Craig’s comments to Montana BLM on stepped up use of PZP in Pryor Mtn Wild Horse Refuge
April 15, 2013
Mr. James M Sparks, Billings Field Manager
Dear Mr. Sparks and To Whom It May Concern:
Montana BLM has zeroed out six of its seven original wild horse Herd Areas. The only one that still has any wild horses left is the Pryor Mountain Wild Horse Refuge, which was established prior to the 1971 Wild Free-Roaming Horses and Burros Act (WFHBA). In fact, Montana BLM has decided to zero out 82% of the original legal acreages that should have been set aside “principally” for the wild horses in the wild. This is a greater percentage of zeroing out than any other Western state. New Mexico comes closest at 77%. Given this initial injustice, it would seem that in the remaining area still home to wild horses, they would be treated much more fairly and given the resources and the Appropriate Management Levels (AML) that would assure their long-term viability. But such has clearly not been the case in the Pryors, where the AML range of 90 to 120 falls far short of the 2,500 individuals that is recommended for long-term viability in the wild by the IUCN SSC Equid Specialist Group (1992).
So I take this opportunity to thank you for sending me this scoping notice. I have reviewed this and wish to oppose the intensified use of PZP on the Pryor Mountain wild horses. They have been assigned an AML that is non-viable; and the further tampering with and inhibition of their reproduction would make them even more non-viable, especially in view of their long-term future survival, as well as their ecological adaptation to the Pryor Mountain ecosystem.
As a wildlife ecologist who appreciates these animals for the returned North American natives they are, I am particularly concerned that BLM’s repeated semi-sterilization of mares (often resulting in permanent sterilization of the mares) will cause serious social disruption. The logic is this: those mares who fail to achieve pregnancy quickly become disaffected with their band stallions and go off with other stallions in their futile attempts to achieve pregnancy. Similarly the stallions become desperate in their repeated futile attempts to impregnate the mares. This leads to widespread discontent and disruption, both within and between the wild horse bands composing the Pryor Mountain – as any – herd. This results in the serious neglect by adults of their duties to educate the younger members of their bands who are not as inhibited in their breeding as before. These immature individuals attempt to breed prematurely when the social units are in disarray. If intact they would be learning the very important lessons for survival in the demanding Pryor Mountain ecosystem, with its harsh winters, etc. As the effect of PZP wanes and some mares come back into a fertile condition, many give birth out of the normal Spring and early Summer birthing season, even in the late Fall or Winter when cold and storms cause them to greatly suffer and even die, along with their offspring. This is totally opposite the true intent of the WFHBA!
The intensified PZP approach to reducing reproduction in the Pryor Mountain wild horse herd is not the correct policy to adopt. It does not adhere to the core intent of the WFHBA. It is a major step toward domesticating these wild horses and seriously compromises their true wildness and natural adaptiveness. What I am offering in place of this “quick fix drug” approach to preserving, protecting, and managing this cherished herd (and all herds should be cherished) is a major and widely employed branch of the science of wildlife conservation known as Reserve Design. If properly and conscientiously applied, this would: (a) obviate the need to drug the Pryor Mountain mustangs by creating a naturally self-stabilizing horse population that would truly become “an integral part of the natural system of public lands” (preamble of WFHBA); and (b) “achieve and maintain a thriving natural ecological balance on the public lands” and “at the minimum feasible level” of interference by man. Both of these mandates come directly from Section 3 a of the WFHBA and should be adhered to by authorities of the BLM and USFS, the two agencies charged with fulfilling the act.
To accomplish these goals, you should:
I go into greater detail as to how Reserve Design can be successfully applied in my recently published book: The Wild Horse Conspiracy, where I also describe the Pryor Mountain situation. I hope that you can get a copy and read it with an open mind. Look under Reserve Design in the Index. Let me know if you want a copy.
Hoping you will give serious consideration to the points here raised. Anxiously awaiting your response.
Craig C. Downer