This is not just CLOUD’S HERD, but the PRYOR HERD. There are so many more horses that deserve just as much if not more attention. This herd is now in danger of being “managed to extinction” by PZP. A phrase that The Cloud Foundation used to live by.
Nye
In 2010 The Cloud Foundation released this:
Observations of PZP contraceptive use in the Pryors
Cross-posted from The Cloud Foundation
TCF does not support or recommend the continued use of the experimental immunocontraceptive drug, PZP, for the Pryor Wild Horse Herd because the drug continues to have an unusual and unpredictable impact on the mares that have received the drug.
PZP treatment was first administered to young females (seven yearlings and one two-year-old) in 2001 when they were given shots in the corrals after a roundup in September 2001. The drug was designed to extend one year of infertility to this group. It was given in two consecutive years. The second year the drug was administered via field darting.
Of these eight young mares, one died and four have foaled. The only two-year-old, Moshi, foaled in 2002, as she was already pregnant. Moshi didn’t foal again for 6 years until her out-of-season filly was born in September 2008.
Of the six remaining yearlings, four have produced a foal. Of the four foals, three were born in September. Administration of PZP was stopped on younger mares in 2005 due to a natural decrease in population largely because of mountain lion predation, and the unexpected absence of foal production by the young mares.
Nearly 50% of the young mares receiving the drug in the years 2001-2004 have never foaled. Of the 34 young mares to receive the drug between 2001-2004, 11 have died, 13 have foaled and 12 have not foaled. Two veterinarians (from Switzerland and Colorado) have independently expressed the same concern to us: mares not producing foals at a typically younger age (i.e. three-seven years) will have a more difficult time conceiving. They point out that this is true not just in horses but in humans as well as other species.
Of the 13 young mares that have foaled, eight foals have been born out of season, including three in September of 2008 alone. One foal born in September, never grew to full-size and was subsequently bait trapped and adopted out in September 2006. Another foal, born to Cecelia, #2224, a mare darted as a yearling and two-year-old in 2003 and 2004, was born in December of 2006. The majority of Pryor Mountain mares foal from May 15- June 15.She didn’t foal in 2007 and then foaled in September of 2008.
Photo evidence attests to the masculine and aggressive behavior of certain PZPed fillies as well as the masculine appearance of Aurora #2036. She has a stallion-like cresty neck and physique. It is obvious that the hormones of these young mares have been altered by PZP.
Of 21 older mares (11 years of age and older) given PZP from 2003-2007, 57% or 12 mares have foaled in spite of the field darting with Porcine Zona Pellucida. Only 43% or nine mares have not foaled (drug worked as designed). One mare, Tonopah #8603, produced a foal at the age of 21 in 2007.
Aside from the cruelty of raising a newborn foal going into a Montana winter, the drug has had other negative side effects in the form of abscesses, bleeding, and swelling on the hips of field darted mares. Of the 54 mares listed on the PMWHR Injection and Reaction Observations –updated June 2007 (BLM-03262), 41 mares are listed with swelling, nodules, bleeding or a combination of all these. 20 mares still have visible signs of nodules even years after they were injected. One mare, Hightail #8901, had an abscess from darting in 2007 which has since healed on its own.
Phoenix #9104 had a major wound at the location of an injection site lump from the last field darting prior to the observed wound. Photo comparisons indicate the wound, which appeared in June 2007 matches the left hip nodule from a previous darting with PZP. (Photos included). The mare and her foal were captured and treated in the corrals at the base of the mountain. Upon release to her band, the abscess looked to be healing although the mare had lost weight while in the Britton Springs corrals. Despite continued weight loss, the mare survived a long winter with deep snow at times, and looks remarkably fit at present.
The BLM has reported that density dependence (the ability for a wildlife population to self-regulate its numbers based on available resources) and compensatory reproduction (over-production by females to increase an under-represented population) have taken place on the Pryor Wild Horse Range. In other words the older mares that continue to reproduce despite the use of PZP are responding to an under-population. Generally the core reproducers as well as the older females share this burden. One older mare, Madonna #8913, who has been darted with PZP yearly since 2003, foaled in June 2007. The foal appeared to have trouble suckling and milk ran out its nose when nursing. The foal likely died during the night, as she was not with her mother the following morning.
