THE COMMENT PERIOD FOR THE MCCULLOUGH PEAKS HMA BAIT TRAP GATHER EA CLOSED AT MIDNIGHT ON 08/12/23. AT THE TIME OF CLOSURE, 6016 COMMENTS HAD BEEN RECEIVED. THANK YOU TO ALL WHO COMMENTED AND HELPED WITH SPREADING THE WORD ABOUT THE UNNECESSARY ROUNDUP AND REMOVAL OF THE MCCULLOUGH PEAKS HERD. YOU TRULY WERE THEIR VOICE.
Even after receiving 4,352 comments on their Scoping Notice, the Bureau of Land Management (BLM) is moving forward with their plan to remove a significant number of wild horses from McCullough Peaks Herd Management Area (HMA) through a bait trapping operation. As per the Environmental Assessment (EA), which was released on 07/13/23, the BLM plans to take the current population of 181 horses down to the Appropriate Management Level of between 70-140 horses. I know many of us care deeply about this amazing herd, so it’s up to us to comment on the EA to let the BLM know that we don’t agree with their plan. All public comments to the EA must be received by midnight MT on August 12, 2023, to be considered. You do not need to be a U.S. Resident or a Resident of the state of Wyoming to comment. In addition, you can comment multiple times.
Once the 30-day comment period is over, the BLM will review comments submitted and will then issue a Record of Decision. As outlined in the EA, the bait trapping will then begin sometime after November 1, 2023. You can read the BLM's EA at the link below.
BLM ENVIRONMENTAL ASSESSMENT (EA)
After spending more than fourteen years observing and photographing the McCullough Peaks wild horses, I’ve developed a deep love and respect for them. This unique herd is not only beloved by me, but by people all over the country and all over the world. Because these wild horses have become so important to so many of us, we need to tell the BLM that we want the McCullough Peaks herd to stay on the range, where they belong.
Following a thorough review of the EA, I prepared some suggested talking points that you can use to aid you in composing your comments. You can use these talking points “as is”, or modify them to send to the BLM. If you have any questions or need any help crafting your comments, you can reach me at sandysisti@yahoo.com
. I would be happy to help you. Thank you all so much for taking the time to speak out for the McCullough Peaks herd.
PLEASE NOTE: You can copy and paste (Ctrl c to copy and Ctrl v to paste) these talking points with a laptop or desktop only. You cannot copy and paste the talking points using a mobile phone. If you can only submit your comments using a mobile phone, please email me at sandysisti@yahoo.com and I will send the talking points to you.
BELOW ARE THE SUGGESTED TALKING POINTS YOU CAN SUBMIT TO THE BLM:
After reviewing the McCullough Peaks HMA Bait Trap Gather Environmental Assessment (EA), I support the “No Action Alternative” of continued population management with PZP with no horses removed from the range. Reasons for my decision are outlined below.
1) The Appropriate Management Level (AML) at McCullough Peaks is 70-140 horses, with the current population at 181 horses. The EA outlines gathering and removing excess wild horses through bait trapping to bring the herd numbers down to AML, however, the EA is unclear as to how many horses will be left on the range after the removal. If herd numbers are brought down to AML, the herd won’t be genetically viable. Dr. Gus Cothran, Professor Emeritus at the Texas A&M School of Veterinary Medicine, states that at a minimum, he
Following a thorough review of the EA, I prepared some suggested talking points that you can use to aid you in composing your comments. You can use these talking points “as is”, or modify them to send to the BLM. If you have any questions or need any help crafting your comments, you can reach me at sandysisti@yahoo.com
. I would be happy to help you. Thank you all so much for taking the time to speak out for the McCullough Peaks herd.
PLEASE NOTE: You can copy and paste (Ctrl c to copy and Ctrl v to paste) these talking points with a laptop or desktop only. You cannot copy and paste the talking points using a mobile phone. If you can only submit your comments using a mobile phone, please email me at sandysisti@yahoo.com and I will send the talking points to you.
BELOW ARE THE SUGGESTED TALKING POINTS YOU CAN SUBMIT TO THE BLM:
After reviewing the McCullough Peaks HMA Bait Trap Gather Environmental Assessment (EA), I support the “No Action Alternative” of continued population management with PZP with no horses removed from the range. Reasons for my decision are outlined below.
