Monday, December 27, 2010

The Iron Curtain

Hey Bob, I thought about titling this post to you. I thought you might want to know. At first, I toyed with Dear Bob or Dear Director Abbey or something that would speak directly from one interested stakeholder to your ears, but as you can see decided against such a simple framing for the massive subject I wanted to tackle.

See Bob, I’ve been a little busy examining your Program statistics again, combing through BLMs FY2011 Budget Justification report to Congress and making a few graphs of my own.

I spent a month working with some great gals, Carla Bowers and Leslie Peeples, in trying to figure out ways to summarize one, giant oozing festering mess – something BLM and their support team are markedly proficient in coating with Teflon©.

It’s an alternative perspective on the Wild Horse & Burro Program that uses almost exclusively the BLMs own publications and numbers to make its case to Congress about why you need to be cut off from any more money until some real answers are coughed up or you are allowed to peddle your sugar coated solutions based on a foundation of non-credible data and lies. If you haven’t already seen it, you can check the "Report to Congress: Refuting FY2011 Budget Justifications and Request to Defund Roundups and Removals Through Appropriations For FY2011 and FY2012" here.

So as you might imagine Bob, I was a little busy when Sue Wallis & Co.’s Slaughter Summit agenda came out announcing you and other key BLM personnel and associates were invited guest speakers.

I also wasn’t able to pay too much attention to your national public response now posted on the front page of BLMs website explaining why you have tentatively accepted the invitation because you are so “fair and balanced” as to meet with such diverse stakeholders – that now include a high dollar conference comprised of the Who's Who of the horse slaughter industry.

After all, while BLM will post every letter of support, agreement and enthusiastic applause for BLMs actions by any group or agency who often has glaringly apparent conflicts-of-interest with wild horses and burros on public lands, “our” public website stays curiously silent, some would say almost censored, of any voice, argument or document that challenges or refutes what the BLM does.

Which reminds me, will the BLM be posting our report on the Wild Horse & Burro website too so everyone can see what some of the "other" issues are because you are so “fair and balanced” towards all diverse stakeholders?

So now I've finally made a little time to see what you’ve been up to and I’ve have a few questions for you Director Abbey.

A few weeks ago, I sent an email to you and a whole list of key BLM employees expressing my concerns about a BLM Press Release for the Callaghan/New Pass/Ravenswood roundup.

Here is the portion of the Press Release I take issue with,

"NDOA brand inspectors must verify the animals are wild horses and burros as defined by the Wild Free-Roaming Horses and Burros Act of 1971. Once verified, the brand inspector will provide the BLM a certificate to transport the animals".

See, this is kind of a problem because it’s deceptive and reminiscent of one of the oldest tricks in BLMs sending-wild-horses-to-slaughter books. You remember, how BLM had been conspiring with state agriculture agency's or turning their heads so brand inspectors could send tens of thousands of wild horses to meat packing plants by citing state jurisdiction over federal law during the first years after the passage of the Wild Free-Roaming Horse and Burro Act?

You do remember that, don’t you? It’s in your own statistics. How almost 70,000 horses counted as roaming free on the range were “privately claimed” between 1971 and 1980. You know, those “non-wild” horses who were carted off to slaughter due to new found private status, thanks to state brand inspectors working in “close coordination” with BLM personnel.

So, I’m sure you remember this as well, how a big legal battle developed and the courts had to decide who was actually responsible for making the determination of what qualified as a wild horse/burro. And the courts said it was you Bob, the authorized agent of the Secretary, who had jurisdiction and ultimate responsibility to make that determination. If the state brand inspectors couldn’t verify the animals were privately owned, they fit the definition of a wild free-roaming horse and burro and were entitled to protection under federal law.

Remember, I sent you those links to the federal court cases, American Horse Protection Institute v. US DOI (1977) and Sheridan v. Andrus (1979) that clearly outlined how state agriculture agencies jurisdiction only extended to verifying animals did not have brands, bills of sale or sufficient evidence to establish private ownership.

