The Bureau of Land Management is seeking public comment on an Environmental Assessment for the North Lander Complex in Fremont County, Wyoming, a plan which includes removing hundreds of wild horses from their home range and implementing fertility control over a 10-year period.
Public comments are due by Feb. 18. For information on how to submit your comment, see below.
The agency’s goal is to reduce to and maintain a wild horse population there at an agency-set “Appropriate Management Level” of 320 to 536 wild horses as well as to remove wild horses that have strayed outside of the complex.
BLM estimates that there are currently close to 2,000 wild horses in the 375,292-acre North Lander Complex, which is made up of the Conant Creek, Dishpan Butte, Muskrat Basin and Rock Creek Mountain Herd Management Areas.
BLM’s proposed action includes focusing removals on “highly adoptable” wild horses under age 5 and returning older, “less adoptable” horses to the range. The agency would geld or vasectomize “up to 95 percent or more” of the stallions released and would treat all mares released with the fertility control vaccine GonaCon as well as intrauterine devices for those that are not pregnant.
In subsequent roundups, under the plan, BLM would use sex-ratio skewing, releasing more stallions than mares.
The Environmental Assessment describes an initial roundup in which it would capture 80-90 percent of the wild horses on the complex, which it estimates would be about 1,900-2,200 horses (if the initial roundup is conducted in 2022). All captured wild horses ages 5 and under would be permanently removed from their home range. About 300 of the remaining stallions would be selected for gelding / vasectomies and a similar number of mares would be treated fertility control and, if not pregnant, IUDs.
“A few” stallions and mares with “exceptional conformation” may be selected for retention without treatment in each [Herd Management Area]. The BLM would also monitor genetic diversity and “one or two 1–2-year-old fillies could be exchanged between HMAs as well as introduced from external HMAs in conjunction with these regular gathers, depending on results of that genetic diversity monitoring,” according to the Environmental Assessment.
Compared to the BLM’s Appropriate Management Level of 320-536 for wild horses on the North Lander Complex, the agency allows about 49,000 Animal Unit Months of seasonal livestock grazing there. That’s the annual equivalent of 4,083 cow-calf pairs (an AUM is defined as the amount of forage needed to sustain one cow and her calf, one horse, or five sheep or goats for a month).
Notes to consider for your letter:
–The preferred action allows for the use of helicopters to remove “excess” wild horses and burros. RTF urges a slower approach of scaling up fertility control as lesser removals are accomplished methodically with bait-and water-trapping techniques.
–The Environmental Assessment notes that the population target, or “Appropriate Management Level (AML),” was determined through the 2014 Resource Management Plan and that a reconfigure of AML is outside of the scope of this Environmental Assessment. Therefore, we assume AML was determined based on BLM’s handbook (USDI Bureau of Land Management 2010), which includes removal scenarios only. If fertility control is some portion of a modern management plan, AML can be brought into context: a decreased population growth rate translates to both longer times between roundups and fewer horses needing to be captured if the growth rate is reduced.
–The preferred action would include removing from the range all captured wild horses under age 5. Healthy populations rely on whatever the norms are in terms of that population’s demographics – adjusting a population of wild horses to skew for more or less of anything does not attain a natural state for that population, with behavior ramifications that are not yet understood. No population of animals should be entirely young, entirely old, or entirely in between.
–The preferred action includes the possible use of fertility control to help manage wild horse and burro numbers. RTF strongly supports the use of safe, proven and humane fertility control vaccines to halt roundups. PZP in particular has been studied and proven safe, effective, and humane over the longest period of time and in the greatest number of horses, including, importantly, the greatest number of horses in free-roaming situations. Further, PZP carries an excellent reputation in wild horse advocacy circles. While we do not disparage scientific research into multiple modalities and methods for the application of fertility control to wild horses, we caution against using methods that have not been thoroughly proven in their efficacy, but more importantly, their safety of use. Because GonaCon interrupts the hormone cascade, it may cause other behavioral changes that would affect herd dynamics. As such, RTF would like to see more studies to ensure that GonaCon meets the parameters of ethical and thoughtful wildlife fertility control.
–The preferred action includes using IUDs. IUDs can only be used in non-pregnant mares, and the majority of mares gathered are more than likely pregnant. IUDs have not been tested on free-roaming horses beyond a small number of free-roaming horses the intention of analyzing effectiveness as well as potential complications. Information about their use will not be complete for several more years. Other forms of fertility control for wild horses have been held to exceedingly high standards (as they should be) for observation and research far and above that which has been seemingly approved for a few newer methods – this will garner further distrust among wild horse advocates and seems inconsistent.
–The preferred action includes gelding stallions. RTF does not advise gelding as a population management tool since there are effective and well-studied, safe and humane and reversible fertility control alternatives and there are not sufficient studies to understand the behavioral effects of gelding some proportion of a population. Modeling for population effects of a certain percentage of male horses in a population being geldings is a guess, at best. The BLM is also proposing gelding older stallions, which risks increased bleeding and requires more recovery time.
–The preferred action includes as an option sex-ratio skewing so that males make up a greater percentage of the herd. RTF does not advise sex-ratio skewing for wild horses for these reasons: (1) management of populations via sex skewing is temporary (populations return to their normal ratios), and (2) healthy populations rely on whatever the norms are in terms of that population’s demographics – adjusting a population of wild horses to skew for more or less of anything does not attain a natural state for that population, with behavior ramifications that are not yet understood (potential heightened aggression in stallions, for example).
How to submit public comment
Click here to read the Environmental Assessment(see “documents” on the left side of the page). As of this post, it appears that the site is not set up to receive comments electronically. Comments may be submitted by mail to: Wild Horse Specialist, BLM Lander Field Office, 1335 Main Street, Lander, WY 82520.