RED DESERT COMPLEX HERD MANAGEMENT GATHER TCF COMMENTS

Benjamin Smith
Wild Horse & Burro Specialist
BLM Rawlins Field Office
1300 N. 3rd Street
Rawlins, WY 82301

Jeremie Artery
Wild Horse & Burro Specialist (Acting)
BLM Lander Field Office
1335 Main Street
Lander, WY 82520

Oct. 6, 2015

Dear Mr. Smith and Mr. Artery:

On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit corporation, our hundreds of thousands of supporters throughout the United States; The Equine Welfare Alliance; Front Range Equine Rescue; Colorado Wild Horse and Burro Coalition; and the over 90 organizations represented thereby, we would like to thank you for the opportunity to comment on the Red Desert Complex Environmental Assessment.

As we stated in our Scoping Comments, March 18, 2015, we are interested in helping you develop an effective and long-term “on the range” management plan that effectively uses reversible fertility control vaccine as a more humane and cost effective alternative to roundup and removals.

Proposed Alternative 2 is unacceptable:

• Serves only to perpetuate the roundup and removal cycle that has been proven to be ineffective, costly and cruel.

• Massive removals of wild horses triggers population increases in subsequent years, a biological response known as compensatory reproduction.

• Fertility control described in Alternative 2 would be ineffective - 21 mares vaccinated with fertility control would have virtually no impact in a population of 480 wild horses.

• In addition to being inhumane and expensive, helicopter roundups shatter the band structure, resulting in increased instability and increased population growth in subsequent years.

• Adding 1705 wild horses to BLM Short Term Holding Facilities would cost American Taxpayers an additional $3 Million each year.

TCF SUPPORTS ALTERNATIVE 1:

Remove all wild horses outside the HMA boundaries and utilize fertility control on mares released back into the HMA. Under Alternative 1, treating 713 mares with PZP-22 and releasing them back into the HMA would have a positive impact on population growth if a comprehensive fertility control program is maintained in following years. Leaving a post gather population of 1800 horses in the 753,000 acres (only one wild horse for every 418 acres!) would ensure genetic viability in each of the 5 HMAs that make up the Red Desert Complex.

OTHER RECOMMENDATIONS IN LIEU OF ALTERNATIVE 1:

1. Remove horses to high AML to maintain genetic viability of the herds and begin a complex-wide fertility control program.

2. Launch a Pilot Fertility Control Program in the Stewart Creek HMA with the help of volunteers. If wild horses are removed, remove only to the Highest end of the AML– or 175 horses which is a minimally genetically viable number. Specifics for a Pilot Program are outlined below.

Elements of Stewart Creek Pilot Fertility Control Program:

We support the goal of balancing recruitment with the death rate so there is no need for removals. To achieve this goal any fertility control program must include the following elements:

• Appropriate timing of darting

• Age specifications of mares in the darting program

• Individual horse identification processes

• Accurate record keeping and flexibility

• Bait trapping to keep family units together. (Helicopter roundups shatter stable family structures)

• Use of volunteers to supplement BLM manpower including TCF volunteers, local horse advocates, wildlife photographers, interested ranchers, and other agencies such as Wyoming State Fish and Game.

It is our understanding that mares darted with PZP 22 in 2011 were hip branded. Those mares need not be primed but can be darted with a PZP booster during bait trapping, and all others can be darted with primer. All mares can be re-trapped within a few weeks or months to receive a booster. A reduction in the herd growth rate should be realized as early as 2017. (See Assateague Model)

1. Darting at the appropriate time of the year: Darting is most effective January through early April just preceding the breeding season. Therefore, we recommend being prepared to begin darting in January 2016. 2. Age Specifications for mares being treated: TCF recommends the following program, which is similar to the plan in the Pryor Mountain Wild Horse Range:

Selectively booster adult mares on age and kinship, developing a genetic variability road map based on the collective knowledge of BLM personnel and those that have followed the herd for a number of years.
Prime (unless mares have received PZP-22).
Booster all 2-3 year-old mares.
Booster all mares 9 and older unless mares have not produced a viable offspring.
Deliver a primer to all filly foals once they are 15 months of age or older.
Remove from fertility control all mares that have been darted for 5-7 consecutive years as they will not return to fertility. The proposal to treat mares after producing a single live foal for the remainder of their lives is extreme and not necessary to achieve zero population growth and will not ensure continuance of the genetic line.
Eliminate from the darting program any mare, regardless of age, that has a life threatening reaction to the vaccine.

3. Horse Identification: To insure that identification errors do not occur, we recommend developing a photo database compiled into books that can be taken into the field to identify bands and individual mares by color, face-leg-coat markings/patterns, direction mane falls, scars, etc. All mare photographs can be entered into the WHIMS program developed by NRCS.

4. Record Keeping to ensure effectiveness of fertility control program: Accurate record keeping is essential to the success of any fertility control program. We recommend monitoring mares after treatment to identify any adverse reactions to the vaccine.

