TCF Comments Pryor EA 2023
April 28, 2023
Mr. Nathaniel Arave
Field Office Manager
BLM Billings Field Office
5001 Southgate Drive
Billings, MT 59101
Submitted online: https://eplanning.blm.gov/eplanning-ui/project/1502632/570
Dear Mr. Arave,
The Cloud Foundation (TCF), is a 501(c)(3) nonprofit organization committed to protecting and preserving America’s wild horses and burros on our public lands through education and advocacy. On behalf of TCF and our nearly 500,000 supporters, I respectfully submit these comments on the Bureau of Land Management’s (BLM) “Pryor Mountain Wild Horse Range (PMWHR) Joint Herd Management Area Plan (JHMAP) Revision Wild Horse Gather Plan And Proposed RMP Plan Amendment (MD WH-7)” DOI-BLM-MT-C010-2020-004-EA.
The proposed RMP Amendment WD WH-7, Pryor Mountain Joint Herd Management Area Plan (JHMAP), and the “re-evaluat[ation] [of] the appropriate management level (AML)” fail to adequately analyze important issues, reasonable alternatives, or consider the prevailing public sentiment. In addition, the proposed RMP Amendment would be contrary to the ruling by the U.S. District Court for the District of Montana in Kathrens v. Zinke, 323 F. Supp. 3d 1142 (D. Mont. 2018). As proposed, the RMP Amendment would also violate the National Environmental Policy Act (NEPA) and its implementing regulations.
I, along with TCF’s board, staff, and supporters, enjoy and appreciate the wild horses currently living in the Pryor Mountain Wild Horse Range. We appreciate wild horses specifically for their natural behaviors – their social bonds, herd dynamics, and individual personalities. Some of us have observed, monitored, reported on, and enjoyed Pryor wild horses for more than 30 years. Therefore, we oppose the proposed RMP Amendment, proposed new HMAP, and the proposed re-evaluated AML; these actions will continue the very real and serious threat to the genetic health of the Pryor herd and risk the long-held continued preservation of the unique Spanish Colonial traits for which the herd is widely known and celebrated.
HIGH-LEVEL OVERVIEW OF TCF’s CONCERNS
BLM must prepare an EIS: TCF urges BLM to prepare an Environmental Impact Statement (EIS) rather than an Environmental Assessment (EA) for the above-outlined Proposed Actions because they constitute a significant amendment to the 2015 RMP and 2009 Herd Management Area Plan (HMAP), by proposing to fundamentally alter the management of this highly popular wild horse herd, its genetic diversity, and its ability to maintain a “self-sustaining population of healthy animals” with sufficient representation of various bloodlines and genetics for which BLM has specifically managed and preserved in the past. At a minimum, if BLM refuses to prepare an EIS, it must explain why this action does not rise to the level of “significance” under NEPA, including through application of long-standing factors for determining significance such as whether the action will be highly controversial or affect unique characteristics of the geographic area or its resource (i.e., the wild horses of the Pryor Mountains).
BLM must allow public comment on any Draft EIS or EA: BLM’s Federal Register notice and Supplemental Information notice regarding the proposed RMP Amendment do not specify whether BLM will allow public comment on a draft NEPA analysis. Whether or not BLM prepares an EIS (which TCF maintains is legally warranted here), TCF urges BLM to solicit public comment for a reasonable period (at least 45 days) on any draft NEPA analysis so that TCF and other stakeholders with relevant subject matter expertise have sufficient time to meaningfully participate in the NEPA process.
BLM may not limit the scope of the RMP Amendment: BLM appears unwilling to consider any important factors related to wild horse management as part of this proposed RMP Amendment, except for the narrow issue of how to define management decision WH-7’s instruction to preserve “all representations in the herd” when removing excess wild horses from this area. But such a limited scope would be arbitrary and unlawful; there are various factors and considerations that are particularly relevant to ensuring the genetic diversity of the Pryor Mountains wild horses in conformance with the 2009 HMAP and 2015 RMP.
For example, BLM must reconsider the Appropriate Management Level (AML) that is necessary to ensure sufficient and functioning long-term genetic diversity in this population.
In addition, BLM should consider and refuse to allow the skewing of the natural sex ratios of wild horses because there is a serious lack of scientific data to demonstrate that sex skewing plays any beneficial role in suppressing population growth in the long term (despite causing major social disruption to the herd through increased stallion aggression that places mares and foals at heightened risk of injury and death). In TCF’s view, the Pryor wild horse herd is unique with bloodlines that are both desirable and important from a genetic perspective, which would be best facilitated with a higher AML that allows for genetic diversity.
TCF was forced previously to litigate BLM’s failure to properly manage this herd’s genetic diversity. (Attachments 1 – 4) In that case, a federal judge issued three key findings, holding that: (1) BLM violated the Wild Horse Act by failing to adequately consider how best to ensure the continuation of unique bloodlines and colors, especially in light of the high foal mortality rate in the Pryor Mountains; (2) BLM violated the Wild Horse Act and the 2009 HMAP by failing to consider its duty stated expressly in the 2009 HMAP to “prevent bloodlines from being eliminated”; and (3) BLM violated the Wild Horse Act and NEPA by failing to properly recalculate the AML to determine whether a higher AML is necessary to ensure a minimum level of genetic diversity in the Pryor Mountain wild horse herd. See Kathrens, 323 F. Supp. 3d at 1150-53. TCF has serious concerns that BLM’s proposed RMP Amendment—which intends to eliminate various bloodlines (including patrilineal bloodlines) without even considering whether to increase the AML to support more sustainable long-term genetic diversity—will violate the Wild Horse Act and NEPA in essentially the same ways that the federal court held BLM’s prior decision contravened those laws. TCF provides the following more detailed discussion to add important context to this high-level summary of our gravest concerns with the proposed RMP Amendment.
I. BACKGROUND
The proposed amendment to the RMP threatens the future of this unique herd. The current RMP language is in conformance with all applicable laws and regulations. For the reasons outlined below, the BLM has always managed the Pryor herd based on science. Yet the EA proposes to end this science-based management and suggests that the Proposed Amendment is to, “Amend the 2015 Billings Field Office RMP Management Decision (MD) WH-7 to be consistent with Federal laws, regulations and policy related to management of genetic diversity in wild horse populations.” However, the EA fails to cite the laws or regulations that require this change. The EA fails to adequately justify or analyze the Proposed Action for the Pryor Mountain Wild Horse Range. Under the Proposed Amendment, the BLM would:
Manage for heterozygosity rather than kinship. The BLM proposes to manage this herd, with its irreplaceable Spanish Colonial genetics, as a “metapopulation.” A metapopulation, in ecology, is a regional group of connected populations of a species. Clearly, the Pryor herd is not geographically or otherwise naturally connected to any other population of wild horses. To treat this herd as a metapopulation would be a grave error and would eventually result in the loss of precisely what makes the Pryor mustangs who they are.
