Pryor Mountain Draft JMAP Comments
May 15, 2020
Jerrie Bertola
Wild Horse and Burro Program Lead
BLM Billings Field Office
5001 Southgate Drive
Billings, MT 59101
Submitted online: https://eplanning.blm.gov/epl-front-office/eplanning/projectSummary.do?methodName=renderDefaultProjectSummary&projectId=1502632#
Dear Ms. Bertola,
The Cloud Foundation (TCF), is a 501(c)3 nonprofit organization committed to protecting and preserving America’s wild horses and burros on our public lands through education and advocacy. On behalf of TCF and our nearly 500,000 supporters, I respectfully submit these comments on the Bureau of Land Management’s (BLM) Pryor Mountain Preliminary JMAP 2020 (DOI-BLM-MT-C010-2020-0004-EA).
INTRODUCTION
The Pryor Mountain Wild Horse Range (PRWHR) is unique. This range, the Pryor herd, and its followers have been at the forefront of wild horse protection since before the establishment of the 1971 Wild Free-Roaming Horses and Burros Act (The Act). Indeed, the PMWHR was the first-ever federally protected wild horse area. Thus, its cultural and historic significance has been defined for generations to come.
The Pryor herd is well-known and beloved on a global scale. Made famous by three acclaimed PBS Nature series documentaries that followed the stallion, Cloud, through the seasons of his life, this herd and Cloud’s descendants are enthusiastically followed and studied by hundreds of thousands of people around the world. The community of support the Pryor horses enjoy is unprecedented, and unlike that of any other herd that exists today.
The revision of the Joint Management Area Plan (JMAP) creates an opportunity for world class, herd-specific management that has never been done before. What is implemented now in the Pryors has the potential to echo across generations, setting an example for wild horse management in other HMAs throughout the West. The PMWHR could become a premier example of how wild horses can be managed humanely, with BLM and volunteers collaborating to manage the herd and maintain a thriving natural ecological balance on the range.
The Cloud Foundation is willing and eager to assist with management efforts and range improvements in the PMWHR. Our mission is to ensure that one day, every foal born on the range gets to live out its life in freedom. We can only make that vision a reality, together.
Through the use of correctly timed and implemented humane fertility control, protection of predators, and the use of volunteers to support BLM in its management of the herd and the range, the productivity of the land can be maximized for all wildlife, including the wild horses. We believe this goal can be achieved. We appreciate the opportunity to submit comments on this Preliminary JMAP for your thoughtful consideration.
PRYOR MOUNTAIN WILD HORSE RANGE
Congress clearly stated in the 1971 Act that wild horses have a special, protected status.
The Act specifically defines the "range" where wild horses were “presently found” (in 1971) as “the land necessary to sustain an existing herd or herds of wild free-roaming horses.” The Act also specifically states that this wild horse habitat “is devoted principally but not necessarily exclusively to their [wild horses and burros] welfare...” [Public Law 92-195 § 1332]
ECONOMIC IMPACTS
The Pryor Mountain Wild Horse Range is a major tourist attraction. People travel from all over the world to see these famous horses, resulting in an essential source of income for the small town of Lovell, WY. The town and its businesses would suffer greatly if this herd were to be reduced to such a level at which wild horse sighting was no longer common. As it stands, at certain times of year, the horses are difficult to find even on the paved DryHead road. If reduced to the low AML of 90, we fear tourists would rarely get a glimpse of these iconic animals they’ve traveled to see.
The PMWHR is extremely popular with wild horse enthusiasts, photographers, and tourists. These horses provide an economic benefit through tourism dollars, both locally and to the states of Montana and Wyoming.
“Special recreation permits are becoming more prevalent as more people wish to pay for the opportunity to participate in guided or organized activities on public lands. Wild horse photography tours, viewing tours, and cattle drives are the primary recreation-permitted activities.”
Pg. 38, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment
The PMWHR is regularly documented by TCF on our website and our Facebook page, which has nearly 500,000 active followers interested in the health and wellbeing of these animals. The horses are regularly documented by photographers in the area on various Facebook pages, garnering thousands of additional unique followers.
“Recreation-related visitation has been increasing in the Pryor Mountains over the last several years and that trend is expected to continue. …. Recreation opportunities are primarily wild horse viewing during the warmer months of the year, especially during foaling season.”
Pg. 38, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment
Furthermore, these horses are a federally protected species, and are credited with symbolizing the historic and pioneer spirit of the American West.
“That Congress finds and declares that wild free-roaming horses and burros are living symbols of the historic and pioneer spirit of the West; that they contribute to the diversity of life forms within the Nation and enrich the lives of the American people…”
Wild Free-Ranging Horses and Burros Act of 1971
They are a beautiful wildlife species that attracts people to the area from locations across the globe. A management objective should be to preserve and enhance opportunities for wild horse viewing.
NATIONAL ACADEMY OF SCIENCES
The National Academy of Sciences (NAS) was founded in 1863 in the midst of the American Civil War. The National Research Council (NRC) was founded in 1916 against the backdrop of the First World War. These two independent research bodies have played significant roles to ensure the U.S. government is provided balanced, fact-based information and data which should be incorporated in governmental decision-making processes.