See, it appears that BLM and Nevada Department of Agriculture (NDoA) recently pulled this jurisdictional shell game last June with respect to the Toana “wild” a.k.a. the Pilot Valley “feral/estray” horses as each agency batted the ball back and forth until a “compromise” was reached. Finally, NDoA “verified” for BLM how those horses were not “wild” in the most suspicious manner possible in order to sell them at state livestock auction - but I’ll explain how that happened a little later in this post.

Well anyway Bob, you didn’t bother to reply, much less address my concerns. In fact, neither did BLM Wild Horse and Burro Chief Don Glenn, BLM Nevada State Director Ron Wenker, Nevada Wild Horse and Burro Lead Alan Shepherd or Tony Lesperance of Nevada Department of Agriculture.

However, I did get a phone call from the local field office promising to get back with me about my concerns but we ended up playing phone tag for so long that BLM re-issued the same statement again in the Clan Alpine round up press release; I guess I should consider that BLMs response.

After all, BLM needs NDoA to issue a certificate of transport, right? Except I can find no such authority in the Nevada Revised Statutes (NRS) requiring BLM to verify the status of a wild horse/burro with NDoA or needing NDoA to issue BLM a certificate to transport them.

Given the historical abuses that have occured with state brand inspectors and how Congressional testimony during the passage of the Act clearly expressed grave concern about the lax and sometimes conflicted interest states had with respect to the livestock industry, I find it curious that neither you nor your authorized agents charged with protecting wild horses and burros nor NDoA itself didn’t feel this was important enough to respond to, couldn't be bothered to provide the NRS provisions supporting your newest press release statements about NDoA's power, or didn't feel the need to share any cooperative agreements granting NDoA this sort of jurisdiction over federally protected animals.

Which leads me to the Slaughter Summit you will be speaking at - but I have to confess, I’m kind of confused. See, I thought the BLM was charged with protecting wild horses and burros from that kind of crowd, commercial exploitation and all. It’s all the BLM ever says, “We don’t sell horses for slaughter”, so I’m a little confused why there’s a veritable cornucopia of BLM’ers listed on the Horse Slaughter Industry’s Summit agenda.

By the way Bob, you do know that American horsemeat is tainted and dangerous for human consumption but these people promote their own pocketbook at the expense of those who eat it anyway, don’t you? Could it be that is why you think the BLM and the horse slaughter industry is a perfect match? Do you think Sue & Co might be interested in acquiring mustang meat free of the drugs given to domestic equine?

Tell me something, Bob. Before you decided to tentatively accept an invitation to Ms. Wallis’s shindig, did you ask her why she came out of nowhere and has made the commercial exploitation and slaughter of wild horses one of her number one goals in all she publishes, says and does?

So this leads me to my next question. When BLM conducted the free and public forum in Denver last summer to discuss “management solutions”, Sue was there and never missed an opportunity to bring up wild horse slaughter as a humane and fiscally responsible alternative to BLMs primary management tool of roundups and removals. Except in the public forum, BLM’s MC poo-pooed Ms. Wallis and told her this kind of solution was neither appropriate nor on the table for discussion (pardon my pun).

Yet here we sit just six months later and while you couldn't bother to make a guest appearance at the "free" public dog and pony show packed with "diverse stakeholders" interested in the Wild Horse & Burro Program, now Bob, you are going to personally speak at Sue’s Slaughter Summit. What’s that about? So what makes her and her cohorts so special and above the public arena? The privacy from prying public eyes? The fact that what you say will be "off the record"? Are you getting a fee for your attendance on top of your taxpayer funded salary that legitimizes your "expertise"? Or is this highly controversial and clear conflict of interest sales pitch going to allow you to meet "key" contacts over salsa in order to coordinate better with Secretary Salazar's "new direction"?

So just to try and summarize how this works (and please feel free to set me straight if I have something wrong):

If I attend a public forum on discussing wild horse and burro management, BLM will tell those trying to bring horse slaughter to the table that it's not appropriate and will not be allowed. But if I want to be part of the Slaughter Summit to hear what you have to say, to hear what other BLM and BLM affiliates recommend, I’m going to have to cough up $300-400.00 dollars to hear a discussion that BLM refused to allow in the “public arena” nor did you feel was worthy enough to attend.