Artificially skew the sex ratio (40%-60% female-male) compared to the naturally occurring 55-45 female-male sex ratio. Sex skewing increases stallion aggression and elevates their risk of injury and death. It also puts the well-being and lives of mares and foals, who can be caught up in these violent conflicts, at risk.
Introduce horses from outside HMAs. Adding horses from outside the herd would dilute the herd’s unique genetics and phenotypic traits which do not exist elsewhere and must be preserved.
Continue to manage the herd at a dangerously low AML of 108 to 121 horses. Based on genetic variation and standard scientific understanding, the low AML should be a minimum of 150 horses.
Opens the door to using fertility control that destroys reproductive organs (e.g., Gonacon, OGF) and is not reversible after as few as 1-3 applications.
The RMP Amendment states:
“…it is evident that the intent of MD WH-7 was to limit the loss of genetic diversity, consistent with Goal WH-2 (“Maintain a wild horse herd that exhibits a diverse age structure, genetic diversity, and any characteristics unique to the Pryor horses.”). However, maximizing genetic diversity at the expense of ecosystem sustainability was not a goal or directive for the herd.” (emphasis added)
The intent of MD WH-7 is clearly to preserve the unique Pryor characteristics -- the primitive phenotypic traits of this specific population of horses -- which is not ipso facto guaranteed by limiting “the loss of genetic diversity.” It was always intended, and formally
memorialized in BLM’s own management documents, that this herd be managed for characteristics unique to this herd. The public and devoted followers of this herd strenuously object to the loss of any of these unique characteristics which have survived for hundreds of years in this isolated and protected herd.
A well-regarded equine geneticist, Dr. E. Gus Cothran (whom BLM often contracts
with to study wild horse genetics), has stated that "[The Pryor Horses] are one of the most significant, if not the most significant, wild horse herds in the United States," Billings Gazette, “Noted geneticist gives his two bits on significance of Pryor Mountain mustangs…” (Attachment 5).
If the sustainability of the ecosystem is threatened, it is only threatened due to negligence and dereliction of duty on the part of the BLM. The agency has failed to carry out the range improvements and maintenance it prescribed for itself in the RMP. BLM has also failed to continue the successful PZP program that has existed in the Pryors since 2001. Thus, any lack of ecosystem sustainability is a direct result of BLM actions – or rather, BLM’s failure to act.
II. POPULATION MANAGEMENT
The Cloud Foundation supports the use of PZP and PZP-22 fertility control as a method to manage wild horse populations when needed. TCF acknowledges that barring a big die-off, a reduction in herd numbers may be necessary. Removals of more than 15 to 20 horses should be done incrementally because there are numerous older horses who may not survive the winter, reducing the population naturally. Incremental removals minimize disruption to the herd and ensure placement of horses into good homes. Only horses 5 years and younger should be removed for humane reasons and to increase adoption success. The population should never go below 150 adults.
This reduction could have been avoided had the BLM accepted the many requests by certified PZP darters to dart mares to prevent pregnancies. BLM managers even turned down the offers of the Science and Conservation Center staff who trained many of us on how to safely administer PZP, an effective and reversible infertility vaccine. The rejection of qualified darters and expert spotters who know every horse on the range and their haunts has resulted in a spike in foaling rates. This dismissal of free help to reduce the number of foals born is completely baffling and has resulted in a rise in foal births from an average of 5-10 a year to over 20.
The Cloud Foundation supports the use of fertility control as a method to more sustainably manage wild horse populations when applied responsibly and ethically. The BLM's EA proposes the use of Porcine Zona Pellucida (PZP) immunocontraceptive vaccines to control the Pryor Mountain wild horse population. However, we believe that PZP-22, a longer-lasting formulation of PZP, offers significant advantages over the single-year PZP vaccine currently proposed.
PZP-22 can provide contraception for up to two years, which reduces the need for frequent handling and darting of wild horses. This minimizes stress on the animals and the potential for injuries associated with close human contact. Additionally, the longer-lasting contraceptive effect of PZP-22 allows for more gradual population growth, which is important for maintaining genetic diversity and the overall health of the herd. WE DO NOT RECOMMEND the use of PZP-22 on young mares who have not contributed to the gene pool.
THE EA MUST ADEQUATELY ANALYZE FERTILITY CONTROL ALTERNATIVES AND PRIORITIZE PROTECTION OF NATURAL BEHAVIORS
Given that the Billings Field Office has opened the door to fertility control methods for mares that "do not respond to PZP," it is important that the EA fully analyze the resulting negative impacts. The NAS determined "preserving natural behaviors is an important criterion" for wild horse management. Therefore, the following should be precluded from management actions:
ovariectomy sterilization alters the animal's ability to produce natural hormones; and
any fertility control (e.g., Gonacon) that alters the production of natural hormones.
In 1971, Congress unanimously passed the Wild, Free-Roaming Horses and Burros Act. It was not called the "American Horses and Burros Act" for a reason. The word "Wild" has a specific legal meaning, especially when it comes to wild horses. Wild behaviors - meaning the natural behaviors that are not changed by anthropogenic means - are the basis for the rich and complex natural social structure of wild horses.
GONACON
The EA must adequately analyze the effects of Gonacon which effectively destroys the ovary and/or ovary function after just two applications. The EA must disclose the most current
research the BLM has paid for relating to Gonacon. Dr. Baker has delivered to BLM his most
recent data that shows 10 years after receiving two injections of Gonacon 75% of mares
remained sterilized – there is no data to show that the majority of mares will return to fertility
after just two injections of Gonacon.
Behavioral endocrinology is the scientific study of the interaction between hormones and
behavior. Biologically speaking, hormones change cellular function and affect behaviors.
Hormones achieve this by affecting individuals' sensory systems, central integrators, and/or
peripheral effectors. Hormones are chemical messengers released that influence the nervous
system to regulate the physiology and behavior of individuals. (Attachment 6) The natural “wild”
behaviors of wild horses are largely dependent on the natural production of hormones.
Just as ovariectomy removes the ovaries, thereby destroying natural hormone production
(Attachment 7), Gonacon acts as a “chemical” ovariectomy because it has a similar effect
through the reduced functionality or destruction of the ovaries and/or the function of the ovaries.