1) The Appropriate Management Level (AML) at McCullough Peaks is 70-140 horses, with the current population at 181 horses. The EA outlines gathering and removing excess wild horses through bait trapping to bring the herd numbers down to AML, h
rd size must be maintained at 150 horses to ensure genetic viability. This fact is acknowledged in the BLM’s own Wild Horse and Burro Handbook.
2) With regard to the use of additional population growth suppression treatments, this EA outlines three conflicting plans for use of GonaCon in conjunction with PZP on mares at McCullough Peaks as follows: GonaCon used on mares older than 13 years that have contributed to the genetic diversity of the herd; GonaCon used on mares that have contributed to the genetic diversity of the herd (no age stipulation), and Gonacon used on PZP non-responders only. Given concerns about the potential for permanent sterilization and injection site abscesses, GonaCon should never be considered as a fertility treatment for any mares at McCullough Peaks. PZP has been used successfully since 2011 and should continue to be used for population management.
3) The EA states that the BLM must manage the rangelands to prevent the range from deterioration associated with an overpopulation of wild horses. The BLM has provided no data indicating the rangeland is deteriorating and without these data, there is no rationale for the proposed gather. In addition, there is no analysis provided for the impact of livestock grazing on the rangeland. An evaluation of the impact of livestock grazing is required to determine rangeland health before any wild horses are permanently removed from McCullough Peaks.
4) The EA states that the older population of horses (20 years of age and above) living within the McCullough Peaks HMA will not be removed. The EA also states that any animals affected by a chronic disease, injury, lameness or serious physical defect, such as severe tooth loss or wear would be humanely euthanized. Horses are categorized as “seniors” beginning at 15 years of age, and at that time they begin to experience tooth loss/wear and would be more likely to present with lameness or injury. Older horses make up 1/3 of the population and, it is feared that a high percentage of these horses will be "euthanized", thus negating the BLM’s proposed action that older horses remain on the range. Issues that are indicators of a horse’s senior status, should not be considered as criteria for euthanasia for any of the McCullough Peaks herd.
5) Of the 181 horses at McCullough Peaks, 59 are greater than 15 years of age with 22 of them over the age of 20. Of the 22 horses over 20 years of age, 5 of them are more than 24 years old. The horses over 24 years of age are in ill health and will probably not survive another winter. Eleven horses were lost during the winter of 2022/2023, with 9 of these horses over 15 years of age. In assessing the condition of the remaining older horses, it is possible that the McCullough Peaks herd could lose 15-20 older horses this winter. When the current rate of attrition is coupled with the 2% average yearly growth rate, the population of adult horses at McCullough Peaks may fall within AML over the next few years, thus negating the need for a bait trap removal.
6) The proposed bait trapping would start during fall 2023 and could continue through February/March 2024. As per the EA, the BLM will check bait traps at a minimum of once every 10 hours, with horses in traps provided a continuous supply of fresh water and hay. As necessary, roads to the traps will be plowed to allow access. Because of the extreme winter weather at McCullough Peaks HMA, roads can be inaccessible for days or weeks at a time. If horses are stuck in traps during a winter storm without food, water or shelter, they could perish. Because of this, all bait trapping operations should cease, with traps closed, during the onset of winter weather.
7) It is imperative that only trained BLM personnel, familiar with the McCullough Peaks herd, conduct bait trapping operations, without the involvement of contractors.
8) What is presented in this EA is a 10-year plan. This is a violation of NEPA, the National Environmental Policy Act. The BLM needs to give the public an opportunity to comment each time they are taking action against the McCullough Peaks herd.
THE COMMENT PERIOD FOR THE MCCULLOUGH PEAKS HMA BAIT TRAP GATHER EA CLOSED AT MIDNIGHT ON 08/12/23. AT THE TIME OF CLOSURE, 6016 COMMENTS HAD BEEN RECEIVED. THANK YOU TO ALL WHO COMMENTED AND HELPED WITH SPREADING THE WORD ABOUT THE UNNECESSARY ROUNDUP AND REMOVAL OF THE MCCULLOUGH PEAKS HERD. YOU TRULY WERE THEIR VOICE.
It is important that you submit your own comments. Please do not rely on a "sign on" letter or petition, because the BLM considers those just one comment.
If you encounter any problems with your electronic submission of comments to the BLM, please contact James M. Fisher, Lead Public Affairs Specialist, BLM at 307-331-3102 (cell) or 307-775-6328 (office), for assistance.
