16 August 2009
James M. Sparks, Field Manager
Jared Bybee, State Wild Horse and Burro Specialist
Bureau of Land Management
Billings Field Office
5001 Southgate Drive
Billings, Montana 59101
Comments on Environmental Assessment DOI-BLM-MT-C010-2009-35-EA
Thank you for the opportunity to comment on the referenced EA on behalf of myself, The Cloud Foundation (TCF), Front Range Equine Rescue, Inc., and the thousands of supporters of these organizations in the United States and around the world, many of whom have visited the Pryor Mountain Wild Horse Range (PMWHR) and hope they can continue to come and see horses on their beautiful range.
Genetic Viability
BLM’s proposed action to round up every horse on the Pryor Wild Horse Range and those wild horses living permanently in the Custer National Forest and remove 70 horses from this population of 190 would damage their genetic viability. Noted equine geneticist, Gus Cothran, wrote in a letter dated July, 16, 2009 “As has been stressed several times, the effective population size is generally 1/4th to 1/3rd of the census population so that a census population of 150-200 is required to achieved the minimum (emphasis added) population size. . . the PMWH has been one of the most important and visible herds within the BLM Wild Horse Program and it is important that it stays viable.”(Exhibit 1)
The long term survival of this unique Spanish herd would be jeopardized by the actions BLM sets forth in this EA. They would violate both their mandate to manage for viable herds and self-sustaining populations should they proceed with this unprecedented removal.
BLM’s plan to introduce horses from another herd every generation to mitigate the inevitable genetic damage is an unacceptable plan considering the genetic uniqueness of this isolated population of Spanish type horses that have roamed the Pryor Mountains for over 200 years.
Introducing horses from other wild horse herds to avoid inbreeding to the Pryor herd would cause disruption at both ends---the herd from which the horses are removed and the herd in which the horses would be introduced into. Simply leaving a viable herd in the Pryors to start with would avoid this cruel, unnecessary and costly action. And we believe any such action would be illegal based on the decision rendered by a Montana federal court judge in July 2008.
U.S. District Court Judge Donald Malloy in a wolf management case ruled that genetic exchange between three subpopulations of wolves must be “natural.” (Exhibit 2-Wolf Management Article, Casper Star Tribune, July 2008) Introducing wild horses from populations outside the Pryor Mountains to avoid inbreeding falls in the same category of illegal manipulation and violates the self-sustaining clause in their contract with the American people.
BLM states that they must manage the herd at the newly defined Appropriate Management Level (AML). Yet, the Pryor herd has not been managed at AML since I have been documenting the horses (1994). On the contrary, the herd has been maintained at between 150-210 horses because BLM knew that a smaller population would result in a loss of their genetic viability. Former BLM Field Manager Sandra Brooks stated that “Preliminary evidence suggests that the herd has been managed at dangerously minimum levels over the past 25 years and an increase in established appropriate management levels (AML’s) will need to be considered in order to preserve the genetic viability of the herd.” (Exhibit 3-Sandra Brooks letter, 1999)
Francis Singer, PhD, wrote in his article, A Demographic Analysis, Group Dynamics, and Genetic Effective number in the PMWHR, 1992-1997, that “. . .any management scenario that includes a decrease in population size will decrease total Ne, and thus increase the predicted rate of loss of genetic variability”. Dr. Singer studied the Pryor herd in depth for more than a decade.
BLM states in this draft EA that do not have adequate knowledge about what constitutes a viable herd. This is simply not accurate. BLM has studies from 1992 addressing minimum standards for genetic viability as Ms. Brooks was well aware of, yet they have chosen to turn a blind eye on this wealth of science.
Range Condition
BLM attempts to trump the viability argument by saying that the range is in a degraded state and cannot support more than 120 horses. As reported in the Billings Gazette in July 2009 the BLM points to the colorful display of wildflowers atop the mountain as evidence of over grazing. (Exhibit 4- Billings Gazette article, July 12,2009)
I recently visited Glacier National Park and saw some incredible displays of wildflowers. It caused me to wonder whether wild horses had invaded the park. Or perhaps bison had been introduced. Of course, there are no big grazers in Glacier just as there are “too many” wildflowers on the Pryors as a result of wild horse grazing. Instead of pointing to hard, current data, BLM falls back on this ridiculous assertion. It was also reported in the same article that wild horses do not eat wildflowers. Hence, I imagine, their conclusion that there is little grass but lots of flowers.
Anyone who has ever done trail riding with their horses in which wild flowers abound know that horses do indeed eat wildflowers. The wild horses of the Pryors are no exception. They not only incidentally eat flowers but prefer them at times. I have followed Cloud’s band in August through the forest as they ate arnica---both the plant and the yellow flowers. We watched in June, 2009 as horses gobbled up yellow composite flowers, shooting stars, bistort, and lupine.