The 1971 Act instructs the Secretary of the Interior to consult with the NAS. The BLM-commissioned 2013 NAS report “Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward” (NAS Report) (Attachment 1) clearly states:
“Horse and burro management and control strategies … should engage interested and affected parties and also be responsive to public attitudes and preferences. Three decades ago, the National Research Council reported that public opinion was the major reason that the Wild Horse and Burro Program existed and public opinion was a primary indicator of management success (NRC, 1982). The same holds true today.” p. 292
The NAS Report also notes:
“Horse and burro management and control strategies cannot be based on biological or cost considerations alone; management should engage interested and affected parties and also be responsive to public attitudes and preferences.” p. 292
The 1984 National Academy of Sciences report on the BLM’s wild horse and burro program states[1]:
“It continues to be obvious that the major motivation behind the wild horse and burro protection program and a primary criterion of management success is public opinion. Attitudes and values that influence and direct public priorities regarding the size, distribution, and condition of horse herds, as well as their accessibility to public viewing and study, must be an important factor in the determination of what constitutes excess numbers of animals in any area. The choice of control strategies, when and if they become necessary, must also be responsive to public attitudes and preferences and cannot be based solely on biological or cost consideration. The issue of excess numbers is conceptually severable from the strategies questions. However, an otherwise satisfactory population level may be controversial or unacceptable if the strategy for achieving it is not appropriately responsive to public attitudes and values.” p1219
I, TCF’s board and our hundreds of thousands of supporters, are interested and affected parties in this action. Some of the proposed actions in the Draft JMAP show a failure to consider the interests of those who cherish the opportunity to observe, photograph, and otherwise enjoy wild horses and their natural behaviors in the Pryor Mountain Wild Horse Range … these are the very horses which Congress declared to be “national esthetic treasure[s]” when it enacted the Wild Free-Roaming Horses and Burros Act of 1971.
I. MANAGEMENT STRATEGY
The intent and objective of the Preliminary Joint Area Management Plan is to establish short and long-term objectives for the management of the Pryor Mountain Mustangs and their habitat. The document states,
“The JMAP is needed to manage wild horses within the Pryor Mountain Wild Horse Range Joint Management Area to maintain the wild horse herd as a self-sustaining population of healthy animals in balance with other uses and the productive capacity of their habitat and attain the objectives outlined in the Billings Field Office Approved Resource Management Plan.”
It also explains that, “Due to monitoring and documentation of the Pryor Mountain wild horses, management within the Pryor Mountain Wild Horse Range JMA can be more specialized than that of most BLM managed herd management areas.”
These are two essential points to which we will refer as we discuss the management objectives and strategies for this unique herd of wild horses.
1. UNIQUE HERD GENETICS
The Pryor Wild Horse Herd is a unique, Spanish colonial herd that traces its roots back to the conquistadors. Because the herd is isolated, there is no genetic interchange with outside horses. The herd that exists today represents the entire genetic repository of these hardy mustangs. They are survivors, uniquely adapted to the rugged Pryor wilderness they call home. As such, the herd and its unique qualities must be preserved.
2. MANAGING FOR BLOODLINES
“In keeping with wild horse management decisions from the 2015 RMP, maintain a mix of colors and bloodlines within the JMA, not allowing any specific color or bloodline to dominate. Maintaining all bloodlines will no longer be a management goal.” (JMAP)
The Pryor Herd is a closed herd with unique Spanish genetic markers. These unique genetics must be protected as a matter of cultural and historic significance. Once lost, they can never be recovered. The draft JMAP states that “maintaining all bloodlines will no longer be a management goal.” If implemented, this could be disastrous for the long-term health and survival of the herd.
Managing for good conformation and a variety of colors is not enough in a herd that is as isolated as this one. Each horse on the range represents decades upon decades of evolutionary adaptation. It is exactly those genetics – and the variety of them – that allows these horses to thrive in the Pryor Mountain environment. Losing any of these valuable and varied genetic lines would be a tragedy for this tiny herd.
3. DOMINANT BLOODLINES
“Any individuals who are part of a dominant bloodline could be considered for removal.” (JMAP)
Considering for removal any horse from a “dominant bloodline” is also ill-advised. First, how is “dominant bloodline” to be defined? To even be implemented, it must be defined according to a science-backed strategy for wild horse management. Is it defined by parentage? Grand-parentage? Solely dam or sire? There is too much room for arbitrary, opinion-based decision making in such a statement to make it a viable management criterion.
Second, bloodlines typically become dominant for good reason. If a specific group of horses are able to reproduce and proliferate, it is because their strong genetics have allowed them to survive and thrive. These are the kind of lines that support the health and longevity of the herd, especially when mixed into a varied genetic pool.
4. OUTSIDE HORSES
“Stallions or mares may be from a different HMA but displaying similar or desired characteristics of the wild horses within the JMA may be released to maintain or increase the genetic diversity of the herd.” (JMAP)
Introducing outside horses must not be considered as a management tool. The Pryor Mustangs are unique. They exhibit primitive markings and stature reminiscent of equines from ages past. They cannot be replaced by the introduction of animals from other herds. Nor is this practice in alignment with the JMAP goal to “to maintain the wild horse herd as a self-sustaining population of healthy animals.” (emphasis added)
A healthy, self-sustaining population has no need for the introduction of outside animals. If this were to become necessary, it would indicate a failure in the management of this irreplaceable wild horse herd. If the Pryor herd is managed at the scientifically acceptable level to maintain genetic variability (150-200), then it should be able to survive, evolve, and adapt over the years without outside intervention.
5. NEW FERTILITY CONTROL MEASURES
“Zona Pellucida (PZP) specifically ZonaStat-H would be the treatment of choice through remote darting application, however if objectives cannot be achieved and new fertility controls are available, they could be used as directed through the most recent direction of the National Wild Horse and Burro Program.” (JMAP)
TCF supports the use of PZP in the humane management of the Pryor Mountain herd. PZP is humane, reversible and effective if implemented correctly. Most essentially, it does not interfere with natural wild horse social behaviors.
