Preliminary Desatoya Herd Management Area Wild Horse Roundup Plan Environmental Assessment (EA) – DOI-BLM-NV-C010-2021-0004-EA

The Cloud Foundation 107 S. 7th St, Colorado Springs, CO 80905

January 9, 2021

Desatoya Wild Horse Roundup PEA

BLM – Stillwater Field Office, Carson City District Office

5665 Morgan Mill Road

Carson City, NV 89701

Submitted via email: blm_nv_ccd_whb@blm.gov

To: Carson City District and Stillwater Field Offices

On behalf of The Cloud Foundation (TCF), a 501(c)3 nonprofit organization committed to

protecting and preserving America’s wild horse and burros on our public lands, and our more

than 500,000 supporters, I respectfully submit these comments on the Bureau of Land

Management’s (BLM) Preliminary Desatoya Herd Management Area Wild Horse Roundup Plan

Environmental Assessment (EA) – DOI-BLM-NV-C010-2021-0004-EA.

The EA fails to adequately analyze important issues and consider the prevailing public

sentiment on the Proposed Action.

I, along with TCF’s board, staff and supporters, enjoy and appreciate the wild horses currently

living in Nevada. We appreciate wild horses specifically for their natural behaviors – their social

bonds, herd dynamics and individual personalities. Therefore, we strongly oppose the Proposed

Action which include: removing the vast majority of wild horses while allowing allow livestock

grazing to continue in the same areas; the use of Gonacon for fertility control because it is

documented to destroy natural hormone production which is necessary to protect natural wild

behaviors, the skewing of the natural sex ratios of wild horses because of the aggression and

chaos that is caused by this unnatural man-made event and due to the lack of data that

suggests this plays any role in suppressing population growth over the long-term (whereas there

is documented data that highlights the real impact of compensatory reproduction that results

from removals); the use of IUDs which have, to date, not been sufficiently tested in wild mares

prior to implementation on the range (without a research study protocol that would be strictly

followed to provide daily, monthly and annual data on subject mares); and based on the EA’s

failure to identify the type of IUD which would be utilized (thereby making providing public

comments impossible – Appendix F is wholly insufficient).

Reducing wild horse populations to lower levels while allowing livestock grazing to continue in

the same area is illegal and wrong, and is opposed by the vast majority of Americans. The

Proposed Action’s removal of wild horses, proposed destruction of the natural behaviors of

these cherished animals through the use of Gonacon which is documented to destroy mares’

ovaries, and implementation of the still experimental and untested IUD will have a negative

impact on us, by definition causing harm to the human environment:

§ 1508.14 Human environment. Human environment shall be interpreted comprehensively

to include the natural and physical environment and the relationship of people with that

environment. ...

I. Overview

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January 9, 2021 – page 2

Desatoya encompasses 157,836 acres (246 square miles) of public lands in central Nevada.

The BLM allows ranchers to graze their private, commercial livestock on these same public

lands -- permitting the equivalent of 800 year-round cows on this habitat that Congress declared

was to be “devoted principally” for wild horse usage and welfare. BLM artificially confines the

Desatoya wild horse population to just 127 to 180 horses. The EA has failed to adequately

justify or analyze the Proposed Action for the Desatoya Herd Management Area (HMA). Under

the Proposed Action, the BLM would:

• Round up at least 183 wild horses (or 85% of the existing population which BLM claims

was counted at 215 in October 2020) and remove 88 horses.

• Continue roundups and fertility control for a 10-year period to keep the horse population

down to just 127 to 180 horses while authorizing 4 times as many private cattle to graze

the same area.

• Artificially skew the sex ratio (40%-60% female-male) compared to naturally occurring

55-45 female-male sex ratio.

• Implement IUDs which remain experimental on wild mares.

• Administer PZP and/or Gonacon which is known to destroy the ovaries, natural hormone

production and natural wild horse behaviors.

The EA states that horses must be removed to maintain a “thriving natural ecological balance"

(TNEB). However, no threat to this balance is greater than the extensive livestock grazing

authorized by BLM in this same area. BLM authorizes year-round livestock grazing in the

Complex, permitting the annual equivalent of more than 800 cow/calf pairs vs. a maximum of

180 wild horses. (Even at current population estimate of 552 permitted cattle grazing exceeds

the current wild horse use.) The artificially low wild horse “Allowable” Management Level (AML)

of just 127 to 180 horses for the entire 157,000 HMA is less than one-fourth (1/4) the forage the

BLM allocates for privately-owned livestock (which is 4 to 6 times higher than allocated for wild

horses).

Throughout the EA environmental damage is attributed to “wild horses” without specific

information indicating the way in which BLM distinguishes between range damage caused by

wild horses and that caused by livestock grazing – whether historic or active. If TNEB is BLM’s

objective and if, as the EA states, range conditions are not meeting this objective, then the first

species that must be removed are the non-native, privately-owned livestock.

II. 1971 Wild, Free-Roaming Horses and Burros Act (Act)

A. Congressional Intent Is Clear: Designated “Range” Is “Devoted Principally” for

Wild Horse Use

Congress clearly outlined in the Act that wild horses have a special, protected status.

The Act specifically identifies 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

then states this wild horse habitat “is devoted principally but not necessarily exclusively to

their [wild horses and burros] welfare...” [Public Law 92-195 § 1332]

The BLM does not hold any discretion or authority to diverge from the clear, stated intent of the

United States Congress. Congress told the BLM those lands are (must be) devoted principally

to these federally protected animals. Again, the clear language of the Act leaves no possible

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January 9, 2021 – page 3

ambiguity about the intent of Congress, or that wild horses “are to be considered in the area

where presently found, as an integral part of the natural system of the public lands.”

“If the intent of Congress is clear, that is the end of the matter; for the court, as well as the

agency, must give effect to the unambiguously expressed intent of Congress.” [Chevron, U.S.A.,

Inc. v. Nat. Res. Def. Council, 467 U.S. 837, 842–43 (1984)].

BLM’s regulations state that “wild horses and burros shall be considered comparably with other

resource values in the formulation of land use plans.” [43 CFR 4700.0-6]1 The EA fails to render

a comparable evaluation of wild horse use of these public lands with that of privately-owned

livestock that use the same area - despite Congress’ clear intention that these public lands are

to be devoted principally to wild horses.

Additionally, Congress was clear in its requirement that “All management activities shall be at

the minimal feasible level...” Obviously, eliminating all wild horses is not a “minimal”

management action. In fact, nothing could be more extreme than eliminating an entire herd of

wild horses from lands specifically designated for their use.

The creators of the EA clearly fall into one of the two categories of BLM personnel noted in the

1982 National Research Council’s report on the BLM Wild Horse Program: “our experience also

suggests that the Bureau must be sensitive to considerable pockets of resistance to the

program within its own ranks and to the pressures which many district and area personnel

feel to depict range, population, and other conditions in an antihorse and antiburro context.”

More on this below.

The EA fails to adhere to the Act.

III. Code of Federal Regulations (CFR)

A. 43 CFR § 4700.6 – Protection, Management, And Control of Wild Free-Roaming

Horses and Burros

BLM statute 43 CFR 4700.0-6 clearly establishes the policies for the agency’s management of

wild horses.

The EA and Land Use Plans (LUPs) fail to address that “Wild horses and burros shall be

considered comparably [similar] with other resource values in the formulation of land use

plans.” (43 CFR § 4700.0-6) The EA cites land use plans that range from 15 to 45 years old;

relying on these land use plans, which fail to authorize resources “principally” or “comparably”

for wild horses is clearly not in conformance with existing laws and statutes. The Final EA

cannot implement the Proposed Action because it is not in compliance with existing laws

and statutes.

1 43 CFR 4700.0-6 Policy (a) Wild horses and burros shall be managed as self-sustaining populations

of healthy animals in balance with other uses and the productive capacity of their habitat. (b) Wild

horses and burros shall be considered comparably with other resource values in the formulation

of land use plans. (c) Management activities affecting wild horses and burros shall be undertaken with

the goal of maintaining free-roaming behavior.

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January 9, 2021 – page 4

43 CFR 4700.0-6 states in part:

“(b) Wild horses and burros shall be considered comparably with other resource values

in the formulation of land use plans.

(c) Management activities affecting wild horses and burros shall be undertaken with the goal of

maintaining free-roaming behavior.”

The EA and Land Use Plans (LUPs) fail to address that “Wild horses and burros shall be

considered comparably [similar] with other resource values in the formulation of land use

plans. (43 CFR § 4700.0-6) The EA cites land use plans that are 33 years old; relying on this

outdated land use plan which fails to authorize the HMA “principally” for wild horses or consider

wild horses “comparably [similarly] with other resource values” in the LUP is not in conformance

with existing laws and statutes. The Final EA cannot implement an action that is not in

compliance with existing laws and statutes.