Gonacon is specifically designed to shut down and destroy the ovaries, which in turn destroys
natural hormone production necessary for the natural “wild” behaviors. Gonacon is designed to
permanently sterilize mares with as few as two applications; the EA must disclose scientific data
that shows whether horses return to fertility after 2 or more applications of Gonacon. The EA
must disclose the complete data the BLM has received from Dr. Baker on his most recent
Gonacon study. The EA must provide and analyze whether there is sufficient data that
demonstrate Gonacon’s short- and long-term efficacy, safety, and ability to preserve natural wild
and social behaviors which are valued attributes of wild horses.
Additionally, the EA must specify if more than one injection of Gonacon is proposed and
the EA must acknowledge that more than two injections of Gonacon are done with the
intent to permanently sterilize the mares.
The USGS researcher, Dr. Holyoak, highlights the effect of Gonacon and its potential use,
noting a significant difference in responsibility between managing feral horses and managing
wild horses. “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 8) This makes clear the permanent sterilization impacts
intended by the use of Gonacon.
The NAS stated in its 2013 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
Again, data shows that Gonacon is designed to literally destroy the ovaries via injection of the
substance thereby shutting down a mare’s estrus cycle and destroying the natural production of
hormones which are known to have behavioral consequences.
Much like castration to males, Gonacon shuts down the natural production of hormones causing
significant 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 must address an important factor—i.e., that the WFRHBA requires BLM to manage wild horses and burros
in a manner that protects their wild and free-roaming behavior. For the above reasons, TCF does not support the use of Gonacon.
A. Volunteer Darting Program
When the BLM implemented a PZP fertility control program consistently, sufficiently, and at the right time of year it was effective in maintaining low-to-zero population growth. This successful PZP program was virtually abandoned from 2017 until the present. As demonstrated by the BLM data foal rates have risen dramatically in the past 5 years.
· 2017 – 9 foals
· 2018 – 12 foals
· 2019 – 16 foals
· 2020 – 17 foals
· 2021 – 21 foals
· 2022 – 22 foals
In 2017, 63 mares were darted (this included 10 mares who were administered both a primer and booster). None of those darted mares foaled in 2018. We understand that it is time-consuming to implement PZP correctly. Finding the mares who need to be darted, darting them before they are impregnated, and getting a good shot all take time and patience. Partnering with dedicated wild horse advocates like those at TCF, who know the individual animals and where their bands are typically found, would greatly improve the success and efficacy of the program. We again offer our assistance and implore BLM to accept help with on-range management activities such as fertility control.
B. Natural Population Management – Predators
There is no mention of mountain lions in the EA. For years, the Pryor herd was managed by mountain lions, which killed all the foals but one in the mid-2000s. The only foal to survive lived near the gate to the horse range on the paved highway where there were numerous tourists and residents passing through. Unfortunately, hunters were called in from Idaho who killed a mother mountain lion atop the mountain. Her kittens of the year perished, no doubt from starvation. Foal births gradually rose after the killing of the lioness.
The loss of foals by natural predation is tough for some people to accept, but it is the best, most natural method of herd management. The female mountain lion would have taught her offspring that wild horses are prey. Since her death, we are unaware of any predation by mountain lions.
Hunting of mountain lions should not be allowed in the horse range as they are a potential natural management tool. We suggest that BLM meet with Montana Fish, Game and Parks, and Wyoming Fish and Game to discuss the elimination of mountain lion permits for the PMWHR. Nature can work if given a chance. The PMWHR is prime mountain lion habitat.
Our recommendations include:
· Utilize PZP or PZP-22 (on mature horses only) as the primary fertility control method for the Pryor Mountain wild horses, in conjunction with a comprehensive population management plan.
· Partner with an NGO that is focused on protecting wild horses and burros to expand the PZP darting program.
· Collaborate with wildlife biologists, veterinarians, and other experts to develop protocols for the safe and effective administration of PZP or PZP-22, with an emphasis on minimizing stress and disruption to wild horses.
· Monitor the long-term effects of PZP or PZP-22 on the health and behavior of the Pryor Mountain wild horses and adjust management strategies as needed to ensure the well-being of the herd and the maintenance of natural wild behaviors which is a valuable trait to visitors and Americans who enjoy wild horses.
· Include protection of predators as a part of a Thriving Natural Ecological Balance and establish a cooperative agreement with the state wildlife management agency to ensure predators in and around the Pryor Mountain Wild Horse Range are protected from hunting. At minimum, the BLM must consider an alternative that incorporates protection
· of predators into the alternative design.
III. PROTECT AND PRESERVE HERD’S GENETICS & PHENOTYPIC TRAITS
The Wild Free-Roaming Horses and Burros Act states that the DOI may “designate and maintain specific ranges on public lands as sanctuaries” for wild horses and the BLM is required to manage the Pryor Mountain Wild Horse Range “for their [wild horses] protection and preservation.” The BLM is required to protect wild horses in several ways including, but not limited to, preventing them from inbreeding, which is not a natural behavior of wild horses, and it is unhealthy. The BLM’s duty to preserve this herd includes ensuring that management actions prevent harm and promote the well-being of the individual horses and herd at large. Clearly, keeping an isolated population of wild horses to a population below 150 to 200 animals will cause individual animals to inbreed and will risk the entire genetic health of the herd in the long term. Indeed, BLM-sponsored genetic reports on the herd highlight the declining genetic health of the population. Dr. Gus Cothran refers to “severe population contractions” that result in increased inbreeding. This threatens the genetic health of the herd because of the “severe population contractions” which occur during BLM status quo roundup practices resulting in a large percentage of the population being removed. This causes the remaining, smaller population on the range to be put at risk of inbreeding if the population is not kept at a minimum of 150 to 200 animals; inbreeding reduces the genetic health of the herd.
From Dr. Cothran’s 2013 “Genetic Analysis Pryor Mountain Wild Horse Range, MT”
Genetic Variation: Both observed heterozygosity and expected heterozygosity in the Pryor Mountain Wild Horse Range herd is above the feral mean. He is slightly higher than Ho which could indicate the very beginning of evidence of inbreeding. However, the difference at this point is not statistically significant.
Genetic variability of this herd in general is on the high side but compared to past
sampling of this herd, variability levels for all measures has been in decline. This is likely due to the population size that has been maintained in recent years. Overall, the herd is showing evidence of Spanish heritage that is stronger than seen recently, although the known mixed ancestry is still apparent. This is possibly due to the efforts to remove horses derived from introductions.
Current variability levels are high enough that no immediate action is needed. However, there has been a general trend for a decline in variations levels of the herd. If the trend continues the variability levels of the herd could drop below the feral average within the next five to ten years. The best way to maintain current levels would be to increase population size if range conditions allow.