The NAS determined "preserving natural behaviors is an important criterion" for wild horse management. Therefore, the following should be precluded from management actions:
· sex ratio skewing which causes stallion aggression due to the unnatural ratio of males to females;
· castration, ovariectomy and other surgical sterilization that alters an animal's ability to produce natural hormones; and
· any fertility control (e.g. Gonacon) that alters the production of natural hormones.
In 1971, Congress unanimously passed the Wild, Free-Roaming Horses and Burros Act. It was not called the "American Horses and Burros Act" for a reason. The word "Wild" has distinct meaning, especially when it comes to wild horses. Wild behaviors are the basis for the rich and complex natural social structure of wild horses.
TCF cannot support any management strategy that would alter natural hormone production and therefore affect the natural social behaviors of the wild horses.
“The very essence of the wild horse, that is, what makes it a wild horse, is the social organization and social behaviors.Geldings (castrated male horses) no longer exhibit the natural behaviors of non-castrated stallions. We know this to be true from hundreds of years of experience with gelded domestic horses. Furthermore, gelded stallions will not keep their bands together, which is an integral part of a viable herd. These social dynamics were molded by millions of years of evolution, and will be destroyed if the BLM returns castrated horses to the HMAs … Castrating horses will effectively remove the biological and physiological controls that prompt these stallions to behave like wild horses. This will negatively impact the place of the horse in the social order of the band and the herd.” (emphasis added) – Dr. Jay Kirkpatrick, wildlife reproductive biologist, Science and Conservation Center, Zoo Montana.
Dr. Kirkpatrick explains that altering natural hormone production through castration essentially changes how that animal feels and behaves. He goes on to say, “Gelded stallions will not keep their bands together. Ovariectomized mares will not display estrous behavior. The very essence of the wild horse, that is, what makes it a wild horse, is the social organization and social behaviors, which in turn were molded by millions of years of evolution. Gelding/spaying will take exactly that away and then you no longer have wild horses... Sterilization is incompatible with the mandate to protect and retain the free-roaming nature of wild horses.” (emphasis added)
In addition to the behavioral changes, the reduction of estrus and alteration of hormones undeniably has an impact on the physiology of any mammal. BLM must exclude these ill-advised and inhumane management strategies, because they violate the spirit and mandate of the 1971 Act.
6. REMOVAL OF EXCESS ANIMALS VIA SELECTIVE REMOVAL CRITERIA
If horses must be removed from the range, TCF supports selective removal. Because of the rigorous documentation of this herd, volunteers and advocates can play an intrinsic part in the selection process. The removal of specific individuals could be recommended by those who know this herd and its genetic lines intimately.
“Due to monitoring and documentation of the Pryor Mountain wild horses, management within the Pryor Mountain Wild Horse Range JMA can be more specialized than that of most BLM managed herd management areas.” (JMAP)
Meticulous record keeping by both the Pryor Mustang Center and the Cloud Foundation for decades allow for the tracing of each horse on the mountain through its matrilineal line. In most cases each horse can also be traced through its patrilineal line. Dr. Gus Cothran also has records from the 1990s, which create a genetic map. His depth of genetic knowledge has resulted in his consistent recommendation that this herd be allowed to exceed the 150-200 horse limit.
BLM’s primary goal should focus on creating a range for the horses that allows for a safely viable population, a population that can survive an event like the winter of 1977 – 78, during which all the foals and old animals perished.
7. WATER GUZZLER MAINTENANCE AND REPAIR -- AND RANGE IMPROVEMENTS
“Existing water developments will be maintained or reconstructed if necessary within the JMA, these existing developments include: Mine Guzzler, Jacks Farm Guzzler, Boundary Guzzler, Old Water Hole, Horse Trap Guzzler, Skyline Guzzler, Ridge Guzzler, Bat Guzzler, Bad Pass Trough, Burnt Timber Catchment, and Cottonwood Spring Trough.” (JMAP)
Please note: two guzzlers are missing from your list – Little Sykes Spring and the Mid-Sykes guzzler.
There are several water catchments on the range that do not function correctly and have not for over a year. The result is that horses spend more time around several guzzlers that are more dependable. The mid-Sykes guzzler requires someone to manually fill it. Visitors to the range have tried to fill the tank which requires someone to literally turn the water on. It takes hours for the tank to fill. This guzzler needs to be retrofitted so that it fills without a human turning the water on.
The trough at Cottonwood Spring is not functioning. We recommend that you allow volunteers to take out all the old fencing and the tangle of makeshift posts and dangerous downed posts and wire. The goal should be to return the spring to a more natural state while also protecting the riparian area.
The first catchment on Burnt Timber Road - The Mine Guzzler - has a problem. When the water level is low, horses must resort to kneeling in order to drink. This is a highly dangerous situation that could result in serious injury. We suggest an evaluation by professionals to make necessary changes to this guzzler. We have photographic proof that horses place themselves in jeopardy to get a drink of water. We can make this footage available if you would like to review it.
The catchment on Cheyenne Flat - the Boundary Guzzler - has also not functioned for over a year. The boot is separated from the tarp, so there is very little water in the main holding tank, even after all the snow melt from winter. The water drains into the ground before it has a chance to get to the main tank.
Given that so many of the guzzlers aren’t functioning properly, it’s no surprise that use is high in certain areas where there is water. This is a human problem; it is not the fault of the horses.