The EA fails to take a hard look at 43 CFR 4700.06(b), given the proposal to remove wild

horses to low AML while allowing livestock grazing to continue. The BLM outlines that the actual

usage of private commercial livestock on the Desatoya HMA continues to exceed the current

wild horse population (actual use is reported at the annual equivalent of 552 cows/calf pairs –

grazing permits show many of these cows are permitted to graze year-round). So, while the

BLM claims 88 wild horses must be removed for TNEB (reducing the already small number of

horses), the BLM continues to allow more private livestock to graze the same area. This is in

direct conflict with governing statute which specifically states that horses “shall be considered

comparable with other resource values in the formulation of land use plans.” If the Proposed

Action is implemented, the BLM will not be in conformance with this statute, because they are

not treating wild horses in Desatoya “comparable” - or the same as - livestock that graze in the

same area.

B. 43 C.F.R. 4710 Management Considerations

The EA fails to take a hard look at the BLM authority to temporarily or permanently reduce or

eliminate livestock grazing from the public lands in the HMA pursuant to 43 C.F.R. 4710.5(a).

This regulation allows the BLM to temporarily or permanently close a public land area to

livestock grazing, "If necessary to provide habitat for wild horses or burros…” The BLM has the

discretion to implement this policy either temporarily or permanently and this action is available

whether or not there is an emergency.

BLM cannot claim that 43 CFR 4710.5 “usually applied in cases of emergency and not for

general management of wild horses since it cannot be applied in a manner that would be

inconsistent with the existing land-use plans.” (43 CFR § 4710.1)” 43 CFR § 4710.1 merely

states, “Management activities affecting wild horses and burros, including the establishment of

herd management areas, shall be in accordance with approved land use plans prepared

pursuant to part 1600 of this title.” There is nothing in part 43 CFR part 1600, nor any BLM

regulation, that prohibits the BLM from amending the LUP or delaying the Proposed Action

until such amending could be implemented.

The EA must consider and take a hard look at using adaptive management and, through the

LUP process, amending the RMP.

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The EA fails to consider utilizing the agency's Adaptive Management mandate and its discretion

under 43 C.F.R. 4710.3-2 and 43 C.F.R. 4710.5(a), which allows for the reduction or elimination

of grazing for privately-held animals in order to improve conditions and forage availability for

federally-protected wild horses or burros.

C. 43 CFR § 4710.5 – Closure to livestock grazing

The EA fails to take a hard look at the BLM’s clear authority to limit livestock grazing, pursuant

to 43 C.F.R. 4710.5(a), to close livestock grazing on areas of public lands:

“(a) If necessary to provide habitat for wild horses or burros, to implement herd

management actions, or to protect wild horses or burros, to implement herd

management actions, or to protect wild horses or burros from disease, harassment or

injury, the authorized officer may close appropriate areas of the public lands to grazing

use by all or a particular kind of livestock.

(b) All public lands inhabited by wild horses or burros shall be closed to grazing under

permit or lease by domestic horses and burros.

(c) Closure may be temporary or permanent. After appropriate public consultation, a

Notice of Closure shall be issued to affected and interested parties.”

The EA fails to consider 43 C.F.R. 4710.5; the BLM cannot claim that this statute is “usually

applied in cases of emergency and not for general management of wild horses since it cannot

be applied in a manner that would be inconsistent with the existing land-use plans.” (43 CFR §

4710.1)”

43 CFR § 4710.1 merely states, “Management activities affecting wild horses and burros,

including the establishment of herd management areas, shall be in accordance with approved

land use plans prepared pursuant to part 1600 of this title.” There is nothing in part 43 CFR part

1600, nor any BLM regulation, that prohibits the BLM from amending the LUP or delaying the

Proposed Action until such amending could be implemented. The EA must consider and take a

hard look at using adaptive management and through the LUP process amending the RMP.

43 CFR § 1610.5-3 states, “Any person adversely affected by a specific action being

proposed to implement some portion of a resource management plan or amendment may

appeal such action pursuant to 43 CFR 4.400 at the time the action is proposed for

implementation.” We are therefore appealing this Proposed Action and the RMP which

authorizes it.

The EA fails to take a hard look at implementing BLM authority, and requirement as discussed

above, to utilize its Adaptive Management mandate and its ability as per 43 C.F.R. 4710.3-2 and

43 C.F.R. 4710.5(a), which allows for the reduction or elimination of grazing for privately-held

animals in order to improve conditions and forage availability for federally-protected wild horses

or burros.

IV. Federal Land Policy and Management Act of 1976 (FLPMA)

“The term ‘multiple use’ means the management of the public lands and their various

resource values so that they are utilized in the combination that will best meet the

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present and future needs of the American people... combination of balanced

and diverse resource uses …”

FLPMA requires that BLM “balance” wild horse and burro use with other uses which equates at

minimum to a 50-50 allocation of available forage between horses and livestock on HMAs. The

EA fails to address this. By allowing livestock to continue to graze and instead of reducing or

eliminating livestock, which is far more pervasive across BLM-managed public lands, the

agency has instead chosen to target wild horses for elimination and removal on the small 11%

of public lands authorized for their use and as their habitat.

The EA fails to address that FLPMA highlights the importance of the non-market value within its

definition of the term “multiple-use.” FLPMA requires that:

“(c) . . . consideration being given to the relative values of the resources and not necessarily to

the combination of uses that will give the greatest economic return or the greatest unit output.”

The intrinsic value of wild horses and burros falls under the non-market definition specified by

both laws.

Sec. 302 of FLPMA states:

“(a) The Secretary shall manage the public lands under principles of multiple use and sustained

yield, in accordance with the land use plans developed by him under section 202 of this Act

when they are available, except that where a tract of such public land has been dedicated to

specific uses according to any other provisions of law it shall be managed in accordance with

such law,” [43 U.S.C. 1732] and Sec. 102 “(b) The policies of this Act shall become effective

only as specific statutory authority for their implementation is enacted by this Act or by

subsequent legislation and shall then be construed as supplemental to and not in derogation of

the purposes for which public lands are administered under other provisions of law” [43 U.S.C.

1701]

In addition, FLPMA requires the public lands to be administered for “multiple-use,” which

Congress defined as:

“the management of the public lands and their various resource values so that they are utilized

in the combination that will best meet the present and future needs of the American people . . .

with consideration being given to the relative values of the resources and not necessarily to the

combination of uses that will give the greatest economic return or the greatest unit output.” [43

U.S.C. § 1702(c)].

While commercial livestock grazing is permitted on public lands it is not a requirement under

the agency’s multiple use mandate as outlined in the Federal Land Policy and Management Act

of 1976 (FLPMA). Indeed, public land grazing is a privilege and not a right, and the BLM is

mandated by law to protect wild horses and burros.

Grazing on public lands is a privilege, and not a right See 43 U.S.C. § 315b & 16 (1943 Taylor

Grazing Act, stating that grazing preferences "shall not create any right, title, interest, or estate

in or to the lands" belonging to the U.S. Government); 43 U.S.C. § 580l (FLPMA similar

provision); Omaechevarria v. Idaho, 246 U.S. 343, 352 (1918) ("Congress has not conferred

upon citizens the right to graze stock upon the public lands. The government has merely

suffered the lands to be so used"); U.S. v. Fuller, 409 U.S. 488, 494 (1973) (grazing permittee

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January 9, 2021 – page 7

does not acquire a property interest in grazing permit); Swim v. Bergland, 696 F.2d 712, 719

(9th Cir. 1983) ("license to graze on public lands has always been a revocable privilege");

Osborne v. United States, 145 F.2d 892, 896 (9th Cir. 1944) ("it has always been the intention

and policy of the government to regard the use of its public lands for stock grazing. . . as a

privilege which is withdrawable at any time for any use by the sovereign without the payment of

compensation"); Diamond Bar Cattle Co. v. U.S.A., 168 F.3d 1209, 1217 (10th Cir. 1998)

(permittees "do not now hold and have never held a vested private property right to graze cattle

on federal public lands"); Alves v. U.S., 133 F.3d 1454 (Fed. Cir. 1998) (holding that neither

grazing permit nor preference is a compensable property interest).

Based solely on FLPMA, wild horses should be allocated 50% of the more than 11,760 AUMS

allocated to livestock and wild horses in Desatoya which would result in a wild horse population

of 490 horses. In fact, that wild horse number should be higher than the 50% based on the Act

which requires the HMA be devoted “principally” to wild horses.

The EA fails to analyze these issues and the Proposed Action is not in conformance with

existing statues and laws.

V. Taylor Grazing Act (TGA)

The TGA provides the government broad discretion to decide whether to allow livestock owners

to use public lands. The issuance of a grazing permit does not confer any entitlement or right to

use the public lands; rather, it is a privilege that can be taken away, if necessary, to protect the

health of the range and/or to protect the wild horses. See 43 U.S.C. § 315b (BLM, is

“authorized” to issue permits for the grazing of livestock on public lands “upon the payment . .

.of reasonable fees”); id. (“the creation of a grazing district or the issuance of a [grazing] permit.