BLM, in the EA, includes events that took place nearly 40 years ago when it was believed the PMWHR was not a genetically diverse herd and needed the infusion of new blood to boost diversity. Horses from the Kiger herd and a stallion from an undisclosed herd in Wyoming were released onto the range. Three years later, the results of genetic testing by E. Gus Cothran revealed that the herd had an acceptable level of genetic diversity. Most of the outside horses were removed, including the Rock who had been hand-picked by BLM, presumably because of his excellent conformation and their belief that the Pryor mustangs were inbred.
BLM has asserted that the Pryor Wild Horse herd has been genetically degraded by mares brought from the Kiger Range in Oregon and specifically a stallion from southern Wyoming (we do not know which herd). The description of whom this stallion fathered is completely inaccurate and speaks to the real “stretch” made here to diminish the Spanish and Native American roots of the herd which runs deep according to Crow historians.
On page 48 Section 3.2.2, the EA states; “a palomino was produced from the Rock and Phoenix.” This is incorrect. The father of Cloud (who was a pale palomino) was Raven, the black stallion son of a sorrel stallion who was the “greeter” at the Bighorn Canyon gate of the horse range for many years. All horses that had been introduced from Oregon and Wyoming were removed shortly after Dr. Gus Cothran’s genetics report revealed a herd with adequate genetics and Spanish markers. Though the Rock and Isabella could have produced Phoenix – a palomino – the color combinations present before the Rock was introduced in the Pryors (as listed in the Ron Hall report) were also capable of producing the palomino coloring. (Coat Color Calculator (animalgenetics.us))
Managing for genetic health is a tightrope walk in a small, isolated herd like the PMWHR. Dr. Cothran has consistently indicated that the population needs to be 150 at a minimum but should be larger if the range will support a larger number. The only effective way to secure a safe future for the horses is to keep the herd at a 150-animal minimum. We would suggest a serious look be given to range expansion onto BLM lands on Demi-John Flat.
It is well documented that a minimum of 150 to 200 animals (the minimum needed for genetic viability) is recommended by the BLM Wild Horse and Burro Handbook and renowned equine geneticist Dr. Gus Cothran:
4.4.6.3 Herd Size
A minimum population size of 50 effective breeding animals (i.e., a total population size of about 150-200 animals) is currently recommended to maintain an acceptable level of genetic diversity within reproducing WH&B populations (Cothran, 2009). This number is required to keep the rate of loss of genetic variation at 1 percent per generation. Animal interchange between adjacent HMAs with smaller population sizes may reduce the need for maintaining populations of this size within each individual HMA.
The Pryor Wild Horse Herd has a “unique genetic makeup,” according to the Forest Service’s Draft Pryor Mountain Wild Horse Territory Report, 2016. (Attachment 9) It is a Spanish Colonial herd that traces its origins back to the conquistadors. Because the herd is isolated, there is no genetic interchange with outside horses.
The herd that exists today represents the entire genetic repository of these hardy mustangs. They are survivors, uniquely adapted to the rugged Pryor wilderness, and they were here prior to the first European settlers in the area. By all standards, this herd is an important historic and cultural resource for the local community and for the nation as a whole.
A. Native American History of the Pryor Wild Horse Herd
In 1994, Ginger Kathrens began conducting interviews with Crow leaders and historians, including Joseph Medicine Crow, a River Crow, and Elias Goes Ahead, a Mountain Crow. Elias was the history teacher at the Pryor High School and a tribal historian. His interview was filmed at the Chief Plenty Coups Museum in Pryor, MT in 2018 by our Cloud Foundation intern. The in-depth interview was part of her college history class requirements. Kathryn edited the interviews and shots on the PMWHR into a film on the history of the Pryor Wild Horse Herd.
Elias indicated that some herds on the reservation were not gentled and had characteristics of their original horses. Have you been to the Pryor MT Museum to learn about their history with horses and the area? I would think this might bring home the historic significance of the herd and its enduring relationship with the Crow Tribe.
Crow tribal historians have asserted that they selected them as smooth, riding horses, and they also acknowledged that they left the wild herd alone to roam the mountains, only picking out a few at a time to allow the wild horse to live in freedom. The Crow tribe possessed more horses than most of the Western tribes.
Elias went on to say that “at the Dry Head Overlook, we do always see ponies there, roaming around those alpine meadows.” With the closure of the horse range to this Forest Service Area, no visitors will be able to see the horses as they are fenced out of this traditional Pryor Mustang area.
To deny the history of the wild horses in the Pryor Mountains is to deny the long and rich history of the Crow tribe.
B. Riding a Pryor Mustang
Adopters of Pryor mustangs can attest to the differences between these Spanish-style horses and other breeds. Jaime Wade adopted Boomer, the son of the Pryor mustang, Boomer, and Pryor mare, Coppertop. Boomer was a young Pryor stallion, removed from the range in 2005 and offered for adoption in Canon City, CO. He was adopted by Jaime Wade who was a horse trainer and riding instructor /trainer at the U.S. Air Force Academy. She gentled Boomer and invited us to film her riding him at the Academy training area. We have footage of Boomer flying around the arena with Jaime sitting the trot!
Boomer was not the only Pryor horse to give their adopters a smooth ride. In 1997, Ann Evans adopted the mares Smokey and Mahogany. They are the daughters of Raven and the mares, Isabella and Grumpy Grulla. They are the birth sisters of Cloud, the palomino we followed throughout his life on the PMWHR.
Ann Evans rode Mahogany for over 1,000 miles of endurance in Florida, Georgia, Colorado, New Mexico, South Dakota, Wyoming, and Montana. Mahogany’s single-footed Indian gait allowed her to sit this very fast trot while other riders were using lots of energy posting the whole way. According to Crow historians, this incredibly smooth gait was selected by Native Americans who had yet to possess saddles. I rode Smokey, also Cloud’s birth sister, several times in Florida and in Wyoming in limited-distance events. She was very smooth and shifted into a single-footed gait when she was tired. It was amazingly comfortable to sit this gait.
Their brother, Cloud, also possessed this smooth gait (also known as an Indian Shuffle or single-footed gait). He could fly across the high meadows at a trot with his back barely moving up and down. There is photographic evidence of this. He was not alone in possessing this fast, energy-efficient gait. Many Pryor horses inherited the single-footed gait including Raven, the father of Smokey, Mahogany, and Cloud.
Raven could race at full speed with his back hardly moving up and down at all. He is featured in the film Year of the Mustang for Wild America on PBS. He is also in the Cloud series.
C. Size and Weight of Pryor Mustangs
Those of us who have competed in endurance on our adopted Pryor Mustangs have a very good handle on both their size and weight. Smokey was in the 875-pound range and Mahogany was in the 925-pound range. They are the birth sisters of the stallion Cloud and were removed as two-year-olds in 1997.