And after I write my check to United Horseman in order to attend your presentation, it will be deposited in an account that will be used for the lobbying and promotion of commercial exploitation and slaughter of wild horses and burros.

So tell me Bob, how is the presence of BLM employees and affiliates as public representatives not considered indirectly contributing money for the promotion of commercial exploitation and slaughter of wild horses and burros or a serious breach of the public trust?

Which leads me to my next line of questioning. I have heard BLM say that if advocates have evidence of BLM selling horses for slaughter, come forward with the proof.

With no access to long term holding facilities, limited access to short term facilities, armed guard access to roundups, humane observers limited to a handful at a time on hand picked days, closely guarded or set back at a half a mile or more away, (by the way Bob, what are we spending to protect you from us and our camera’s these last few years – I couldn’t find that in the budget info), blanket closure of public lands, refusal to disclose gather locations in advance, and discussions in the 2008 Team Conference Calls about how to block access by the media, the citizenry and Congress through secret locations and sealing the deal by justifying such secrecy from those attempting to ascertain the whereabouts of horses and burros by labeling them potential eco-terrorists, with all that going for you Bob, when exactly do you think the public will be able to “get proof” from behind the BLM’s Iron Curtain?

One a side note, this also leads me to ponder; Bob, are you and other BLM personnel and affiliates worried about your safety at the Slaughter Summit? After all, there will definitely be people in attendance who do not support the BLM’s “humane treatment “ of wild horses and burros via non-slaughter, do not believe wild horses and burros have any place as integral components of the public lands and who feel the BLM is failing to be fiscally responsible. Will you and other BLM affiliates be shadowed by armed escorts to protect you from them like the BLM does to the general citizenry who advocate for lawful, transparent and humane treatment of wild horses and burros?

But back to that “proof” thing of the BLM selling wild horses for slaughter. Let me start by saying, as soon as the BLM starts letting advocates follow the wild horses and burros from the roundup pens through transport and from short term to long term holding, maybe we will have a chance. But then again, the BLM seems pretty adamant about not letting the public in to anything but the most carefully controlled slices of “management” they have yet to privatize and even much of that, advocates are having to fight tooth and nail to get.

Since you called advocates out on the issue of proving the BLMs selling wild horses to slaughter, I have to confess - you are right. I don’t have photos from start to finish showing BLM gathering horses, transporting or selling them to killer buyers with follow up shots of killer buyers transporting them and making the trek to Mexico or Canada with their carcasses finally hanging from a meat hook. Is that the kind of proof you mean, Bob?

But here are some interesting tidbits I have been pondering for a while that may have relevance and maybe you can provide some answers to.

First, check out these photos. These were taken last spring on Highway 395 through Carson City to Reno. They are official BLM horse haulers and the advocate that spotted them was surprised to see BLM suddenly in the horse hauling business with such brand new, shiny trucks.

So we submitted a Freedom of Information Act (FOIA) to try and find out when they were purchased, how much BLM spent, and where they were headed too. And guess what Bob? The FOIA came back with “no records found”. Yep, that’s right, they couldn’t find any records of BLM purchasing these shiny new trucks. Actually, that’s not totally correct as the FOIA did add they were able to confirm the purchase of trailers (not the trucks) were made through the Eagle Lake office in Susanville, CA and if we wanted the info, we’d have to resubmit the FOIA to them. Go ahead and check out the FOIA response HERE.

While the FOIA response wouldn’t provide any significant info on the BLMs purchases, if you look closely, you’ll find they were able to provide a little info on the Model# of the horse trailer, which just happened to be brand spanking new in 2008.

Hey, Bob, wasn’t that the year the BLM announced they had such a money crisis that they were now considering euthanizing all our stockpiled wild horses? But ya got enough money to buy brand new shiny horse trailers and semi-trucks? Wow, who knew….

I also wanted to bring your attention to something else that provoked a great deal of curiousity for me about that FOIA response saying the trailers were purchased by the BLM in Susanville, CA. See, if you look at this website's advertisement for Featherlite trailers, it says in bold letters that there are no Featherlite dealers in California. So, wouldn't that mean BLM had to purchase them outside of CA? So why did the FOIA response say the purchase records are being kept in CA even though they had to have been purchased out of state?