BLM is either knowingly misleading the public or is simply unaware of range science and wild horse behavior. Range experts, Jeff Powell, PhD, and Judith Von Ahlfeldt, PhD, interpreted these statements in their letters attached. Powell stated that “It is a universal ecological fact that very high precipitation after a drought, even with a couple of intervening year of average precipitation, causes seeds of many forbs or wild flowers to be ‘flushed’ and break dormancy. I am certain the grasses are there , but are not as showy as spring and summer flowers. And the perennial grasses will respond to the high precipitation, but at a more prolonged rate that the ‘opportunistic’ forbs.”
Von Ahlfeldt wrote that the BLM action is a “faulty basis for removal of a large number of animals” referring to the older range study techniques upon which BLM is depending. She also said that “During those dry years the grasses and ecosystem as a whole was able to sustain the herd. . .Wildflowers are having a banner year (2009) everywhere. . .if all the horses were moved to another area for a decade, climate would still be the main driver for the year-to-year range condition. . .” (Exhibits 5 and 6- Powell and Von Ahlfeldt letters)
Dr. Von Ahlfeldt’s letter is similar to other range studies on the Pryors in which Jace T. Fahnestock and James K. Detling write that “. . . plants in both the lowland and upland communities of this study suggest a tighter coupling of these communities to abiotic factors, such as growing season precipitation, than to herbivory at the ungulate densities encountered in the PMWHR.” (Exhibit 7- The Influence of Herbivory on Plant Cover and Species Composition in the PMWHR, USA, 1999)
Pictures taken of the Pryor range in late June, 2009 would attest to an abundance of wild flowers, green grass, and fit horses in a year of above average moisture. Removing these spectacular animals from their abundant home is unthinkable. (Exhibit 8- Digital images of the Pryor Herd, June 2009)
Timing of Round Up
In a meeting with the BLM in early July, I asked why this round up is scheduled earlier than round ups in previous years (1994, 1997, 2001, 2003) BLM responded that the round up crew was available at that time.
It is unacceptable to us that small foals should be subjected to a helicopter drive when they are not yet 2 months old simply because it is convenient for BLM. We submit a photo of Madonna’s foal born in late July. Incidentally, Madonna (#8913) is 20 years old and in great health which is testament in itself to the health of the Pryor Horses. Without a healthy range, mares would hardly be producing foals like this little one into their 20’s. (Exhibit 9-Carol Walker picture taken on July 26th of Madonna’s one-day-old foal)
Concern should be for the health and welfare of the animals, not because of helicopter and round up crew availability. A helicopter round up several weeks ago in the Challis Herd (Idaho) resulted in the death of seven animals to date, one of which was a small foal.
Bigfoot
When asked if the dark bay stallion, Bigfoot (#8603), would be round up, I was told that they would try to round up ALL the horses. If Bigfoot is captured, BLM standard operating procedures (SOP’s) call for putting down crippled animals. Bigfoot has been crippled by arthritis for years. Despite his knees, swollen larger than soft balls, and his stiff walk, the 23 year old comes out every spring, hopeful he can win a mare. This stallion is beloved by many who admire his courage and his optimistic attitude. We have watched as he suddenly gallops out to challenge another stallion. We marvel at his heart and spirit and feel inspired as a result. (Exhibit 10-photos of Bigfoot)
Should this round up proceed as planned, it would be criminal to drive this stallion into a trap where he would be vulnerable to BLM’s SOPs. We ask that BLM leave Bigfoot alone in his valley. Let him live out his life in peace.
Removing Older Horses
Not only Bigfoot, but other horses that are 10 and older (Cloud is in this age group) would be subject to removal---horses that have lived their entire lives in freedom. They include the majority of band stallions and lead mares. They are the horses with the collective wisdom to pass down to the younger generations. They must not be removed.
The Cloud Foundation has suggested that, if a round up is conducted, it should focus on only young animals in the yearling and two-year-old age groups. These are the most adoptable and usually the most easily trained. Removing 20 from these categories will not be as damaging to the genetics of the herd as a massive removal of 70 horses, many of whom fall in the 10 and older category. The Cloud Foundation and Front Range Equine Rescue would encourage qualified and appropriate adopters to attend and bid on these 20.
Consider that in the recent Cedar Mountain herd removal, hundreds of horses were rounded up, yet only 17 were adopted. In the famous Sulphur Herd, also in Utah, hundreds were removed and a mere 8 were adopted. The remainder of the horses were taken to short and long term holding facilities. While some will find qualified adopters, the majority will not. Gus Warr, State Wild Horse and Burro Specialist, expressed his optimism before the round up stated, stating that they usually have no trouble adopting out most horses as they are so popular.
BLM needs to factor in a still weak economy and a horse market that is virtually non-existent; BLM holding corrals and pastures are full; more wild horses are confined than roam free. BLM has stated that they have inadequate funds to feed the incarcerated animals and have discussed killing them. And still, they insist on removed more wild horses including the Pryor mustangs. This is beyond comprehension for any of the wild herds and particularly shocking considering the health of the Pryor range and the fame of this beloved herd.