To our knowledge this is the only herd in the West to receive PZP via field darts (Assateague Island off the coast of Virginia uses field darts with few reported problems). We believe that the many problems with swelling, bleeding and abscessing may be partially blamed on field darting. The projectile is shot through unclean surfaces on the hips of the mares.
Of the original group of young mares given the shot by hand while in the corrals, only one had any swelling. The other seven had no swelling, nodules or abscesses. This compares with 41 of 54 mares (a staggering 76%) with reported swelling, nodules and bleeding from at least one field darting experience. 43% of the mares darted in 2007 have nodules or bleeding and one mare had an abscess (Hightail #8901).
According to scientific reports, not all darts are recovered. Some needles may break off and remain in the mare where they could cause later abscessing. Significant problems may not be immediately observed, rather bacteria may linger and the problem area might be walled-off for some time then suddenly emerge as in the case of Phoenix #9104. This was mentioned as a possibility by four of the six equine veterinarians with whom we consulted. These veterinarians practice in California, Oregon, and Colorado and were asked for their opinions regarding the efficacy of field darting mares in the PMWHR, the potential hazards of this practice, and the possibility for a late abscess to appear months after the darting. One veterinarian expressed concern that the mare was darted again, thereby placing more strain on the immune system. Phoenix is one of the older mares who has produced a foal despite being darted.
Ironically, the initial stated reason for the administration of PZP by BLM was “purely from the standpoint of compassionate use”. Compassionate use was defined as “the use of the tool (or in this case a fertility control agent) to improve the quality of life of another (in this case younger or older wild mares).” (BLM Field Manager, Sandra S. Brooks-June 3, 2004). BLM sought to prolong the life of the older mares by causing them not to foal and to delay the foaling of the younger mares for one year.
The stated goal of the scientific community regarding an ideal wild horse fertility control agent was that it should be “at least 90% effective” (Wild Horse Contraceptive Research document, 1991 USGS website, posted 2-21-06). While the drug appears to be over 90% effective on Assateague Island, it has not performed in a similar manner in the Pryors. It has not prevented the foaling by a majority of the older mares and it has prevented foaling by the majority of the younger mares, in some cases, for seven years.
Most importantly, instead of trying to manage the Pryor Mountain Wild Horses in a natural way, allowing for a predator-prey balance and only conducting a roundup when truly necessary, wild horse managers opt for the use of PZP in combination with helicopter roundups and bait trapping. These policies threaten the health of the unique Spanish mustangs of the Pryor Mountains.
In addition to the statistical analysis of PZP use, it is hard not to comment on the social stress placed on both mares and their bands stallions when the mares cycle monthly and are repeatedly bred but do not settle. In July of 2008, we witnessed one young mare (#2315) being bred three times in a fifteen-minute period while she struggled to get away. Mares that cycle monthly attract the attention of bachelors and other band stallions on a regular basis and the stallion expends energy both in defense of his mare and in breeding her. This social unrest has not been reported on Assateague Island, but is easily observed in the Pryors, when individual horse bands come in close proximity to each other during the summer months.
Nirvana
Now they issue this:
Help Cloud’s Herd Today!
Dear Friends of Cloud, his family and herd;
Comments are due on September 6th regarding the more effective use of PZP for mares in the Pryor Mountain Wild Horse Herd. View our comments, which were sent to BLM this week.
In a nutshell, we advocate on the range management for all our wild herds to prevent removals as much as possible. Our goal: reproduction + natural mortality = 0. Of course there will be years when mortality is higher than reproduction and vice-versa, but over time, births and deaths will average out.What we are proposing for the Pryor mares will achieve this goal. What BLM is proposing will come close, but there will still removals, probably in 2015. However, when a removal happens, it will likely be smaller than in the past.
In 2012, 46 young Pryor horses were removed from their families and their home (including 7 foals). Some would have gone to BLM short-term holding corrals had it not been for TCF, our adopter friends, and particularly Lisa Friday & Legacy Mustang Preservation in Virginia. In all, we accounted for over half of those adopted.
But, we can’t continue to this as most of us have as many mustangs as our properties can sustain. And, TCF also rescues Pryor horses from previous adoptions which is an on-going process. Currently we have three horses looking for good, forever homes.