What the FOIA also wasn’t able to provide is info on where that truck was headed. It informed us that the BLM isn’t required to keep logs of the drivers and destinations because the license numbers were registered to stock trailers only.

It seems BLM is exempt from reporting requirements because “driving logs are not established or maintained for trailers”. Wow, how amazingly convenient. Except those stock trailers were connected to semi-trucks with a big fat BLM logo on their side driving down a public highway that BLM couldn't/wouldn't provide any information on. I wonder what the Department of Transportation has to say about no logs required when BLM hauls horses on public highways...

So this led me to wonder, when BLM hired the Cattoors to remove the Pilot Valley horses last June from the “old” Toano Herd Area and then transferred them to NDoA, who in turn dumped them at an auction house where Jill Starr of Lifesavers Rescue spent a fortune saving them from killer buyers, whose trucks were used to transport the “non-wild” horses from the pens to the auction; BLMs or Cattoors?

I guess it doesn’t really matter though because either way, the BLM has freely admitted they were responsible for their removals while admittedly working in “close coordination” with NDoA during the whole operation.

So this in turn raised a few questions for me as well and here’s why.

Turns out, there was this girl who lived in Pilot Valley back in 2007/2008 named Crystal. She fell in love with all those “non-wild” horses there and discovered yet another big, festering mess that ultimately revealed BLM was planning on removing them in 2010. This upset her so much, she started a campaign and a blog to try and stop BLM from wiping out the bands. You can check out her blog HERE that chronicles her story.

Well Bob, I wanted to make sure I drew your attention to the last blog post Crystal made. It's titled, "Whose Jurisdication Are The Horses Under"?

According to Crystal, it appears that BLM first denied they were under their jurisdication while NDoA insisted they were BLM horses after all. After some "close coordination" due to Crystal's questioning, it seems a solution was found; BLM claimed them as "feral or estray" and NDoA backed BLM up by verifying they weren't really wild horses -despite no proof of private ownership or claims - and this would allow them to be sold at a commercial livestock auction.

Just to refresh your memory Bob, you might want to re-read that first court case I sent you the link for as you will find an amazingly similar description of the Toana/Pilot Valley jurisdictional issues playing out over thirty years ago. See, "private claims" were made about horses that were released so long ago, no owner could be identified back then - just like BLMs recent claims about the status of the Toana Herd Area horses they allowed to be sold at private auction....

And guess what Bob? You know what else Crystal did when she was trying to get to the bottom of that Toana/Pilot Valley mess? She actually went out and took lots of photos of the Pilot horses too. She even went so far as to make a video filled with a whole bunch of photos she labeled as the Pilot Valley bands.

Apparently, she was a little upset because the BLM was telling her that they were going to remove them because they were starving and so she posted all these great photos of fat, shiny horses on the range to prove this just wasn’t true!

So, I’ve taken the liberty of embedding Crystal’s video here so that you can get a really good look at the “non-wild horses” she included in her video back in 2008. Pay particular attention to all the wonderful colors some of these “non-wild horses” have as she asks if they look they are starving.

Now, here’s a video of the Pilot Valley horses that showed up at the Fallon Livestock Auction last June. These are the same horses that BLM/Cattoor were responsible for removing from the Pilot Valley area that Crystal had been photographing two years before. Notice anything different about these horses?

Not only is anything with color gone but anything that might have resembled a distinctive wild horse on the range disappeared by the time they hit the feedlot. Now I’ve pondered this quite a bit Bob, as I’m sure you can imagine, trying to figure out; why did so many of the horses in Crystal's video fail to show up at the Fallen livestock auction?

Could it be that BLM missed them during the round up and they are still out on the range? Except, the BLM’s Herd Area statistics for 2009 reported 168 horses in the Toano Herd Area and 172 showed up at the Fallen Livestock Auction; the numbers are so damn close, it can’t really account for how the horses of color or resembling “wild” horses disappeared.