YOU CAN ALSO MAIL IN COMMENTS TO THE ADDRESS BELOW:
Refer to DOI-BLM-WY-R020-2023-003-EA
BLM Cody Field Office
Attn: Abel Guevara, Wildlife Biologist
1002 Blackburn Street
Cody, WY 82414
WHEN MAKING PUBLIC COMMENTS TO THE BLM:
Keep your comments:
- Civil
- Mature
- Professional
- Scientific and fact based
DO NOT make any comments that are rude or threatening in nature. We need as many people as possible to submit comments and let the BLM know how important the McCullough Peaks herd is to them personally and to the public. Any rude or threatening comments will be discounted and will only hurt our chances to protect this beloved herd.
Thank you to our friends at Save our Wild Horses for this helpful guideline.
If you would like to read my unredacted comments to the McCullough Peaks HMA Bait Trap Gather Environmental Assessment, you can find them below. You can also use these comments to formulate your own response, if you like.
UNREDACTED COMMENTS TO "McCULLOUGH PEAKS HMA BAIT TRAP GATHER ENVIRONMENTAL ASSESSMENT" AS COMPILED BY SANDY SISTI
After reviewing the McCullough Peaks HMA Bait Trap Gather Environmental Assessment (EA), issued on July 13, 2023 by the BLM Wyoming-Cody Field Office, I support the “No Action Alternative” with regards to the McCullough Peaks herd. Under this action, a gather to remove excess wild horses would not occur and PZP Immunocontraceptive Vaccine (PZP) would continue to be used as a means to manage population growth rates. I do not support the BLM’s “Proposed Action Alternative” which includes bait trapping to remove excess horses to achieve AML; implementation of GonaCon for use on mares in the herd, and maintaining AML in the future through maintenance gathers.
It must be noted that the BLM recorded the McCullough Peaks population in the EA as 181 wild horses as part of the official population inventory performed on 05/31/23. Due to the presumed death of additional horses, the total number of horses on the range is currently 178. Because another count will be performed before the proposed bait trapping operations begin, the number of 181 will stand for use during this discussion.
Reasons for my decision to support the “No Action Alternative” with regards to the proposed bait trapping of the McCullough Peaks herd are outlined below.
1) The current Appropriate Management Level (AML) at McCullough Peaks is 70-140 horses. The BLM records the current wild horse population in the EA as 181 on 05/31/23, when the official count was performed. The EA outlines gathering and removing excess wild horses through bait trapping, to bring the herd numbers down to AML, however, the EA is unclear as to how many horses will be left on the range after the gather. Conflicting final numbers mentioned within the EA are as follows:
- AML (70-140 horses)
- 100 horses
-High AML/Upper Limit of AML (140 horses)
Neither of these three possibilities will leave the herd genetically viable. Dr. Gus Cothran, leading horse geneticist and Professor Emeritus at the Texas A&M School of Veterinary Medicine, states that at a minimum, herd size must be maintained at 150 horses to ensure genetic viability and a healthy population. Lower population numbers lead to more in-breeding, resulting in the population being vulnerable to multiple health problems. According to the BLM’s own Wild Horse and Burro Handbook “A minimum population size of 50 effective breeding animals (i.e., a total population size of about 150-200 animals) is currently recommended to maintain an acceptable level of genetic diversity within reproducing WH&B populations (Cothran, 2009)”.
On page 9 of the EA it states “If future genetic monitoring indicates a loss of genetic diversity, the BLM would consider introduction of horses from HMAs in similar environments to maintain the projected genetic diversity.” Bringing the numbers of wild horses at McCullough Peaks down to a level that does not support genetic diversity is unacceptable. The population has been successfully managed with PZP since 2011 with 2023 seeing only a 1% growth rate. Continuing the current population management strategy, the “No Action Alternative”, will allow the population to remain genetically diverse without the need to introduce horses from other HMAs.
