Researcher Marybeth Devlin’s comments to BLM’s National Wild Horse & Burro Advisory Board

photo:  Carol J. Walker

We are posting researcher Marybeth Devlin’s comments the the BLM’s National Wild Horse & Burro Advisory Board are below:

Sterilization-Study — Predicated on Fraudulent Claim of Overpopulation
BLM uses “overpopulation” as its reason to conduct population-suppression research.  However, the alleged overpopulation of wild horses is a pernicious lie, a concocted crisis, particularly in Oregon.  BLM is targeting the Warm Springs herd for these experiments.
The Warm Springs Herd’s Arbitrary Management Level ( High-AML)
According to BLM, the maximum number of wild horses that the 499,457 acres (780 square miles) composing the Warm Springs habitat can sustain is 178.  That number represents a recent 12% reduction from the original high-AML of 202.  Such numbers are not environmental requirements but rather political constructs, set for administrative convenience and political expediency.  The reduced upper bound of the Warm Springs AML establishes a maximum stocking density of 1 wild horse per 2,806 acres — nearly 4.4 square miles.
The Warm Springs Herd’s Austere Management Level (Low-AML)
BLM does not manage up to the maximum but rather down to the minimum, that is, down to the low bound of the AML — 96.  That number reflects a recent 13.5% reduction from the original low-AML of 111.  As with the high-AML, the low-AML is not a scientifically-determined number.  This even-more austere management level corresponds to a stocking density of 1 wild horse per 5,204 acres —  well over 8 square miles.
Sparsely Populated, Widely Dispersed
Obviously, BLM aims to keep the Warm Spring wild horses few and far between.  The paltry stocking-density is designed to easily create the false impression of an overpopulation when, in fact, even when over the AML, the herd is underpopulated.
Warm Springs is not alone.  Listed below are other herds in Oregon that are also restricted by sparse stocking densities, down-to-which BLM culls these herds:
1 wild horse per  2,073  acres  —  3.2  square miles  —  Sand Springs
1 wild horse per  2,302  acres  —  3.6  square miles  —  Stinking Water
1 wild horse per  2,320  acres  —  3.6  square miles  —  Palomino Butte
1 wild horse per  2,832  acres  —  4.4  square miles  —  Pokegama
1 wild horse per  2,885  acres  —  4.5  square miles  —  Liggett Table
1 wild horse per  2,972  acres  —  4.6  square miles  —  Coyote Lake / Alvord Tule
1 wild horse per  4,381  acres  —  6.8  square miles  —  Beatys Butte
1 wild horse per  5,062  acres  —  7.9  square miles  —  Paisley Desert
Long Gestation — Delay in Beginning Reproduction — Alternate Year Foaling
Horses are a slow-growth species when it comes to reproduction.  The gestation-period lasts an average of 11.2 months, and a mare produces just 1 foal.  There is a delay of two or — usually — three years before fillies begin to produce foals (National Research Council 1980, citing Eberhardt et al. 1982, and Garrott and Taylor 1990).  Further, there is evidence that wild mares tend to foal every other year, likely due to inadequate energy-reserves to sustain a pregnancy every year (NRC 1980).
The Birth Rate ≠ The Herd-Growth Rate
Generally, BLM has been misusing the birth rate as a proxy for the herd-growth rate.  However, the birth rate and the herd-growth rate are two different measures.  For a herd-growth rate to be valid, the birth rate must be reduced by the respective death rates for foals and for wild horses other-than-foals.
The birth rate among wild-horse herds not managed with contraceptives was found to average 17% to 20%; but within a year, between 32% and 50% of those foals vanish (McCort 1984, citing NRC 1980; and Gregg et al. 2014).  Thus, the birth rate is just a temporary blip in the data.  Only 50% to 68% of foals survive to become yearlings.
Adult-Mortality Must Also Be Factored
Meanwhile, the mortality rate (extrapolated from the survival rate) for wild horses other-than-foals ranges from 3% to 20%, with a median of 11.5% (BLM Smoke Creek EA 2017, citing Wolfe 1980, Eberhardt et al. 1982, Garrott and Taylor 1990).  That 11.5% can be deemed a reasonable estimate of adult mortality among free wild horses is supported by two statements, found in recent BLM environmental assessments regarding captive wild horses kept in long-term, off-range pastures (ORPs):
1. “Natural mortality of wild horses in ORP averages approximately 8% per year ….”  and
2. “Wild horses residing on ORP facilities live longer, on the average, than wild horses residing on public rangelands ….”
Expected Annual Growth, Even with Percentages Rounded to Favor Growth
Birth rate:    17% to 20% — Midpoint: 18.5% — Rounded up20%
Foal-survival rate:  50% to 68% — Midpoint: 59.0% — Rounded up60%
