THE FUDGE FACTOR

On July 9, 2010, the BLM issued a press release announcing the results a massive aerial census called the Tri-State Survey. It’s purpose was to count wild horse populations over a two million acre area utilizing a new census method being developed by U.S. Geological Survey (USGS) in partnership with BLM over the last several years.

The methodology uses several observers from different vantage points of the plane (or helicopter as the case may be), silently recording what they see individually and afterwards, the observers determines the reliability of their “sightability” by comparing notes to verifying accuracy of what each observer had seen in relation to what the other observers had seen for a cumulative total. This then becomes the basis for “animals missed” by one observer from another to determine the error rate of each individual observer from the total count.


“This improved population survey methodology…incorporates peer-reviewed techniques that have been used for decades to estimate wildlife populations around the world”.

BLM Press Release #2010-22
July 9, 2010

The direct “raw” counts of wild horses are then fed into a computer modeling software program called Program MARK developed by Gary C. White and Kenneth P. Burnham of Colorado State University. The original paper used for scientific citation outlining MARKs capabilities was developed for a conference in 1997 so I guess this must be the “decade” of peer-reviewed work BLM is now referring too.

In reviewing the literature on Program MARK, it discusses how its parameters were created to estimate populations of wildlife survival rates based on marking an animal (such as a bird band or tag) and “re-encountering” the marked animal at a later date. MARK then incorporates multiple analysis of a variety of factors and data to determine a broad spectrum of potential possible outcomes with a strong focus on survival rates.

Program MARK also seems to be a work in progress as the programmers have been adding additional options and fixing bugs in the software since 1998 with the most recent updates added in June 2010. It is described as “a large, complex program, and in general it is not an application that can be learned by simply browsing the helpfile.” The recommended starting point in beginning to grasp its application is a 800+ page (and growing) online book hailed as the “first step” in learning to use it.


“A statistician cooperating with USGS will analyze the preliminary data obtained during the inventory flights to provide population estimates with a 95 percent confidence interval”

BLM Press Release #2010-22
July 9, 2010

To summarize my current understanding of BLMs newest incorporation of this decades long peer-reviewed method they have recently begun waving around to try and explain the unexplainable with respect to their historical crazy population estimates is – it’s really just a very complicated computer modeling program the average Joe hasn’t got a chance of sorting out. We are just going to have to take their word for it. Swell….

Yet, sometimes even the most seemingly complicated subjects can be boiled down to the simple basics, so let’s take a look at the numbers USGS and BLM have released so far.

The results of the “raw” direct counts of wild horses found in the Tri-State Survey area were reported by BLM on July 9, 2010 in the following chart:

After merely a month and a half of BLM releasing the Tri-State direct count results shown above, USGS and the "cooperating statistician" published Program MARKs results for the Tri-State Survey on August 25, 2010, with just a few, tiny adjustments.

If you compare the two charts, (the direct count numbers along side the modifications yielded by Program MARK), besides noticing a variety of complicated official columns that include coefficient variations and upper and lower confidence levels, there’s couple of interesting numbers that stand out.

The first is, the direct count of the wild horses seen in the Fox Hog Herd Management Area reported in July were adjusted “upward” from 172 to 300 in the August version of the data. No need for complicated programs here, just a little “tweaking” of the supposedly directly counted numbers as suddenly 128 wild horses were moved into the Fox Hog HMA.

The other change to the July direct count numbers occurred between wild horses reported “Outside” the California HMAs, adjusted from 430 in July to 302 in August. However, a little cross referencing between the “CA Outside the HMA” numbers and the Fox Hog numbers revealed the shift between the two perfectly matched the increase in the Fox Hog HMA numbers. In other words, USGS moved 128 wild horses from “outside” the California HMAs to “inside” the Fox Hog HMA and the results put the Fox Hog wild horse population from under their appropriate management level to significantly over it with removals now scheduled for the fall of 2011.


The other thing that the “average Joe” can also deduce from the newly adjusted numbers is, the computer modeling determined only a 98 horse difference between what was directly counted in the raw data and adding estimations for wild horses that were missed by the observers in the plane. This equates to only a 2.3% difference between the direct counts and the added estimates, at least during this particular survey.


“The modeling and analysis to be completed will make adjustments to the preliminary data to account for animals not observed during the flight. The simultaneous double-count/sightability bias correction technique will provide more valid population estimates than the standard uncorrected aerial inventory method.”

BLM Press Release #2010-22
July 9, 2010

While I will save questions for the accuracy of the raw count data for the Tri-State area for a later date, I would like to draw everyone’s attention to the BLMs unofficial “fudge factor” that is being slipped into this new, highly touted, state-of-the-art, “more-valid-population-estimate-than-ever-before” public relations campaign phony baloney.

After BLM receives the Tri-State area’s “direct count” data from the July 9, 2010 aerial census, less than a month later they issue a Preliminary Gather Schedule for Fiscal Year 2011 on August 5, 2010, which includes a tentative plan to gather some of the HMAs inventoried in the Tri-State Survey.

