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January 23, 2015

BLM Mount Lewis Field Office
Attn: Michael Vermeys, Acting Field Manager
50 Bastian Road
Battle Mountain, NV 89820
Via email:
RE: Environmental Assessment DOI-BLM-NV-B010-2015-0011-EA
Dear Mr. Vermeys,
These comments on the Environmental Assessment (EA) entitled “Fish Creek Herd Management
Area Wild Horse Gather Plan ” (DOI-BLM-NV-B010-2015-0011-EA) are submitted on behalf of
the American Wild Horse Preservation Campaign (AWHPC). They are endorsed by the xx,xxx
citizens who have submitted their own comments in opposition to the proposed roundup and the
inadequacy of the EA.
AWHPC is dedicated to preserving the American wild horse in viable free-roaming herds for
generations to come, as part of our national heritage. Our grassroots efforts are supported by a
coalition of over 70 historic preservation, conservation, horse advocacy and animal welfare


The Proposed Action involves an roundup to be completed early in 2015 which would include
the capture of all horses the Bureau of Land Management (BLM) estimates to be living in the
Fish Creek Herd Management Area (HMA), i.e. approximately 500-549 wild horses, and the
permanent removal of 200 wild horses from the HMA with the remaining 300-349 horses to be
released (including application of the PZP (Porcine Zona Pellucida) fertility control vaccine to
the estimated 150-175 mares targeted for release)The Proposed Action includes returning horses
to the range in the same sex ratio as those horses rounded up.The 2015 roundup would be
conducted with a helicopter.
The EA states that the 2015 roundup is the “first phase” in a long-term population management
strategy that involves large scale wild horse roundups in an attempt to attain the BLM’s
Appropriate Management Level (AML) of 101-170 wild horse for the HMA. This AML is based
on the BLM allocation of 72 percent (72%) of forage resources in the HMA to privately-owned
livestock that are permitted by the agency to graze in the HMA. The proposed action includes,
over the next ten years, the BLM would continue to implement fertility control through bait and
American Wild Horse Preservation Campaign, P.O. Box 1048,
Hillsborough, NC 27278

AWHPC comments on EA Fish Creek HMA
January 23, 2015
Page 2

water trapping, darting and helicopter roundups. The BLM plans to continue using helicopters
roundups in order to implement population growth control protocols and to remove wild horses.
AWHPC supports the BLM’s plan to use PZP fertility control in this roundup and over the longterm plan to manage population growth. We also support the maintenance of natural sex ratios as
artificially skewing wild horse sex ratios causes increased stress and aggression among wild
horses. Following is a summary of our comments regarding the remaining aspects of the
agency’s Proposed Action:


AWHPC opposes the removal of any wild horses from the Fish Creek HMA and instead
recommends the reduction of private livestock to accommodate wild horse populations
(see below) and the gradual reduction of the wild horse population through the
application of PZP and natural attrition.

AWHPC urges the BLM to use bait and water trapping and/or remote darting to apply
PZP fertility control as a priority method for capturing horses. Helicopter roundups
should only be used as a last resort and only after bait trapping and remote darting have
proven unsuccessful.

AWHPC strongly urges the BLM to maintain social structure of horses captured in CatchTreat-Release (CTR) roundups. This will reduce the stress and trauma of wild horses
captured by ensuring that social groups are kept together at all times and will likely make
it easier to recapture these horses for subsequent vaccination with PZP. .

If BLM does use helicopters to roundup horses, AWHPC recommends the addition of
strict policies addressing distance, pace, and temperature issues, as detailed below and
attached, in the standard operating procedures (SOP) for helicopter roundups and/or the
animal welfare policy.

The BLM should select the alternative that would result in the suspension or reduction of
livestock grazing, as permitted by law, in order to accommodate the current wild horse
population until it is gradually reduced through the use of fertility control and natural
attrition. Permittees could be compensated for non-use, an action that would still be costeffective given the high cost of rounding up, removing and warehousing wild horses in
holding facilities.

1. AWHPC Supports an Alternative that Would Reduce the Wild Horse Population Through
Fertility Control Only
AWHPC opposes the removal of 200 wild horses from the HMA and instead urges the BLM to
accommodate the present wild horse population and to reduce its size gradually, over time,
through the PZP fertility control program, in accordance with Alternative 2, (EA at 17-18).
Through use of PZP fertility control, BLM has successfully managed population growth and