. . shall not create any right, title, interest, or estate in or to” these public lands. Id. (emphasis

added). Indeed, the TGA also provides that the Secretary “is authorized, in his discretion, to . . .

classify any lands within a grazing district, which are . . . more valuable or suitable for any other

use,” 43 U.S.C. § 315f, including use by wild horses that are required to be protected under the

WHMA (Wild Horse Act). See 16 U.S.C. § 1333(a); see also 43 C.F.R. § 4710.5(a).

While the BLM claims 88 wild horses must be removed for TNEB, the BLM reports that the

agency is allowing the current “actual use” of livestock to exceed more than the annual

equivalent of 550 cow/calf pairs to graze in the same area. If these public lands can

accommodate hundreds of cows, there is no sound or legal basis for the removal of 88 wild

horses from this HMA.

VI. 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 Secretary of the Interior is instructed by the Act to consult with the NAS. The BLMcommissioned

2013 NAS report “Using Science to Improve the BLM Wild Horse and Burro

Program: A Way Forward” (NAS Report) (Attachment 1) clearly states:

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“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. 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 notes:

“Livestock grazing occurs on 160 million acres of land (65% of BLM land) with a

maximum of 12.5 million AUMs of grazing authorized and 8.6 million AUMs used. By

contrast, wild horses exist on 26.9 million acres of BLM land and are authorized

318,060 AUMs and are estimated to have used 447,689 AUMs. Put another way, of

forage allocated on BLM land to wild horses and livestock, wild horses account

for just 5% of consumption, while livestock account for 95%.”

The 1984 National Academy of Sciences report on the BLM’s wild horse and burro program

stated2:

“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

“Biologically, the area may be able to support 500 cattle and 500 horses and may be

carrying them. But if the weight of public opinion calls for 1,000 horses, the area can

be said in this context to have an excess of 500 cattle. For these reasons, the term

excess has both biological and social components. In the above example, biological

excess constitutes any number of animals, regardless of which class above 1,000.

Social excess depends on management policies, legal issues, and prevailing public

preference...” p1193

“[BLM] Personnel attitudes must also be accounted for in the decision-making

process. We have, in the process of our inquiries, encountered a broad range of

attitudes toward the wild horse and burro management program among BLM

employees. We are not, however, confident that attitudes are evenly distributed

throughout the Bureau. Indeed, we have met many employees who are sincerely

committed to wild horse and burro management in the spirit of the 1971 Act. But our

2 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

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experience also suggests that the Bureau must be sensitive to considerable pockets

of resistance to the program within its own ranks and to the pressures which many

district and area personnel feel to depict range, population, and other conditions in

an antihorse and antiburro context.” p1220

The EA fails to consider the interests of those who cherish the opportunity to observe,

photograph, and otherwise enjoy wild horses and their natural behaviors … 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.

VII. Preserving and Protecting Natural 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 methods that alter an animal's

ability to produce natural hormones; and

• any fertility control (e.g. IUDs, Gonacon) that alters the production of natural hormones

which are generated through natural estrus cycles and related physiological functions.

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.

Wild behavior is directly related to managing wild horses because without natural wild

behaviors the BLM would be managing “free-roaming” horses which could include unbroke

domestic horses that would have altered natural behaviors due to the surgery. The BLM

contention that, “BLM is not required to manage populations of wild horses in a manner that

ensures that any given individual maintains its social standing within any given harem or band”

is in direct violation of the WFRHBA and Congress’ intent to preserve and protect America’s

wild horses.

A. Castration/Gelding – Discussed in EA, but Not Included in Proposed Action

The NAS stated that maintaining natural behaviors in free-ranging horses is in the public interest

and that BLM should be more responsive to public sentiment.

“Individual males vary in their behavioral response to castration—for example, in the loss

of male-type behavior, such as aggression and sexual interest, depending on the age

and sexual experience of the male. However, some or total loss of sex drive would be

likely in castrated stallions, and this is counter to the often-stated public interest in

maintaining natural behaviors in free-ranging horses.” p123

“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.” p142

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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:

“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.”

BLM has claimed that castration does not alter the natural behaviors of stallions. This is patently

false, as explained by renowned biologist Dr, Kirkpatrick above. Further, BLM refutes its own

claim by citing “anecdotal” information regarding returning castrated stallions to the range

stating, “Once released, anecdotal information indicates geldings would be expected to form

bachelor bands.” A true stallion has the biological imperative to claim mares and reproduce. If

geldings are expected to only “form bachelor bands,” this is an enormous departure from the

natural social behavior of a wild stallion. Thus, BLM contradicts itself.

Deciding which males will become permanent bachelors and not contribute to the gene pool of

the herd is indeed altering natural behaviors. To draw a parallel, while a human male may

choose to stay single and/or not have children, this is very different from forcibly castrating him.

A castrated human male, like a gelding, loses all sexual hormone production, which intrinsically

and definitively changes his biology and his behavior for the rest of his life.

Castration is performed in domestic settings largely to alter the horse’s natural behaviors and to

make him more docile and manageable – to make him a lifelong bachelor without stallion

behaviors. Gelding destroys natural stallion drives -- not just breeding behaviors but other

ritualistic social behaviors as well. These behaviors are essential for the social hierarchy of the

herd and each family band to remain intact. Most stallions do not naturally remain in bachelor

bands for life.

Bruce Nock, Ph.D., at Washington University School of Medicine and an expert in the

physiological effects of stress, states that gelding may compromise a horse’s ability to survive in

the rugged and extreme natural environment:

“Gelding (removing a horse’s testes) will have irreversible effects on both the individual

horse and the herd. A gelded horse does not behave as a “wild” or “free-roaming” horse.

. . It decreases muscle mass and strength, reduces bone density, and increases frailty.

These deficits put the horse at a significant disadvantage on the range in terms of

survival. A gelding will still have to compete with intact stallions for resources. His

smaller size and strength, however, will not only put him at a competitive disadvantage,

it increases the likelihood that agonistic encounters with intact stallions will result in

severe injuries.”

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“The compromised physical capacities that accompany gelding are likely to endanger

castrated horses in a number of ways. In addition to undermining their ability to compete

with intact stallions, it may diminish their ability to traverse the harsh terrain and great

distances normally travelled to acquire food and water. This would jeopardize their

survival particularly during challenging weather conditions, like droughts or heavy snow

storms. A limited geographical home range is also likely to deplete local resources and

negatively impact the ecological system as a whole. To survive in the wild, a horse must

be able to achieve a certain fitness level that may be impossible to attain once the

animal is castrated. In my professional opinion, releasing a castrated horse into a wild

herd is an inhumane management approach that certainly does not ‘protect’ or ‘help

preserve’ wild horses in any sense of the word.”

Experts state and data shows that releasing a castrated wild stallion to the range would

change natural behaviors that are imperative to his status as a wild horse. (Attachments 2,

3) BLM’s stated interest to release geldings to the range is to reduce reproduction rates, yet

BLM has also stated releasing geldings to the range would have only a “minor” impact on

reproduction rates because “a single intact stallion can breed a large number of mares.”

Again, BLM contradicts its own information which shows that gelding stallions is an utter

waste of tax-payer funds, resulting in little to no impact on population growth rates.

(Attachment 3)

B. IUDs – Included in Proposed Action

The BLM states, “Up through the present time (May 2020), BLM has not used IUDs to control

fertility as a wild horse and burro fertility control method on the range.” (Draft

Environmental Assessment DOI-BLM-UT-W020-2018-015-EA, p 10) In fact, BLM has not

conducted sufficient research to determine which type of IUD to utilize or how IUDs will be

tolerated by wild mares who are not available for monitoring or medical care. There is no data

that supports monitoring a mare for 24 hours after insertion of an IUD is sufficient. There is no

data available on the best type of IUD to be utilized in wild mares or if IUDs in wild mares create

complications, discomfort, short- or long-term health issues, etc. Therefore, an Environmental

Impact Statement (EIS) is necessary before implementing the administration of IUDs in wild

mares living on the range.

The BLM’s EA (DOI-BLM-NV-S030-2020-0003-EA) states, “…O-ring IUDs, the IUDs fell out at

unacceptably high rates over time scales of less than 2 months (Baldrighi et al. 2017).

Subsequently, the USGS / OSU researchers tested a Y-shaped IUD to determine retention

rates and assess effects on uterine health; retention rates were greater than 75% for an 18-

month period...” The current EA does not provide sufficient data or documentation that IUDs

have long-term safety in wild mares (this is due to the lack of available science supporting the

usage of IUDs in wild mares).

IUDs are known to fall out of mares and may cause complications which would never be

detected, given that wild horses are free-roaming and cannot be regularly monitored.

Before subjecting free-roaming mares to the potentially painful and dangerous condition of a

partially-ejected IUD – the complications of which could be serious – an EIS is required. This is

precisely the type of situation that calls for an EIS to ensure the safety and efficacy of

implementing this precedent-setting government action.