Here we watch BLM mushroom the 172 wild horses from the Fox Hog HMA to an estimated 726 – and this was before USGS made the little “tweak” to revamp the estimate to 300 wild horses.

But it doesn’t stop there. The High Rock HMA goes from a direct count of 300 to BLMs “new” number of 747 and Massacre Lakes jumps from 148 to 220 as well. All totaled, BLM reports they are projecting to gather 1,735 wild horses from the High Rock, Fox Hog, Massacre Lakes and Wall Canyon HMAs next fall.

So, I tried to see if there were any way to make BLMs numbers work with real world math and big surprise, no matter what I tried, it just didn’t fly!

First, I totaled the Tri-State wild horse population (just from the July raw count data as BLM had yet to see the results of Program MARKs estimation when they released the Preliminary FY11 Gather Schedule). The results from the survey of the four HMAs were merely 707 wild horses.

So then I padded the “official” HMA populations by adding the entire 430 wild horses the Tri-State Survey cited as “outside CA HMAs” to this total. Yes, all the wild horses from the entire CA area. This brought it up to 1,137 wild horses.

Next, I subtracted what BLM was projecting to gather (1,735 wild horses) from what the Tri-State Survey had counted for these same HMAs (but also included all wild horses reported in the survey as “outside” now totaling 1,137 wild horses).

Then I tried adding a 20% reproduction rate to the original raw count of 1,137 wild horses because next spring will cause populations to go up - but the 20% reproduction rate couldn’t even come close. Okay, how about a 25% reproduction rate? Still not even in the ballpark. The fact of the matter is, the only way BLMs numbers would “jive” is by adding a 52% reproduction rate to the wild horses found in the Tri-State Survey. And don’t forget, BLMs estimate includes foals and weanlings that aren’t even capable of reproducing yet!

The methods BLM is now touting as bringing “more valid” population estimates to the Wild Horse and Burro Program resulted in merely a 2.3% adjustment by USGS and Program MARK. But by the time BLM got a hold of them, populations moved into the realm of pure fantasy.

And can’t ya just hear Salazar now. “Common Congress, ya just gotta believe us and give us the money to keep rounding em up – no questions asked! JUST LOOK AT THESE NUMBERS! Why, the wild horses are just positively overrunning the range! And they are based on the newest, most technologically advanced peer-reviewed census methods available!”

Anybody else wondering what the population of America’s mustangs and burros would really look like if USGS used Program MARK as it was originally intended – to estimate survival rates - but used BLMs removal numbers instead?

East Fork High Rock Canyon
Home of wild horses overrunning the range.
Photo courtesy of BLM.

For The Future

The Bureau of Land Management’s Winnemucca Field Office is accepting public comment, input, suggestions and recommendations for the development of their new Resource Management Plan. This is a crucial framework that will guide BLM in future decisions affecting the area for the next 10-30 years.

This Winnemucca Field Office is the responsible district for the Calico Complex and many other wild horse and burro use areas in Northern Nevada.

Please take a few moments out to submit your ideas, comments, input and suggestions for incorporation in the final plan as the number of comments BLM receives, as well as the kinds of recommendations, are critical to the future of wild horses and burros.

Listed below are some of my own ideas and recommendations. Feel free to use them for inspiration or incorporation in your own comments.

Wild Horse from the Calico Herd Management Area
Courtesy of BLM - 2004

Winnemucca Draft Resource Management Plan

I support Alternative C as well as the incorporation of the following recommendations in all Alternatives and analysis in the Final Environmental Impact Statement and Record of Decision.

> Include legal land descriptions for all Herd Areas and Herd Management Areas.

> Review all Herd Areas within the planning area for reintroduction to Herd Management Status as required by CFR 4700.3-1. Provide a detailed analysis and reasons for previous withdrawals as well as potential mitigation measures that may reinstate wild populations on legally designated Herd Areas.

> Identify wild hose and burro use areas as suitable for designation as wild horse and burro “ranges” to be devoted principally as sanctuaries for their protection and preservation as per Section 1333(a) of the Wild Free-Roaming Horse and Burro Act and 43 C.F.R 4710.3-2.

> Develop Alternatives that incorporate the designation of ACECs (Areas of Critical Environmental Concern) for all remaining wild burro herds and the critical habitat and resources if necessary to insure self-sustaining genetically viable populations within the planning area as per the FLMPA, Section 202 [43 U.S.C. 1712] (a)(3) for long-term sustainability.

> Identify Herd Areas, Herd Management Areas and Ranges that provide unique opportunities to develop public viewing opportunities and/or development of ecotourism based on the promotion of wild herds as well as including an analysis of potential economic benefits this would bring to local communities.

> Identify any bands or herds that use two or more Herd Management Areas to secure suitable year-long habitat and resources based on environmental conditions, migratory patterns or seasonal movement.

> Base wild horse and burro resource allocations on scientific and rational principles. Incorporate suitability criteria be established within the framework of the RMP as recommended by the National Academy of Science over 30 years ago to better reflect actual use and available forage for free-roaming populations to achieve accurate appropriate management levels and “excess” determinations.