Pryor Mustangs are generally no taller than 14.1-14.3 hands. There are several exceptions on the range which are the horses that grew up in the Forest Service lands where the soils are deeper and so the forage is generally more abundant and taller. TCF adopted whole bands of mustangs in the 2009 Roundup, and they are in the range of the horses mentioned above. But those born in captivity are larger and weigh more. Our Pryor Mustangs born in captivity are 14.3 to 15 hands and can weigh closer to 1,000 lbs.
Some of the horses that were born and raised in the now “off limits to horses” area of the Forest Service lands are the tallest horses on the PMWHR. Those are the stallions Hernando and Grijalla. They look to be several inches taller than their counterparts.
Elsewhere, in the non-Spanish wild horse herds, the horses are larger and heavier than the Pryor Mustangs. The Kiger horses in Oregon are smaller as they have some Spanish genetics.
Both Ann Evans and Ginger Kathrens have competed in endurance with horses that dwarf our Pryor Mustangs. The Arabian horse is the most popular for long-distance racing and they tend to be not only fast but, in some cases, closer to 15.2 to 16 hands.
So, in calculating forage offtake (and extrapolating those figures to recalculate the AML), consider the size of the Spanish mustangs of the Pryor Mountains. They eat less than the larger horses that are found in many of the wild horse herds. This needs to be taken into account, of course. Therefore, the AUM for a Pryor horse should not be calculated at 1.25, but remain at 1 AUM as is stated in the Wild Horses and Burros Management Handbook. Any other result would
be arbitrary, capricious, or otherwise not in accordance with law.
D. Lumbar Vertebrae
The first time I visited the PMWHR was in March of 1994. Reverend Floyd Schweiger who was instrumental in saving the herd when the BLM intended to round them all up, gave us a history lesson. BLM had intended to get rid of the horses. Schweiger and others like Hope Ryden uncovered a giant wooden trap erected on the lower part of the range. The BLM had denied any plan to remove the herd, but the giant wings of a wooden trap revealed the deception and the Secretary of the Interior, Stewart Udall, quickly created the Pryor Mountain Wild Horse Range before the roundup began. This whole Wild West tale is detailed in Hope Ryden’s carefully crafted book, America’s Last Wild Horses. The citizens of Lovell played a key role in coming to the aid of the horses and one of their ring leaders was driving my sister and me down the paved road in the Park Service section of the Pryor Mountain Wild Horse Range.
We stopped to admire several horses foraging on meager grasses. He pointed out the low tail settings, rafter hips, and stripes on a dun mare. I had never seen horses that looked like this.
As we reached the end of the range he pulled over. “I want to show you something,” he said and we climbed out of the car and into the bushes. Not 20 feet from the road was a horse skeleton. All the meat had been stripped off the bones and the spine lay before me. “Look” he pointed to the spine. “Here,” he put his hands on the spine and counted the lumbar vertebrae. He stopped at five and explained the significance of the fifth vertebrae that was fused to the sixth. “Spanish horses usually have five vertebrae or a fifth fused to the sixth.” I put my hands on the spine and counted. I had never seen the spine of a horse, let alone one with Spanish history.
Rev. Schweiger was a historian and immersed himself in the history of the herd he had followed far before there was a Pryor Mustang Range. I never forgot this moment and to this day if I find an intact horse skeleton on the range, I will count the vertebrae.
The photo here is of Cloud’s mother, Phoenix. Note the fifth lumbar vertebrae is fused to the sixth - characteristic of Spanish-type horses. The Pryor Mustang Center has Phoenix’s spine for all to see.
Phoenix’s daughter – also demonstrates the lumbar fusion trait.
Our recommendations include:
· Continue the management of the herd specifically to preserve Spanish Colonial traits.
· Manage the herd for kinship to prevent inbreeding and ensure genetic health.
· Establish a minimum AML of 150 to 200 adult horses.
· Continue to manage for color diversity – an indicator of genetic diversity/variability.
IV. THE PROPOSED ACTION MUST ADDRESS BLM’S FAILURE TO CONDUCT RMP-PRESCRIBED RANGE IMPROVEMENTS
Rangeland health is often cited as a reason to remove wild horses. In 2018, the BLM’s
EA stated that utilization had been meeting goals in almost every area of the PMWHR. If the range is no longer meeting healthy rangeland criteria, the blame must fall on human negligence.
“Based upon monitoring data collected in 2015, 2016, and 2017 the use objective was being met in the Dryhead, parts of the lower elevation areas, and has continued to be met in the mid-elevation areas until recently… Some use patterns of the wild horses are shifting as more time is being spent in the mid-slope areas due to guzzlers.” Pg. 31, PMWHR Bait/Water Trapping Gather & Fertility Control Environmental Assessment
It is important to note that during these years (2015 - 2017) when the objective was being met, BLM was adequately and properly implementing the PZP fertility control program (2016 was the last year BLM sufficiently administered PZP)
A. Fire Danger
In the HMAP for the PMWHR from 2009, there were many methods of rangeland improvement suggested:
“Prescribed fire for the enhancement of forest health, wildlife, and wild horse habitat could occur primarily in the mapped area…”
Pg. 46, PMWHR HMAP 2009 (Attachment 10)
One of the biggest threats to the PMWHR in the higher elevation areas is the loss of the limber pine forests. Significant deadfall and dying trees endanger the entire Pryor ecosystem. The risk of catastrophic fire is real and a major threat to the survival of a species of concern, the beautiful Clarks Nutcrackers who harvest the pine nuts and cache them in order to survive the winter.
The EA does not address this issue although it remains a significant concern as does the amount of deadfall on both Burnt Timber and Sykes Ridges. Again, volunteers could augment professionals to make the range more productive and far less vulnerable to a catastrophic fire. Removal of deadfall will increase forage for the Pryor Herd as well. Again, volunteers could assist in your efforts to make the PMWHR a safer and more productive range for all the wildlife and the public as well.
We would argue that this is pertinent to this EA. Catastrophic fire is a threat to a whole array of species, including wild horses who rely on the cool limber pine forests. . . a forest that is disappearing.
B. Guzzlers
To our knowledge, BLM has not adequately considered or implemented the other range improvements as prescribed in the 2009 HMAP including the use of guzzlers to improve horse distribution. A real effort should begin as soon as is feasible to repair the skirt of the Skyline guzzler above the Kruger Valley. This is of concern as the horses rely on this water source far more than in years past. Other, repairs on the other guzzlers need to be made in a timely manner.
The stated reason for having operating guzzlers is to spread the use of the horses. Guzzlers are effective in doing this only if they function properly. We hope that BLM will listen to and respond quickly to the reports of guzzler problems. Numerous observations of guzzlers not working as intended are disheartening. BLM must take responsibility for the lack of leadership in this regard, and most importantly for NEPA purposes must disclose this fact and incorporate it into the agency’s analysis of impacts and alternatives.