Desatoya Roundup EA, The Cloud Foundation comments

January 9, 2021 – page 12

“For IUD-treated mares, 80% (12/15) were infertile after Year 1, but only 29% (4/14) and 14%

(2/14) were infertile after Years 2 and 3, respectively. For IUD mares that were infertile, it

was possible to visualize the IUD by ultrasonography, leading us to conclude that mares that

became pregnant had lost their IUDs.” (Attachment 4)

More recent studies which only tracked horses for a shorter time period report, “The study

resulted in a 75% retention rate” for the Y design IUD conducted by Oklahoma State

University.” (Attachment 53) Questions regarding negative impacts to wild horses resulting from

IUDs (including but not limited to scar tissue, physical damage, infertility, etc.) remain

unanswered and further study is needed prior to implementation in situ. However, pen trails are

not sufficient because they (a) did not follow the mares for living in “pasture” settings with

multiple stallions for an extended period of time – a minimum of three to five years is minimal

given the BLM has not plan to remove the IUDs from free-roaming mares who are subjected to

this experiment.

The BLM has failed to conduct in situ trials with horses that are known by either BLM or BLM

volunteers. This is necessary so that the horses can be monitored in the wild over a period of

years to determine the short- and long-term deleterious psychological and physiological effects

of this new and relatively untested surgical sterilization. IUDs are not commonly used in

domestic mares who have their movement confined and are regularly administered medical

care and provided feed and water.

Subjecting mares who are living in harsh environments – with no access to medical care – to

this experimental surgical sterilization is inhumane and irresponsible. At minimum, BLM must

conduct additional pen trials which must be followed by limited in situ trials. Trials of these IUDs

should be undertaken first in well-known free-roaming mares who are easily monitored for at

minimum five years. Such in situ trials must be conducted with sufficient protocols in order to

record behavioral, physiological effects before proceeding with implementation on mares

outside of a well-controlled in situ study.

IUDs (o-ring) cause “mild chronic endometritis” or inflammation of the inner lining of the uterus

(endometrium). (Attachment 6). Endometritis is an inflammation of the inner lining of the uterus

(endometrium). Symptoms may include fever, lower abdominal pain, and abnormal vaginal

bleeding or discharge and has been found to be related to infertility.4

Currently, there is insufficient scientific data available to support the use of IUDs in free-roaming

horses without the necessary scientific study with acceptable protocols. The EA fails to consider

the likely negative effects and short- and long-term implications for mares.

The National Research Council in 1980 noted that “..IUDs often dislodged and surgery was

impractical in field conditions…” (Attachment 1, page 93) This is supported by the studies on

IUDs in mares. “20 percent of the IUD-treated mares were pregnant” because “the pregnancies

of the IUD-treated mares were due to loss of the relatively small IUDs, not to failure of efficacy,

because no IUDs were found on ultrasound examination of the pregnant treated mares.”

3 Note the Dr. Holyoak who conducted the IUD research for USGS states, “The IUD, if administered to the original

mustang pools, will maintain their genetic line while a product like GonaCon EQ can be used to shut down the

reproductive cycle of abandoned feral horses.”

4 https://www.healthline.com/health/endometritis

Desatoya Roundup EA, The Cloud Foundation comments

January 9, 2021 – page 13

(Attachment 1, page 122) “Mares that had IUDs in place continued to exhibit estrous cycles with

the same frequency as control mares.” Ibid.

Further study is needed because further data is needed to determine whether different types of

IUDs suppress estrus (Attachment 7), which would in turn destroy natural hormone production

which are necessary for natural wild behaviors (as discussed in these comments).

The above are just a few examples of the medical issues that must be thoroughly analyzed in

an EIS which includes:

1. identify the specific type of IUD that would be utilized.

2. conduct adequate pen trials and then to conduct limited on-range trials with mares that

are known and easily monitored prior to implementation in wild, free-roaming mares who

cannot be monitored or administered follow up medical care.

3. determine the short- and long-term affects to mares.

4. determine whether the specific IUD model proposed for use would destroy estrus cycles.

5. determine how IUDs would be removed from mares and when removal would occur.

If IUDs are found to be safe, effective and preserve natural behaviors, they may be an

alternative to the humane, reversible PZP fertility control. However, removal of IUDs would

remain a challenge for horses in the wild and would need to be adequately analyzed in an EIS.

The Proposed Action fails to specify which type (marble, metal, soft, hard, etc.) of IUD would be

utilized – therefore meaningful comments on the specific IUD cannot be provided. An EIS is

required in order to more thoroughly evaluate this precedent-setting application.

To summarize, the BLM must conduct pen studies prior to implementing this on easy-to-monitor

free-roaming mares; such monitoring should continue for a number of years until the IUD is to

be removed. After the pen studies, in situ studies will be needed that adhere to a rigorous

protocol in order to extract usable data that addresses concerns expressed in these comments.

The EA fails to indicate how or when IUDs would be removed from wild mares. An EIS would

allow all these issues to be adequately analyzed and would provide the public with an

opportunity to provide more meaningful comments.

C. Gonacon and Other Drugs that Shutdown Natural Hormone Production, Included

in Proposed Action

Gonacon destroys natural wild horse behaviors and with repeated application permanently

sterilizes mares. Currently there is insufficient data to know the long-term impacts of Gonacon

on wild horses and how many injections of Gonacon permanently destroys ovaries. The USGS

researcher, Dr. Holyoak, highlights the difference of managing feral horses to wild horses who,

“The IUD, if administered to the original mustang pools, will maintain their genetic line while a

product like GonaCon EQ can be used to shut down the reproductive cycle of abandoned feral

horses.” (Attachment 5)

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

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January 9, 2021 – page 14

We now know that GonaCon literally shuts down a mare’s estrus cycle destroying the natural

production of hormones which are known to have behavior consequences.

Castration (gelding) and Gonacon shut down the natural production of hormones cause

changes to wild horses’ natural behaviors including:

• behavioral disruption of social structure and band integrity

• physiological disruption of hormones that play a vital role in 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 EA fails to address that the WFRHBA 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 with (not in

substitute for) the overarching intent of the WFRHBA: to protect wild horses. In addition, the

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.”

The same need to preserve behaviors necessary for maintenance of social organization, band

integrity and expression of natural behaviors applies to mares. Gonacon research in other

species highlight, “there are potentially large ecological effects—such as changes to natural

selection, effects on social structures and reproductive behavior, timing of mating and birthing

seasons, changes to longevity, and effects on migratory or movement patterns—that still need

to be examined in free-ranging populations prior to use as a management tool.” Yet the EA fails

to adequately analyze material scientific evidence on Gonacon and the issues raised above and

an EIS is required. (Attachments 8a-b)

It appears from the limited studies of the application of Gonacon to wild mares (Theodore

Roosevelt National Park) that social behaviors were defined as “herding, reproduction, agonism,

harem-tending, and harem-social behavior” and “harem-social (e.g., allogrooming, pair-bonding,

female-female urine marking), harem-tending (e.g. stallion defense of a band female or

recruitment of a new female into the band), herding (e.g., driving or snaking behavior by the

stallion), interaction-with-humans” (Attachment 9) These identified social behavior categories

are inadequate to determining the behavioral impacts that relate to inter-horse bonds, individual

bonds with the band, social status within the band, survivability behaviors necessary to thrive

during inclement weather, etc.

These studies did not identify lead mares, distinguish whether individual horse behaviors or

personalities were altered due to the treatment. Behavioral observation for studies conducted in

the Theodore Roosevelt National Park were conducted for three to four months (April-

July/August, 2009 and 2010) and five months (March-July, 2014). Roundups occurred in 2009

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January 9, 2021 – page 15

and 2013. If human studies on behavior changes were done with a similar behavioral protocol –

peoples suffering from mental illness may never be identified as long as they continued to

groom, interact with other people, had sex, slept, etc. Clearly behavioral changes which could

negatively impact a mare’s standing with the herd or her bonds with other members of the herd

would not be captured through this methodology.

Gonacon shuts down estrus cycle in mares and impacts various natural hormone production.

Gonadotropin-releasing hormone (GnRH) suppression, whether by agonist, antagonist or

vaccine has been based on the disruption of regulatory feedback between gonads and the

pituitary, which, in turn, disrupts reproductive function (Dawson et al. 2006). The hypothalamus

secretes GnRH, which, in turn, stimulates the release of the gonadotropin follicle stimulating

hormone (FSH) and luteinizing hormone (LH) from the anterior pituitary. FSH causes follicular

growth and elevated estrogen secretion from the ovary, and LH causes ovulation, luteinization

and elevated progesterone levels. Both estrogen and progesterone have far-reaching biological

actions not only for successful reproduction but also provide feedback upon behavioral

platforms in the brain, causing important reproductive behaviors to occur. In most mammals,

the pituitary gland secretes factors into the blood that act on the endocrine glands to either

increase or decrease hormone production. This is referred to as a feedback loop, and it involves

communication from the brain to the pituitary to an endocrine gland and back to the brain. This

system is very important for the activation and control of basic behavioral activities, such as sex;

emotion; responses to stress; and eating, drinking, and the regulation of body functions,

including growth, reproduction, energy use, and metabolism. [Society for Neuroscience,

Hormones: Communication between the Brain and the Body, 2012].