Adoption demand for mustangs is weak across the country. On the range management is the fiscal and humane solution—keeping wild horses on their ranges with their families where they are the safest. Of course, predator protection is what we continue to push for.
Nature is a better manager than we humans can ever be. But, in the meantime, the reversible vaccine, PZP, is the logical tool. It has proven to be safe, effective 90% of the time, and it is reversible. So, when predation or extreme killer storms occur, the field darting can be put on hold.We hope you’ll take time to read our comments and then formulate your own.
Comments can be mailed or emailed. The address for mailing is:
Jim Sparks, Field Manager
5001 Southgate Drive
Billings, MT 59101-4669.Email is blm_mt_wildhorse@blm.gov. (Please note: spaces are underscores)
Thanks for making your voices heard on behalf of Cloud and all the Pryor Mustangs!Happy Trails, Ginger
Maneulita
You can Click TCF to read the original post. I ask TCF to explain.
The Pryor Mountain Wild Mustang Center has released their comment and concerns for this proposal. These folks have had years more experience with these horses then TCF. I ask you to please read their comment and compare. Click on PMWMC to read it. Then ask yourself: “Who Knows This Herd Best?”
This is the comment I sent in. While I do agree and work with PMWMC, I am still asking for no change to the current program at this time.
August 28, 2013
Jim Sparks, Field Manager BLM Billings Field Office 5001 Southgate Drive Billings, MT 59101
Dear Mr. Sparks,
I am writing in regard to the Bureau of Land Management’s recently released Pryor Mountain Wild Horse Range Fertility Control Modification Preliminary Environmental Assessment August 2013 (DOI-BLM-MT-0010-2013-0034-EA).
I am a Montana resident, permit holder (within the Pryor Range) and very frequent visitor to the Pryor Mountain Wild Horse Range.
I do not support the current Proposed Action in the Fertility Control Modification (2.1 Proposed Action) for the following reasons:
1. Long-term herd sustainability should be a primary management goal for the Pryor Mountain wild horses. The 2009 HMAP has stated that maintaining representation of all bloodlines is a major objective. The 2011 fertility control plan and 2012 gather plan have been consistent with this and the other objectives of the Plan, such as maintaining a core breeding age population.
2. By exposing fillies to PZP for four consecutive years there is an increased risk of sterility in this potential core breeding age group. (example would be Aurora, # 20036, who was primed as a yearling, vaccines in 2009 and has never foaled).
3. Allowing each mare to have only one descendant runs the risk of loss of important bloodlines and may greatly effect the genetics of this herd. This herd has a unique history and bloodlines, and preserving those bloodlines is very important. The Pryor Mountain Wild Horse Range is not the Assateague Island National Seashore, and so the fertility control plan developed there should not be assumed to be appropriate here.
4. I feel that the current fertility plan is beginning to show favorable results. Last year (2012) there were 25 foals born and this year (to date) only 15 (13 surviving). I would
like to see this current program remain in place. I would rather see small removals (of 10 or less) then to have a too aggressive fertility program that may greatly effect this herd.
5. One of the recent publications by an advocacy group, suggested there is no market for the adoption of Pryor Horses, and that was their reason for an increase in the PZP program. I disagree with that and realize that adoption should be a separate issue that should be addressed separately, not making it the reason to increase the current fertility plan. The PMWMC and I have discussed several ways that may help with a successful adoption and we plan to work together in the future to make that happen.
Thank you for considering my comment.
Sincerely,
Sandra P. Elmore Wild In The Pryors
Mercuria
I ask you to please submit a comment against any changes to the program at this time.
You can send your comments to:
Jim Sparks, Field Manager BLM Billings Field Office 5001 Southgate Drive Billings, MT 59101
This night was filled with the sounds of horses. Not as many stallion screams as the night before, but still plenty of activity. It seemed some of the horses were finally moving down towards this part of the mountain.
At 5:00 am, I was awoke by the sound of a very loud whinny. I sat straight up in my tent. It was still dark out. I sat there waiting for another whinny. Had I really heard a whinny, or had I dreamt it? Regardless if it was real or not, I decided to get up.
I had just finished making coffee when I could see a few horses down the road. It was Cappuccino and his band. It was just beginning to get light.