Repair of current water catchments will allow for the desired dispersal of wild horses, better spreading their use across the range. Currently, with several guzzlers broken, use is concentrated around the few functioning guzzlers. Reconstruction and repair of malfunctioning guzzlers is consistent with Rangeland Health Objectives:
“Decrease utilization by wild horses within a 1-3 mile radius of existing water developments from heavy/severe to light/moderate.” (JMAP)
Fencing
TCF supports removing old fencing on the range and repairing perimeter fences to keep the horses safe inside the JMA. We will be happy to help clean up the fencing in the South Administrative Pasture so that area can be added to the range and its AUMs included in the AML.
Please also acknowledge the appropriate AUMs for the now-open North Administrative Pasture and add these AUMs to the AML.
Range Expansion
BLM should also consider expanding the Pryor Wild Horse Range to include the 6,000-acre Demi-John Flat, which was recommended for inclusion in the original range assessment and recommendations in the early 1970’s. The Sorenson Extension, in the Park Service lands, had also been recommended by several knowledgeable parties as a fitting addition to the range. A former Park Service employee assisted in a study conducted by a biologist out of Laramie which concluded that this land would benefit from regular grazing.
Wild Horse Annie Cattle Guards
All cattle guards in the PMWHR must be replaced with safer, “Wild Horse Annie Cattle Guards.” We have footage and photographs of domestic mares in the PMWHR from May 2019. These mares had been left behind by a drive operation in the horse range – a disaster in and of itself. On top of that, they were attempting to leave the range, presumably to go “home,” and had injured themselves attempting to cross the cattle guard on the north end of the DryHead. We managed to open a gate and guide them through, but the injuries had already been sustained.
Another tragic case was that of the stallion Jemez. He sustained an injury to his ankle which resulted in BLM having to euthanize him. Jemez was a bachelor stallion in search of a mare, and it’s very possible his injury was sustained in an effort to traverse a cattleguard.
Wild horse Annie cattleguards are safe and effective. The cattleguards in place now present a danger to the horses, particularly the young ones. We urge you to work with the Park Service to replace these cattle guards so that no further lives are lost, or injuries sustained.
7. SEASONAL CLOSURES
The implementation of PZP has resulted in foaling being spread throughout the year. There is no peak foaling season any more. Therefore there is no need to close the range. Twenty-six years ago, when I first started coming to the Pryors, most mares foaled from May 15-June 15 although there were always a few born outside this window. It is very different now and mares foal year-round.
Rather than implement a closure, which would no longer be helpful, please educate the public on the need to keep a respectful distance through clear, visible signage.
We also suggest BLM maintain a presence on the range - a part-time worker or a team of volunteers - to monitor human behavior atop the mountain from mid-June through September 1. This employee or the volunteers would also be available to answer questions about the horse herd during the high-tourism months, mid-June through the end of August.
BLM did have a seasonal employee on top in the past. However, this individual was rude to the public and disdainful of the horses, stating he was “proud to say I don’t know the name of a single horse.” This was a poor representation of the agency, and offended visitors.
Any volunteers or employees would need to be appreciative of the herd, familiar with wild horse behavior, and familiar with the names of the horses. The Pryor Mustang Guide would be an excellent resource for this employee or volunteer(s).
II. MANAGEMENT ACTIONS
1. GONACON
The NAS stated in its 2016 Report, “Thus, to the extent that GonaCon preserves natural behavior patterns while effectively preventing reproduction, it is a promising candidate as a female-directed fertility-control method. However, further studies of its behavioral effects are needed.” p. 149 (emphasis added)
We now know that GonaCon does not preserve natural behaviors because it explicitly shuts down a mare’s estrus cycle.
The Cloud Foundation cannot support any management strategy [Castration (gelding), ovariectomy (spaying), and drugs or vaccines (e.g. Gonacon)] that shuts down the natural production of wild horse hormones. The changes to wild horses’ natural behaviors, which include the following, could be catastrophic to the health of the herd:
· Behavioral disruption of social structure and band integrity.
· Physiological disruption of hormones that play a vital role in the survival ability in the harsh and rugged wild environments.
· Environmental impacts caused by sterilization procedures which may alter the way horses utilize the land.
The Act requires BLM to manage wild horses and burros in a manner that protects their wild and free-roaming behavior. While Section 3(b)(1) as modified by the Public Rangelands Improvement Act of 1978, outlines options for population management that include sterilization, it is to be read in conjunction with and not in substitute for the overarching intent of the Act: to protect wild horses.
In addition, the 1971 Act directs BLM to work with independent experts, such as the NAS, which has clearly stated the importance of preserving natural wild behaviors in all management actions:
“A potential disadvantage of both surgical and chemical castration is loss of testosterone and consequent reduction in or complete loss of male-type behaviors necessary for maintenance of social organization, band integrity, and expression of a natural behavior repertoire.”
2. HELICOPTER DRIVE TRAPPING
Helicopters have not been used in the Pryors since 2009. Previous managers considered it too disruptive and potentially dangerous. Using helicopter drive trapping again would indicate a breakdown in management. Bait trapping is the only safe method of removing horses and has been conducted safely in 2013 and 2015.
The steep, rugged terrain should rule out the consideration of helicopter drive trapping. Driving terrified horses over 10 miles down rocky terrain from over 8,000 feet to 3,500 feet in the desert has resulted in injury to many of the foals.
In 2009, respiration rate of prime-condition bachelors reached over 150 respirations per minute, more than ten times the average respiration rate. A young mare colicked but survived. Another tied up but recovered. In 2001, a foal was considered for euthanasia due to lameness and an adult mare was observed to be foaling on the run and was never seen again.