> Develop and incorporate within the framework of the RMP the methodology used to distinguish wild horse and burro impacts from livestock and other rangeland users. One potential method is to mandate monitoring and utilization levels be measured prior to the introduction of livestock in a given area order to distinguish class use and impacts.

> In all Herd Management Areas, assure management plans will provide allocations and resources adequate to maintain a minimum of 150 animals at all times on the range per individual HMA as necessary to maintain long-term genetic viability according to the best available science. This will prevent inbreeding or population crashes as required by CFR 4700.0-6(a) and to ensure that populations are being managed as an integral part of the natural systems of the public lands.

> In individual Herd Management Areas, prohibit management plans and strategies that fail to provide for self-sustaining wild horse and burro populations lower than a minimum population of 150 animals based on the concept of “genetic interchange” between bands or herds from different Herd Management Areas. The only exception to this could be if BLM can conclusively document known population interchanges by photographs or other identifiable markings of animals on a multiple and consistent long-term basis.

> If necessary to provide habitat for wild horses or burros, to implement herd management actions, or to protect wild horses or burros from disease, harassment or injury, invoke BLMs authority to reduce or close areas of public lands to grazing use by all or a particular kind of livestock as established by C.F.R. 4710.5 (a), with the goal of maintaining self-sustaining genetically viable wild horse and burro populations through allocations assuring resources are adequate to maintain a minimum of 150 animals at all times on the range per individual HMA.

> Prohibit the use of “blanket” management options that allow for wild horse and burro reductions without supporting data to make excess determinations, i.e., “in the absence of species specific data, equitable reductions in livestock and wild horse and/or burros authorizations will be implemented.” The historical problem with the management approach of authorizing “equitable reductions” is there is no accountability or consequence to BLM if they fail to reduce the livestock portion of the projected reductions. Traditionally, BLM has removed wild horses and/or burros or reduced their population objectives while making no changes or increasing livestock authorizations shortly after applying changes exclusively to free-roaming populations.

> Prohibit the issuance of non-renewable grazing permits in any wild horse and burro Herd Area, Herd Management Area or Range in order to allow maximum long-term rangeland health due to year long grazing pressure in these designated areas.

> Establish criteria within the RMP framework for incorporating periodic monitoring at “key” times to establish data on available water. This should include mandatory flow rates, water quality data, status of historic sources (in order to collect trend data on water availability) and photographic evidence to establish credibility in BLMs data.

> Various related multiple use decisions issued by the Winnemucca Field Office as well as surrounding areas indicate the potential for significant and cumulative impacts to underground aquifers and water sources due to drawdown. Incorporate provisions within the RMP that provide mitigation measures for water loss, increase available habitat, disperse consolidated grazing pressures, and insure supplemental low cost water sources are available in times of drought or harsh environmental conditions for wild horses and burros as well as other wildlife species within the planning area.

> Prohibit the use of any sterilization measures on populations that fall below the minimum genetic threshold of 150 animals or less and assure balanced gender structures to preserve natural herd behaviors and social dynamics.

> Prohibit the inclusion of foals one year and under in population inventories and calculations occurring on the range for “excess” population determinations.

> Establish population objectives and thresholds for big game species within the planning area to insure habitats support a “thriving natural ecological balance” between all species. The current policy to omit critical information on species populations, increased pressure on resource requirements and their resulting impacts fails to conform to federal law mandating scientifically sound management decisions and quality data to determine suitable habitat for all rangeland users. As public stewards, BLM needs to recognize and honor their position to preserve and protect all resources for the American people, both now and for future generations. State wildlife agencies have a vested interest in increasing big game populations to increase revenue. As such, studies, data, recommendations and management objectives may contain inherent “conflicts of interest” and biased towards the balanced management of resources on public lands.

> Provide for public review a detailed examination and analysis of all current multiple use applications within each Herd Area and Herd Management Area within the planning area. This is to include current livestock authorizations, the percentage each allotment overlaps existing wild horse and burro areas as well as maps clearly showing the relationship and resource allocations between livestock and wild equids within the planning area. The purpose of this information is to help the public be reasonably informed as to BLMs compliance with the Act’s mandate to accomplish the protection of wild free-roaming horses and burros through their consideration as an integral part of the natural system of the public lands as well as their relationships with other uses of the public and adjacent private lands as outlined in CFR 4710.3.

> With respect to wildlife impacts to critical resources required by wild horse and burro populations, provide current estimated big game populations such as elk, pronghorn, mule deer and bighorn, populations affecting the wild horse and burro areas within the planning district, reasonably foreseeable future big game population objectives for these same areas that may impact management strategies to maintain self-sustaining genetically viable herds.

> All other multiple use authorizations within Herd Areas and Herd Management Areas such as current mining, oil and gas operations as well as renewable resource projects such as solar, wind or geothermal impacting or reasonably projected to impact habitat and/or resources in the Winnemucca Herd Areas and Herd Management Areas as well as projects or proposals that can be expected to be implemented in the reasonably foreseeable future. This should include a detailed map of each Herd Area and Herd Management Area in the planning area to allow the interested public to assess the impacts of other multiple uses to wild horse and burro habitat and populations in a site-specific manner.