Adult-mortality rate:  3% to 20% — Midpoint: 11.5% — Rounded down10%
For a hypothetical herd of 100 horses, we would calculate the high-normative growth-rate as follows:
60%[20%(100)]  [10%(100)]  =  ?
60%(20)    10  =  ?
12  10  =  2    and …
2/100 =  2%
If we used NRC‘s findings — 17% foaling rate, 68% survival rate — the growth rate would be 1.6%.  If we used Gregg et al.’s findings — 20% foaling rate, 50% survival rate — the growth rate would be 0%.
BLM Deceptively Uses the Birth Rate as the Population-Growth Rate
BLM officially cites “20%” as the average population-growth rate; but 20% is actually the high end of the unadjusted birth rate.  Please note that 20% is 10 times the expected growth rate.
BLM’s Herd-Growth Figures Were Not Backed Up by Source Data
BLM’s updated sterilization-study EA cited the 2013 National Research Council’s (NRC) report as the authority for its claim of a 20% annual growth rate.  However, the NRC Committee had no choice but to accept BLM’s alleged population-growth rate.  Why?  Because, as the NRC complained in its report, BLM failed to meet the Committee’s data-requests, provided incomplete records in many instances, and lacked data supporting the national population statistics.
“The committee found that a substantial proportion of the HMA estimates published by the national office did not correspond to the ones the committee received from the field offices; discrepancies ranged from modest to many hundreds of animals.”
BLM told the NAS that it had discarded the records.  The absence of the back-up documents prevented the researchers from tracing data-discrepancies to their source.
Invalid Year-to-Year Population-Growth Data
Because the subject EA targets the Warm Springs horses for sterilization per an alleged high reproductive rate, let’s review what BLM claimed were the herd’s annual growth rates in recent years.  The chart below tracks BLM’s reported population-growth figures for the Warm Springs herd as of March 1 of each year since 2010, the year that will serve as the base, the starting point.  Note that contraceptive treatment (PZP) should have significantly reduced the growth-rate; but BLM ignored that effect.
2010  —  362  —  November 2010 cull.  PZP given
2011  —  111
2012  —  133  —  20%  —  10  times the 2% high-norm despite PZP
2013  —  160  —  20%  —  10  times high-norm
2014  —  192  —  20%  —  10  times high-norm
2015  —  368  —  92%  —  46  times high-norm
2016  —  442  —  20%  —  10  times high-norm
2017  —  586  —  33%  —  17  times high-norm
2018  —  739  —  26%  —  13  times high-norm
2018  —  886  —  20%  —  10  times high-norm — after the foaling season.
Note that the biologically-implausible growth rates compound, as each successive year is calculated per those that preceded it.  It is according to these falsified growth rates that BLM claims an overpopulation, one that would appear to double every four years … or sooner (note the 92% increase that BLM reported in 2015).  However, per the true high-normative growth rate of 2%, it would take 35 years for a herd to double.
Falsified Herd-Growth Rates Found in BLM Reports for Oregon
Warm Springs is not the only herd in Oregon whose year-to-year population increases defy credulity.  It is important to consider the others because BLM claims one of the objectives of its experiments is to determine the feasibility of sterilizing the mares of additional herds that it claims are overpopulated.  Thus, BLM aims to set a precedent.  Below are some of BLM’s fraudulent one-year herd-growth rates:
101%  —    50  times high-norm  —  South Steens
102%  —    51  times high-norm  —  Pokegama
104%  —    52  times high-norm  —  Palomino Butte
170%  —    85  times high-norm  —  Stinking Water
179%  —    90  times high-norm  —  Paisley Desert
256%  —  128  times high-norm  —  Beatys Butte
317%  —  159  times high-norm  —  Jackies Butte
Fraud Is a Crime
BLM’s representations with regard to Oregon’s wild horses are false and misleading.  Making false and misleading representations = fraud, which violates Title 18 USC 1001 of the Federal criminal code.  Embezzlement and theft — expenditures of government funds for fraudulent reasons — violate various sections of Title 18 USC Chapter 31.
Pattern of Fraudulent Reporting, Leading to Misuse of Government Funds
There also seems to be a pattern to this fraud.  It appears to extend across BLM field offices, district offices, the state office, and the National Office.  BLM offices in other states have also reported fraudulent wild-horse herd-growth rates.
As American citizens, we expect our government officials to administer programs and funds honestly.  In Oregon and elsewhere, BLM appears to coordinate the reporting of fictitious figures to secure increased funding to solve a phony problem.
Marybeth Devlin