Because the Pryor mustangs make great riding horses, it is important that they are not damaged during their capture. Injuries can show up later after they are placed in situations where they are being trained and ridden. A Pryor mustang stallion, the son of Raven and Grumpy Grulla, was rounded up in the 2005 selective helicopter roundup. He was later put down after he broke his leg when asked to canter in a round pen at the Prison Training Program in Canon City, Colorado. This trauma was not the fault of the prison, the damage likely occurred during the helicopter stampede and the pressure caused by cantering resulted in the catastrophic leg break.
3. GENETIC TESTING
“Hair follicle and/or other genetic material samples will be collected periodically for ongoing genetic diversity monitoring. Results of genetic monitoring analysis will contribute to BLM management decisions intended to maintain acceptable levels of genetic diversity, and to minimize the risk of inbreeding depression.” (JMAP)
TCF supports the use of genetic testing to analyze and maintain the genetic health of the herd. E. Gus Cothran, PhD, has been keeping records on the Pryor Herd since the early 1990s and he should be considered in the hair analysis process.
4. HORSES LEAVING THE JMA
“Wild horses which pose a biosecurity risk, stray onto private land, or repetitively leave the JMA should be removed.” (JMAP)
The Pryor mustangs should not be physically able to leave the JMA. If this happens, it is because fencing is inadequate or broken down. A recent example of this is when a young Pryor stallion passed through downed fencing and was on the Tillett Ranch property. He was captured by BLM and placed under quarantine in the Britton Springs Corrals. After the perimeter fence was repaired and he was deemed safe to return to the range, the young stallion was returned to the range. TCF greatly appreciates the expert capture, care, and return of this stallion to the PMWHR. He is now a band stallion.
Volunteers should be considered assets to the BLM. Frequent visitors to the range found the spot where the stallion left the range and assisted in repair of the fence. TCF would be very willing to assist with on-range fencing improvements and other projects that contribute to the health and safety of the horses.
III. MANAGEMENT, MONITORING AND IMPLEMENTATION OBJECTIVES
1. REMOVAL TO LOW APPROPRIATE MANAGEMENT LEVEL (AML) [Population Control Objectives 1 & 4]
The current AML of 90-120 is far below the scientifically accepted number to maintain genetic viability (per E Gus Cothran, PhD). Maintaining genetic diversity is a stated management goal of this draft JMAP, thus AML must be raised to at least 150.
We are concerned about the genetic viability of this herd. The proposed removal down to low AML (90) will render the PMWHR herd genetically non-viable. According to equine geneticist Dr. Gus Cothran:
“Both observed heterozygosity and expected heterozygosity in the Pryor Mountains Wild Horse Range herd is above the feral mean. He is slightly higher than Ho which could indicate the very beginning of evidence of inbreeding.”
Pg. 4, Genetic Analysis of the Pryor Mountains Wild Horse Range, MT, E. Gus Cothran, 8.2013 (Attachment 4)
Additionally, Dr. Cothran notes that the variability of the herd is in decline.
“Genetic variability of this herd in general is on the high side but compared to past sampling of this herd, variability levels for all measures has been in decline. This is likely due to the population size that has been maintained in recent years.”
Pg. 4, Genetic Analysis of the Pryor Mountains Wild Horse Range, MT, E. Gus Cothran, 8.2013
At present, the Pryor herd numbers roughly 165 horses. If it were to be taken to the low side of AML at 90, this would constitute a 45% reduction of the herd and an irretrievable loss of essential genetic lines. Such a massive removal would have catastrophic ramifications on genetic viability. Essentially, it could render the herd nonviable.
Equine geneticist Dr. Gus Cothran has long stated that in order to remain genetically viable, herds must be 150-200 animals in size at a minimum (Ne50). At their current population level, the Pryor horses barely meet this requirement for a healthy, self-sustaining herd. AML in the PMWHR should be adjusted to reflect sound scientific processes for wild horse management in order to ensure the long-term health and survival of the herd.
“The best way to maintain current [variability] levels [in the PMWHR] would be to increase population size if range conditions allow.”
Pg. 5, Genetic Analysis of the Pryor Mountains Wild Horse Range, MT, E. Gus Cothran, 8.2013
Dr. Cothran has been quoted many times over the last decade in reference to increasing the AML for what he calls “one of the most significant, wild-horse herds in the United States” (see Appendix 3):
“The concern in keeping only 120 horses on the range, Cothran said, is the threat of a potential die-off that could reduce the herd even further, reducing the herd’s genetic diversity.”
Billings Gazette, “Noted geneticist gives his two bits on significance of Pryor Mountain Mustangs,” Sept. 9, 2009 (Attachment 3)
In the winter of 1977-1978, the Pryors experienced a winter so harsh that nearly half the herd died. If that were to happen again, the herd could potentially rebound due to its healthy size and genetic variety. However, if reduced to the low AML of 90, a stochastic event could be so severe that the herd might never recover.
The National Academy of Sciences Report from 2013 endorses Dr. Cothran’s work as a helpful tool for BLM management of herds.
“The Cothran studies are excellent tools for BLM to use in managing herds to reduce the incidence of inbreeding…” National Academy of Sciences 2013 Report: Using Science to Improve the BLM Wild Horse and Burro Program – A Way Forward (p.192)
"How Appropriate Management Levels are established, monitored, and adjusted is not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change." (emphasis added). National Academy of Sciences 2013 Report: Using Science to Improve the BLM Wild Horse & Burro Program - A Way Forward
As interested and affected parties in this action, TCF and our followers are entitled to see the rangeland monitoring data that supports AML, if it exists. We appreciate you agreeing to share this data on our phone call of May 12, 2020. We look forward to receiving that data.