Commercial vaccines that have been tested in mares include Equity (CSL, West Ryde, NSW,

Australia), Improvac (Pfizer Animal Health, Sandton, South Africa), and GonaCon (USDA).

The inhibition of GnRH will cause an absence of FSH and failure of follicular development

(Checura et al. 2009), and ovulation failure. (Attachment 10)

Unfortunately, the Baker, DL (2018) study (Attachment 9) which BLM relies on heavily to

administer Gonacon in wild horses is not forthcoming with, at minimum, questionable safety

issues for treatment in pregnant mares. In one instance Baker, DL (2018) claims, “We found this

vaccine to be safe for pregnant females and neonates.” Yet, it is documented that Gonacon use

in pregnant mares the first trimester (which may extend further) may cause abortion. Baker, DL

(2018) also states, “inoculation with GonaCon-Equine vaccine, during approximately the second

trimester of pregnancy, does not affect the existing pregnancy of treated females or neonatal

health and survival” and “revaccination could be applied to pregnant mares, during midgestation,

without risk to the existing pregnancy.” However, the key is during mid-gestation,

supporting other data that Gonacon causes abortions if administered prior to “mid-gestation.”

Again, Baker (2018) can only summarize its data on neonate safety “when applied at

approximately mid-gestation.”

The reversibility of Gonacon, after multiple treatments, continues to remain highly uncertain

based on current data available. In fact, the Baker, DL (2018) study only claims that some

mares recovered to fertility after a single dose of Gonacon, “demonstrating reversibility of the

primary vaccine treatment.”

Based on Baker, DL (2018) data, mares treated with one application of Gonacon experienced a

30% reduction in foaling in the first year of results; 22% reduction in the second year and no

reduction in the third year. “Gonacon is one of the rare exceptions among animal vaccines in

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January 9, 2021 – page 16

that the formulation initiates high antibody titers that remain elevated in some individuals after a

single-injection; however, little research has been conducted to evaluate booster doses of this

vaccine in any free-ranging wild ungulate [17, 24] or domestic species.” The second treatment

in 2013 resulted in no foals for all treated mares, 4 foals for treated mares in 2016 and 1 foal for

treated mares in 2017. This highlights the high uncertainty of permanent or long-term

sterilization impacts and efficacy with more than one application and multiple use of Gonacon.

Clearly, additional years of observation are needed to ascertain what percentage of these

mares can return to fertility. The data to date remains incomplete with highly uncertain shortand

long-term effects.

The side effects of Gonacon on wild mares are equally uncertain; the Baker, DL (2018)

references two unpublished citations which were also authored by Dr. Baker, “Evaluation of

biological side effects has been reported for numerous wild ungulate species including whitetailed

deer [13, 34], elk [15, 16, 35], feral pigs [36], bison [21], and free-ranging horses [17, 24].”

Baker, DK (2018) claim that Gonacon “does not significantly change social behaviors [37]” relies

on Ransom, J (2014) which narrowly defined social behaviors as “associated with herding,

harem-tending, reproduction, and agonism from stallions toward females.” So Baker, DL (2018)

claims that, “A summary of results from these investigations indicate that GonaCon is reversible,

safe for use in pregnant females, does not significantly change social behaviors [37]” are highly

questionable because reversibility after more than one application has not been established,

safety during first trimester and possibly later has not been established and changes to social

behaviors have not been adequately studied due to the narrow identification of social behaviors.

Gonacon remains an experimental drug that should not be used outside a tightly controlled

study and as Baker (2018) states, “additional research is needed to complete the objectives of

this study including: 1) to define the duration of effective contraception postrevaccination, 2) to

determine if long-term or permanent infertility is a possible outcome, and 3) to assess if return to

fertility (if it occurs) results in altered birth phenology of treated mares.”

Other findings have revealed that Gonacon “altered reproductive behaviours that are integral to

the maintenance of the complex social structure of herd animals such as horses.” (Attachment

10)

D. Sex Ratio Skewing/Altering – Included in Proposed Action

The EA fails to provide any scientific information or data to support the artificial skewing of the

sex ratio. The Proposed Action is to skew sex ratios to 40/60 female/males. Wild horse natural

sex ratios favor females – the natural ratio is generally between 55/45 female/male ranging up

to 40/60 female/male. Creating unnatural sex ratios increases aggression among males and

causes stress and social disruption; it would create dangerous situations for females, who are

subject to repeated rape by stallions as a result of the lack of mares. Additionally, this increased

aggression between stallions and against mares puts foals at great risk of injury and death. This

ill-conceived management strategy has no basis in science and would have a devastating

impact on both individual horses and family bands.

The BLM Beatys Butte EA DR FONSI 2009 (Attachment 11) states:

"If selection criteria leave more studs than mares, band size would be expected to

decrease, competition for mares would be expected to increase, recruitment age for

reproduction among mares would be expected to decline, and size and number of

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January 9, 2021 – page 17

bachelor bands would be expected to increase..."

The BLM EA for the South Steens Wild Horse Gather (Attachment 12) states:

“Skewing the sex ratio of stallions v. mares would result in a destabilization of the

band (stallion, mare and foal) structure moving it from five to six animals to three

animals. 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.”

The BLM EA for Black Mountain and Hard Trigger HMA EA (Attachment 13) states:

“Band size would be expected to decrease, competition for mares would be expected to

increase, recruitment age for reproduction among mares would be expected to decline,

and size and number of bachelor bands would be expected to increase. Fighting

between band stallions and surplus stallions could result in the mares and foals not

being allowed to feed and water naturally as the herd stallion tries to keep them away

from bachelor bands.”

The BLM knows that sex ratio skewing does not significantly reduce population numbers

and that it destroys the important and complex structure of wild horse society – and puts

horses in danger by causing stallion aggression for limited mares. The Proposed Action fails

to address these important issues.

E. Ovariectomy – Included in EA, but Not Included in Proposed Action

The BLM has failed to adequately analyze the documented issues associated with the barbaric

ovariectomy via colpotomy as discussed herein. Castration and ovariectomy have not previously

been implemented as management strategies. These are highly controversial and, in the case

of ovariectomy via colpotomy, a risky, archaic procedure that is both unstudied and

inappropriate for wild animals.

The BLM cannot implement these fertility controls without an EIS because they would be

precedent-setting and likely be used for management in other HMAs. Therefore, an EIS is

required to thoroughly analyze the impacts of these proposed actions.

Both castration and ovariectomy and are primarily used on domestic horses to alter behaviors –

to make the animals more docile and conducive to training. This is done to kill the “wild” and

make the animals more tolerant of human dominance. Interfering in this way with wild horses or

burros is counter to the very spirit of the WFRHBA.

The Cloud Foundation has documented that mares – especially lead mares – play a critical role

in wild horse natural behaviors and social structure. Mare hormone production would be altered

through spaying or ovariectomy, or through the use of drugs such as Gonacon, which shutdown

a mare’s estrus and cycles. The resulting changes to their natural behaviors may only be known

on an individual basis.

Desatoya Roundup EA, The Cloud Foundation comments

January 9, 2021 – page 18

Altering a mare’s hormones through spaying or ovariectomy will result in the consequent

reduction in or complete loss of natural lead-mare-type behaviors necessary for maintenance of

social organization, band integrity, and expression of a natural behavior repertoire. In fact, the

impacts of sterilization on wild horses can be severe, affecting their physiology and ability to

survive, as well as their behavior, and can therefore impact the herd. A few excerpts follow here

regarding the importance of maintaining natural wild, free-roaming behaviors and the negative

impact that spaying would have on the individual behaviors, social behaviors, band structure,

etc. of wild horses.

We know that mammalian behaviors, especially social behaviors, are related to hormone

production. Therefore, it’s understandable that shutting down the production of certain

hormones would likely cause the loss of natural behaviors essential to “wild horses.”

Additionally, wild horses and burros living in extreme environments rely on their natural instincts

for survival -- destroying natural behaviors may actually put the lives of these animals at risk.

Dr. Jay Kirkpatrick, director of the Science and Conservation Center in Montana and

internationally-recognized expert on wildlife reproduction and biology summarized:

“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.”

“Wild horses typically live in reproductive bands consisting of adult mares, their

dependent offspring, and one or more stallions who lives revolve around trying to protect

mares from harassment by other stallions and securing exclusive reproductive access to

the mares for themselves; …Mares, meanwhile, simultaneously bond to one another and

compete with each other for access to water, food, and other resources for themselves

and their foals. Neither geldings nor spayed mares participate in these fundamental

processes of wild horse behavior.” – Allen T. Rutberg, Ph. D., Assistant Director, Center

for Animals and Public Policy, Tufts-Cummings School of Veterinary Medicine.