Precipitation
The major document BLM refers to as a guide in the PMWHR was a range survey taken by the NRCS in 2002-2003 and reported to the public in 2004. The study was conducted during a severe drought. According to the Western Regional Climate Change Center 2005 was the lowest amount of spring moisture in 57 years in Lovell, Wyoming. Since that time, however, precipitation has been on the increase.
The word drought is still used by some BLM officials who live outside of Montana in relationship to the Pryor Range. Nothing could be further from the truth. The drought index for Carbon County in which the PMWHR is located lists the county as having no drought. (http://nris.mt.gov/drought/status/Jul09/drtstatus.jpg)
According the Water Resources Data System as of August, 2009 (http://www.wrcc.dri.edu/cgi-bin/cliMAIN.pl?wylove) the Bighorn Basin is at 106% of normal precipitation. Compare this with 2003 which was the driest year since 1960.
Our pictures (Exhibit 8) attest to the health of the range. Local residents and regular visitors to the PMWHR recognize that the amount of precipitation has created a range in great shape with green hills even in the low desert country. This is amazing for August.
Yet, BLM still seems committed to a destructive removal. They talk about how the removal will help to improve “riparian” areas. Only one “riparian” area exists in the designated range to our knowledge. The pictures submitted were taken in late June of 2009. (Exhibit 11: Pictures of Crooked Creek stream edge) In these pictures note the condition of the steam side and the lack of impact the horses who regularly frequent this area are having. Two bands are currently using Crooked Creek---Sam and his mare, Hightail (both nearing 20 years of age) and Admiral’s band of five horses and one foal (as of June, 2009).
Removing the “old couple” (as we refer to Sam and Hightail) would be unthinkable. When the public can see no horses, these two seem to make an appearance and brighten the lives of so many people. Admiral’s band offers the public a chance to see a real wild horse foal from the convenience of a paved highway, when few other horses are visiting the low country in the Bighorn Canyon National Recreation Area. Disturbance of this little band is totally unnecessary and robs the public of their chance to view the relationship of mother and foal and the nurturing role of the wild horse family including the stallion father.
PZP
BLM has indicated that they will give PZP-22 to every mare returned to the range who has foaled. We object to the unselective nature of giving all mares who have ever foaled a drug which would defer pregnancy for two years. And, we object to giving the mares the drug in September. Jim Sparks and Jared Bybee of the Billings BLM Field Office have indicated in meetings with us that they believe one reason the drug has not performed as anticipated (out-of-season births or no births after it wore off) is the time of year in which it was administered (July-November). They believe it should be given early in the year. Why then, would they plan to administer the drug in September? This is irresponsible to say the least, and cruel if this new drug results in the problems documented with the one-year vaccine.
Giving PZP to the vast majority of Pryor mares while taking the population to non-viable levels is dangerous. The population would have a harder time bouncing back from random weather events such as the one which occurred in the winter of 1977. The herd could literally crash if a similar event happened when the population is lower than it was in 1977. They could also be more vulnerable to an immediate crash due to the vagaries of living wild. One of these vagaries is predation, which is on the rise this summer. Foals have disappeared at an increased rate. Mountain lions have been known to prey on yearlings as well and even attacked an older wild horses on the PMWHR. The horse survived but carries the scars from the attack.
Although BLM has stated that there has been no social disruption as a result of mares coming into season month after month during the normal estrous months (March-October), we have witnessed and filmed this disruption. It has also been documented on the East Coast in the Shackleford Banks by Cassandra Nunez as reported the Wild Horse Congress in October of 2008. Ms. Nunez states that she is “investigating the effects of immunocontraception on the behavior of wild horses. My research has shown that females receiving the drug are less loyal to the harem male, switching groups at a higher rate than females not receiving the drug.”
Any future skewing of the sex ratio to favor males over females would only heighten this disruption. Competition for mares is already high in the Pryors due in part to the concentration of horses on the mountaintop during the peak-breeding season. See PZP Contraceptive Use in the Pryors.
Conclusion
The PMWHR is home to the most famous wild horse herd in the world, a fact that helps the economy of the small towns around the herd area. People come from around the U.S. and abroad to see these popular and charismatic animals. Many members of the public know the individual animals in the herd, particularly the pale stallion, Cloud, and his family. The horses provide enjoyment and also an opportunity for people to sit quietly and witness the natural and complex behaviors of America’s native equid species. I am unaware of another place where this is possible. I sometimes refer to this magical area as the Yellowstone of Wild Horses.
On behalf of this beloved herd, we ask that BLM allow time to see if their planned range improvements will achieve the desired results. In the interim we hope BLM will work in a collaborative way with the Custer National Forest and the Montana and Wyoming Fish and Game on range expansion and protection of the mountain lions who help keep the herd in balance with its home.
Right now, the horses are fat and content and unaware of the calamity to come. We ask that you move cautiously BLM for there is much to lose. Listen to the voices of the American people as well as noted scientists. Leave the wild horses alone in their peaceful kingdom.
Sincerely,
Ginger Kathrens
Volunteer Executive Director
The Cloud Foundation