From the draft JMAP, “AML would be evaluated, as needed, following an in-depth analysis of resource conditions including actual use, utilization, available forage and water, range condition and trend and precipitation data.” This statement indicates that AML can indeed be changed based on ongoing rangeland monitoring data.
The JMAP must disclose and address these questions and issues so that the public can provide meaningful comments:
a) Upon what data was AML first established?
b) Where is the current and continual monitoring data that supports AML today?
The PMWHR has supported a herd which averaged 146 horses for over 40 years while maintaining a thriving natural ecological balance. The variety of wildlife that proliferates on the range is a testament to its health. The fact that the herd is also thriving would additionally support this statement. It is time to undo the mistakes of the past and set an AML that is supported by the science of genetic viability as well as current and continual rangeland monitoring data.
2. POPULATION GROWTH AND “NON-RESPONDING” MARES [Population Control Objective 2]
“Manage wild horse populations to allow for a 5% average growth rate or lower.” (JMAP)
When I first came to the Pryors, the average growth rate was around 8%. When massive removals take place, as proposed in this Scoping document, the horses attempt to compensate by having more foals more frequently, a phenomenon known as compensatory reproduction.
“…the annual removal of foals from the Chincoteague NWR herd results in compensatory reproductive mechanisms and higher foaling rates.” From Compensatory Reproduction in Feral Horses, by Dr. Jay Kirkpatrick and Dr. John Turner
In the 2001-2006 time period, the herd was largely kept in check by predation. In 2004 every foal on the mountain was killed by lions. The only exception was a colt born near the gate of the horse range in the Park Service lands. Nature can create a dynamic equilibrium over time, if allowed to work as intended. Fluctuations are normal and should be allowed. This, of course, is the most desirable type of management and certainly the most economical.
When the mountain lions were killed in order to continue testing the efficacy of PZP, nature’s population control was destroyed. While PZP can be extremely effective, natural predators should still be protected at all costs, as part of a thriving natural ecological balance. There is no reason or excuse for hunting these important predators within and around the PMWHR. They fill a niche in the Pryor Mountain ecology and must be treated as a key part of the environment.
“Mares that are non- responders to ZonaStat-H would be considered for removal or treated with another approved fertility control vaccine.” (JMAP)
You cannot determine PZP is not effective if BLM is not adequately administering PZP, meaning that mares are not vaccinated in a timely manner to prevent pregnancy. The JMAP cannot merely claim that PZP is not effective, therefore we moved on to “plan b”. Rather, the BLM must make a good faith effort to work with volunteer PZP darters (as volunteered by TCF) and ensure all mares are adequately vaccinated. Otherwise, arguably the BLM refused to adequately implement a PZP fertility control program and instead only went through the motions to set up the program for failure.
Mares cannot be considered “non-responders” to PZP without years of meticulous data to support this conclusion. For PZP to work as designed, darting must be undertaken at the correct time of year, typically January through April and early May. Therefore, to prove a mare is “nonresponsive,” records must show that she has been darted within the correct time window every year for many years in a row, while still producing a foal annually. PZP darting records must also be available to interested and affected parties so the public can understand how and why these important decisions are made.
On the other hand, there are mares who first received PZP in the first year of the PZP study and did not return to fertility, and mares who had one foal and then did not foal again in subsequent years. It was believed that a change in the adjuvant corrected this over-reaction. These mares should not be considered for removal –i.e. labeled as “non-responders”- when the error in the adjuvant was clearly, but accidentally, caused by humans.
The PZP darting program is in disarray. Some of the most talented darters of PZP are available to BLM to augment the delivery of PZP on time. However, BLM has declined this expert help for unknown reasons. These volunteers have been used in the past by the previous managers and should be considered again. BLM once wrote an article, entitled “Partnership in the Pryors”, about the success of the volunteers working with BLM darters. We would like an explanation as to why offers of volunteer darting teams (under the direction of BLM) have been ignored.
“Apply fertility control to mares within the JMA to reduce population growth rates below natural rates of approximately 20%.” [JMAP Management Objective 5]
Quoting a reproduction rate of 20% is BLM boilerplate language that doesn’t apply in the PMWHR, if indeed it applies anywhere. Wild horses, as already discussed, engage in compensatory reproduction after massive removals, which have long been BLM’s management action of choice. It remains to be seen what natural wild horse reproduction rates truly are, when they are left alone.
Certainly, in the PMWHR, reproduction rates are much lower. In 1994, it was around 8% and predation was almost certainly a factor along with the vagaries of living wild. Even now, when PZP has admittedly not been applied effectively due to a federal shutdown and record cold temperatures, the herd’s reproduction rate only reached roughly 10% in 2019. With the appropriate and effective application of PZP through BLM-volunteer collaboration, we believe the Pryor herd can be entirely managed without the need for highly unpopular removals.
3. BALANCING SEX RATIOS [JMAP Population Control Objective 3]
“Balancing sex ratios of the population to be adjusted to a 50/50 male/female sex ratio.” (JMAP)
The draft JMAP does not provide any scientific information or data to support an artificial skewing of the sex ratio in this herd. Wild horse herds are almost always naturally balanced slightly in favor of females. We are unclear why the intent here is to unnaturally skew the ratio to 50/50.