The NAS 2013 on ovariectomizing wild mares:

“Any of the methods [castration, ovariectomy and GnRH products] described may also

affect behavior. Because all methods affect sexual function in some way, changes

in expression of sexual and social behavior should be considered. The ideal

method would not eliminate sexual behavior or change social structure

substantially. Castration, ovariectomy, and the GnRH products (vaccines and

agonists) eliminate or substantially reduce steroid hormone production and so

have a potentially profound effect on the expression of sexual behavior. In contrast,

vasectomy and the PZP vaccines result in a prolonged breeding season, with increased

sexual interaction, because females continue to undergo estrous cycles but fail to

conceive.” p149

“Typical side effects associated with ovariectomy in many species include decreased

activity and weight gain.” p115

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January 9, 2021 – page 19

Years of conducting ovariectomies in domestic horses shows that behavioral change (referred

to as "improvement" for domestic mares because estral behaviors are deemed in the domestic

setting as undesirable) is seen in 83% of the mares who underwent surgery (Attachment 14a-h).

In addition to the behavioral changes, the reduction of estrus and alteration of hormones

undeniably has an impact on the physiology of any mammal. Any woman who has gone through

menopause knows this.

The BLM has not adequately analyzed available research that outlines the hormonal changes

and the implication those changes have on bone density, as well as the other physiological

implications these procedures would have on wild mares.

Ovariectomy causes menopause (which most horses do not naturally experience) and in turn

has a cascading impact to various body functions, processes and conditions – including bone

conditions and other deleterious physiological conditions that would likely jeopardize the longterm

welfare of animals who live under harsh environmental conditions. (Attachment 15).

Research shows that ovariectomy alters behaviors and personality; behaviors and personalities

drive the social dynamic of the individuals and social group. Ovariectomizing mares will

negatively impact the place of the individual in the social order of the band and herd -- and will

likely negatively impact the family band on the whole.

There are grave concerns about the physiological and psychological impacts that result from

ovariectomy and the related conditions and implications – both direct and indirect. There is

scientific literature that outlines the various deleterious effects of inducing premature

menopause (especially in a species that does not go into menopause). (Attachments. 16)

Prior to pursuing ovariectomies, Gonacon and/or any other fertility control treatment which

destroys natural hormone production on wild mares, the BLM must analyze the following

detrimental effects that would likely be caused from the sterilization method:

• Changes to the horse’s diestrus phase – the impact to hormone production or

organ/gland functions which directly and indirectly impact the horse’s physiology and

psychology.

• Changes to the horse’s estrous phase – the impacts to hormone production or

organ/gland functions and the direct and indirect resulting impacts to glands, organs,

tissues, production of hormones and all possible impacts to the horse’s physiology and

psychology.

• Changes to the horse’s production of progesterone – the impacts to hormone production

or organ/gland functions and the direct and indirect resulting impacts to glands, organs,

tissues, production of hormones and all possible impacts to the horse’s physiology and

psychology.

• Changes to the horse’s pituitary gland or the function of the pituitary gland and all

resulting impacts to hormone production – the direct and indirect resulting impacts to

glands, organs, tissues, production of hormones and all resulting impacts to the horse’s

physiology and psychology.

Desatoya Roundup EA, The Cloud Foundation comments

January 9, 2021 – page 20

• Changes to the horse’s production of estrogen – the impact to hormone production or

organ/gland functions, including all direct and indirect resulting impacts to glands,

organs, tissues, production of hormones and all possible impacts to the horse’s

physiology and psychology.

• Changes to the horse’s production of gonadal hormones – the impacts to hormone

production or organ/gland functions, including all direct and indirect resulting impacts to

glands, organs, tissues, production of hormones and all possible impacts to the horse’s

physiology and psychology.

• Changes to the horse’s serotonin pathways, catecholamine neurons and the basal

forebrain cholinergic system.

• Changes to ovarian steroids.

• Changes to cardiovascular health and immune function.

The BLM must base wild horse management decisions on science, not convenience. The

science clearly shows that removing ovaries has long-term, negative effects on a wild horse’s

physiology and psychology and in turn, on social behaviors. The EA fails to adequately analyze

existing data available on the deleterious effects of castration/ovariectomy and fails to provide

any supporting science or data to support the long-term implications of castration and

ovariectomy.

VIII. An EIS Is Required

The BLM cannot justify its failure to prepare an EIS on the highly controversial actions included

in the Proposed Action including plans to implement the still experimental implantation of IUDs

in wild mares. Implementation of IUDs in wild mares will have major negative impacts to “wild”

and “free-roaming” horses as intended by the WFRHBA. An EIS must be prepared for this

proposed action to fully examine all direct, indirect and cumulative impacts.

The actions opposed, as outlined in this letter should be rejected because the EA fails to

provide sufficient analysis of readily available alternative actions and is thus in violation of

governing laws and statutes

The BLM’s proposal to implement highly controversial IUD and Gonacon will “cause loss or

destruction of significant scientific, cultural, or historical resources,” 40 C.F.R. § 1508.27(b) –

i.e., the very “wild” and “free-roaming” horses that Congress has declared are “living symbols of

the historic and pioneer spirit of the West,” that are to be considered “an integral part of the

natural system of the public lands.”

Additionally, the BLM has received thousands of comments opposing various component of the

Proposed Action – including but not limited to comments against gelding, sex ratio skewing,

IUDs, Gonacon, etc. BLM has received similar public comments in response to various EAs,

scoping and public meetings.

NEPA requires agencies to prepare an EIS regarding all “major Federal actions significantly

affecting” the environment, 42 U.S.C. § 4332(C), and the CEQ implementing regulations set

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January 9, 2021 – page 21

forth a number of criteria governing when an action is to be considered “significant” for this

purpose. 40 C.F.R. § 1508.27.

There can be no legitimate doubt that, at the very least, there is certainly a “substantial

question” regarding many of the CEQ “significance” factors.

In light of the public’s opposition to these management approaches and particularly the experts’

consistent concerns about the dire environmental impacts it may have on the individual horses

and the herds as a whole, it is clear that the environmental effects of the BLM’s action have

been and remain “highly controversial.” 40 C.F.R. § 1508.27(b);

“Controversy” under this factor also includes “substantial questions are raised as to whether a

project . . . may cause significant degradation” of the environment. Anderson, 314 F.3d at

1018. There is tremendous scientific controversy regarding the use of dangerous sterilization

strategies. Releasing geldings is known to have greater negative impacts to the environment (as

cited herein); additionally, as previously stated there are negative impacts to the human

environment for many of the proposed actions.

Lastly, the concerns and issues raised in this letter are precisely the types of uncertainty about

environmental impacts that require preparation of an EIS. See Fund for Animals v. Norton, 281

F. Supp. 2d at 234 (“uncertainty as to the impact of a proposed action on a local population of a

species, even where all parties acknowledge that the action will have little or no effect on

broader populations, is a ‘basis for finding that there will be a significant impact’ and setting

aside as FONSI”), quoting Anderson, 314 F.3d at 1018-2.

Implementing, through a Decision Record, any of the opposed actions outlined in this letter

“may establish a precedent for future actions with significant effects,” [40 CFR 1508.27].

IX. EA Fails to Take a Hard Look at PZP Fertility Control Alternative

The EA fails to take a hard look at fully implementing (administer to a minimum of 85% of all

mares) a humane PZP fertility control program and reducing livestock grazing as an alternative

to the Proposed Action. The EA fails to consider implementing a humane PZP fertility control

program as an alternative. If wild horses need to be reduced in the HMA, humane PZP fertility

control should be used to accomplish this as recommended by the NAS (Attachment 1)

The BLM must be open to working with volunteer groups to determine whether bait trapping

may be effective to administer PZP. If not, the humane helicopter protocol (see Addendum) for

capture-treat-release should be followed to utilize helicopters to capture horses for fertility

control. TCF and other volunteer organizations would be happy to work with the BLM to

implement this humane management that prevents removals, and allows wild horses to live and

die wild as intended by the WFRHBA.

Despite claimed environmental concerns, it is important to note that the BLM continues

to permit livestock grazing in the Complex. Clearly, wild horses can – and do – thrive in

the Complex. The BLM has determined there is sufficient water and forage to continue

allowing livestock to graze throughout the HMA (as stated previously).

The EA fails to analyze alternatives that would avoid the need for the Proposed Action.

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January 9, 2021 – page 22

The EA must consider implementing a rigorous PZP program to humanely manage wild horses

in this Congressionally-designated wild horse habitat – after working through the LUP process

to increase the AML so that wild horses are treated as the principal user of the resource (or a

minimum in balance with livestock usage) which would be in conformance with existing statutes

and laws.

