The agency-set Appropriate Management Level for the complex is 1,550 – 2,165 horses. The current estimated 2021 population is 5,105 horses. The plan calls for “Gather to the Low End of AML and Use Non-Permanent Fertility Control Treatments – immunocontraceptives and intrauterine devices (IUDs).”
Public participation in natural resource management issues is far from perfect, but it is important to engage respectfully and with relevance to a planning document. Opinions matter, but not in public commenting! We encourage you to carefully read through all of the documents, including appendices, on the BLM’s commenting website, and use the online form to comment BY APRIL 30, as you see fit:
https://eplanning.blm.gov/eplanning-ui/project/1501993/510
Comments should address specific portions of a planning document; with updated information or expertise you have about a point in the Environmental Assessment, or a suggestion about missed or inappropriate analysis within the EA. These are the comments that are considered. (For example: While it would be great to have a higher AML, it is outside of the scope of comments relevant to this EA. That comment would be relevant to a Land Use Management process.)
Some things Return to Freedom will comment about:
- Implementation of this plan could take place entirely in 2021. RTF’s preference is that fertility control modalities should be scaled up alongside slower removals so that gather-removals always utilize fertility control as an adequate portion of the management scheme, and there is less immediate stress to holding facilities, contractor availability, budget, and transportation. Populations are stabilized over time and lowered, where applicable, more slowly. AML does not need to be achieved before fertility control is implemented.
- The BLM is suggesting treating some mares with two forms of fertility control: an immunocontraceptive vaccine and an IUD. An untested combination of fertility control mechanisms implemented in the same mare is not rational. Fertility control vaccines for wild horses have been held to exceedingly high standards by the BLM (as they should be) for observation and research before use as a management tool on free-roaming wild horses – this same standard must be held for any and all forms of potential fertility control. Mixed modalities of fertility control has not been studied in wild horses. Further, there is no way to understand which modality is effective, or not effective, and makes future analysis of methods impossible.