2) With regard to the use of additional population growth suppression treatments, this EA outlines three conflicting plans for use of GonaCon on mares at McCullough Peaks as follows:
- “Continue current use of PZP, but use GonaCon on mares older than 13 years old that have contributed to the genetic diversity of the herd.” (Page 6 of EA)
- “Continue current use of PZP, but use GonaCon on mares that have contributed to the genetic diversity of the herd.” It is noted in this instance that there is no age stipulation for the mares. (Page 8 of EA)
- “The BLM will continue to use PZP, however, several mares have not responded to PZP treatments and continue to give birth every year. The BLM is considering and hoping that other vaccine treatments (GonaCon) will allow the mares that do not respond to PZP an opportunity to no longer be submitted to the stress of giving birth every year.” (Page 17 of EA)
The January 9 Scoping Notice for McCullough Peaks mentioned the possible use of GonaCon for mares that continued to foal even when treated with PZP (i.e. non-responding mares). Currently, there are only three known non-responding mares at McCullough Peaks; all over 14 years of age. It is unclear when reading this EA, what the plans are for use of GonaCon at McCullough Peaks. If the BLM uses GonaCon on any and all mares that have contributed to the genetic diversity of the herd, they will be moving the herd one step closer to obsolescence.
Given concerns about is potential for permanent sterilization and injection site abscesses, GonaCon should never be considered as an additional or alternative fertility treatment for any mares at McCullough Peaks. PZP has been used to effectively manage this herd since 2011 and its use should continue into the future. If continued reproduction from the three non-responding mares remains a concern, a stricter schedule for field darting with PZP should be implemented with input from personnel at the Science and Conservation Center in Billings, Montana. PZP-22 is also suggested as an alternative for these non-responders as it has been proven to be longer acting in preventing conception.
With regard to continuous PZP use, there appears to be at least seven mares at McCullough Peaks that have never foaled, and may perhaps be sterile, possibly due to PZP. This includes: Taurus, Sanita, Onyx, Black Beauty, Neka, Seminole, and Sunrise. All these mares were born around the time that the PZP program was initiated and all are between 11-13 years or age. These are only anecdotal field observations, as I have no access to the BLM's specific data on darting or foaling, but it is possible that their individual immune systems reacted differently to the administration of PZP, thus rendering them sterile. This unexpected effect could work to balance out population growth on a herd-wide scale. It is requested that the fertility of these mares be further evaluated and if this hypothesis proves correct, the potential infertility of these breeding age mares should be factored into any projected growth rate for the herd.
3) On page 13 of the EA it is stated that the BLM must “manage the rangelands to prevent the range from deterioration associated with an overpopulation of wild horses”, however, the BLM has provided no data nor any other indication that the rangeland is indeed undergoing deterioration. If there is no indication of deterioration, nor data to support this theory, what is the rationale for the proposed gather?
In addition, there is no data analysis provided for the impact of livestock grazing on the rangeland. Within the EA, the consideration of changes to livestock grazing was essentially dismissed out of hand with no analysis provided. An evaluation of the impact of livestock grazing is required to determine rangeland health which is needed before any wild horses are permanently removed from the McCullough Peaks HMA.
4) It is stated on page 6 of the EA that “Cody Field Office will not remove the older population of horses living within the McCullough Peaks HMA.” At this time, 59 horses at McCullough Peaks are greater than 15 years of age with 22 of them over the age of 20. Page 18 of the EA states that “the older population of horses represents 13% of the current population”, which would indicate that the “older population of horses” are horses over the age of 20.
The EA also states on page 10 that “Any animals affected by a chronic or incurable disease, injury, lameness or serious physical defect (such as severe tooth loss or wear, club foot, and other severe congenital abnormalities) would be humanely euthanized using methods acceptable to the American Veterinary Association (AVMA).” Horses are categorized as “seniors” beginning at 15 years of age and at that time they begin to experience tooth loss and wear and would be more likely to present with lameness or injury. If horses in this age range are caught in the bait trap and examined, it can be inferred that those with age-related issues will be euthanized as outlined in the EA. Since these senior horses make up one-third of the population, it is feared that a high percentage of these senior horses will be removed from the population immediately, thus negating the statement that members of the older population will be allowed to remain on the range. Issues that are indicators of a horse’s senior status (i.e., severe tooth loss or wear, lameness, etc.) should not be considered as criteria for euthanasia for any of the McCullough Peaks herd.
5) The aging population of horses at McCullough Peaks is extremely concerning. Population numbers will continue to plummet as natural attrition of older horses decrease the herd size significantly over the next few years. This expected die off will drop the population to dangerously low numbers, well below the requirements for genetic viability, even without the proposed bait trap removal.
There are currently 181 adult horses at McCullough Peaks (yearling to 26 years old). Of these 181 horses, 59 are greater than 15 years of age with 22 of them over the age of 20. Of the 22 horses over 20 years of age, 5 of them are more than 24 years old. These horses over 24 years of age (all mares) appear to be in ill health and will, most likely, not survive another winter.