Range overuse cannot be attributed solely to wild horses. The responsibility falls on the shoulders of BLM to keep vital water systems working as intended. Volunteers on the range have been reporting problems for years.
As you know, there are several water catchments on the range that do not function correctly and have not for more than 3 years, which we reported at the time of the 2020 Draft JMAP scoping comments. We also reported these issues in our scoping comments one year ago. BLM’s lack of action in making timely repairs results in horses spending increased time around guzzlers that are functioning properly.
1. The mid-Sykes guzzler requires someone to manually fill it. Visitors to the range have
tried to fill the tank which requires someone to turn the water on, wait 2-3 hours for it to fill, and then manually turn the water off. This guzzler needs to be repaired so that it works as it is intended -- without requiring a human to turn the water on and off.
2. The trough at Cottonwood Spring is not functioning. This malfunction has been reported to the Billings Field Office numerous times dating back to 2014. We recommend that BLM allow volunteers to take out all the old fencing and the tangle of makeshift, dangerous downed posts, wire, and heavy gauge wire panels. The goal should be to return the spring to a more natural state while also protecting the riparian area.
3. The first guzzler on Burnt Timber Road - The Mine Guzzler - has a problem. When the water level is low, horses must resort to kneeling in order to drink which is dangerous and may have led to the near-fatal injury of a bachelor stallion several years ago. This is a highly dangerous situation that could result in serious injury since this is not a natural behavior. We suggest an evaluation by professionals to make necessary changes to this guzzler. We have photographic proof that horses place themselves in jeopardy to get a drink of water. We can make this footage available if you would like to review it. Coordination by the Pryor Mustang Center has improved the reporting of problems. BLM needs to follow through in a timely manner with retrofitting and repairs.
4. The catchment on Cheyenne Flat - the Boundary Guzzler - was also not functional for more than three years. The boot was separated from the tarp, so there was consistently very little water in the main holding tank, even after all the snowmelt from winter. The water was draining into the ground before it had a chance to get to the main tank, evidenced by the water-saturated ground surrounding the area below the tarped portion of the guzzler.
This was finally repaired by volunteers but should be checked during regular monitoring of the guzzlers.
Repair of current water guzzlers is BLM’s responsibility and would allow for the desired dispersal of wild horses, better distributing their use of the range. Currently, with several guzzlers broken, use is concentrated around the few functioning guzzlers. Reconstruction and repair of malfunctioning guzzlers are consistent with Rangeland Health Objectives:
“Decrease utilization by wild horses within a 1-3 mile radius of existing water developments from heavy/severe to light/moderate.” (JMAP 2020)
5. Improving and repairing existing water guzzlers will help distribute wild horse use of the range, alleviating pressure on high-traffic areas. The concentration of use in these areas is due to disrepair and malfunction of certain guzzlers; thus, the horses are forced to congregate at the few working water sources. They should not suffer due to human negligence. Coordination by the Pryor Mustang Center has improved the reporting of problems. BLM needs to follow through in a timely manner with retrofitting and repairs. TCF would be happy to help with any or all of these important projects in any way we can.
C. Invasive Plants – Native Plants
Invasive plant species are, as indicated in the 2015 RMP, a problem on the horse range. A great friend of the Pryors, Jack Sterling, is certified to spray for the invasives and has expressed his willingness to lead a team of volunteers to spray in areas targeted by BLM. You have a popular herd that has a following. Use these interested and able people to help.
We realized that you may not have the authority in the Park Service section of the horse range but because it impacts the horse herd, we would mention the rise in the amount of cheatgrass in the Park Service section of the range. I remember a time when there was virtually no cheat grass there. That is not the case now. Park Service staff are trying to prevent the spread and improve the range by spraying along the roads but more effort should be made to deal with the valleys on Mustang Flat that are full of cheatgrass. The BLM must cooperate with the Park Service on this
issue, resulting in an MOA or MOU setting forth both agencies’ respective responsibilities in addressing cheatgrass.
In addition, the BLM has stated that aerial seeding with native species would be used to improve range conditions.
“Aerial seeding with native species appropriate to the PMWHR would be used to supplement seed source and attempt to improve ecological conditions.”
Pg. 42, PMWHR HMAP 2009
Aerial reseeding can be done anywhere on the range, including the mid ridges which can be done in the summer when there are few horses in these areas. Temporary fencing can be constructed for reseeding in non-WSA (Wilderness Study Areas) where practicable. The health of the range can be improved without risking the genetic health of this unique wild horse herd.
To our knowledge, reseeding hasn’t taken place per PMWHR HMAP 2009.
D. Off-Road Use
Damage to the range is not attributable solely to wild horses. The excessive and growing problem of off-road use by ATVs and UTVs has caused untold damage. Sykes Ridge Road has a new “road” toward the Hole in the Wall area. Volunteers would be willing to put up appropriate signage there and at numerous other points on the ridges leading to the top of the mountain. We appreciate the new signage atop the mountain, but more is needed.
It is discouraging and shameful that BLM employees are sometimes the people driving off-road. We have observed this in both winter and summer, and it sets a horrible example for those who see them breaking their own rules. One specific instance was glaring. BLM seasonal employees were seen driving from the Bat Guzzler on Sykes Ridge. This guzzler is a quarter mile or so off the road! Sadly, it is not the only instance of their abuse of the range. Clear directives to these employees are needed.
E. Range Damage Factors
BLM fails to consider that the ecological and climatic effects of widespread ruminant grazing have imposed ecological and climatic challenges within the PMWHR – both before the creation of the PMWHR and currently beyond the PMWHR. Many outside impacts, not the least of which is human-caused climate change, have impacted and continue to impact conditions on the horses’ only home range.
In the 1950s, thousands of privately owned sheep were allowed to graze the top of East Pryor Mountain, causing permanent damage. The hillside across the road from the big pond was terraced because the sheep had caused the whole hillside to erode. The terracing may still be seen – are still visible – today. The range at the top of the mountain has been permanently degraded as a result of that sheep grazing.
An attempt has been made by volunteers to remove old, barbed wire (still pervasive in the forests atop the mountain) left over from that time period. Much still remains and has caused injury for horses – particularly foals. To our knowledge, BLM has made no concerted effort to collect this downed fencing.
Our recommendations include for prescribed range improvements:
Conduct a thorough inventory of the currently available resources within the PMWHR and potential expansion areas and develop a plan for monitoring and managing these resources in the long term
· Pursue partnerships with non-profit organizations, academic institutions, and other stakeholders to leverage additional resources for wild horse management, research, and outreach.
· Explore opportunities for grant funding and public-private partnerships to support the implementation of range improvement projects, monitoring efforts, and other management activities.
