting, April 13, 2016

   
Submitted by Nicole Rivard


The first group of wild horses we ever saw roaming free with their families were from the White Mountain Herd in Wyoming. We were so thrilled our hands were shaking to the point some of the photos we took came out blurry.


That’s why as a correspondent for Friends of Animals and campaigns director for Friends of Animals, and U.S. taxpayers, we are sickened by the BLM’s, or should I say modern day Frankensteins’, latest putrid schemes to undermine Wyoming’s wild horses. As members of the Wild Horse and Burro Advisory Board, we ask you to recommend that the BLM get a complete overhaul, one that replaces decision makers with people who are not wedded to welfare cattle and sheep ranchers.


We at Friends of Animals hope that automatically comes with a new administration next year, so the BLM’s wild horse extinction plan will be stopped before it’s too late. Six states have already lost their wild horse populations completely: Missouri, Iowa, Arkansas, Texas, Oklahoma and Kansas.
And from BLM’s latest proposals, it looks like Montana and Wyoming are next.


BLM’s tools for executing its extinction plan, are becoming more and more horrific, and more and more unlawful in terms of the Wild Horses and Burros Act of 1971. The Rock Springs, Wyoming Field Office is proposing to roundup wild horses from the White Mountain and Little Colorado Herd Management Areas (HMAs), and to conduct a research study in conjunction with the United States Geological Survey (USGS). The roundup would include helicopter drive trapping. The USGS research study would “place radio collars on a portion of the mares and place radio tail tracker tags on a portion of the stallions in the HMAs.” A year after the radio collars and tags are placed on the wild horses, a portion of the White Mountain HMA mares would be gathered, SPAYED and studied further “to examine their behavior and band fidelity, demography (birth and survival rates), and spatial ecology both pre-and post-treatment.” In addition, “the Little Colorado HMA would be gathered to the high Appropriate Management Level (AML) of 100 wild horses and would be studied as a control group.”


Why spend millions of dollars on research when studies already exist proving the negative effects of fertility control, such as the use of PZP, on America’s wild horses. FoA believes it’s because the newer research was not published by BLM cronies.


Equine experts warn that the spaying of wild mares, otherwise known as “ovariectomy” pose unreasonable risks to even domesticated horses under controlled conditions, and the National Academies of Science (NAS) has specifically recommended against spaying wild mares under field conditions because they may be followed by prolonged bleeding and peritoneal infection. While spaying wild mares will surely reduce wild horse populations, it will do so while causing unnecessary trauma, pain and possibly death to the treated horses. Further, this level of intervention, that will involve using a helicopter to roundup wild mares, penning or corralling them, immobilizing, sedating them and slicing off their ovaries with possibly fatal results, is hardly the “minimum” level of wild horse management called for under the WHBA.


Lack of transparency
Under the current leadership, the BLM is a corrupt agency that acts as if its transparent to the public but really isn’t. In 2014, BLM convened a panel of experts from the NAS to review 19 research proposals “aimed at developing new or refining existing techniques…for the contraception or permanent sterilization of either male or female horses and/or burros in the field.” In January of 2015, the NAS panel rated each of the 19 research proposals on the basis of three factors related to the goal of controlling wild horse populations. However, the results of that review, were published in an Appendix that is not available to the public.


So while BLM will choose a spaying method from among methods reviewed by a NAS panel of experts, the public will not be privy to the experts’ assessment of the strengths and weaknesses of each method. This is unacceptable.

We will not be neutralized
What is also unacceptable to FoA is the addition of Ginger Kathrens of the Cloud Foundation to the Advisory Board in the category of humane advocacy to try and neutralize wild horse advocates. Sadly, the leader of the Cloud Foundation being window dressing for the BLM might be good news for wild horse Cloud and may guarantee he and his family will never be ripped from the Pryor Mountains of Montana, but it certainly isn’t good news for the rest of America’s wild horses.


At last year’s Wild Horse and Burro Advisory Board meeting in Oklahoma City, Kathrens, who was once one of the harshest critics of the BLM, was called an “asset” by the agency. And a few months prior to that she lauded BLM for ending cruel helicopter roundups in the Pryor Mountains and for utilizing a “humane” birth control vaccine as an alternative to the removal of wild horses from the range and administering it in a manner that keeps the horse families together respecting the importance of their social structure.


It is maddening that anyone who calls themselves a wild horse advocate can ignore the fact that when the Humane Society obtained ESA registration for PZP in 2012, the organization never provided evidence that PZP doesn’t have negative side effects…it just provided information about the efficacy of PZP and actually requested waivers for most of the studies ordinarily required from an applicant seeking pesticide registration—including a toxicity study, ecological effects and environmental fate guideline study. The majority of research submitted by HSUS was published by the late Dr. Jay Kirkpatrick, a veterinarian who manufactured PZP, and did not consider the biological, social and behavioral effects the drug can have on wild horses.