Eleven horses were lost during the winter of 2022/2023: 9 stallions, 1 mare and 1 newborn foal. Of the horses lost, 9 were over 15 years of age. In assessing the condition of the remaining older horses, it is possible that the McCullough Peaks herd could lose approximately 15-20 older horses into the spring of 2024. When this current rate of attrition is coupled with the 2% average yearly growth rate, the population of adult horses at McCullough Peaks may well fall within AML over the next few years, thus negating the need for this costly bait trap removal.
6) The start date of the proposed bait trapping is recorded in the EA as during fall 2023, sometime around November 1, 2023. The end date of the proposed bait trapping is difficult to determine when reviewing the EA as there are conflicting timelines listed. Page 9 of the EA states “Implementation of management actions would begin in the fall of 2023 and would continue until environmental conditions or policy and management objective changes require new analysis of additional management actions”. It is unclear if the “environmental conditions” noted in the statement above refer to winter weather conditions. If that is the case, we could infer that because the traps cannot be accessed during winter weather, they would be closed so that horses would not be left inside the traps unattended, without food, water or shelter, for extended periods of time.
Conversely, page 10 of the EA states “The proposed gathers would occur between November 15 and March 15 for bait trapping when conditions are conducive to gather due to the horse’s responsiveness to hay. Approximately 40% of the McCullough Peaks HMA is accessible to BLM staff during winter months when conditions are conducive to conducting a bait gather. Bait gathers would conclude by March 15 in order to avoid disrupting sage grouse breeding season”. This scenario would draw one to conclude that bait trapping would continue through the winter months.
In addition, the table on page 23 of the EA, states that the timing of the gather is November 1 to February 28 and “BLM would plow the access roads to the traps, if there are horses within the trap that need to be shipped to off range corrals”. This would imply that trapping would continue during winter weather with horses remaining in the traps during storms. Appendix E-Gather Operations Standard Operating Procedures (page 32 of EA) states that “BLM Personnel shall provide animals held in traps with a continuous supply of fresh clean water at a minimum rate of 10 gallons per animal per day. Animals held for 10 hours or more in the traps shall be provided good quality hay at the rate of not less than two pounds of hay per 100 pounds of estimated body weight per day”. In addition, page 33 of the EA states that “Traps shall be checked a minimum of once every 10 hours.”
Because of the extreme winter weather experienced at McCullough Peaks HMA, roads and two tracks can be inaccessible for days or weeks at a time. Plowing would not be possible on interior roads within the HMA as plowing is often impossible even on main highways. When the McCullough Peaks HMA experiences winter storm activity with high winds causing extreme snow drifting, it is unreasonable to expect BLM personnel to be able to access any horses contained in the traps every 10 hours to ensure they have sufficient water and food. If horses are stuck in the traps during a winter storm without food water or shelter, they could perish. Because of this, all bait trapping operations should cease, with traps closed, during the onset of winter weather.
7) The EA states that BLM staff familiar with identification of the horses will most likely conduct immediate bait trapping operations. The EA also states on page 6 that “In subsequent years a contractor may be utilized” and on page 9 that “gather operations would be conducted by BLM personnel or a contractor”. A contractor should never be utilized to perform bait trapping at McCullough Peaks since they don’t have the BLM’s detailed knowledge of these horses. BLM staff members know each horse’s age, history and genealogy and as stated on page 6 of the EA “will help ensure that family bands will remain together and the proper horses slated for removal are safely trapped”. Because contractors lack this essential information related to the McCullough Peaks herd it is imperative that only trained BLM staff members, familiar with these horses, conduct any bait trapping operations.
8) What is presented in this EA is a 10-year plan, meaning that for all the actions the BLM are planning to take over the next 10 years, this is the only opportunity they are giving for the public to comment. This is a violation of NEPA, the National Environmental Policy Act. The BLM needs to give the public an opportunity to comment each time they are taking action against the McCullough Peaks Herd.
9) For more than ten years, the population at McCullough Peaks has been successfully managed using PZP. This is a major accomplishment and has become a model to follow for other HMAs. With only a 2% average yearly growth rate for this herd, it is evident that PZP is effective. Because of this, the BLM should continue with its use of PZP for birth control without the implementation of Gonacon as a secondary population management tool. In addition, natural attrition should bring population numbers within AML over the next few years, so the Proposed Action Alternative, of bait trapping, should be dismissed.