I have to admit, I haven’t been able to figure this one out yet so maybe you could help me Bob. How would you explain the difference that Crystal attributes to Pilot Valley back in 2008 and those that showed up at the livestock auction a little less than two years later?

And this in turn brings me to another subject I have been pondering that perhaps you could answer. It’s about some of the questions raised when a FOIA by the Conquistador Program produced a document now called the 2008 Team Conference Calls, which revealed candid discussions between BLM personnel while they were discussing ways to kill wild horses.

Here are some of my most immediate questions in relation to the BLM and slaughtering wild horses that maybe you would graciously address.

***What was the BLM’s Wild Horse & Burro Chief’s response to this email exposed in the 2008 Team Conference Call Report, which stated: “Sally had an e-mail from a person in Canada who wants 10,000 horses that he would slaughter the horses and send them to a third world country. Don is going to send the e-mail”.

***Why did the BLM guy from Oregon, Jim Johnson say, “Jim said he has a demand for horses going to Denmark, but they are having a problem getting titled horses”? Why would a BLM employee have knowledge of and personally reference that HE has a demand for horses to ship to Denmark for slaughter?

***What did the Team mean when they said, “Having horses rendered would need to be done instead of selling horses to slaughter”?

But maybe you’ll address my concerns at Sue’s Slaughter Summit, eh? And then all I’ll have to do is cough up hundreds of dollars to hear your answer that will then be used to promote slaughtering the very animals you were put in charge of protecting against this sort of thing.

Then there’s this other thing that has really been bothering me too. Now granted, I really haven’t had much time to go through every HMA available because the BLM is so busy issuing new proposals to remove/zero out wild horses and burros that I can barely catch my breath, but me and a friend were able to go over of some of them and this is what we found so far.

I made this graph below by cross-referencing the BLMs National Gather Schedules for 2006/2007, which reports how many wild horses/burros the BLM publicly reported they removed in each Herd Management Area (HMA) during the roundups, with those same horses/burros found in the Capture Status Report that was crowbarred out of the BLM by a FOIA submitted by American Horse Defense Fund. (Note: While AHDF had requested info on ALL captured wild horses and burros, the BLM would only release this information for a nine-month period.)

Notice how the numbers don’t match? In fact, most of them look like they would just about fill a load for a horse trailer. You know, the one’s the BLM doesn’t have to keep logs of.

But Bob, I’m sure you are not too worried because after all, all you have to say is, “The BLM doesn’t sell wild horses to slaughter” and that seems to be all the “proof” that is required by the BLM, unlike the general public who are held to a completely different standard of credibility.

Since you will be busy getting ready to make your pitch at the Slaughter Summit and I won’t get to hear it because I refuse to contribute money to an organization that is aggressively pursuing the legalization of slaughtering horses, wild and domestic alike, maybe after you get a break in your busy schedule you could take some time to publicly explain to interested stakeholders such as myself –

***Why wild horses the BLM reported as being removed from the range failed to make their way into the Capture Status Records.

***Or better yet, why animals BLM failed to report they had removed ended up in holding facilities after all.

But of course, that will just lead to more questions, wouldn’t it? Questions whose answers BLM will continue to try and deflect with public affairs specialists while hiding behind an iron curtain of a Program now run more like a classified military operation than a natural resource issue.

And one last question Bob, since I have you on the line. Will you and Ms. Wallis be pleased when Salazar's "new direction" privatizes the Program and partners with organizations such as hers and neither of you will have to answer to the public anymore?

Friday, December 3, 2010

Horse Photography: The Dynamic Guide

Carol Walker of Living Images and the author of the multi-award winning Wild Hoofbeats: America’s Vanishing Wild Horses recently handed me her newest book, “Horse Photography: The Dynamic Guide for Horse Lovers” and asked me what I thought.

Well, to be honest, the only real talent I’ve discovered I have with respect to photography is an uncanny knack of taking great shots of my thumb! So, as you might imagine, a world-class photographer like Carol asking me for MY feedback about her new book came as a bit of a shock.