I was happy to see them for a couple of reasons. One was to see that Cappuccino was indeed back with the band after running with the boys two days ago, and two, I had learned the night before from some visitors (thank you Patty!) that one of the yearlings had been wounded. They showed me the photo and I knew instantly it was McKeahnie. I was anxious to see the wound for myself.
McKeahnie was lagging behind a bit, but did not seem to bad. It appears to be a puncture wound. It was beginning to drain pus out. From time to time he would stop and bit at his hind foot. I wondered if he had a bit of numbness from the wound. I was concerned, but I do believe it will heal just fine. I did call Jared and let him know. And I will be looking forward to seeing how he is when I go up again soon.
We spent some earlier morning time with this band while we waited for the sun to come up. The photos are a bit grainy because of the low light.
They seemed a bit bothered by our presence, so we left them and headed down Burnt Timber road where I had seen some horses heading earlier. There were several bands there. Galaxy, Blue Moon, Garay, Coronado, and Baja. The first time in days they had gone down this way.
Galadrial and BeulahKetchikan and Gringo
TecumsehTecumsehCoronado’s without Santa Fe.GarayNirvanaNirvanaSequoyahSequoyah and NirvanaIsadoraBacardi
Topper TooWashakie and BajaBajaWashakieTopper Too
Maia
We stayed there until the sun started to get hot, watching them move into the trees for shade and relief from the flies.
We had to head down the mountain today. We went back to camp to pack up. Tomorrow I would have a day trip and be back up here.
Today I wanted to get down and check out lower Skyes, hoping to get a glimpse of Cecila. I had heard that some thought she was pregnant. I had not seen her since February. I knew that she had foaled last year the middle of August. So I was pretty sure if she was, she may have a new foal with her.
Just as we were leaving, we saw Cloud and his band.
MicaMicaNimbus and InocentesNimbusFeldsparCloud
I always keep a watchful eye out as I head down Burnt Timber, even though most of the horses are on top.
I had not seen Garcia and band. But as spread out as the horses were right now, I thought perhaps I may have missed him. I also still was holding out hope that I would see Two Boots or Starman or even Prince.
We were high up the road above the lower water guzzlers when I noticed some dark-colored horses by one of the guzzlers. My heart skipped a beat. Was Two Boots one of them?? I looked through the binoculars. It wasn’t Two Boots, but it was Garcia and his band! How cool was that?? They were the only band using this part of the range right now. Smart band. The forage of course was not as great as on top, but they had the whole place to themselves. It was so great to see the water guzzlers doing what they hoped it would do. AND there was still water for them in them!
We stopped and hiked back to them. They were very surprised to see us and were a bit bothered by our presence. So after snapping a few photos, we left them to their solitude.
Millicent, Norma Jean, Great and Garcia, August 22, 2013
When we reached Lower Sykes, the thermometer on the truck read 95 degrees. It would be like an oven out there for hiking, but I was determined to check on Cecilia. I hiked up a couple tall hills and glassed around. It only took me a minute to spot them way off. I don’t believe Ceceila is pregnant.
Ceceila, Mato and Sitting Bull, August 22, 2013
It had been a great first 5 days on the mountain.
Later that evening I met with Matt and Nancy at the PMWMC. We talked about the new proposed PZP program. Here is a link to their blog on the letter they wrote. Click CENTER to go there.
There is still time to submit your letter too. Click HERE for more information on how to do that.
Wild in the Pryors is asking that you submit your comments before September 6, 2013 in regards to the recently released Pryor Mountain Wild Horse Range Fertility Control Modification Preliminary Environmental Assessment August 2013 (DOI-BLM-MT-0010-2013- 0034-EA).
Nye
Nye and Niabrara will be yearlings in the spring of 2014. They could be given PZP treatment this next spring if the proposed Modification takes effect. They would be treated at the age of 1, 2, 3, and 4 until they move into the 5-10 age range where, with the current Fertility Plan, treatment stops. The questions arise, “How many years can PZP be administered without causing irreversible infertility?” and “Will their response be similar to other Pryor fillies who were treated at a very young age and faced infertility problems?”
Aurora, age 13. Was given PZP as a yearling and has never had a foal.
Manuelita picture below will be given her first PZP treatment this fall if it takes effect.
Manuelita. Will she ever be able to conceive?
Comments are due by September 6, 2013.