 

10 comments

  1. Well said, Marybeth. Let’s face it … the only persons that have worked for 47 plus years for the extinction of wild horses and burros are those with a financial interest. This has been and continues to be unacceptable, illegal and the American citizens are disgusted at the “sell-out” of our lands and resources by the USFS and the BLM agencies that are responsible to PROTECT them.

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  2. They are immune to facts and science, but not to public opinion or votes. Make your voices heard Nov. 6 if you want future generations to know and see wild horses and burros, in the wild, on our public lands in sustainable healthy numbers.

    Liked by 1 person

  3. Given these massive numbers estimated, it’s also pragmatic to base attrition on ‘cumulative’ percentages, that is the higher a population, the more animals would perish in a given year.
    Each animal that survives the following year increases its odds of perishing. If BLM data were believable, and based on a mere 10% mortality, this year alone would see 7,000+ horses die – from accidents and injuries, predation, starvation, dehydration or old age.

    But that isn’t how the data is presented. The data presumes – and makes Public – 100% survival in infants and adults each and every year.

    In addition to leaving the effects of PZP out of the data sets, a five-year-long severe drought also had no deleterious effect on these animals, either. They simply learned to survive – and apparently, thrive – on dust and tumbleweeds.

    As long as there are people who make decisions against these animals based on flawed data and outright misrepresentation, this data will remain unchecked. It’s just too much effort to track down the truth.

    Liked by 2 people

    • Maybe I’m jumping to conclusions but, it seems to me the BLM just cant comprehend that wild horses & burros CAN exist in an area that cattle cant. IF they are allowed to migrate – which they normally would do – IF THEY COULD! For instance, just the Pryer horses were so much better off before they were deliberately fenced off one of their ranges.

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      • It’s a small thing, really, but it became very important to me:

        During a late Summer expedition to a huge HMA in Northern California, we noticed an area with the dried remnants of bunch grasses.

        The horses or burros had indeed eaten the grass down to the crown. But what was most remarkable to me was they had left behind several stalks with the seed heads intact. Very smart and intuitive.

        So it isn’t simply livestock versus wild equines. It’s also how these animals utilize the range.

        We also saw stream beds and water sheds with no vegetation left at all. And no hoof prints of any kind of the equine variety.

        The research material is hard to come by, and probably no longer archived but I’ve read several EAs for grazing allotments that have stated forage overlap – that is, plants in common for grazing – between cattle and wild equines as low as 11%. So how the forage is utilized on an HMA is often clouded by rhetoric and very old data, and not actual fact.