It got worse too - but let me not jump ahead of the story here…

So as always, the first thing that reaches out and riveted me was Carol’s unbelievably gorgeous photos. Stunning show horses, overflowing manes and tales, glistening coats, big, beautiful eyes, arching necks, gaits, stances, running, rearing, domestic horses, wild horses, you name it, she made sure to cover it all.

But unlike your average coffee table book, which may or may not capture the magnificence and spirit Carol’s horse photography is renown for, there’s actually a purpose behind these photos and suddenly, I realized why I WAS the perfect person to get feedback from about this book – but I’ll get back to that shortly as well.

The second thing that stirred me, once I could take my eyes off the photos, was the way she introduced the book. It was immediately apparent that she just absolutely loved horses, all horses, any kind of horse and this love had grown out of a working knowledge and understanding of these unique and special beings who are so inspirational to so many.

It was the following quote that touched me deepest and in my opinion, epitomized the essence of the book:

Why photograph horses? Because they fill my heart. Capturing them on film or digital allows me a way to express that relationship. It also gives me a way to show their spirit, their joy in life, and their beauty so that others can see it too.”

To simplify it even further, it was her explanation of how photography is a tool to express: The Relationship Between….

Anyone who has developed a relationship with an animal knows exactly what she is saying here. As you spend time together, you learn about all their little quirks (and they, yours!), their likes and dislikes, crazy antics and definitive character. They make you laugh, uplift your heart, cause you to melt like butter when they strike that certain pose that is uniquely them and yes, even teach you a lot about yourself and the world around you. Let me also add as testimony to the power of the horse, those who have chosen equine companions and spent the time to develop a loving relationship with them are some of the most profoundly affected people I know!

Simply put, that is the purpose behind Carol’s book; to show and share her relationship with equines and by extension, to help all of us formally condemned to a world of thumb shots to grasp the art and basic techniques for immortalizing the best of our companions and our relationships with them.

“Horse Photography: The Dynamic Guide for Lovers” is amazingly simple, helpful, easy to understand, not overly technical and covered a wide range of topics. Through comparison photos, she shows what to do and what not to do, what to look for and how to adapt to situations such as unflattering environments, proper angles, lighting, backgrounds, horse color, how to bring out the best and what to avoid to prevent highlighting the worst.

Which leads me to how things got worse from my thumb blocked world.

I have to confess, twice I found myself looking at photos and thinking, “Wow, what a cool shot. I really like the way it…..” only to discover, it was a photo of what NOT to do! Oops!

After the initial embarrassment was over, I couldn’t help but think, “That was really clever.” Why? Because she included photos of what might qualify to the untrained eye as a “good photo”. Then she clearly and simply explains why it failed to bring out the best of the subject and suddenly, I could see! Imagine that!

That’s why I was the perfect person to have review this book and must say, it’s a great book. Not just because of the non-stop pages of vividly dynamic breath taking horse photos, but because it opened up a world of possibilities and offered easy to grasp tools that anybody can immediately use.

Truly, this is a gift given from Carol to us; a gift of a lifetime of expertise, experience and knowledge generously shared and simply given to those who love horses.

For those who just might find themselves wanting to learn how to capture their companions and inspirations through photographs that hone in on what the heart sees, I would highly recommend “Horse Photography: The Dynamic Guide for Horse Lovers”, as you just can’t help but come away feeling inspired and confident that the world of framing “all things equine” is now within reach.

For those who might be interested, there’s also a variety of outstanding special packages now being offered on her previous multi-award winning book, "Wild Hoofbeats: America's Vanishing Wild Horses" that include The Cloud Foundation’s new 2011 Wild Hoofbeats Calendar showcasing the McCullough Peak wild horses as well as Screensavers, DVDs, Slideshows and lots of other cool wild horse stuff.
2011 Calendar
The Cloud Foundation

Saturday, October 30, 2010


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.

Friday, October 22, 2010

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.

4:30 P.M. PST

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

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.

Saturday, October 16, 2010

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


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)


Public Lands Grazing Program
Taxpayers For Common Sense

Oprah Accused Of Whipping Up Antibeef Lynch Mob

A Nightmare In The Old West

November 11, 1949 - September 25, 2010

Saturday, October 2, 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.


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.