Stop the BLM from Destroying 5 Wild Horse Herds in Wyoming By Carol J. Walker

The Bureau of Land Management (BLM) has released a Scoping Document with a 30 day public comment period on 5 of the largest wild horse herds in Wyoming:

Adobe Town, Salt Wells Creek, Great Divide Basin, White Mountain and Little Colorado.

I have been visiting, observing and photographing the wild horses in these 5 herds since 2004.

The BLM claims that these herds are “overpopulated” even though they completed a roundup of three herds, Adobe Town, Salt Wells Creek and Great Divide Basin only 2 years ago. The last roundup and removal in White Mountain and Little Colorado was in 2011.

The BLM provides figures of their wild horse population estimates in these 5 herds using a flyover and a statistical double-count method, and one of the new changes is that now any horse over the low range of AML is considered “excess” – this is not how an excess determination is made. For example, the BLM says there are 929 wild horses in Adobe Town and the AML is 600-800, so the actual “excess” is only 129 horses not 329. This change does make a difference and is the creative math that the BLM uses to justify their actions. They are also now counting foals which they have never done before in their population estimates. This allows them to pad their counts and justify a roundup.

The population estimates for these 5 herds swing wildly and unbelievably from year to year. Basing the need for a roundup on the BLM’s figures is absurd. There is a need for an actual count of wild horses to be done in EVERY HMA by an independent agency. Without that, it leaves the BLM open to distort their statistics any time they want to justify “excess” horses to do a roundup.

Herd Management Area Adobe Town Salt Wells Creek Great Divide Basin White Mountain Little Colorado Nov. 2019 929 745 1069 391 411 March 2019 994 766 1096 401 412 March 2018 767 576 791 284 408 March 2017 820 835 650 265 367 March 2016 1037 728 670 321 396 March 2015 602 117 199 241 259 October 2014 519 29 91 March 2014 624 251 831 194 104 March 2013 520 686 527 88 246

*October 2014 immediately follows the Checkerboard Roundup, BLM posted these figures on BLM WY Facebook page

**roundups of Adobe Town and Salt Wells Creek and Great Divide Basin in the winter of fall of 2014 and fall of 2017, a roundup of Adobe Town and Salt Wells Creek in the winter of 2013

Here is the online BLM site for all the documents on this plan:

https://eplanning.blm.gov/epl-front-office/eplanning/projectSummary.do?methodName=renderDefaultProjectSummary&projectId=1501993

Here are the alternatives that the BLM has come up with to manage the wild horses in these 5 areas:

Gather and remove excess wild horses and apply PZP (porcine zona pellucida) or Gonna Con fertility control vaccine to a group of mares that will be released back into the HMAs. Establish a 60% to 40% male to female ratio within the HMAs. Gather and remove excess wild horses. Spay a group of mares and neuter a group of studs that will be released back into the HMAs. Apply PZP or GonaCon to the remaining mares released back onto the HMAs. Gather and remove excess wild horses, without conducting any population growth suppression activities. No Action – Do not conduct any gather or removal activities, and do not conduct any population growth suppression activities.

The only acceptable choice is number 4, No Action. The BLM likes to throw as many possible things together as possible. Birth control has never been meaningfully used or studied in these areas. Treating a handful of mares every 4 – 10 years then removing the mares that have been treated does not give using PZP birth control any sort of chance to work at maintaining or slowing population growth. In 2010 the BLM treated 39 wild mares from Adobe Town and 60 wild mares from Salt Wells Creek with PZP. In 2013, 40 wild mares were treated with PZP and released into Adobe Town. Many wild mares who were removed during this roundup were marked as having received PZP in 2010. No birth control was used in the 2014 Checkerboard Roundup of Adobe Town, Salt Wells Creek and Great Divide Basin. In 2017, no birth control was used in the roundup of Adobe Town, Salt Wells Creek and Great Divide Basin. Again, many mares with markings from having been treated in 2010 and 2013 were removed.