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    • It seems they are well aware of the data (they own it after all) so I don’t credit them with ignorance or lack of comprehension, but rather with clear and cold-blooded intent to line a few pockets and kill as many horses as possible while misleading and acting in opposition to the public good. Management is not methodical killing or barbarism disguised as “research,” nor does stewardship at “minimal feasible” levels remotely resemble their current policies and practices. And how about that accountability to the public? How do they make up the $100 million plus lost in the grazing permit system? Why no equivalent extermination and removal plans for the millions more livestock on public lands, and the greater financial losses? Why no equivalent demonization of domestic livestock as “invasive” or non-native, which is patently true?

      They know all this but relentlessly push an agenda clearly opposing science, federal laws and our public trust. Believing them ignorant ignores the harsh truths. Congress empowered them and Congress must hold them accountable, or terminate their mandate.

      VOTE THIS NOVEMBER IF YOU WANT ANYTHING TO CHANGE.

      Liked by 2 people

      • No – I dont believe they are ignorant, Icy – I believe they are intentionally trying to eradicate all wild horses & burros from this country. They dont want to admit or understand that the horses & burros – if allowed & actually given their OWN herd areas with NO livestock – could live free with much less “management”. I can only stand so much intentional stupidity!!! There sure is a lot of that going around these days. I hope & pray that EVERYONE who reads these blogs does vote – everyone! At this point, there are so many absolutely important issues & our wild horses & burros are a big one.

        Liked by 2 people

      • Maggie, we disagree as I believe they fully do understand that wild horses and burros can survive on their own without livestock — as this was the case throughout most of Ameican history, and the protections were enacted in 1971 as unprecedented losses were then occurring. In other words, the long arm of history shows they survived and thrived here for millennia, while no equivalent argument or evidence exists showing a similar history for domestic livestock. Wild horses, for example, pre-date Bison on this continent by thousands of years, yet Bison remain the iconic American mammal for a lot of people.

        Species vs. species arguments are generally pointless, though. My take on this is that the BLM is very well aware of what they are doing, and do not suffer from a lack of understanding or comprehension. It’s very clear they have almost zero interest in “less management” at least until the last horse takes its last breath and the last paycheck is cashed.

        VOTING IS THEIR ONLY VOICE

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  4. From AMERICAN HERDS

    Planning Obsolescence (a few excerpts)

    The second half of a two part wild horse cleansing operation was completed on September 29, 2007 in the BLM Ely District where 68 wild horses were removed in and around the Moriah Herd Management Area (HMA), leaving an estimated 20 wild horses remaining.

    The first part of these cleansing operations occurred the beginning of August in the Jakes Wash HMA, where every horse BLM could gather was removed. As is a common pattern with removal operations, BLM gathered less wild horses than they projected but removed more than they originally planned.

    Though BLM is required to “manage” for self-sustaining populations of wild horses, the Jakes Wash wild horses are only allowed 252 AUMs of forage while livestock operations affecting the HMA have been issued 15,725 AUMs – wild horses are given less than 2% of the forage available in the area. (9)

    To help illustrate this point, BLM just approved the White River Ranches Term Permit Renewal for the Tom Plains Allotment of which 50% falls within the Jakes Wash HMA. A total of 6,036 AUMs was allocated for cattle, which translates into enough to forage to feed 503 cattle annually. (10)

    For BLM, this is a win/win situation because even if there are public protests lodged against the zeroing out of the Moriah and Jakes Wash HMAs during the Resource Management Plan Final Decision, the handful of wild horses now remaining will be too old, too weak, and too few to do anything more than just die off and disappear.

    http://americanherds.blogspot.com/2007/10/planning-obsolescence.html

    Liked by 2 people

  5. Betrayal of the American people who counted on Nixon’s law to protect them.We are ignored by this administration when speaking out.None of the senators are stepping up to stop it.They call Taking out pregnant horses overies with a chain and killing their babies steralizations.We call that abortion and murder!

    Liked by 1 person

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