Creating unnatural sex ratios increases aggression among males and causes stress and social disruption. It can create dangerous situations for females, who may be subject to being repeatedly raped by stallions. I have footage of a burro jenny being repeatedly raped by jacks specifically as a result of this inhumane, yet acknowledged management practice.
Sex ratio skewing could also have a devastating impact on individual horses and family bands, as band stallions must remain ever vigilant, expending precious energetic resources to fight bachelors who aim to break up their family unit.
“The natural sex ratios of adult wild horse herds are nearly always skewed toward females. The main reasons for this: differential survival of adult males and females and foal sex ratios.” (Garrott and Taylor 1990).
“Higher mortality in male horses may be due to injuries acquired during fights for mates or under conditions of food shortage and being unable to obtain sufficient nutrients since male horses naturally need more nutrients than females.” (D. Siniff, J.Tester, and G. McMahon 1986).
The BLM EA for the South Steens Wild Horse Gather[2] (Attachment 2) states, “Skewing the sex ratio of stallions v. mares would result in a destabilization of the band (stallion, mare and foal)…Social band structure will be lost resulting in combative turmoil as surplus stallions attack a band stallion trying to capture his mare. This could result in the foal being either killed or lost. The mare and foal will not be allowed to feed or water naturally as the stallion tries to keep them away from the bachelor bands of stallions, resulting in stress to the mare during her lactation condition.”
Sex-ratio manipulation could lead to disruption in the Pryor Mountain herd, where some bands have been intact for years. Wild horses rely on and survive as a result of their strong familial bonds. Disruption of bands and stress created by artificially manipulating the sex-ratio of the herd could put the horses’ welfare in danger. It should be removed from consideration.
4. REMOVAL OF NON-BREEDING INDIVIDUALS [JMAP Removal Criteria 3]
“Wild horses that are no longer breeding or have contributed genetically could be removed unless needed to achieve AML.” (JMAP)
The removal of older horses is inhumane. They are less trainable and less adoptable than younger horses. Removing them is indefensible and cruel. Perhaps nothing in this document is as repugnant as this potential action. To have lived one’s entire life in freedom only to be captured in the last year(s) of one’s life is unthinkable.
Additionally, these mares may not be reproducing, but are still being bred, as documented in a video I have of Hernando breeding Phoenix taken in April, 2020. Note that Phoenix is the oldest horse in the PMWHR, so it is likely the other senior mares are also being bred without producing foals. This is favorable for population control, as the urges of the stallion are being met, without the risk of reproducing. Destabilizing these bands could actually have the effect of increasing the reproduction rate.
Consider also that senior wisdom is important in the survival of the family unit. These older mares have experiences that are passed down to the younger generations. Where do you go when a sudden, atypical storm comes? Where can water be found during extreme drought? These mares are reservoirs of essential historical knowledge of the herd. They act as teachers and they are often the steadying influence that keeps the family unit safe and intact. Horses mirror the behavior of their elders and this elder wisdom is important to their survival.
5. “SUCCESSFUL” FOALING
“Successfully foaling is defined as a foal living to be 1 year of age.” (JMAP)
Allowing only 1 foal per mare is ill-advised in any environment, particularly in an extreme environment like the Pryors. Mares must be allowed to contribute at least 2 foals who live to adulthood. Consider again the 1977-78 winter in which all the older and youngest horses died.
The PMWHR is a much more dangerous environment comparatively than wild horse HMAs in more temperate areas. The terrain itself is more rugged than any of the other herds with which we are familiar. I have experience with two band stallions dying from falls—Pierre and Opposite. I am confident there are others. It is common that horses simply disappear. Most bodies are never found.
Allowing only a single foal before a mare goes on PZP is rash and dangerous. Considering the rugged terrain, harsh weather, and risk of predation, mares should be allowed to have at least 2 foals before being put on PZP.
6. COMPLETE RANGELAND HEALTH ASSESSMENT [JMAP Management Objective C – Rangeland Health]
The Cloud Foundation supports all efforts to scientifically document and assess the health of the range. We stand ready to assist with range restoration efforts, and we look forward to receiving the rangeland health data promised.
In years past, rangeland health was cited as a potential reason for removals. However, in the. last EA, it was stated that utilization had been meeting set goals in almost every area of the PMWHR.
“Based upon monitoring data collected in 2015, 2016, and 2017 the use objective was being met in the Dryhead, parts of the lower elevation areas, and has continued to be met in the mid-elevation areas until recently… Some use patterns of the wild horses are shifting as more time is being spent in the mid-slope areas due to guzzlers.”
Pg. 31, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment
Additionally, in the HMAP for the PMWHR from 2009, there were many methods of rangeland improvement suggested:
“Prescribed fire for the enhancement of forest health, wildlife, and wild horse habitat could occur primarily in the mapped area…”
Pg. 46, PMWHR HMAP 2009
“Aerial seeding with native species appropriate to the PMWHR would be used to supplement seed source and attempt to improve ecological conditions.”
Pg. 42, PMWHR HMAP 2009
We realize that a legal challenge was filed on prescribed burns. Exempting that action, to our knowledge, reseeding and other range improvements have never been carried out. This was confirmed by the BLM team in a meeting with TCF in March of 2019.
We hope that BLM is planning to carry out these essential range improvements. If the range is now not meeting standards, the first thing that must be considered is the agency fulfilling its responsibilities to maintain and restore a healthy rangeland environment.
Aerial reseeding can be done anywhere on the range, including the mid ridges which can be done in the summer when there are few horses in these areas. Temporary fencing can be constructed for reseeding in non-WSA (Wilderness Study Areas) where practicable. The health of the range can be improved without risking the genetic health of this unique wild horse herd.