> Include detailed analysis of the miles, kinds and locations of fencing within each HA/HMA within the planning district. Reaffirm strict limitations on fencing in wild horse and burro Herd Areas, Herd Management Areas or Ranges in order to preserve their free-roaming behaviors and to prevent entrapment, injury, death or undue degradation of resources due to limitations on seasonal or migratory movement.

> Incorporate protections for predators in and around herd management areas as a management tool for low cost population control and to support the “thriving natural ecological balance”.

> Prohibit management strategies that are based on “adoption criteria” as the primary consideration. This policy fails to conform to both the intent and the mandates of the Act. Incorporate management strategies that support historical herd traits and local community values for the bands/herds.

> Utilize range management to address wild horses and burros who wander across the borders of Herd Management Areas (HMAs), instead of permanently removing them.

> Removals of any kind should be rare and minimal. Other methods of management must be employed first and given a fair opportunity to succeed. If a limited removal is necessary, it must be done in a humane manner that respects horse social structure and keeps families intact.

~DEADLINE~
MONDAY, OCTOBER 25, 2010
4:30 P.M. PST


SUBMIT TO:
Winnemucca RMP
c/o Bob Edwards
Attn: Winnemucca RMP
Bureau of Land Management
Winnemucca District Office
5100 E. Winnemucca Blvd.
Winnemucca, NV 89445
Fax: (775) 623-1503
Email: wdrmp@blm.gov

Please be aware that your submissions will become part of the public record, including personally identifying information. Though you may request BLM keep this information private, they may not be able to guarantee it in all instances.

RELATED LINKS

WINNEMUCCA DRAFT RESOURCE MANAGEMENT PLAN

Public Comment Submission

In Defense Of Animals - Alternative Comments

Gubmint Cheese

The following article is solely an opinion piece of the author and does not reflect the thoughts, feelings, opinions, attitudes or beliefs of any other wild horse, burro or equine enthusiast across the globe.

Due to the large body of evidence regarding the ability of western stockman whose paths are crossed to retaliate in often unyielding and brutal fashions, (regardless of their stature in society), if you are a western stockman reading this, please remember that you are suppose to look like you value individual freedom, which includes opinions such as mine. Also, may I throw out for your consideration; it’s just not good business to bite the working class hand that feeds you.

#

“Despite the lack of data, BLM has proceeded with horse removals using targets based on perceived population levels dating back to 1971 and/or recommendations from BLM advisory groups comprised largely of livestock permittees.”

Improvements Needed In Federal Wild Horse Program
Government Accounting Office
Report RCED-90-110, August 1990

Well, it’s that time again for the Nevada Cattleman’s Association (NCA) to hold their annual convention in good ole (as in Good Ole Boy) Elko, Nevada, November 10-12, 2010, first announced in the NCA’s Executive Director’s September Monthly Message titled, “75th NCA Convention Nears; Wild Horse Gathers: Let Your Voice Be Heard”.

Included in the message was how NCA coordinated with a cozy coalition to send letters of opposition to the same Congressional representatives who signed on to a July 30, 2010, letter urging a moratorium on round ups until a scientific study by the National Academy of Science (NAS) could be completed.

While the Director ignored the Congressional call for science-based management as the reason for the moratorium, an inaccurate but easy-to-read summary was presented to NCA members by merely stating, “The letter was filled with misinformation and half truths”.

The NCA Monthly Message also encouraged members to submit a long list of unsubstantiated talking points to cattleman conspirator Secretary Salazar in support of continued wild horse stampedes. These included crocodile tears for starving and dehydrated mustangs, lack of humane treatment by leaving them on the range to die and what fabulous stewards permittees are of biodiversity, wildlife and rangeland health on public lands.

As I read through the pile of cow patties being served on a golden platter, I was struck at how the public lands Welfare Queens showed no shame in their desperate defense of their government cheese.


“A welfare queen is a pejorative phrase used in the United States to describe people who are accused of collecting excessive welfare payments through fraud and manipulation.”

Wikipedia, 10/15/10

The rural ranching community in Nevada has been shown to be predominately Republican, a party characterized by propaganda touting fiscal responsibility, belief in a free-market equals a free society and demands for reduced government regulations and involvement.

The GOP front for the GOB (Good Ole Boys) network was actually the first to create the image of an inner city Welfare queen, a stereotype and name coined by none other than self-proclaimed Sage Brush Rebel and GOB hero, Ronald Reagan himself.

With Reagan’s help, the New Right of the early 90’s targeted many of the welfare programs through derogatory connotations singling out women (and American African women in particular), for engaging in lazy, immoral behavior and using children to increase their government sponsored incomes. Not surprisingly, most of the stories used to create this stereotype - including Reagan’s - turned out to be false.