I am strongly opposed to any type of surgical sterilization of wild horses. The method that BLM has been wanting to use on wild mares, ovierectomy via colpotomy is dangerous, cruel and inhumane. Thousands of members of the public as well as members of Congress and over 80 veterinarians have spoken out against the use of this method of spaying: https://www.thecloudfoundation.org/comments-and-articles/2019/6/8/blm-resurrects-cruel-plan-to-sterilize-wild-mares

Gelding stallions should not be a part of this analysis. The death rate for gelding wild stallions can often be as high as 5%. And the effect on both the gelded stallions and on the social and behavioral structure of the herd and family bands can be extremely detrimental. If you remove what makes wild horses wild, a very large degree of that is their family and society structure, then you are destroying wild horses.

Gonacon is a birth control treatment that has not been sufficiently tested on wild horses. There is currently a study of Gonacon use on wild mares going on in Theodore Roosevelt National Park. It has not been studied sufficiently to rule out sterilization or dangerous side effects such as stillborn foals. The effect of the use of Gonacon on social behaviors of wild horses has also not been sufficiently studied.

Skewing the sex ratios of the horses in the herds can have an extremely detrimental affect on wild horses and also has not been studied scientifically. In nature, wild horses exist in about a 50% mares to 50% stallions ratio. The BLM thinks that if they change the ratio to 60% or more stallions to 40% or less mares then the birth rate will grow less. What happens instead is there are more bachelor stallions, smaller families, more aggressive fights between stallions where mare and foals are injured. The stability of the family band becomes disrupted and I have observed this in the McCullough Peaks Herd in Wyoming where they skewed the sex ratio 66% to 33% in 2009.

If birth control must be used in these herds to limit population growth then PZP is the only choice – it has been studied for over 40 years being used on wild horses and since it can be delivered by dart in the field or in a pen using bait trapping to capture the horses instead of dangerous and costly helicopter roundups it is by far the most humane option.

This plan for removing and experimenting upon wild horses in these 5 Herd Management Areas is discussed in this document as a multi-year plan, meaning the BLM would like to only allow the public to comment once even though the BLM will then continue these actions without any public input. They have not done this in the past for these 5 herds.

The BLM must prepare an Environmental Impact Study, EIS, for the roundup and removal of wild horses in these 5 herds due to the breadth and scope of the project. It will span 10 years and impact 3.5 million acres of our public lands with inhumane roundup, removals and experimentation on our wild horses. Using a Environmental Assessment, EA, here instead of an EIS is counter to NEPA. There is extreme public interest in these actions, and strong public opposition to inhumane sterilization experiments also warrants the preparation of an EIS.

The plan to remove 2,702 wild horses from these Herd Management Areas in Wyoming is wrong, and adding these horses to the 45,000 wild horses currently in BLM Holding Facilities is outrageous. These horses should be managed on our public lands where they live. After the 2014 Checkerboard Roundup, when the American Wild Horse Campaign did a FOIA request for the deaths of wild horses, in just a couple of months over 75 horses died, and that did not count the foals that died before being freeze branded. Helicopter roundups and stockpiling wild horses is cruel, dangerous, life-threatening and very expensive to the American taxpayer.

https://www.wildhoofbeats.com/news/death-toll-mounts-from-blms-wyoming-wild-horse-roundup

The plan to remove 2702 wild horses from these 5 herds and then experimenting on and sterilizing the wild horses that remain is the BLM’s endgame for America’s wild horses. We must oppose this plan and save our wild horses.

Please comment in your own words by December 20, 2019 on this proposed plan.

Some points I would suggest you mention:

-The correct alternative is the NO Action Alternative.

-The BLM must prepare on EIS for this project given the scope and public opposition.

-Do actual counts of wild horses using an independent agency.

-Opposition to spaying wild mares, gelding stallions, chemical vasectomies and the use of Gonacon.

-Opposition to skewing the sex ratios of the herds.

-Manage these 5 herds on public lands where they are found.

-If birth control must be used, use the proven, humane, PZP.

Please make your comments by the end of the day, December 20, 2019.

You can submit comments through the BLM website:

https://eplanning.blm.gov/epl-front-office/eplanning/comments/commentSubmission.do?commentPeriodId=8000489

You can also email comments to: blm_wy_rsfo_wildhorse_hmas@BLM.gov

And send them by mail to:

BLM Rock Springs Field Office

High Desert District

Multi-Year Wild Horse Gather

280 HWY 191 North

Rock Springs, WY 82901