5. Flexibility: TCF would like to see specific language in the upcoming EA which allows for flexibility in order to change course if unintended consequences occur or unanticipated events happen (i.e. a rise in predation or a catastrophic killer storm), or if the genetic health of the herd can be better maintained by eliminating a particular mare from treatment. We suggest you reserve the option to make changes, which is consistent with DOI Adaptive Management – learning by doing, and adapting based on what’s learned. Adaptive management encourages flexibility. (http://www.doi.gov/ppa/upload/executive_summary-27.pdf)

6. Bait Trapping in Lieu of Helicopter Roundup. Helicopter drive trapping totally disrupts bands and social structures, which can accelerate herd growth due to an increase in breeding when stallions acquire new mares. Wild horses can be more safely captured for the application of the fertility control vaccine, PZP, through bait trapping, which keeps family bands together, thereby promoting family band stability. Bait trapping and darting with PZP can be accomplished using BLM personnel as well as volunteers.

In addition to being more humane, bait trapping and darting can be accomplished at the proper time of year for the vaccine to have maximum efficacy. BLM would have control of the wild horses in their HMAs, rather than the helicopter contractors and their availability. Bait trapping also offers the least expensive and least invasive method to treat or remove select young horses that might have the opportunity to be adopted.

7. Volunteers to supplement BLM Manpower Volunteers can supplement BLM manpower to document herds, keep records, determine appropriate mares for PZP application, set up and monitor bait traps, and dart mares with PZP. Volunteers are being used in the Pryor Mountains, McCullough Peaks and Sand Wash Basin, just to name a few HMAs. Bringing volunteers into the decision making and implementation of a Fertility Control Program can supplement BLM manpower and improve BLM credibility and transparency with the public.

Additional Recommendations for Red Desert HMAs:

1. Appropriate Management Levels Appropriate Management Levels in Lost Creek, Stewart Creek, Antelope Hills and Crook Mountain, and Green Mountain should be reevaluated and increased to ensure genetic variability, which requires a minimum population of 150-200 horses.

2. Bait trapping in lieu of Helicopter Roundups. Helicopter drive trapping totally disrupts bands and social structures, which can accelerate herd growth due to an increase in breeding when stallions acquire new mares. Wild horses can be more safely captured for the application of the fertility control vaccine, PZP, through bait trapping, which allows for keeping family bands together, thereby promoting family band stability. Bait trapping and darting with PZP can be accomplished using BLM personnel as well as volunteers.

3. AUM’s AUM allocation to livestock grazing far outstrips wild horses. Livestock AUM’s must be reevaluated and reduced if necessary to ensure that forage within the HMA’s is devoted principally to the welfare of wild horses in keeping with the Multiple use management concept (Wild Horse and Burro Act) as well as to other wildlife species.

4. Repatriate Removed Horses The taxpayer burden of housing an additional 1705 wild horses in Short Term Holding exceeds $3 million per year. Repatriate removed horses to zeroed out HMA to avoid further overburdening holding facilities. As non-reproducing herds these horses could easily adapt to HMAs/HAs that are no longer inhabited by wild horses.

5. Horses outside the HMA Boundaries Areas in Northwest Stewart Creek and Southwest Green Mountain where horses consistently roam outside the HMA boundaries, should be added to the HMA’s, as these areas are known to be places where wild horses have historically congregated.

6. Managing Complex as one HMA We recommend analyzing the possibility of managing the Red Desert Complex as one HMA and redrawing boundaries to create a contiguous area. This would eliminate the need to roundup out of bounds horses. Allocating more acreage to wild horses and using fertility control could eliminate the need for future removal. There appears to be very little state or private ownership in the areas.

7. Fencing The practice of “laying the fence down” seasonally to facility wildlife crossing is not a safe alternative to allow passage of wildlife. Fences should be “rolled up” to insure that no wildlife is tangled or injured by wire.

8. Lease relinquishment/compensation If public land ranchers are interested in voluntarily relinquishing their leases, compensate them for voluntary activities which could include fence removal, and monitoring wild horses.

CONCLUSION:

While we wholeheartedly support the use of fertility control programs to reduce the numbers of horses removed from the range, we also encourage the BLM to take natural measures in managing wild horses on the range, such as protection of predators.

By taking positive steps to perfect “on the range” management the BLM will save American taxpayers millions of dollars. We believe The Red Desert Complex could be a model for the management of wild horses in a humane and cost effective way.

Thanks for taking time to answer our questions and welcoming our input on ways to keep the horses on the range within population levels that allow for genetic diversity. If you have any questions about the contents of this letter, don’t hesitate to give us call.

Sincerely,

Ginger Kathrens
Executive Director
The Cloud Foundation
107 S 7th St.
Colorado Springs, CO 80905
719.633.3842

The Cloud FoundationOctober 6, 2015