Apparently, the welfare queens of the inner city had a lot to learn from the original Welfare Queens of public lands. While inner city queens waited on lists for months to access government housing on postage stamps butted back to back in run down neighborhoods, the public lands Welfare Queens commanded tens of thousands of acres for their backyard with demands this right be passed down from generation to generation with no questions asked.

Pushing out children by the dozen to receive government subsidies was no match for pushing out cattle numbering in the thousands and food stamps paled in comparison to the $1.35 p/month ranchers are forced to pay to feed a 1,200 lb. plus animal. This equates to the total weight of an inner city queen, her entire diaper bound brood, her current partner found sneaking out of the bedroom during welfare inspections with hundreds of pounds still left over.

To the GOB Welfare Queens, fiscal responsibility only applies to any government program that’s not supporting them while the free-market is invoked only after they transport their government gorged beef to livestock auctions to sell to the highest bidder.


THE MYTH: “Over time, the cowboys of the American West developed a personal culture of their own, a blend of frontier and Victorian values that even retained vestiges of chivalry. Such hazardous work in isolated conditions also bred a tradition of self-dependence and individualism, with great value put on personal honesty.”

Wikipedia, 10/15/10

The modern Western rancher grew from the frontier work of the American “cowboy” (literal meaning - a boy who tends cows) but in reality, the majority of today’s ranchers are far removed from their historical roots.

Bloated by government subsidies, giveaways and handouts, the self-dependence of their ancestors is only a dim memory of prodigy who now ferociously suckle the government teat while the individualism of yesteryear has been reduced to a battle cry masking childish tantrums thrown by spoiled brats who don’t get their way.

Don’t me wrong, just because they are cow boys doesn’t prevent them from being dangerous!

The western cowboy now turned rancher also shares many common themes illustrated in William Golding’s “Lord of the Flies”. This is a story of how a group of boys stranded on a deserted island descended into primitive and savage behavior. They eventually turned lazy and idle as struggles for power and domination became the central theme of their daily existence, much like the Western stockman of today.

To me, the most notable difference between the boys in Lord of the Flies and today’s modern cow boys is, the boys in the book were rescued and returned to civilized behaviors; the modern day rancher sprouted from a culture developed by boys who continued to stay isolated and so, never really learned how to grow up.

While the GOB Welfare Queens of the NCA speak of half-truths and misinformation about wild horses and burros on public lands, I reflected on Nevada’s proud ranching heritage. Here, on almost exclusive owned public lands, many ranchers hide out in remote areas and demand their names be kept secret lest the taxpaying public actually catch wind of who is turning our landscapes to waste for a pittance.

One of Nevada’s proudest heritage moments was when a Nevada consulting firm (with absolutely no affiliation with the Nevada Cattleman’s Association, I’m sure) issued a report titled, “A Technical Review of U.S. General Accounting Office Rangeland Management and Public Rangelands Reports 1988-1990” in response to the GAO’s findings about the truth of public lands livestock grazing.


“Despite lack of adequate data on the number of wild horses the land can support, BLM has proceeded with removing horses. For example, BLM’s Nevada State Office concluded that available data were not adequate to justify removing wild horses; however, in both instances BLM’s responsible district and resource area offices chose not to revise their plans to remove horses in their areas. In contrast, BLM has frequently used the lack of detailed carrying capacity and range monitoring data to explain why it has not taken action to reduce widely recognized overgrazing by domestic livestock.”

Improvements Needed In Federal Wild Horse Program
Government Accounting Office
Report RCED-90-110, August 1990

Apparently, the GAO was forced to defend then recently released rangeland reports as cow boys ran balling to Congress and waiving the consulting firms report to demand retractions from a “biased” GAO. The list of Congressional requesters demanding the GAO review their own methodology included Senators Harry Reid, Conrad Burns, Larry Craig, Orrin Hatch, and John McCain to name a few.

What were some of the main bones of contentions the Nevada consulting firm had with what the GAO had to report?

They screamed about how the problems of riparian area destruction, overstocked grazing allotments and the resulting declining and potentially permanent range conditions were mostly attributed to livestock grazing. They cried about the GAO’s recommendation that more aggressive enforcement of trespass livestock be addressed, more comprehensive data on land conditions and trends be made available, and of course, they had a hissy fit when the GAO reported the range issues stockman continue to attribute to wild horses and burros fell squarely on the suckling livestock industry instead.

The GAO’s review and response to the consulting firms report, not surprisingly for those of us living in a state controlled by these Hand-Out Harry’s was, “the consulting firm’s critique is not valid…contained little factual data to substantiate its assertions [and] misrepresented our reports’ findings to support its position”.

“GAO found that despite congressional direction, BLM’s decisions on how many wild horses to remove from federal rangelands have not been based on direct evidence that existing wild populations exceed what the range can support. Moreover, wild horse removals often have not been accompanied by reductions in authorized livestock grazing levels or effective range management to increase the land’s capacity. As a result, range conditions have not demonstrably improved….”

