With less than two weeks before comments are due for the preliminary EA for the Spring Creek Basin roundup this fall, some thoughts.
First, here’s the link to the preliminary EA.
And here is information about where to send your comments.
I’ve been reading over the preliminary EA for our roundup this fall, and our groups (National Mustang Association/Colorado, Four Corners Back Country Horsemen and Mesa Verde Back Country Horsemen – singularly, and collectively as Disappointment Wild Bunch Partners) propose to support “Alternative 1 – Proposed Action: Helicopter drive trap and capture up to 60 wild horses in order to remove 50 excess animals. Apply the contraceptive porcine zona pellucida (PZP) with annual boosters over the next five years, and establish a 60% male sex ratio.”
A roundup IS necessary in Spring Creek Basin with the attendant removal of some horses for the benefit of the herd as a whole and for the finite, fenced environment on which they depend.
Notice that this preliminary EA is for the roundup, not specifically and/or separately for fertility control. I/we thought that was coming in a combined EA, but that’s apparently not the case. The fertility control EA will have to be much more complete – along the lines of the Pryor Mountain Wild Horse Range Fertility Control Environmental Assessment, but there are some things that need to be addressed in the roundup preliminary EA as presented.
Some of my concerns about our preliminary EA:
* Application of PZP: All the mares will need to be treated with primer this fall (primer, not “primary”), not just the mares captured and released. Hopefully, that’s just an oversight in this prelim EA because I’ve been talking about that all along. Also, I wonder when the number of mares to be “treated” fell from 10 to five? This has never been discussed with us by BLM. Note, it’s still “10″ on the roundup schedule, even though the number of horses to be captured/removed varies between this preliminary EA (round up 60/remove 50) and the roundup schedule (round up 65/remove 45) – and has changed from the original roundup schedule (round up 90/remove 60). I was never sure where the number 10 came from originally (in fact, this was the first glimmer we had that BLM was planning fertility control here), and I’m making the possibly erroneous assumption that that’s the number of mares BLM thinks to give the booster (as opposed to the primer … but given the information about PZP, the EA writer is unfamiliar with PZP at all) … The point is, that number from BLM is premature; no one knows the post-roundup makeup of the herd or number of total mares, and there is no herd manager or approved fertility control plan in place to dictate for certain one way or another. As it says about gender skewing in this preliminary EA: “It is impossible to determine the sex ratio of captured horses until the gather takes place.” (Page 12, third full paragraph) It also is impossible to determine the number of mares to be boostered (or even given the primer) until the roundup is complete and the number of horses and makeup of the herd is known. But to implement the program, it is necessary to treat all the mares with the primer. They get it just once in their lifetimes, but they have to get it before the booster can be given the first time. The primer needs to be given even if the mare will not be boostered next spring. In the future, we will have a seasonal application plan of boostering selected mares in the late winter/early spring and giving primer doses in the fall to maturing fillies. NMA/CO will pay for the PZP (primer and booster doses) for the first five years. This should not be a problem, and it should not have been overlooked in this preliminary EA.
* Low range of AML: This preliminary EA continually mentions taking the population back to the bottom range of the AML – 35 (AML is 35 to 65 adult horses). We also have repeatedly argued against that, especially with the implementation of an annual PZP darting program. Based on the precedent in Spring Creek Basin of leaving 43 horses after the last roundup and the PMWHR statement that their “Decision Record” states “The population will not be taken to the low range of AML when fertility control is utilized” (top of Page 3), I’d like to see that acknowledged here, especially with the continuation of gender skewing. Even with gender skewing (apparently even less than this prelim EA proposes – gender skewing was said to be 55% stallions/45% mares post-2007 roundup and is planned to be 60% stallions/40% mares this fall), and the PZP-22 that was administered to the released mares in 2007 not working (it worked on one mare; two of the original five have since died), and the introduction of three mares (from Sand Wash Basin, for their genetics) between the last roundup and currently (and three foals produced by two of the mares), we still went four years before a roundup. There’s no rational reason to remove more horses than necessary given BLM’s troubled Wild Horse & Burro Program and all the horses in holding. In fact, rational reason dictates managing horses in the wild as much as possible and appropriate – as is the case here. So our suggestion is for BLM to leave 40-45 horses after this roundup, in conjunction with the annual PZP darting and their 60/40 gender skew. We do not plan to contest the gender skewing – partly because I think it will fall on deaf ears and so it’s not a battle worth fighting at this time, and partly because, if we are given enough time and not hampered in our ability to prove the efficacy of PZP here, it should naturally skew back to normal (and I’m curious enough to see that happen).