We ask that you send your comment to: Jim Sparks, Field Manager BLM Billings Field Office 5001 Southgate Drive Billings, MT 59101
Your comment should be polite and to the point. We would like you to ask that the current PZP program remain in effect and no changes be made to the current program.
Please make your comment short and to the point.
Start your comment with this reference:
I am writing in regard to the Bureau of Land Management’s recently released Pryor Mountain Wild Horse Range Fertility Control Modification Preliminary Environmental Assessment August 2013 (DOI-BLM-MT-0010-2013-0034-EA).
Nye and Galena, August 2013
Long-term herd sustainability should be a primary management goal for the Pryor Mountain wild horses.
“Removing females even temporarily from the breeding pool is likely to reduce the effective population size and genetic diversity of the population.” (p. 125 of the National Science Academy report.)
Yearlings Mercuria and Morgana, August 2013. Will they become sterile?
Please send your comments in today. You can read more on this proposal by clicking on PZP. You can read the Pryor Mountain Wild Mustang Center’s letter regarding this proposal by clicking on PMWMC.
The Pryor Mountain Wild Mustang Center and Wild in the Pryors have very similar thoughts and feelings on this Fertility Control Modification. I hope you all will join us in submitting your comments.
Sandy
We are against the Cloud Foundation and BLM partnership for extreme PZP in the Pryors for the following reasons:
1.) It ruins natural selection.
2.) According to the National Academy of Sciences there is no evidence of overpopulation.
3.) Reserve design is the healthy choice for management.
4.) Risks of sterility could ruin the herd’s genetic viability.
5.) Unnatural and increased stress on wild mares from wild stallions continuously trying to breed them month after month, year after year, until they are allowed by mankind to have one foal.
6.) Man made fertility control drugs endanger the wild herds’ ability to adapt through reproduction to environmental stresses.
7.) The “Restricted Use Pesticide” known as PZP is not allowed on domestic horses–surely for safety concerns and therefore should not be allowed on native wild horses who have been misclassified as “pests” by the Environmental Protection Agency.
Natural selection has allowed native wild horses to evolve and survive for more than a million years. We believe it is unethical for a government agency and a nonprofit organization to go against natural evolution and manipulate breeding through excessive roundups and drugs approved for use as “restricted use pesticides”.
Now the public is witnessing the final phase of the Salazar Plan announced in 2009 (managing wild horses to extinction) using an EPA fast-tracked “Restricted Use Pesticide” called Porcine zona pellucida–a form of zona pellucida extracted from the ovaries of pigs.
And speaking of pigs, where are the pigs’ ovaries coming from? How were the pig’s ovaries extracted?
The Pryor Mountain Herd is already one of the two herds designated with “Treasured” status–that means they are protected and will never disappear. No need to sell out to ”restricted use pesticides” for “pest” control!
“We are proud to be working with the BLM, and we hope our partnership with them will continue and may set an example for the management of other wild herds throughout the West,” said Ginger Kathens, Executive Director of The Cloud Foundation in the BLM’s top story released on August 12, 2013.
What happened to The Cloud Foundation fighting for America’s wild horses’ right to live their natural lives in freedom?
“Why is Ginger Kathrens now supporting the extreme use of PZP when a couple of years ago she appeared to be against using the drug, against ruining natural selection and against creating zoo-like settings on mountaintops?” asks Anne Novak, Executive Director of Protect Mustangs.”
Please don’t forget to submit your comments against the increase of PZP in the Pryors. They are due September 6. Click HERE to find out how to submit your comments.
To learn more about Protect Mustangs, Click on MUSTANGS.
I just saw this on the BLM facebook page and I thought it would be of interest to post it here for you to read. The success of the current PZP program is becoming very apparent.
This success is another reason why the current PZP program should remain in place. With the help of TCF and the NPS the horses that need to be vaccinated are apparently getting it. Let’s not rush into a stronger program until we see the results of a year or two with this increased help.
Please click (TopStory Horse) below to go to the article and please do not forget to send in your comment regarding the proposed increase in the PZP program. Click PZP to go to my post telling you how to do that. PZP
I have been home now for a little over a week. It feels good to have some time with my husband Bill and my animals. But I do miss the Pryors and look forward to my next trip, which is coming up fast.