Improvements Needed In Federal Wild Horse Program
Government Accounting Office
Report RCED-90-110, August 1990

However, the NCA made nary a peep when the DOI’s new grazing regulations came out in 2006, despite long-time BLM employees Erick Campbell and Bill Brookes claims of doctored environmental analysis and suppression of scientific information supporting how the cattle industry would have “slow, long-term impact on wildlife and biological diversity in general”.

Campbell also called the DOI’s approval of the Bush Era grazing regulations a “white wash” and “a crime” as well as adding, “They took all of our science and reversed it 180 degrees”. Brookes added, “Everything I wrote was totally rewritten and watered down”.

Apparently, that’s the kind of misinformation and half-truths NCA can support!

The NCA’s Monthly Message also showcases Past President Boyd Spratling, currently masquerading as a Representative of Veterinary Medicine on the National Wild Horse and Burro Advisory Board. Dr. Spratling (or is it Past President Spratling?) has been busy providing testimony on wild horses in the Interim Public Lands Committee and recently met with Senator Ensign to discuss wild horses and the “El Paso/WWP” situation. (It would seem Senator Ensign is incapable of recognizing a conflict of interest situation even if it is sitting on his lap....)

This is the same Boyd Spratling who refused to address, much less develop, humane handling guidelines for helicopter rounds ups back in 2007 and who stated the deaths of almost 200 wild horses from the Jackson Mountain were the results of “The very people that claim to care the most about those horses were actually the ones driving the death nail in their coffin”.

This same ex-President Spratling also developed the current BLM approved on-the-range stallion castration policy, refused to participate in repeated requests regarding review of BLM management plans and AML decisions for our wild herds, ignored evidence indicating BLMs on the range wild horse and burro population data is in error and failed to address critical issues found within new census techniques now being used to substantiate biologically impossible populations.


“BLM also sometimes deferred its horse removal decisions to advisory groups comprised primarily of livestock permittees. In Nevada, BLM established target wild horse population levels on this basis in eight herd areas. Since livestock permittees have a vested interest in keeping wild horse populations low to reduce competition for forage for their livestock, setting horse removal levels on the basis of their views may not be appropriate.”

Improvements Needed In Federal Wild Horse Program
Government Accounting Office
Report RCED-90-110, August 1990

While the NCA relies on old-time mythology of the cow boys “great personal honesty” to sell its hypocritical contortions of rangeland reality, copied below is one of the NCAs talking points about why a moratorium on wild horse gathers must not be allowed:

Elevating one species over another, particularly a species which demands more forage than can be replaced, jeopardizes other users of public lands, and threatens native plants and wildlife species. Finding and keeping Appropriate Management Levels is the key to the balance of management and impacts on public lands. Tipping the scale towards the domination of wild horses does not correlate with the directive of the Bureau of Land Management.

.
Yes, at long last NCA has finally issued a statement the American public and wild horse and burro enthusiasts can finally agree on; “The elevation of one species over another…jeopardizes other users of public lands.”

And why doesn’t the GOB Welfare Queens want to tell the truth about the reality out on the range?

Because as you peruse the Nevada Cattleman’s Association’s website and see all those smiling faces under their Welfare crowns (a.k.a., the cowboy hat), know those grins weren’t just from saying “Cheese” like the rest of us suckers do, they were saying “Gubmint Cheese!”


“Wild horse and burro populations consume forage on the public rangelands and consequently contribute to the overgrazing problem. However, as we have noted in previous testimony, the primary cause of the degradation in rangeland resources is poorly managed domestic livestock (primarily cattle and sheep) grazing. When more animals are allowed to graze in an area than the land can support, forage consumption exceeds the regenerative capacity of the natural vegetation, resulting in erosion, watershed damage, and other deterioration. Although recognizing that overgrazing was occurring, BLM range managers reported that no adjustments in the authorized livestock grazing levels were scheduled in 75 percent of the allotments threatened with further damage. These managers cite insufficient data on specific range conditions and resistance by livestock permittees as the primary reasons why action had not been taken.”

Improvements Needed In Federal Wild Horse Program
Government Accounting Office
Report RCED-90-110, August 1990

RELATED LINKS

Historical GAO Rangeland Management Reports

Improvements Needed In Federal Wild Horse Program
(GAO/RCED-90-110, August, 1990)

Observations on Management of Federal Wild Horse Program
Testimony and Statement by James Duffus III, Director
(GAO/T-RCED-91-71, June 20, 1991)

Current Formula Keeps Grazing Fees Low
(GAO/RCED-91-185BR, June 1991)

Assessment of Nevada Consulting Firm’s Critique of Three GAO Reports
(GAO/RCED-82-178R, May 4, 1992)

Congressional Requesters/Contacts and Documents Reviewed
(GAO/RCED-92-193R, May 4, 1992)

Results of Recent Work Addressing the Performance of Land Management Agencies
(GAO/RCED-92-60, May 12, 1992)


OTHER LINKS

Public Lands Grazing Program
Taxpayers For Common Sense

Oprah Accused Of Whipping Up Antibeef Lynch Mob
CNN/1998

A Nightmare In The Old West

OBITUARY: KENT RANDOLPH KNUDSON
November 11, 1949 - September 25, 2010

A Similar Vaccine

Recently, I have seen some interesting new trends developing in BLM wild horse & burro proposals.