V. BLM MUST CONSIDER REASONABLE ALTERNATIVES
A. Expand the Range to Accommodate a Minimum Population of 150 Wild Horses
Expanding the PMWHR has been discussed for decades. In a 1999 Letter to the Forest Service, BLM Billings Field Office Manager Sandra S. Brooks stated:
“Preliminary evidence suggests that the herd has been managed at dangerously minimum levels over the past 25 years and an increase in established appropriate management levels (AMLs) will need to be considered in order to preserve the genetic viability of the herd. Several options are available to help remedy this situation – one of which is the potential for range expansion, even on a seasonal or limited basis.”
Rather than risk the genetic health and eventual loss of the Pryor Herd, BLM should consider expanding the Pryor Mountain Wild Horse Range to include the 6,000-acre Demi-John Flat (referred to by Ron Hall as Demijohn Pasture in combination with Frail Lands land), which was recommended for inclusion in Ron Hall’s original range survey in the early 1970s, a report the BLM mentions in the RMP Amendment document. Mr. Hall stated that Demi-John Flat had clearly been used by wild horses and that it would serve as an excellent place for the public to view the horses. The Act mandates that wild horses must be managed “where presently found” (in 1971) and Mr. Hall verifies in his 1970’s report that they were indeed found on Demi-John Flat. BLM affirms the veracity of Mr. Hall’s report by quoting it in the proposed amendment documents and should be bound by the facts and the directive of the Act, to manage this herd where they historically lived in 1971, including Demi-John Flat. (Attachment 11)
Gail Tillett Good, a long-time resident whose family goes back generations in Lovell, Wyoming, also stated in a written declaration that the Pryor mustangs historically roamed all of East and West Pryor mountains, including vast tracks of land that are now restricted to them. She specifically mentions Demi-John Flat as a place she herself saw wild horses living during 1969-1972. (Attachment 12)
Clearly, the Pryor Herd was “presently found” by local observers in and around Demi-John Flat in 1971, as well as in other areas the BLM has made off-limits to the herd now. According to the Wild Horse Act, the BLM must expand the range to the “amount of land necessary to sustain…” the existing Pryor herd. This expansion would not exceed their “known territorial limits” as supported by testimonies of Ron Hall, whose report BLM cites in their own RMP, as well as other local residents very familiar with the Pryor herd. Failure to manage wild horses in these areas is arbitrary, capricious, and otherwise contrary to law.
Historically, the Demi-John Flat was used extensively by the Native people and their horses. Crow Elder Howard Bogess and former Montana BLM State Director Mike Penfold have both indicated their support for adding Demi-John Flat to the wild horse range, feeling it is long overdue and a very appropriate addition.
Additionally, the Sorenson Extension (Park Service area north of Sorenson Ranch) was used by the horses years ago and would be a great addition to the range again. This scenic area would give visitors an almost 100% chance of seeing wild horses when they visit the U.S. Park Service lands. Wild horses are the number one year-round reason that visitors come to Bighorn Canyon Park based on a Park survey conducted several years ago. Boating and fishing are number one in the summer, but the horses are the number one reason year-round!
B. Ron Hall Report and Range Expansion
Ron Hall, a BLM employee in the 1960s-1970s and a knowledgeable horseman, was brought into the Pryor’s in the summer of 1969 after Secretary Udall created the PMWHR. His job was to assess the herd and the area and to write a detailed report on his observations and his recommendations on the management of the horses which included an assessment of their habitats based on direct observations of horses and from tracks, trails, and horse droppings.
Ron’s recommendations were taken in some cases and not in others. One of the “others” is Demi-John (Pasture) Flat and the Frail Lands. He felt these lands would make an excellent area for the public to view the horses and that it could accommodate 33 HUs on the 7,657 acres.
Hall also indicated that the horses had been in the Forest Service lands near the Dryhead Overlook. This was substantiated by Crow Historian Elias Goes Ahead in an on-camera interview: “. . .at the Dry Head Overlook, we do always see ponies there, roaming around those alpine meadows.” Elias took his history class up there in his role as the history teacher at Pryor High School.
Neither of these recommendations was taken but still remain excellent ways to expand the range into highly productive lands with great viewing opportunities for the public. In order to comfortably support a genetically sustainable herd the range needs to expand into those areas as recommended in the Hall report.
Habitat Expansion –
Area 1 - Mystic Allotment – Acreage 2064 – 27 AUMs
Area 2 – Forest Service – Lost Water – Acreage 3948 – 40 AUMs
Area 3 – Park Service – North of Sorensen Ranch – Acreage 7040 – 35 AUMs
Area 4 – BLM – Crooked Creek Allotment – Acreage 3560 – 6 AUMs
Area 5 – BLM – Frail Lands and Demijohn Pasture – Acreage 7657 – 33 AUMs
Area 6 – NPS - Little Mountain Area
Area 7 – Additional Areas – Gyp Springs, Bluewash, the entire Custer National Forest
Land Trade Opportunities in Priority Listing
1. T. 9 S., R. 27 E., Sec. 36 – State Section.
2. T.9 S., R. 27 E., Sec. 25, SW1/4SE1/4 – Private.
3. T.8 S., R. 28 E., Sec. 16 – State Section.
4. T.8 S., R. 28 E., Sec. 8, W1/2, SW1/4NE1/4, W1/2SE1/4, SE1/4SE1/4.
5. T.9 S., R. 28 E., Sec. 16 – State Section.
Note: Any of the private lands that could be acquired from Tillett's private land at the SW corner of the horse range to Tillett's private land at Sykes Spring would be a desirable addition to the horse range. The private lands primarily enclose the southern boundary of the horse range. (* Some of the above areas have been added into the designated range)
The Ron Hall report from 1972 provides critical recommendations for the management of the PMWHR that are still relevant today. The report suggests expanding the range to include the Custer National Forest lands to the north and the Bighorn Canyon National Recreation Area to the east. These additional lands would provide essential forage, water, space, and cover for the Pryor Mountain wild horses, allowing for a healthier, more sustainable population.
Expanding the range would also help to address the issue of limited resources, a key concern in the BLM's EA. Providing wild horses with more land will reduce the pressure on available resources and lessen the need for costly and controversial management actions, such as roundups and long-term holding facilities.
We encourage BLM to work with the Bighorn Canyon National Recreation Area (BCNRA) to reopen the Sorenson Extension for wild horse use. The BCNRA reports that overall wild horse viewing is the number one activity in the BCNRA based on personal interviews with those coming into the visitor center. If the Sorenson Extension was available for wild horses, it is likely that there would be more reliable viewing at all times of the year, drawing even more visitors and increasing benefits to the local economy.