X. EA Lacks Scientific Data and Justification for Removal of “Excess” Horses

The EA fails to provide hard data that shows there is a need to remove “excess” horses that

cannot be fulfilled by reducing or eliminating livestock grazing. In fact, the EA states, “Removal

of excess horses would benefit the rangeland conditions and available forage, allowing

livestock grazing to be permitted by the reduced competition for vegetation and water

resources. …. Livestock grazing is expected to continue at similar stocking rates …”

The Proposed Action is not intended to improve the Thriving Natural Ecological Balance

(TNEB). The Proposed Action is to “reduce[d] competition for vegetation and water resources” –

or to remove wild horses, so livestock can have greater use of the resource. The BLM’s biases

towards and preference for livestock is evident in the AUMs allocated for livestock compared to

wild horses in this HMA. Livestock graze on 155 million acres of the 245 million acres managed

by the BLM. That’s 63% or nearly 2 of every 3 acres is used for livestock. Wild horses, on the

other hand, are relegated to just 26.9 million acres or just 11%. Even on this tiny portion of

BLM-managed public lands that are designated for their use – wild horses are allocated less

than 20% of the resource or AUMs.

The EA does not sufficiently justify the Proposed Action as the law does not require that wild

horses be removed merely because they are over the AML; rather, the agency must show that

the existence of the horses – as opposed to livestock or other factors – are causing harm to the

Thriving Natural Ecological Balance (TNEB) and the EA must take a hard look at other

alternative actions before implementing the Proposed Action.

Anecdotal examples of wild horse range usage are not sufficient to justify the Proposed Action

given the historic problem of livestock overgrazing. Despite the range conditions cited in the EA,

the BLM is maintaining the current permitted livestock grazing levels. On one hand the BLM

claims that removing horses is needed because the range is suffering due to horses and that if

the removal doesn’t take place the environment will suffer. Yet, on the other hand, BLM

continues the same number of livestock grazing and claims that does not have a negative

impact on the range and endangered species and, accordingly, BLM land health assessments

do not indicate a need to reduce livestock.

These inconsistent assessments indicate that further analysis is needed to justify the Proposed

Action and analysis is needed of the alternative to reduce or eliminate livestock grazing in order

to allow the current population of wild horses to remain in the HMA.

In addition, BLM is understating forage usage by livestock, as documented by Dr. John Carter,

range specialist and Utah Director for the Western Watersheds Project in the attached report:

"BLM is understating forage consumption by cow/calf pairs by a nominal 50% based on

the average body condition and frame scores. The implication of this on stocking rates is

obvious. Based on forage consumption alone, not considering proper utilization, forage capacity

and capability factors, BLM is over stocking allotments 33% based on failure to take into

account current cattle weights and calves." (Attachment 17)

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January 9, 2021 – page 23

Clearly the understatement of forage consumption and overstocking of allotments results in

extensive livestock damage to the range, further demonstrating that the BLM has no evidence to

that the damage is being caused by horses alone.

The EA fails to provide Rangeland Health Assessments or to indicate whether livestock

allotments are meeting Rangeland Health Standards for allotments in the Complex. The EA also

fails to indicate when the livestock allotment permits, within the Complex, were renewed.

Without reviewing and incorporating the data from the allotment rangeland health assessments

it is impossible for the BLM to make a determination of whether wild horses need to be removed

from these public lands. Livestock allotments overlap with the majority of the Complex. The EA:

• Is lacking in hard monitoring data, including data that support the claim that horses are

overpopulating the range and/or causing damage for the range. The EA is deficient of

monitoring data that clearly separates the impacts of livestock and wild horse use.

• Fails to consider the fact that horses utilize the environment, including stream riparian

areas, very differently from cattle.

• Fails to provide adequate information about water sources on the range, including how

fencing and engineering of wells and springs for livestock grazing has impacted water

availability for wild horses and other wildlife species, how fencing may or may not be

negatively impacting the ability of horses to access water throughout the HMA, and other

pertinent data necessary for managing range conditions for multiple use.

XI. Adaptive Management

The EA fails to consider utilizing Adaptive Management. BLM Adaptive Management document

states, “The RMP will be implemented using adaptive management processes. Under adaptive

management, decisions, plans and proposed activities are treated as working hypotheses

rather than final solutions to management of resources and uses. For the purposes of this

plan, adaptive management represents a process that tests, evaluates and adjusts the

assumptions, objectives, actions, and subsequent on-the ground results from the

implementation of RMP decisions..” (Attachment 18)

The Adaptive Management: U.S. DOI Technical Guide states, “…the use of adaptive

management in resource management almost always requires a fundamental shift from the

status quo…” and goes on to state, “adaptive management requires a much more open process

of decision making, in which stakeholders are directly engaged and decision making authority is

shared among them. It also requires that objectives, assumptions, and the other elements of the

decision making process be explicit, and therefore amenable to analysis and debate…”

(Attachment 19)

XII. “Allowable” Management Level

The AML set for Desatoya at just 127 to 180 wild horses was established more than 20 years

ago. The EA must disclose the data that is the basis for establishing this AML. These AMLs no

longer represent the use of the recourse that “will best meet the present and future needs of the

American people” and does not fulfill the BLM requirement (FLPMA) to ensure “balanced” use of

the resource.

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January 9, 2021 – page 24

The EA fails to adequately analyze the current AML in light of the fact that wild horses are (a)

thriving in the HMA, (b) livestock grazing continues in the HMA and (c) the Proposed Action is in

violation of existing laws and regulations that protect wild horses on these public lands. AML

must be in conformance with the 1971 Wild Free-Roaming Horses and Burros Act. The majority

of AUMs or forage allocation within the HMA must be “principally but not necessarily exclusively

to wild horses” as outlined in the 1971 Wild, Free-Roaming Horses and Burros Act (WFRHBA).

XIII. NEPA Requires Review and Analysis of CURRENT Conditions

The Proposed Action would continue through 2030 and the effects of those actions will continue

beyond 2030. This highlights the uncertainty of implementing the proposed new, unproven and

controversial actions over a 10-year period. Given the highly questionable short- and long-term

safety, efficacy and impacts that will likely result from the actions outlined in the EA, a 10-year

Decision Record is against the best interests of the public and puts the wild horses the agency

is required to protect at risk. By issuing a 10-year Decision Record, the public’s ability to take

legal action may be constrained. It is our right to oppose actions covered by the DR within the

10-year period as more information becomes available. Given that the Proposed Action includes

vague and expansive terminology to include and implement currently untested fertility control

methods, citizens would have no legal recourse to object to actions which may be taken in the

future that would not be disclosed to the public.

National Environmental Policy Act (NEPA) requires that agencies review current data and seek

public input and information regarding governmental actions. Indicating that this EA would

satisfy the NEPA requirement for future actions over the next 10 years is blatantly incorrect,

unethical and sidetracks Congress’ intent to include the public and ensure that agencies have

the best current information when making decisions.

Due to changing environmental conditions, a blanket, 10-year EA cannot be considered

sufficient under NEPA. The final EA must fully disclose, describe and analyze specific and

current range data, water availability, range usage (differentiating usage by livestock and

horses), and the agency’s intended actions, and allow the public ample opportunity to review the

data and comment on the proposed action, as required by NEPA. To reiterate, NEPA requires

that the BLM conduct further environmental analysis and public comment for future wild horse

roundups and management actions and cannot rely on an outdated,10-year-old EA.

XIV. Animal Welfare

The EA fails to adequately address the protection of wild horses during the proposed roundup.

The BLM’s “Comprehensive Animal Welfare Program (CAWP)” is woefully inadequate in

establishing humane standards for the treatment of wild horses and burros during a roundup. It

must go further in its protection of these animals.

If helicopters are to be used as a part of any management, the plan must consider, analyze and

implement humane standards as outlined in the below recommendations. These

recommendations are necessary to reduce potential stress and harm to the wild horses during a

roundup. The EA must consider the following information to minimize trauma and injury to wild

horses during a roundup:

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January 9, 2021 – page 25

a) Limit the distance wild horses may be chased by a helicopter to no more than five (5)

miles.

b) Require that the helicopter not chase/move wild horses at a pace that exceeds the

natural rate of movement of the slowest animal. This means that if an animal begins to

lag behind, the helicopter must lift pressure off the band so as to bring them in together.

Keep older, sick and young animals together with their companions, bands or mothers

as they are moved to the trap. The helicopter should not move or capture compromised,

old, weak or young animals.

c) Establish strict requirements for suspending helicopter roundup operations in

temperatures below 32 degrees F (freezing) or over 90 degrees F. Roundups outside of

this temperature range would be blatantly inhumane.

The EA must also consider and analyze the welfare standards attached in the Addendum.

The EA must consider and implement the following with regards to CAWP:

• Improved public observation of all agency actions. There is significant public interest in the

agency’s management of wild horses and burros and its management of these protected

animals. The NAS specifically recommended to the BLM to improve the transparency of its

management of the Wild Horse and Burro Program (Attachment 1). The treatment of the

wild horses and agency transparency are paramount.