While certainly not as horrifying as the recent discovery at Sheldon National Wildlife Refuge of scattered horse bones, a mass grave or the terrifying events experienced by the courageous Leslie Peeples, the ramifications of these trends are certainly disturbing.

As the accelerated Obama/Salazar meat machine continues to grind up America’s wild horses and burros behind closed doors while contemptuously spitting them back out into the publics face, here is one of the latest trends BLM may be about to foist on our herds.

Captured wild horse.
Oregon Warm Springs Canyon HMA (2006).

On September 15, 2010, the BLM Burns District Office in Oregon announced the opening of a public comment period on a fourth alternative being added to an already released Environmental Assessment regarding the removal of wild horses in the Warm Springs HMA.

The summary of this new alternative is, “The BLM has subsequently added a fourth alternative to the EA analyzing the application of a 2-year Porcine Zona Pellucida (PZP-22), or similar, vaccine to approximately 43 horse mares. At this time, the BLM is soliciting comments on the additional alternative of injecting mares with PZP-22.”

Public comments were restricted to input only pertaining to the addition of this new alternative and were limited to twelve days; the comment period ended on September 27, 2010.

Perhaps some of you caught all that was transpiring in the two tiny sentences BLM posted in the proposal but for those of you who didn’t, let me elaborate. There are two key phrases here that should have supporters of self-sustaining wild herds on public lands and open public processes extremely alarmed.

The first issue is based on BLMs strategic wording, public comments are limited to ONLY injecting mares with PZP-22. Yet, that’s is not all BLM is proposing here, is it? The sentence states, “or similar vaccine” and that’s the second issue.

What does “similar” vaccine mean?

According to two BLM internal reports generated in 2008 and obtained by advocates under the Freedom of Information Act, the BLM’s Team Conference Calls (July 2008) and Alternative Management Options (October 2008), wide spread sterilization measures were aggressively explored throughout as is also now included in Salazar’s proposed new direction for the Wild Horse & Burro Program.

The following quotes were taken from these two reports and BLM has had two years to follow through on the discussions and recommendations regarding “similar vaccines” BLM was then putting on the table for our wild herds future.

STERILIZATION OF MARES USING SPAYVAC™ OR GONACON™

SpayVac™
“Spavac™ was used in the Virginia Range horses with the testing being done at the Carson City Prison.” With respect to what the Team called, “The Carson City horses”, they stated “11 out of 15 have not gotten in foal”.

“A captive trial of estray horses in Nevada indicates it may be a more effective, longer lasting fertility control agent than conventional PZP.”

“A single vaccination of SpayVac™ could maintain a high level of contraception within wild mares for at least 4 years or could be permanent.”

“Based on the Nevada estray horse trials (Killian et al in press 2008), SpayVac™ exhibits the ability to reduce population growth in wild horses. If it proves to be permanent, it may be a valuable tool for use on specific mares in non-reproducing herds.”

“The captive trial in Nevada showed 100% contraception in Year 1, 83% in Years 2 & 3 & 4 (Killian et al. in press 2008). This rate of efficacy exceeds previously reported efficacy rates for PZP use in wild mares.”

“If proven to be permanent, SpayVac™ could be used to create non-reproducing herds of mares.”

“There is no SpayVac™ product currently available for use and no one is making it” and “it is barely available as a research product”.

“Additional research on the duration and long term effects of SpayVac™ are needed. These research trials could begin shortly after vaccine production resumes.”

“To date, there is no projected dosage cost for SpayVac™ as no inventory is available. Costs may be similar to the one-year PZP vaccine BLM is currently using (about $200 per dose and an estimated $500-1,000 to capture and mark treated mares).”

“A study for the research and development of SpayVac™ would require approximately $250,000 for captive trials over a five year period”.

“SpayVac™ could be ready for experimental use in one to two years and for management use in free-roaming horse populations in approximately six years if the above issues are resolved.”

“There is no regulatory approval for the management or investigation use of SpayVac™ through EPA or FDA. The Researcher/developer would need to obtain written permission from EPA or FDA for its investigational use or a letter saying that isn’t necessary.”

“If SpayVac™ proves to be permanent it could potentially threaten the genetic viability of the treated population by limiting the genetic contribution to fewer animals.”

“Data is not available that describes the impact of SpayVac™ on the behavior and physical health of the mares.”

“It may be several years before SpayVac™ is ready for field use on an experimental basis. An investigational approval or exemption needs to be obtained from the EPA to develop SpayVac™ for management use. The vaccine would also have to be brought into production again (about a one year waiting period). Additional research trials could begin shortly after vaccine production resumes. Based on these projections, it will be about six years before SpayVac™ could be a usable management tool for fertility control in free-roaming populations of wild horses.”

“Based on the Nevada estray horse trials (Killian et al in press 2008), SpayVac™ exhibits the ability to effectively reduce population growth in wild horses. If it proves to be permanent, it may also be a valuable tool for use on specific mares as individuals in non-reproducing herds.”


