The Wild Horse Conspiracy

Pryor Mountain Wild Horse Capture and Gather Scoping due October 6th, 2017

September 27, 2017
James M. Sparks, Field Manager
BLM – Billings Field Office
5001 Southgate Drive
Billings, MT 59101
Re: Scoping Notice: Capture and Removal of Excess Wild Horses and Continued Fertility Control in the Pryor Mountain Wild Horse Range (PMWHR), Document # 4720 (MT010.JB) Public comments due in writing by Friday, October 6, 2017 by 4:30 PM Mountain time. Contact Jerrie Bertola at (406) 896-5223. Fax number is (406) 896-5298. To access document go to
Dear Mr. Sparks:
Thank you for sending me this Scoping Notice. I have been following, reading about, and observing the Pryor Mountain wild horse herd and habitat for many years and have made field observations in 2003, 2015, and again in 2016, all during the late spring period of May and June. In 2016, I did an Ecological Evaluation and Reserve Design proposal, which I sent to your office; and this report’s reception was acknowledged by your secretary. My accumulated knowledge and concern for these horses leads me to protest your current proposed Capture and Removal of 15 to 20 so-called “excess” wild horses for the following reasons:
1. BLM’s failure to acknowledge and respond to my ecological evaluation report and its recommendation concerning bringing the Pryor Mountain wild horse herd up to a more viable and ecologically integrated population level that would at the same time incorporate the sound principles of Reserve Design in order to allow for a more naturally self-stabilizing population.

2. Much to my sorrow, It has come to my attention that an elegant young mare (named Isadora by The Cloud Foundation) and whom I observed in June 2016 was recently found dead by an observer (see “The Life and Death of Isadora: A Pryor Mountain Mare” on ). Having observed this mare and certain behaviors of her band, I am concerned that she may have died because of the adverse effects of PZP darting. It has been observed that such extensive PZP treatments as the BLM is undertaking with the Pryor herd can and do lead to social disruption, excessive mountings of mares by stallions, particularly young stallions who would normally be reined in by the older stallions, as well as terrible frustration experienced by both mares and stallions, and the consequent frequent breakup of their bands (“patron” stallion-and-lead-mare-led social units). Observations of mares, particularly those of less stout physique, suffering from such excess mountings becoming internally damaged, stressed out, and even dying have been made in many areas where PZP is extensively used on a herd. I believe that Isadora could be one such victim.

3. The current population of 160 wild horses should not be considered excess in an area of 38,000 acres; and the current Appropriate Management Level (AML) of 90 to 120 wild horses is genetically substandard, or non-viable. Given substantial annual adult mortality of ca. several percent and much greater annual mortality rates of young, particularly newborn, during their first year (often 50%), as well as the deleterious complications caused to the herd by PZP administration, I urge BLM to revise its protection and management plan for the Pryor Mountain herd in order to assure its long-term viability. The Wild Horse and Burro Act stipulates “minimum feasible management” (Section 3 [a]) not what BLM is currently doing to the horses!

4. BLM should reassess the long-term effect that PZP administration on 70% or more of the Pryor Mountain mares is having on the immune systems of these wild horses. It has been proven that PZP is most effective on animals with strong immune systems and that consequently those females with weakened immune systems are precisely those who go on to produce more offspring. The inevitable consequence of this is that the herd’s overall immune system, resistance to disease and infection, and strength of constitution decline significantly, possibly after just a few generations. Hence PZP can lead to a seriously weakened herd that runs a serious risk of die-out. It takes much vigor for a population to survive in the wild; and it goes against the Wild Free-Roaming Horses & Burros Act to overly compromise this vigor. The Act’s true intent is to assure the wild horses’ natural health and survival vigor in the wild, and this entails having adequately substantial population levels to resist the vicissitudes of nature, e.g. disease, fire, drought, fierce, cold blizzards, etc. For this to occur, a herd needs substantial genetic variability among its diverse members. (See: Gray, M.E. and Cameron, E.Z. 2010. Does contraceptive treatment in wildlife result in side effects? A review of quantitative and anecdotal evidence. Reproduction: 139: 45-55. and also .)

5. As a wildlife ecologist and head of a NGO organization concerned with the survival of Perissodactyls including America’s wild horses, I highly urge you at BLM to do all within your power and authority to increase the AML of the Pryor Mountain wild horse herd, particularly by restoring its traditional summering meadows on Custer National Forest lands. It is egregious that Custer National Forest officials have refused to honor their responsibility toward these wild horses, for it has been irrefutably proven that they occupied these meadows in 1971 and, hence, are legally entitled to this vital portion of their year-round habitat. The increasing “squeeze plan” against the Pryor Mountain horses is even more outrageous given the fact that six out of seven of the legal wild horse Herd Areas (HAs) in the state of Montana have been “zeroed out”, i.e. BLM decided not to protect and manage for wild horses in these HAs at all! One would think that out of a sense of fairness, the BLM would demonstrate extra attentiveness to the Pryor Mountain mustangs and their individual and collective well-being on account of the foregoing gross denial of their legal rights in six of their seven legal areas. What the Custer National Forest has done has been the subject of lengthy legal protest, and BLM could have made the difference here for the wild horses had their officials honorably defended the horses’ legal rights to land, habitat, and freedom. Additionally, we should consider that the Pryor Mountain HA is a legally declared Wild Horse Range that dates from 1968 in its creation, a few years before the passage of the WFHBA in 1971.

6. BLM officials should recognize and stress the positive contributions that wild horses make to many ecosystems. Their contributions include the building of healthy soils through their feces that supply valuable humus and also the dispersal of a great variety of plant species via their seeds that are often capable of germination and given a fertile ground in which to do so in the process. Also, horses act as a much-needed counter-balance to all the ruminant herbivores that modern American society overly promotes, including both domestic and game, cloven-hoofed herbivores. Wild horses (as well as wild burros) also play an increasingly crucial role as catastrophic wildfire preventers, or mitigating agents, since they munch down profuse vegetation, either earlier in the year when it is greener or later in the year when it is drier and coarser, and create rich, moisture-retaining soils in the process. Thus, they prevent the buildup of what firefighters call “fuel load” that can lead to catastrophic fires spreading over 100,000s or even millions of acres and setting soils, watersheds, wildlife communities, human infrastructures, etc., way back. This fire-prevention role of the wild horses makes them extremely valuable in this present day and age of Global Climate Change/Warming. And it has been seriously proposed that we increase the wild horse and burro herds and disseminate them to many regions in America for precisely this reason (see .

7. Again, I offer my assistance, both as a wildlife ecologist and as a human being who appreciates and is closely identified with the wild horses in the wild. I offer this in good faith to help you at BLM to fulfill your honorable duty and responsibility by concomitantly increasing both the appropriate habitat and the population numbers of the Pryor Mountain mustangs. These are wonderful remnants of the Spanish Colonial mustang lineage and they figure prominently in the quality of life index of millions of “general public” people. These horses have been ecologically adapting in and around the Pryor, or Arrowhead, Mountains for many generations, dating back at least to the days of the Lewis and Clark expedition and, still earlier, the great Native American tribes … but in the grander sense dating back for millions of years, since the true cradle of all horses’ species, genus, and family is North America — and the Pryor Mountain National Wild Horse Range (PMWHR) is right in the midst of the horse’s ancient and long-standing stomping grounds, as abundant and even quite recent fossil remains prove (see Chapter I of my book The Wild Horse Conspiracy .
Craig C. Downer
Wild Horse and Burro Fund
P.O. Box 456
Minden, NV 89423
Cc: Various interested parties.

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