Sunday, July 18, 2010

BLMs New Wild Horse and Burro Mis-Management Plan Handbook

And comments from a real expert;

Pat Fazio's email to BLM on new handbook

Pat gave us permission to share her email to the BLM.


Dear Mike (BLM)

Where was the public input on this just-released BLM policy handbook? ... BLM Issues New Policy Handbook on Wild Horse and Burro Management

I thought we had until August 3, 2010 for making online comments. I see many deeply troubling new policies, including releasing gelded stallions back onto existing HMA's with intact stallions, mixing herds, and freeze-branding mares that have been vaccinated with native PZP and PZP-22. Since when did the FDA require freeze-branding of in-the-wild mares? Why not microchipping or another form of inconspicuous ID? This is ranching wild horses, with no respect for natural social organizational patterns and genetic integrity within herds. I have been waiting for enlightened in-the-wild management, not mass manipulation, with no regard for reversible fertility control or wild behavior. Wild horses have been mismanaged for decades, allowed to breed, without control, while safe and effective fertility vaccine sat on the shelf... It was simply too much trouble to take the contraceptive route than to gather (often under adverse, even lethal, conditions) and to hold, at far higher cost to the American taxpayer. Various inhumane methodologies employed by the BLM during the past 29 years make me cringe. They should make everyone uncomfortable, but apparently not. A little pre-planning for strategic water development and fertility control, for example, might have prevented the on-going and tragic Elko District gathers.

I have not read this entire policy handbook yet. I am almost afraid to read the rest... Why should the public bother submitting comments, when policies are already in place? The Website section for public comments has been out of order for weeks, now. Is this the way environmental conflict resolution is carried out... with a BLM bulldozer... and the public be damned?

Not that anyone gives a hoot, but my patience is flat-out gone, on many fronts. However, I'm still here, and I intend to use this fury to take my discontent to a higher level. The Elko (Tuscarora) gather was the final straw, or so I thought... and now this.

I ask the BLM to retract this document. It violates NEPA, in my non-lawyer's view, pre-empts many rational provisions that the ROAM Act would have introduced, and disrespects the scientifically established endemic status of wild horses in North America. Are we to have a few "Treasured Herds," and throw the rest away as pests and nuisances on federal lands? The BLM should politely excuse itself from the Wild Horse and Burro Program. It does not have the capacity to understand, empathize, or care. When the U.S. Grazing Service was combined with the General Land Office in 1946 to form the Bureau of Land Management, we put wild horses and burros into the hands of their historical enemies. Does this make any sense to you?

Please see the PZP fertility control section below.


Patricia M. Fazio, Ph.D., Statewide Coordinator

This is the fertiltiy section she is referencing:


4.5.3 Reduce Population Growth Rates

During gather or herd management area planning, the authorized officer should consider a range of alternatives to reduce population growth rates and extend the gather cycle for all wild horse herds with annual growth rates greater than or equal to 5 percent. Alternatives may include but are not limited to: use of fertility control, adjustments in the sex ratio in favor of males, a combination of fertility control and sex ratio adjustment, and management of selected HMAs for non-reproducing wild horses. Additional management alternatives (tools) may be considered in the future, pending further research (see Chapter 8). Use of Fertility Control as a Tool to Slow Population Growth Rates

a. Use of Porcine Zona Pellucida (PZP). There are two forms of the conventional PZP agent:

¨ The 1-year agent, delivered as a liquid primer injection and follow-up booster one month later; additional boosters must be injected annually by hand or by darting to continue treatment.

¨ The 22-month agent that includes the same primer shot as the one-year agent as well as a second injection of three time-release pellets (1-, 3- and 12-month pellets) to booster the vaccine over a 12-month period of time.

Foaling rates of 6 percent in Year One, 14 percent in Year Two and 32 percent in Year Three following treatment compared with 54 percent foaling in untreated controls have been reported for PZP-22 (Turner, 2007). Maximum effectiveness is not achieved unless mares are treated during a 3-4 month window prior to foaling. Research has shown that the best time to apply PZP is during the winter gather season (i.e., November-February).

The use of PZP, under an investigational exemption held by the Humane Society of the United States, requires treated mares to be physically marked (freeze branded) or readily identifiable in order to be compliant with FDA requirements. Application is limited to individuals specifically trained to handle, mix, and administer the product. Post-treatment monitoring in accordance with the Standard Operating Procedures (SOPs) is required.

As part of an appropriate environmental analysis, the authorized officer will analyze the use of the 22-month PZP vaccine in all wild horse herds, particularly those where: (1) the annual herd growth rate is greater than 5 percent and (2) the post-gather herd size is 50 animals or greater. Fertility control will be most effective when treatment of 50-90 percent of all breeding-age mares within the herd is possible using application in conjunction with gathers or remote delivery (darting). Our current understanding is that to maximize treatment effects, at least 90 percent of all mares should be treated.


The authorized officer should apply the 22-month PZP vaccine to all release mares when the NEPA analysis supports its use. In herds where sex ratio adjustments are made, fertility control may be implemented in combination with sex ratio adjustments to further reduce population growth rates.

b. Increased Use of PZP. One option to slow population growth rates (and reduce the number of excess wild horses removed) would be to gather selected HMAs and apply PZP-22 every 2 years. Because PZP does not totally eliminate reproduction, some excess horses may need to be removed from treated herds over time. Implementation should generally be limited to HMAs that have had high gather efficiencies (i.e., a high percentage of the actual population is captured). Because 70-90 percent of the breeding-age mares may need to be treated to effectively reduce population growth rates, 80-100 percent of the actual population may need to be captured.

c. Remote Application of PZP. Remote application of the 1-year formulation of PZP is problematic, as it is very difficult to approach most wild horses closely enough to allow darting (i.e., follow-up treatment). Remote application of PZP-22 is not possible at the present time since the pellets must be administered by hand injection.

Remote application of the 1-year PZP agent may be considered for herds where individual horses can be identified (consistent with FDA requirements) and are approachable. Remote application is limited to individuals specifically trained to administer the product by darting.

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