About GonaCon ™

“GonaCon™ is also a product that needs to be re-looked at for sterilization of mares.”

“GonaCon™ is an experimental gonadotropin-releasing hormone (GnRH) immunocontraceptive vaccine developed for deer by scientists at the U.S. Department of Agriculture’s (USDA) Wildlife Services’ (WS) National Wildlife Research Center (NWRC).”

“GonaCon™ reduces or eliminates the production of sex hormones (e.g., estrogen, progesterone, and testosterone) within the target animal.”

“Efficacy rates after the first year appear to be similar to or somewhat lower than the PZP-22 BLM currently uses.”

“It may be several years before GonaCon™ is ready for field use on an experimental basis in wild horses and even longer before it is available for management use.”

“The developer of GonaCon™ must first obtain the necessary documentation and approvals from the EPA to use the product outside of research trials like the Nevada estray horse trials.”

“NWRC has received Environmental Protection Agency (EPA) authorization for the investigational use of GonaCon™. This permit allows NWRC researchers and their collaborators to ship and test the vaccines on both captive and free-ranging animals. Tests for the GNRH vaccine are ongoing in several states and countries, involving a wide range of wildlife and feral species, including horses”.

“GonaCon™ is currently not available for management use under the authority of the EPA and the registration is in process for deer only.”

“GonaCon™ will be registered as a “Restricted Use” product. Although final label language has not been negotiated with EPA, NWRC anticipates the product will be labeled for use by State or Federal wildlife or natural resource management personnel or persons working under their authority. GonaCon™ users will need to follow State authorization processes.”

“The National Park Service is planning field trials with wild horses to investigate the efficacy of GonaCon™ as a tool to control population growth. However, it may be several years before GonaCon™ is ready for field use on an experimental basis in wild horses. The developer of GonaCon™ must obtain the necessary documentation and approvals from either EPA or FDA to investigate the vaccine on a broader scale than currently with the Nevada estray horse trials.”


So, tell us Secretary Salazar, if the proposed action is “soliciting comments on the additional alternative of injecting mares with PZP-22”, why is “similar vaccine” included? And “what” similar vaccines are being referenced here that the public is suppose to on comment in the Warm Springs HMA “fourth alternative” with no further explanation or analysis?

To add fuel to the fire of what the Oregon BLM staff is doing behind Salazars iron curtain of secrecy, in the 2010 Post-Gather Report for the South Steen’s wild horses BLM listed 59 mares as treated with PZP. However, at the end of the Post-Gather Report in the notes section, in bold capitol letters, they added “NO PZP ADMINISTERED”.

I contacted Oregon BLM to request clarification as to what this meant. The response never really answered the question. Mr. Hopper merely stated that a new Post-Gather Report “was being revised” and when it arrived, BLM re-wrote history by “eliminating” the No PZP Administered and replaced it with “59 mares were treated with PZP.”

Now, it would seem to me that if someone took the time to write in bold, capitol letters, “NO PZP ADMINISTERED” in the field notes while still entering 59 mares being treated, there’s a bit of a clue about the possible fertility control experiments going on in the field.

Now we have “similar vaccine” craftily inserted in the Warm Springs “fourth alternative”.

As for whether this similar vaccine is SpayVac™ or GonaCon™ or some other Frankenstein concoction BLM has managed to whip up since 2008, the potential “permanent sterilization” of mares through their use, combined with an unknown number of castrated stallions they intend to return to the range as described (kind of) in the EA, BLMs "Proposed Action" yielded a projected median population growth (the one BLM always uses) of 50 wild horses over an 11 year period. (Appendix E, 2010 Warm Springs HMA Gather, Win Equus Population Modeling, July 16, 2010, Proposed Action, pg. 51).


Will these be some of the last foals the Oregon Warm Springs Herd Management Area will ever produce after BLMs newest proposed gather?

Photo of foals representing the Warm Spring HMA. Courtesy of BLM.

Probably not as BLM states part of the Proposed Action is "To ensure genetic viability, two to three horses with similar traits from another HMA would be returned to the West Warm Springs HMA" (pg. 7)

That's right, the fertility control measures are going to be so strong after BLM gets through with the Warm Springs wild horses in the upcoming round up, they are going to have to import wild horses from other areas to keep the populations from genetically crashing.

###

For an additional excellent article that provides summary examinations of everything BLM discussed and presented in their 2008 internal reports, check out Animal Law Coalitions, “BLM’s Final Solution For Wild Horses and Burros” by Laura Allen.

To learn more about the “et al” mentioned in BLMs referencing of (Killian et al press 2008) used as the supporting study to move forward on BLMs fertility control alternatives, read “Crooks and Liars: Nevada Agriculture Director Scuttles Birth Control Study”, October 17, 2008, by Willis Lamm of KBR Horse.

Click Here for BLMs original South Steens 2010 Post-Gather Report.

Click Here for BLMs edited version of the South Steens 2010 Post-Gather Report.