* Modeled population growth: Also, I’m disappointed that BLM’s “Win Equus” model of population growth and this preliminary EA seem to present a token use of PZP rather than making full use of it in a plan of sustainable management that will actually save BLM money and labor and us horses. This preliminary EA suggests status quo (even with the use of PZP and gender skewing): the continuation of roundups every few years – three per 10 years (2011, 2016 and, presumably, 2021) – as was done in 2001, 2005 and 2007. Why? Just five years between this roundup and the next? Why? My proposal shows that it’s possible to reduce roundups here from three per decade to one – with all the attendant cost savings, in roundups (lack thereof; this would amount to at least $150,000 in savings per decade in roundups NOT held), and horses going to holding (lack thereof; this is by far the biggest savings over time, at least $2 million saved in horses NOT removed and sent to holding during the decade). So BLM is already anticipating that PZP won’t work? Or that it won’t use the PZP well enough to be as beneficial as it could be? With a roundup in 2011, the next anticipated roundup (by BLM) – indicated by this preliminary EA – will be in 2016 (Page 31) and, presumably, one to follow in 2021, that’s three per decade – exactly what we’re trying to prevent.
Again, reviewing some precedents to the above issues: In 2007, BLM left 43 horses (remember, low end of the AML is 35). Pryor Mountain, in its fertility control EA (which, again, we do NOT yet have here …), says that when PZP is used, the herd population does NOT need to be reduced to the low end of the AML. Mention is made in our EA (Page 12) that it is “impossible to determine the sex ratio of captured horses until the gather takes place.” By all logic, it also is impossible to know how many mares to treat post-roundup with PZP – other than with primer, and this number should be “all.”
A concern raised specifically by our Colorado chapter of the National Mustang Association is the lack of mention of our group’s longtime role in advocating for these particular mustangs – about 15 years’ worth.
On page 41, the preliminary EA states: “The Four Corners Back Country Horsemen has helped obtain horse counts in the Spring Creek Basin HMA for several consecutive years (I believe this is at least 12 years). They also have been consulted regarding the proposed gather and subsequent local adoption. Some members have expressed an interest in observing the gather but none have expressed any specific concerns relative to the gather or the adoption.”
I guess I can’t speak for 4CBCH, but NMA/CO and MVBCH have expressed concerns – members of both our groups made comments at the public hearing. Not mentioned? Why? Also, although 4CBCH has, indeed, conducted counts all these years, BLM has not very often taken their counts into account. Case in point: In February 2007, a flyover was conducted during which two BLM personnel (the then-current herd area manager and the previous herd area manager) counted horses. They each (separately, we were told) observed “97 horses.” In May that year, during their annual count, 4CBCH counted about 120 horses. Based on my knowledge of the 2007 roundup and subsequent documents and my own documentation, there were between 110 and 120 horses in the herd. Based on the numbers in this preliminary EA we’re now discussing, there were at least 118 horses present in the herd pre-roundup 2007. 4CBCH just about nailed it – but was discounted.
In the paragraph above the aforementioned, it states: “A local wild horse advocacy group the Disappointment Wild Bunch [Partners] (affiliated with the Colorado Chapter of the National Mustang Association (NMA)), has worked closely with BLM on several projects and have been consulted regarding both the proposed gather and the adoption planned immediately afterward at the Montezuma County Fairgrounds. In ” (One wonders what got cut out …)
Correctly, NMA/CO is one of the represented groups that make up Disappointment Wild Bunch Partners. Each group holds equal representation as a stakeholder in the welfare and well-being of the Spring Creek Basin wild horse herd. NMA/CO was formed at the request of a former BLM herd area manager (surprise?) and is the longest-serving advocate of the Spring Creek Basin herd.
Also, no mention is made of the specific, extensive documentation project conducted (by yours truly) that enables – finally – a sustainable management plan for this herd – and would allow for NOT BRANDING PZP-treated mares. This hasn’t been mentioned, but it’s a lingering concern. NMA/CO, 4CBCH and MVBCH have been the foundation and support of the documentation work I’ve been able to do to reach this point. Nationwide, BLM hasn’t been able to figure out a sustainable management plan in 40 years (euthanization, sterilization, tens of thousands of horses in holding, more being rounded up, HMAs and HAs zeroed out/reduced in size … need I say more?!) – though some individual herds have and are on that path (Little Book Cliffs, Pryor Mountain, McCullough Peaks). Now we have been able to, in less than three years, hand BLM a sustainable management plan on a silver platter. We had hoped bait trapping would be the method of this roundup … but that’s another story … and it’s likely coming in the future.
I’m extremely proud of the accomplishments we’ve made, and I’m cautiously optimistic for the future (I say that a lot; it has been a frustrating journey in many ways). We have a lot more work to do, but we’re here, we’re obviously not going away, and we will continue to advocate for the sustainable future of our Spring Creek Basin mustangs.
Again, with any questions, please contact me by leaving a comment or email me at mtbgrrl (at) fone (dot) net. If you’re a long-time reader of this blog and enjoyer of these mustangs, you are aware of most of the unique components of this herd and how/why we’ve arrived at this point. If not, I’ll be happy to explain some of the “back story” in more detail. Thank you with all appreciation for your support of our Spring Creek Basin mustangs.