• All removal operations must be located on public lands to allow public observation of all

activities. No government operations should be located on private lands for which the

owners will not give permission for public observation of activities.

• Real-time cameras with GPS should be installed on all aircraft and/or helicopters used in

operations and video should be live streamed on the Internet. This will improve the

transparency and accountability of roundup operations and enable the BLM and public to

monitor the direct impact motorized vehicle usage has on wild horses and the environment.

• Real-time cameras should be installed on any traps, corrals and temporary holding pens,

again, so that BLM personnel, public and media can monitor the entire roundup operation

and treatment of the horses.

The recommendation of real-time cameras is also supported by a report commissioned by

Cattoor Livestock Roundup, a long-time roundup contractor hired by the BLM which states:

“Video monitoring of animal operations is a good way to ensure humane handling is

taking place on a daily basis. Video cameras mounted in helicopters and in the

capture and holding pens can also render the activists’ videos as simply nothing more

than proof that your business ‘walks the walk’ when it comes to upholding animal

welfare standards.” The report was prepared by Mark J. Deesing, Animal Behavior &

Facilities Design consultant for Grandin Livestock Handling System. Deesing was an

assistant to the highly regarded livestock industry consultant Dr. Temple Grandin.

(Attachment 20)

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January 9, 2021 – page 26

Video cameras will improve the transparency of the operations and enable the BLM and public

to monitor the direct impact motorized vehicle usage has on wild horses and the environment.

TCF would be happy to provide technical assistance and financial assistance to establish these

real-time cameras as described above.

XV. Public Input

The NAS (Attachment 1) states:

“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 1982 National Research Council report on the BLM’s wild horse and burro program stated:

“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… [A]n otherwise satisfactory population level may be

controversial or unacceptable if the strategy for achieving it is not appropriately

responsive to public attitudes and values…”

According to the White House Council on Environmental Quality (CEQ), under National

Environmental Policy Act (NEPA), “agencies are required to determine if their proposed actions

have significant environmental effects and to consider the environmental and related social and

economic effects of their proposed actions.”

The BLM has succeeded in doing one thing over the years: PROVED that this roundup-andstockpile

policy is an economic FAILURE. There is no doubt that rounding up wild horses and

burros is a FAILURE economically, a FAILURE from a social or societal perspective, a

FAILURE from a humane perspective and a FAILURE from a management perspective.

As stated by the NAS, NRC and CEQ the BLM must consider the prevailing public preference

which, in this case, is to humanely manage wild horses and burros on the range using PZP, a

method of fertility control that has been successfully and safely used for decades. BLM must

also develop year-round water sources to accommodate the wild horses on the range, just as is

regularly done for privately-owned livestock on public lands. An amendment to the RMP

increasing AML for horses. Adaptive management could and should be used to postpone the

removal of horses until the RMP is amended.

XVI. Conclusion

As a result of the aforementioned deficiencies, the BLM should re-evaluate the alternative for

managing wild horses in the Pancake Complex. We urge the BLM to avert the need for this

unnecessary mass removal of wild horses from this HMA by:

• Re-evaluating and increasing wild horse AML by reassessing and amending plans under

BLM’s Adaptive Management Policy;

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January 9, 2021 – page 27

Dana Zarrello

• Decreasing or eliminating livestock grazing in affected HMAs pursuant to 43 C.F.R.

4710.5(a); and

• Designating such areas to be managed principally for wild horse herds under 43 C.F.R.

4710.3-2.

The EA has failed to establish that:

• An overpopulation of wild horses exists and that removal is necessary.

• The AML is appropriate given the continued livestock grazing that continues in the

Complex.

• Alleged range damage is caused by wild horses as opposed to the livestock grazing in

the area and the history livestock damage caused in the Complex.

• There is an appropriate and fair distribution of resources between livestock, wild horses

and other wildlife species in this federally-designated HMA.

• The proposed action will not have harmful effects on individual wild horses, wild horse

herds or the environment;

• Recreational users of these public lands, specifically those who enjoy wild horse

photography and viewing, will not be negatively impacted by the Proposed Action.

In summary, it is time for the BLM to listen to the American people, stop pitting American

against American, and create win-win solutions so advocates and ranchers can work together.

We request that the important issues raised in this letter be given a hard look and the Proposed

Action is modified in the Final EA. The vast majority of Americans greatly cherish our iconic wild

horses. We urge the BLM to be responsive to the public’s call for a fair and equitable program

that protects natural behaviors and respects the wonderful, complex social structure of our wild

horses.

Thank you for your consideration,

Dana Zarrello

Executive Director

The Cloud Foundation

Attachments:

1. “Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward,”

National Academy of Sciences (2013)

2. Expert statements and data on castration/gelding (attachments 2a-b)

3. BLM statement on geldings and population control

4. Killian, et al

5. Blakeney, OSC-Holyoak IUD research (2020)

6. Daels, O-ring IUD article

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January 9, 2021 – page 28

7. New IUDs for suppressing estrus in mares

8. Gonacon articles (attachments 8a-b)

9. Baker (2018)

10. Hall (2017)

11. BLM Beatys Butte HMA EA and

12. BLM South Steens HMA EA

13. BLM Black Mountain and Hardtrigger HMA EA Ovariectomy/Castration abstracts

14. Ovariectomy articles (attachments 14a-i)

15. “Updating the Animal Unit Month,” Dr. John Carter, Western Watersheds Project

16. BLM document, Appendix N: Adaptive Management

17. Adaptive Management, the U.S. Dept of Interior Technical Guide

18. Temple Grandin letter dated 2012

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January 9, 2021 – page 29

ADDENDUM

Standards for Wild Horse Treat-and-Release Gathers

The following humane recommendations are made for the use of helicopters in wild horse

management. These recommendations should be utilized to conduct humane fertility control

through a comprehensive PZP treat-and-release program that would will maintain the integrity of

wild horse family bands in order to minimize trauma and disruption and facilitate successful

release of treated bands back to the range. Family bands and social groups shall refer to

bachelor bands as well as stallion-led harem bands.

A. Pre-capture Evaluation of Existing Conditions

1. If possible, in advance of the roundup, field observation (game camera, observation, etc.)

should be conducted and documented for identification of bands, individuals within bands and

locations of bands to be gathered. Individual health or lameness issues should be noted. If a

helicopter is to be utilized, documentation of the target horses should be made day(s) before the

roundup; documentation should include an assessment of the location, number of bands and

individuals in each band to be gathered, as well as color markers that distinguish individual

bands. Photographic document should be utilized.

2. This information should be used to plan capture operation and configuration of the trap and

holding pens.

B. Humane Standards for Helicopter Roundups

1. To keep horses in a band together, the rate of movement of the animals should not exceed

the natural rate of movement of the slowest animal in the band. Every effort should be made to

keep older, sick and young animals together with their bands as they are moved into the trap.

2. If a member of a band is separated during the roundup, the BLM manager should make an

assessment on a case-by-case basis as to whether that animal should be pursued by the

helicopter or rounded up. In the event the animal is captured, every effort should be made to

place and hold that animal with its original band members after the animal is brought into the

trap.

3. Solitary animals should not be pursued by a helicopter or rounded up.

4. Every effort should be made to bring individual bands into the trap separately. If this is not

possible, the number of bands brought into the trap per run should be kept at a minimum to

ensure the integrity of the social groups. Pens for each band should be available to prevent

stallions from fighting.

5. The number of bands captured per day should be planned according to the pre-capture

evaluation and should not exceed the capacity of the holding pens to maintain horses within

their family bands.

C. Construction of Traps and Holding Facilities

1. The temporary holding pens should be constructed at the trap site. Both trap pens and

holding pens should be constructed to accommodate the maintenance of intact family groups

and should be configured based on the number and size of bands identified during the preDesatoya

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January 9, 2021 – page 30

capture evaluation. Pens should be made as large as possible to reduce stress and tension

among the animals.

2. A number of holding pens should be constructed away from other pens and can be separated

by alleyways in order to provide adequate space to reduce tensions between bachelor and

harem bands.

3. Pens with shared paneling should have snow-fencing or a similar visual barrier on the shared

paneling to minimize stallion interaction.

4. Bands, including bachelor bands, should housed individually. No mixing of social groups

should occur.

5. The on-site holding pens should be equipped with stationery or mobile chutes and other

necessary equipment to allow for processing and application of fertility drugs at the trap

location.

6. In the event that holding pens are constructed at a separate location from the trap site, family

bands members should be identified and documented and should be kept together at all times

during the holding period.

D. Holding and Release of Wild Horses

1. Horses should be held in intact family bands, including bachelor bands.

2. Every effort should be made to treat and release horses in the shortest time possible, after

the horses have been given time to rest and recover from the roundup, with the goal of treating

and releasing horses within 24 hours of capture.

3. Bands should be released at the same trap location where they were captured.

4. Bands should be released individually, with sufficient time between band releases to allow the

safe dispersal of horses back to the range.

# # #

Dana Zarrello