Even though I am not there, I know the horses are fine. They have been fine for over 200 years (many more than that I am sure) and I hope that they will continue to be fine. But with the up coming PZP proposal, I am not sure this will be the case. Let’s just say I am worried. I need to think about this proposal and meet with some others that know and care about this special herd before I make any final judgements and construct my letter to the BLM in regards to it.
I had a message on my cell phone from Jared saying this was coming out (thank you Jared for the call). I did go on their website: BLMWEBSITE. On this page you can go to the lower left and see MT/DK Draft Resource Management Plans. Under there, there is a link to the PMWHR fertility control modification. There are several links to read, and I encourage you to read them.
A couple of days later I got my “Interested Party” letter in the mail telling me about the proposed plan.
Dear Interested Party,
United States Department of the Interior
BUREAU OF LAND MANAGEMENT Billings Field Office 5001 Southgate Drive Billings, Montana 59101-4669
August 1, 2013
After consideration of public input during scoping the Pryor Mountain Wild Horse Range (PMWHR) Fertility Control Modification Preliminary Environmental Assessment (EA) DOI-BLM- MT-010-2013-0034 and unsigned Finding of No Significant Impact (FONSI) are available for a 30 day public review and comment period. The documents will be available at the Bureau of Land Management (BLM), Billings Field Office (BiFO) website at http://www.blm.gov/mt/st/en/fo/billings_field_office/wildhorses/pryorherd.html. The comment period will be conducted beginning August 6, 2013 and ending on September 6, 2013
This EA is tiered to the PMWHR/Territory EA (MT-010-08-24) and Herd Management Area Plan (HMAP) May 2009. This tiered EA has been prepared to analyze the impacts associated to wild horses and other resources from modification to the current fertility control prescription. The analysis from the HMAP and the 2011 Fertility Control EA are incorporated by reference. All other impacts and affected environment are already described and analyzed in the HMAP and subsequent FONSI and Decision Record (DR). These documents are also available at the BLM web address above.
Comments about the EA or unsigned FONSI can be sent to blm_mt_wildhorse@blm.gov or at the letterhead address by close of business September 6, 2013. To best ensure interested party’s comments are received, comments can be sent in a written form and mailed or hand delivered to the Billings Field Office. The BLM will consider any substantive comments and revise the EA or FONSI as appropriate. Before including your address, phone number, e-mail address, or other personal identifying information in your comment, you should be aware that your entire comment, including your personal identifying information, may be publicly available at any time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so.
Thank you for your interest in the management of the PMWHR by the Billings Field Office. If you have any questions concerning the EA or unsigned FONSI, please contact Jared Bybee, Montana/Dakotas State Wild Horse and Burro Specialist, at (406) 896-5223.
Noble and Naolin, July 2013
Below is the unsigned FONSI. If I am understanding this right, this will be the proposal and will be signed if they don’t hear enough feedback suggesting other wise.
FINDING OF NO SIGNIFICANT IMPACT (FONSI) ENVIRONMENTAL ASSESSMENT DOI-BLM-MT-0010-2013-0034-EA (Pryor Mountain Wild Horse Range Fertility Control Modification Preliminary Environmental Assessment Tiered to the Pryor Mountain Wild Horse Range/Territory Environmental Assessment And Herd Management Area Plan May 2009)
This unsigned FONSI and EA (DOI-BLM-MT-0010-2013-0034-EA) is to modify the current fertility control prescription and apply fertility control to nearly every mare on the PMWHR through 2015 in order to help maintain the appropriate management level of 90-120 wild horses and reduce the need for a large scale gather. The modification to the current prescription would begin in the fall of 2013 and last through 2015 (the life of the current prescription). The modification to the fertility control would consist of applying primer doses to in the fall to mares in the one year old age class (when they are not quite two) and any mare that has not ever been primed in the fall of 2013. Mares ages 5-10 years old that have offspring on the range that are one year old or older would be given a booster. The rest of the treatment would continue as currently is. This would continue in 2014 and 2015. Treatments would still be designed to treat mares before becoming pregnant which in the spring, however in 2014 and 2015 boosters would be applied any time of the year. The EA is available for a 30-day public review and comment period beginning on August 6, 2013, and will end on September 6, 2013. The documents are available on the Billings Field Office website at http://www.blm.gov/mt/st/en/fo/billings_field_office/wildhorses/pryorherd.html.