There have been a significant number of studies done in the PMWHR regarding the ecology of the range. In the discussion section of a paper submitted by Jace T. Fahnestock and James K. Detling, the two authors state:
“Mean annual precipitation in the PMWHR, especially in the lowlands, is closer to the dry end of the precipitation range in the above studies, and the responses of 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.”
Managers’ Summary – Ecological Studies of the Pryor Mountain Wild Horse Range 1992-1997
During the time the studies were conducted, the population of wild horses was similar to the current population. This would suggest that precipitation is a main factor in the success of plant growth in the PMWHR.
Improving and repairing existing water catchments will also certainly disperse wild horse use of the range, and alleviate pressure on areas where use might, at present, be high. Concentration of use is due to disrepair and malfunction of certain guzzlers, thus the horses are forced to congregate at the few working ones. They should not suffer due to human negligence. TCF would be happy to help with any or all of these important projects in any way we can.
7. HEALTHY POPULATIONS OF WILD HORSES [JMAP Management Objective/Implementation Objective D]
“Forage and water resources are finite on the JMA. Young, fertile animals that are determined excess, can be sent to other wild horse herds (i.e. in Utah -- Sulphur or other recipient HMA) to ensure that any unusual genes from the PMWHR JMA are maintained in other herds of wild horses.” (JMAP)
We are currently intervening on behalf of the BLM in Beaver County, Utah, to protect the Sulphur Herd from massive reductions. Transplanting horses from the Pryors to the Sulphur herd makes no sense. Why round horses up in the PMWHR and put them at risk somewhere else?
While both herds display Spanish genetic markers and phenotypic features and colors, the two herds are distinct. They cannot be simply combined or replaced. The Sulphur horses likely originated from horse traders that traveled from the southern California area eastward on important trade routes through what is now Southern Utah.
The Pryor mustangs, on the other hand, likely originated from traders and Native Americans in Mexico. The traders moved north though what is now New Mexico. They traded on the eastern slopes of the Rockies and northward into what is now Montana. The Crow Tribal historian Elias Goes Ahead, in a recorded interview with us, related the pride of the Crow tribe in accumulating some of the largest horse herds amongst all the tribes. He related that the horses in the Pryor Mountains “are descended of our horses.”
There is new and exciting research being conducted regarding Native American horses, driven largely by the work of Dr. Yvette Running Horse Collin, PhD. Indeed, the Pryor mustangs exhibit some of the phenotypic traits of these ancient animals, such as the leg stripes, webbing on the face, and dorsal stripe seen on duns. It will be interesting to see what her continued research and genetic testing reveals.
The bottom line is that maintaining a healthy, self-sustaining population means to cultivate the genetic health of the herd by keeping it at a healthy size. Again, the country’s foremost equine biologist, Dr. Cothran, has cited this number as a minimum of 150-200. The Pryor herd now exists healthily at 165 horses, give or take. The land has supported this population range for decades. With the much-needed range and infrastructure improvements proposed in this draft JMAP, it can likely support the herd at this size indefinitely.
CONCLUSION
The JMAP must disclose, analyze and take a hard look at the information and questions outlined in this letter. The disclosure of data and information is important to ensure the public is given sufficient information to provide meaningful comments.
The objective of The Cloud Foundation has always been to collaborate with the BLM in the management of a healthy herd and a healthy range. We do not want to have an adversarial relationship with the Billings BLM. We again offer ourselves and our team as volunteers to help with the darting program, range maintenance and improvements, and any other projects where we might be helpful. We have a volunteer, trained darting team already working with Rawlins BLM to get a fertility control program off the ground. These same darters are willing and available to help in the Pryors.
The mission of our organization is to protect wild horses on our public lands. We believe removals are a last resort and should not be carried out using helicopters. We do understand that selective removals may, at times, be necessary – but these should be carefully considered with input from those who have followed and documented this herd for decades.
Because we abhor removals, we are proponents of humane fertility control. While it’s always a joy to see new foals, with each new birth we fear that it will eventually be captured and removed. We are public advocates for the responsible, effective use of PZP and could be a huge asset to the BLM in locating, identifying and even darting the Pryor mares.
Members of our team, including myself, have already been certified to dart via the Science and Conservation Center. Based on the examples of successful BLM-Volunteer darting programs across the West, there should be minimal bureaucratic red tape. Many successful precedents have been set already and we hope to see many more in the years to come. Some outstanding examples – Little Book Cliffs, CO; McCullough Peaks, WY; Virginia Range, NV; Sand Wash Basin, CO; Spring Creek Basin, CO – just to name a few.
In conclusion, we sincerely want to establish a collaborative working relationship with BLM. We will fight for this herd as our hundreds of thousands of supporters expect us to. But we believe there is ample common ground to work together for the healthy, successful management of this treasured wild horse herd.
Sincerely,
Ginger Kathrens
Founder and Executive Director
The Cloud Foundation
LIST OF ATTACHMENTS
Attachment 1: 2013 NAS Report: Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward
Attachment 2: Sex Ration Skewing; South Steens Gather BLM EA
Attachment 3: Cothran Article Billings Gazette
Attachment 4: Cothran Pryors Genetic Study
[1] Department of the Interior and related agencies appropriations for fiscal year 1984 hearings before a subcommittee of the Committee on Appropriations, United States Senate, Ninety-eighth Congress, first session · Part 1
[2] http://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFinal.pdf, page 41