More recent research independent of HSUS and Kirkpatrick has demonstrated repeated applications of PZP can cause physical damage to treated mares; it is not completely reversible; it can increase mortality in foals post-PZP effectiveness; and it interferes with herd cohesion, which is critical to the overall health of wild horses. In addition, preventing mares from producing foals can create a genetic bottleneck that may ultimately extinguish the species as a whole.


Plus, by BLM’s own admission, darting wild horses with PZP is generally not practical for BLM because it is difficult to approach most wild horses closely enough on Western rangelands, so it will never replace roundups as PZP pushers would have the public believe.
Extinction plans in Wyoming and Montana


Last summer Kathrens silently sat back as the BLM rounded up with a bait and water trap and removed of 18 “adoptable” “excess” horses between the ages of 1 and 3, including a foal—nearly all of the youth of the Pryor Mountain Wild Horse Herd in Montana.


The Pryor Mountain Wild Horse Herd includes Cloud, the pale palomino wild stallion and his family, made famous by the Cloud Foundation’s Emmy award-winning documentaries. BLM’s crime that it got away with last summer comes after years of forcibly drugging Cloud’s family with the fertility control pesticide PZP, which unfortunately the Cloud Foundation has participated in despite Kathren’s saying at March for Mustangs in 2010 that “Freedom and family is everything to wild horses.”


There were only a measly 170 wild horses left in the entire state of Montana last year and the BLM Billings Field Office thought that was too many. Montana’s BLM has already zeroed out six of seven of the original wild horse Herd Areas in the state.


What exactly does that mean? Following the passage of the Wild Horses and Burros Act in 1971, The BLM was directed to identify areas where wild horses and burros were located. Seven Herd Areas of Montana were designated as places where wild horses lived. Unfortunately for wild horses, the BLM was charged with determining whether or not there was enough food, water, cover and space to support healthy diverse populations of wild horses over the longterm…as well as thousands of cattle and sheep allowed to graze on public lands. Areas which met their criteria were then designated Herd Management Areas. Sadly, the Pryor Mountain Wild Horse Range is the only place wild horses currently exist in the entire state of Montana.


Remove cattle and sheep from HMAs
Instead of wasting time and millions of dollars putting wild mares in Wyoming at an unreasonable risk, BLM should be focusing its attention on re-evaluating the lower and upper appropriate management levels (AMLs) at the White Mountain and Little Colorado HMAs before removing any horses and removing cattle and sheep from HMAs altogether. While the two Wyoming HMAs encompass an area of 1,022,952 acres, the AML for the White Mountain herd is 205-300, the AML for the Little Colorado herd is 69-100 horses. On two HMAs, encompassing over a million acres of public land, BLM allocates forage for at most 400 wild horses. And yet on those same public lands, cattle and sheep are allotted forage at 400 times the rate allocated to wild horses: On grazing allotments on the White Mountain and Little Colorado HMAs, BLM has allocated 161,250 “active” AUMs for cattle and sheep.


Likewise, in Checkerboard HMA in Wyoming, also targeted for another roundup, cattle and sheep far outnumber wild horses. In 2014 there were 356,222 cattle; 45,206 sheep; and only a measly 1, 912 wild horses in the Checkerboard HMA.  Now the The BLM’s Rock Springs Field Office proposes to remove all wild horses from the checkerboard lands within and outside of the Great Divide Basin, Salt Wells Creek, and Adobe Town Herd Management Areas (HMAs). Wild horses located within the BLM solid block lands of the HMAs supposedly will not be gathered.

 The push to remove the horses is coming from the Rock Springs Grazing Association (RSGA), whose 50 members view the mustangs as competition for cheap, taxpayer-subsidized livestock grazing on the public lands in the checkerboard. In 2010, the government invited the RSGA ranchers to sue the BLM to secure funding for wild horse roundups. Two years later, BLM settled the case by capitulating to RSGA demands to eliminate wild horses on a two-million-acre swath of public and private land in southern Wyoming known as the Wyoming Checkerboard.


When BLM drastically revised AMLs in the 2013 Consent Decree with the RSGA, it did not do so based on an assessment of range conditions as required under the WHBA, but based on a court order, which did not contemplate that BLM is obligated to comply not only with Section 4 of the WHBA, but also with the Unlawful Inclosures of Public Lands Act.


BLM’s constant violations of the Wild Horse and Burro Act and the National Environment Policy Act will never go unnoticed by Friends of Animals and we will continue to hold the agency’s feet to the fire no matter who it appoints to its board. We are not going to be neutralized. Our aggressive agenda to protect wild horses that relies upon many approaches not previously considered by wild horse advocates continues. And our legal teams continues to come up with new approaches under other federal and state laws.


We are bolstered by our injunction in 2015 prohibiting the roundup of the famed Pine Nut herd in Nevada. Today they still roam wild and free as they should. FoA’s definition of wild means no human exploitation and manipulation of the animal, period. Humans should not be managing any wild animal by keeping them in small “herd areas,” or limiting their population through roundups, relocation, sterilization or forcibly drugging them with fertility control drugs.


It is a dream we cannot give up on; if we do, then any chance of a return to ecological balance is lost forever.