Based on the analysis of potential environmental impacts in the attached EA and consideration of the significance criteria in 40 CFR 1508.27, I have determined that with proposed mitigating measures incorporated as part of the proposed action this would not result in significant impacts on the human environment. An environmental impact statement (EIS) is not required.
The decision to approve or deny a modification of the current fertility control prescription to mares within PMWHR, and if appropriate a signed FONSI with rationale, will be released after consideration of public comments and completion of the EA.
Niobrara, June 2013
While I am not opposed to using PZP, I am opposed to the overuse of it.
Last year most of the J, K and L girls got removed. So that alone will make a huge difference to the upcoming years of foals. This year we have begun to see the effects of PZP. There have only been 15 (13 surviving) foals born compared to 25 last year.
Please read and please submit your comment letter. Comments need to be in by September 6, 2013.
The Cloud Foundation released their PZP Proposal. You can click on TCF to read it. I am not opposed to some of their ideas, and I support the idea of no more removals. But to rush into another plan, could be detrimental to the horses. Is this “playing with mother nature” a bit too much?
I do think it would be nice to see Seneca have a foal.(read TCF proposal to see what I am talking about). However currently she is in a band of 4 (The Greeters), including her 1/2 brother and son. Which one would she breed with? Either one may lead to a less than perfect foal.
I still think the current program should remain in place. The current plan has only been in place since 2011. Due to the schedule, weather and only one person delivering the injections for the 2011 year, we have yet to see what a good year looks like. You can read more about my thoughts and the letter I will be sending to Jim Sparks in regards to this, by clicking PZP.
This current plan will remain in place until 2015. I do believe the plan has room for improvement. But why rush it? My first concern is for the welfare of the entire Pryor Herd and the future generations.
There have been a lot of questions and confusion on the scoping letter that was sent out last week. You can read about that letter by clicking SCOPING LETTER. I decided to make another post on it, so that those that want to know more can read it in this post, instead of having to wade through all the comments from my previous post.
I am still waiting to hear from The Cloud Foundation on what exactly what their proposal is going to be. I have been in contact with Ginger and I hope to have that answer soon.
So while I waited, I contacted Jared to ask for some clarification on what this meant. Thank you so much Jared for getting back to me so fast. Here is what he had to say:
Sandy,
You really need to ask TCF what they exactly have in mind. The scoping letter pretty much explains it. TCF isn’t the only party that has wondered if the current PZP prescription is adequate, based upon the details provided in the scoping notice about demographics, efficacy, timing due to access, etc TCF just requested BLM do more. The first place to start to determine the feasibility is a scoping notice. There has been no proposal from any party for an Assateague model, that died in 2010 when the preliminary current EA was issued and the public saw exactly what they asked the BLM to do. This is an opportunity for the public to send BLM a proposal, instead of BLM sending one out and trying to read the tea leaf’s. Any scoping comments provided to the BLM are public record.
Hope this clarify’s things
Jared Bybee
Rangeland Management Specialist
Montana/Dakotas State Wild Horse and Burro Specialist
5001 Southgate Drive Billings MT 59101
Desk:406-896-5223
Mobile: 406-698-4831
Fax: 406-896-5281
Lakota, June, 2012
I have my letter ready to send, but will wait until I hear from The Cloud Foundation on their proposal. But, I am thinking it will not change. Here is that letter:
Dear Mr. Sparks,
In regards to the scoping letter regarding the PZP program released April 1, 2013, I as a Montana resident, frequent visitor to the Pryors and permit holder within the Pryors request that the current PZP program remain in place. I feel I have been able to observe and study the horses in their home intently. This year alone, I will be with them for more than 50 days.
I feel that we should see how the current plan works on a good year. With the NPS assisting in the darting of the horses, I feel that the horses will be given the injections in a more timely manner. We should give this program some more time to see how it is working and then re-evaluate as necessary for the next phase starting in 2015.
I would hate to see a rushed decision on changes to the PZP program.
I do not support any changes to the current plan.
Thank you.
Sincerely,
Sandra P. Elmore
UPDATE: Here is the link to TCF proposal, just released tonight. I still stand by my letter above. ClickTCF to go there.