C. Implement Pasture Rotation to Protect Range Health Increase AML
The 2009 Herd Management Area Plan for the PMWHR (HMAP) states:
“During the long term (25 years), the number of wild horses in a herd area will be permitted to increase if monitoring shows that additional forage is available. Ultimately, the Pryor Mountain Wild Horse range (PMWHR) has the potential to support up to 179 wild horses yearlong. This assumes all areas now grazed by the wild horses will continue to be available. However, the projected long-term population increase in this action is considerably less than the potential level of 179 head since no rotational grazing systems will be in effect.”
With this in mind, we suggest that wild horse use be restricted in the upper elevations until early June (suggested to TCF by former BLM Wild Horse and Burro Specialist) so that those plant communities have an opportunity to grow before they are grazed. This can be accomplished by closing both Burnt Timber and Sykes Roads at the locations of the traps constructed in the mid-twentieth century to capture wild horses. These sites are in disrepair, but they can be improved. Volunteers can to help repair fencing and gates now so that horses cannot access the high country until June 2023. The gates would be closed in the winter long after all the horses have migrated to the lower elevations.
Also, this seasonal closure would prevent people on ATVs, SUVs, and trucks from accessing the top of the mountain and driving off-road. Damage to the top of the mountain has occurred in the winter months and particularly in the late fall and spring. The gates could be reopened at any time in the winter to accommodate changing conditions and situations.
Grazing rotation was mentioned for consideration in the 2004 NRCS Report:
“It could be designed to allow for vegetative recovery following grazing, and seasonality of grazing could be somewhat controlled. This would allow for the greatest range recovery for the benefit of the horses in the shortest period of time.”
The 2009 PMWHR HMAP states, “Under this action the initial stocking level will be 121 adult horses.”
Since then, the Administrative Pastures have been added to the PMWHR. They have an AML of 6-8 horses (see Appendix 2).
Our recommendations include:
· Reevaluate the Ron Hall report and consider its recommendations for range expansion.
· Collaborate with the U.S. Forest Service and the National Park Service to explore opportunities for cooperative management of the expanded range.
· Conduct a thorough inventory of the currently available resources within the PMWHR and potential expansion areas and develop a plan for monitoring and managing these resources in the long term.
· Based on expanded range and better management practices, increase AML to a minimum of 150 adult horses.
CONCLUSION
Over the years, BLM has received tens of thousands of public comments calling for the protection of the wild horses of the Pryor Mountains: expansion of the existing range to accommodate a larger herd, increasing AML, protection of natural social behaviors, prohibition of sex ratio skewing, and the preservation of the unique gene pool of the herd and individual bloodlines.
We understand the argument presented in the RMP Amendment notice that every mare cannot breed with every male to produce offspring of every possible parental combination. However, that is not what is being asked of BLM. BLM is responsible for the health and safety of this unique and isolated herd and must take action to preserve as many bloodlines as possible. We are asking for an increase in AML to accommodate a minimum of 150 horses, to ensure the unique and important gene pool and bloodlines are protected, in order to prevent the introduction of horses from other HMAs and prohibit the skewing of the sex ratio.
The proposed RMP Amendment and JHMAP fail to consider a reasonable range of alternatives as required by NEPA. BLM has failed to consider the permanent implications of this action. We urge BLM to abandon the Proposed Amendment and develop an amendment that more closely aligns with the decades-long intention, policy, and management practice for the Herd. Public opinion vastly supports the protection of this herd and its unique Spanish characteristics. We would again like to offer our assistance to BLM. If AML is raised to a safe minimum level of 150 adult horses, TCF will gladly assist with the implementation of a robust PZP darting program and volunteer to help with range improvements. We believe this is a great opportunity to work together for the good of the horses, other wildlife, and the range, and we hope you agree. Please let us know if you are interested in discussing this in more detail with us.
SUGGESTED ALTERNATIVE (We appreciate BLM’s willingness to consider additional alternatives for the benefit of the Pryor Wild Horses and the range. We suggest taking points from alternatives 3 and 4.
· The Pryor Wild Horse Herd will be managed matrilineally considering bloodlines and promoting color diversity.
· Adjust AML to a low AML of 150 horses.
· Removal of horses down to 150 will be done incrementally with between 15-20 horses removed in the first bait/water trap; subsequent removals to bring herd size down to 150 over the course of the 5–10-year management period. Removals of more than 15 to 20 horses should be done incrementally to account for winter losses and reduce stress to the herd.
· Horses removed will be chosen considering lineage and family representation on the range.
· No horses over the age of 5 are to be removed from the herd. Horses 5 and under are more readily adopted and adapt more successfully to domestic life. The older horses are often more traumatized by removals from family and home. They are generally more difficult to gentle. There are far fewer people equipped to handle the specialized training needed for an older wild horse.
· Removing horses in smaller groups will minimize disruption to the herd; and ensure the placement of horses into good homes.
· Older horses pass on vital survival skills to the young, their bands, and to the herd. They should not be removed from the range for this and other humane reasons.
· Re-implementing a comprehensive darting program in conjunction with natural attrition over the coming years will prevent overpopulation. Natural deaths should be close to births in numbers each year.
· Work with Park Service, Forest Service, and Private citizens to expand the range to better accommodate a viable herd size.
· Partner with trained volunteers and NGOs to assist in the management and regular maintenance of the Pryor herd and range.
Sincerely,
Ginger Kathrens
Founder & Board President
The Cloud Foundation
ginger.kathrens@thecloudfoundation.org
Kerry Ferguson
Executive Director
The Cloud Foundation
kerry@thecloudfoundation.org
Jesse M Daly
Opererations Manager
The Cloud Foundation
jesse-daly@thecloudfoundation
Attachments:
Attachment 1: TCF 2018 Comments
Attachment 2: 2018 Filed TRO
Attachment 3: 2018 Filed Motion
Attachment 4: 2018 Plaintiff’s Exhibit A, Ginger Kathrens Declaration
Attachment 5: Article: Billings Gazette, “Noted geneticist gives his two bits on significance of Pryor Mountain mustangs”
Attachment 6: Nelson, R.J., Hormones and Behavior: Basic Concepts, Ohio State University, 2010
Attachment 7: Hedberg Y, Dalin AM, et al. Effect of ACTH on steroid hormone levels in the mare. Part B: effect in ovariectomized mares. Anim Reprod Sci. 2007 Jul;100(1-2):92-106
Attachment 8: Blakeney, OSC-Holyoak IUD research (2020)
Attachment 9: Draft Pryor Mountain Wild Horse Territory Report, 2016
Attachment 10: PMWHR 2009 HMAP
Attachment 11: Ron Hall Report Excerpt, 1970s
Attachment 12: Gail Tillet Good Declaration