FoA's Official Comments 

National Wild Horse and Burro Program

Attn: Ramona De Lorme

1340 Financial Blvd.

Reno, Nevada 89502-7147

Comments from Priscilla Feral, President of Friends of Animals

I’m not here to thank you for anything. I’m here to express dismay and it’s dismay that there is a landscape in America—it’s federal public lands—and that instead of embracing that habitat for indigenous wildlife and for animals with whom we have co-evolved, it's used for the meat industry. And we have a government agency who caters to the meat industry. The groups that partner with BLM, the groups called assets, cater to the meat industry too. They eat cows, they eat sheep—and you have a government agency who thinks its role is to uphold the meat industry. 

In Nevada cattle and sheep outnumber horses in some places 114 to 1; 50 to 1; 30 to 1. The same is true in other states including Wyoming. How do you possibly breed animals into existence only to be made into chops and hamburgers, and call it a boon to civilization. Those animals live only so long, to then reach a blood drenched slaughterhouse. And now the same is true for wild horses. They are being decimated across western states.

You are finding cooperation with other groups through contracts, money exchanges, whatever excites them to do your biddings and to suppress populations already at very low levels. In Montana 6 out of 7 wild horse herds have been abolished and we had a fight over the seventh herd, The Pryor Mountain horses.

We are going to be filing another lawsuit next week, Friends of Animals, to protect some horses that are up for another raid. And this is going to go on and on and these challenges will go on until there is a new administration, perhaps a new Secretary of the Interior, perhaps some new employees at the BLM. I think the agency needs to be dismantled. What’s wrong here is not the minutiae, I can’t argue all your little numbers, it’s that you have someone offended that a wild horse acted like a zebra. Zebras are wild horses too. They defy domestication. I defy domestication and I ask you to stop viewing them as nuisances, as dogs and cats with prolific breeding possibilities. And simply let them be what they are intended to be, wild animals living on federal public lands.  


Comments from Nicole Rivard, correspondent, Friends of Animals

As Wild Horse and Burro Advisory board members, we at FoA would like you to advise the BLM to stop committing crimes against wild horses. In July the BLM announced more crimes—that it would be spending $11 million over the next 5 years to develop tools for managing wild horses, like longer lasting fertility control as well as methods for spaying & neutering wild horses. Well please inform BLM not to waste their time or taxpayers money. We are taking legal action to prove that using fertility control on wild horses likely violates the Wild Horse and Burro Act of 1971. We have already filed a legal petition to cancel registration of wild horse fertility control pesticide PZP. That measure—along with getting wild horses listed as endangered under the Endangered Species Act will once and for all ensure that America’s wild horses are protected and not treated as pests by the BLM.

Our legal petition with the U.S. Environmental Protection Agency requests the agency consider new scientific evidence demonstrating the need to cancel the registration of PZP for population control of America’s wild horses, which was issued to the Humane Society of the United States in 2012. Information is now available regarding the unintended—and previously undisclosed—side effects on both targeted mares and wild horses in general. When the HSUS obtained ESA registration for PZP, the organization never provided evidence that PZP doesn’t have negative side effects…it just provided information about the efficacy of PZP and actually requested waivers for most of the studies ordinarily required from an applicant seeking pesticide registration—including a toxicity study, ecological effects and environmental fate guideline study.

The majority of research submitted by HSUS was published by Dr. Jay Kirkpatrick, a veterinarian who manufactures PZP, and did not consider the biological, social and behavioral effects the drug can have on wild horses. More recent research has demonstrated repeated applications of PZP can cause physical damage to treated mares; it is not completely reversible; it can increase mortality in foals post-PZP effectiveness; and it interferes with herd cohesion, which is critical to the overall health of wild horses. In addition, preventing mares from producing foals can create a genetic bottleneck that may ultimately extinguish the species as a whole. 

FoA is adamant that new studies indicate that PZP use is harassing, and even killing, wild horses in ways not considered as part of the initial registration process. While it is true that the WHBA provides for an exception from general mandates to protect wild horses to control their populations, this exception is both narrow (the animal must be deemed “excess”) and can only be applied if the implementing agency first completes certain statutory requirements. 

It may be that with regards to the decision to dose a particular mare, the implementing agencies can comply with the WHBA. However, the other horses in the herd that are not dosed with PZP as well as the unborn foals cannot be legally defined as “excessive” and, thus, the risk of harassment or death to these animals posed by PZP violates the WHBA.

Comments from Edita Birnkrant, campaigns director, Friends of Animals

Speaking of the BLM being keen on spending $11 million dollars over the next five years to develop new management tools, as advisory board members you should demand why this is necessary when science says that if you leave herds along, they would self-regulate. 

We at FoA know it’s because the BLM is beholden to cattle and sheep ranchers who don’t want wild horses on public lands at all. That’s why AML’S are set pathetically low, yet millions of cattle and sheep are allowed to graze on public lands. In Beaver and Iron County, Utah, where wild horses are scapegoated, data shows cows and sheep outnumber wild horses 10.6:1; in Oregon it’s 33:1. And prior to a massive roundup in Wyoming last summer, there were 356,222 cattle, 45,206 sheep, and only 1,912 wild horses. It seems that it’s easier for the BLM to accommodate ranchers and manage wild horses to extinction, than to consider holistic ways to manage our public lands. 

Insanity is doing the same thing over and over again expecting different results.  As Advisory Board members it is your job to confront the BLM and ask them why they continue to engage in roundups and fertility control, despite the National Academy of Sciences (NAS) report in 2013 saying: “The indirect effects of management are considerable. One likely response is compensatory population growth as a result of reductions in numbers. Horse and burro populations are seldom limited by density because they are kept below food limited carrying capacity through removals and to some extent through treatment with the contraceptive PZP. Indeed, AMLs are usually set in such a way that considerable forage material is uneaten; this is the very purpose of the allowable use level. That leaves horses and burros in a position for compensatory population growth because they are below food-limited carrying capacity. If there were no intervention, herds would reach food-limited carrying capacity. Removals are likely to keep the population at a size that maximizes population growth rate which in turn maximizes the number of animals that must be removed and processed through holding facilities.”

We would like you to suggest to the BLM that they use some of the $11 million dollars to buy back grazing permits from ranchers when they become available, so that cattle and sheep grazing is not permitted in Herd Management Areas. In addition, before another wild horse is ripped from the land or forcibly drugged with PZP, the BLM should be required to provide accurate population counts, preferably with an outside agency that does not treat ranchers as clients. As it stands now, we cannot believe population estimates, and that’s not just the opinion of FoA, it’s the opinion of the National Academy of Sciences. 

Their report states: On the basis of the information provided to the committee, it cannot consider the national statistics scientifically rigorous. The procedures used for developing annual HMA population estimates from counts are not standardized and often are not documented, but it seems clear that the national statistics are the product of many hundreds of subjective and probably independent judgments and assumptions by range managers and administrators about the proportions of horses counted in surveys, population growth rates, effects of management interventions, and potential animal movements between HMAs. 

Please demand from the BLM the science that has them concluding that as of March 1, 2015, there were 47,329 wild horses on public lands, but on March 1, 2014 there were 40, 815 wild horses on public lands. It seems like they just decided that the overall wild horse population grew by 20 percent, which is what they have been spouting for years, committing yet another crime against America’s wild horses.