AWHPC comments on EA Fish Creek HMA
January 23, 2015
Page 3

attained zero population growth in other HMAs, such as the McCullough Peaks herd in
Wyoming, and we believe that your program should be given the time necessary to gradually
reduce the herd size through fertility control and natural attrition. Certainly, administering PZP
and keeping these animals with their families on the range is more in line with the BLM’s
mandate for “minimally feasible management” and a far more humane and fiscally sustainable
management approach than permanently removing wild horses from the range.
The National Academy of Sciences (NAS) report entitled Using Science to Improve the BLM
Wild Horse and Burro Program: A Way Forward (Attachment 1) upheld the validity of PZP
fertility control for use in wild horses:
In the short term, more intensive management of free-ranging horses and
burros would be expensive. However, addressing the problem immediately with
a long-term view is probably a more affordable option than continuing to
remove horses to long-term holding facilities.
(NAS Report at 306) (emphasis added.).
Most promising fertility-control methods for free-ranging horses or burros are
porcine zona pellucida (PZP) vaccines and GonaCon™ vaccine for females and
chemical vasectomy for males. This conclusion is based on criteria such as
delivery method, availability, efficacy, duration of effect, and potential for side
effects. Although applying these methods usually requires gathering horses and
burros, that process is no more disruptive than the current method of population
control — gathering and removal — without the further disruption of removing
animals. Considering all the current options, these three methods, either alone
or in combination, offer the most acceptable alternative to removing animals
for managing population numbers. (See Attachment 1).
Under the management regimes reviewed by the committee, BLM will have to
remove free-ranging horses from western rangelands indefinitely unless very
aggressive fertility-control programs are implemented (Garrott, 1991; Eagle et
al., 1992; Garrott and Siniff, 1992; Gross, 2000; Bartholow, 2004, 2007). As
briefly discussed in Chapter 2, there may be more horses in the short-term and
long-term holding facilities than on the range. An average of more than 8,000
horses are moved from the free-ranging population to holding facilities annually,
and almost 60 percent of the Wild Horse and Burro Program’s budget was
allocated to the care and maintenance of captive animals in fiscal year 2012
(BLM, 2012c). The amount of money needed to care for horses in the long-term
holding facilities will continue to increase and, in the long run, could consume
the entire budget allocated to the Wild Horse and Burro Program. (NAS Report at
No method that does not affect physiology or behavior has been developed. The
most appropriate comparison in assessing the effects of any fertility-control
method is with gathering. That is, to what extent does the prospective method
affect health, herd structure, and the expression of natural behaviors compared

AWHPC comments on EA Fish Creek HMA
January 23, 2015
Page 4

with the effects of gathering? The selected methods are considered the most
promising because they have the fewest and least serious effects on those
parameters. Their application requires handling the animals (gathering), but this
process is no more disruptive than the current method for controlling numbers
and does not entail the further disruption of removal and relocation to long-term
holding facilities. Considering all the current options, these three methods,
either alone or in combination, offer the most acceptable alternative for
managing population numbers. (NAS Report at 7)
Published research documents both the cost-effective nature of using PZP fertility control
(Attachment 2) and its success in attaining population goals. (Attachment 3).
As mentioned in the NAS report and as cited in the EA, the BLM is spending a large percentage
of its Wild Horse and Burro Program budget on the stockpiling of approximately 50,000 wild
horses in government holding facilities – this is based on the agency’s failure to humanely
manage the wild horse herds on the range and its insistence instead on continuing its roundupremove-warehouse approach. Although this EA outlines a path for increased use of fertility
control, it still includes large-scale wild horse removals, which will exacerbate the fiscal crisis
currently faced by the BLM’s Wild Horse and Burro Program.
AWHPC supports the BLM’s plan to maintain the natural mare to stallion ratio and to refrain
from adjusting the sex ratio to favor stallions. Alternative 3 outlines the possibility of unnaturally
skewing the sex ratio in the Fish Creek HMA, favoring stallions and resulting in large bachelor
bands within the area. AWHPC opposes this option.
The BLM in other wild horse roundup EAs has acknowledged that a natural sex ratio generally
favors females, or may be close to a 50:50 distribution. These EAs have predicted that unnatural
sex ratios of 60:40 or higher favoring males could have impacts, including:
“competition for mares would be expected to increase, recruitment age for
reproduction among mares would be expected to decline [meaning younger
mares would begin breeding] … Fighting between band stallions and surplus
stallions could result in the mares and foals not being allowed to feed and water
naturally as the herd stallion tries to keep them away from bachelor bands.” (See
Black Mountain Hard Trigger EA, p.19, available at
AWHPC encourages the BLM to strive to maintain natural sex ratios of the individual
populations on the range, and that any removals that do take place should be conducted in
accordance with that goal.
2. AWHP Urges the Use of Helicopter Roundups Only as a Last Resort and Urges BLM to
Include More Stringent Humane Standards if Helicopter Roundups Are Used

AWHPC comments on EA Fish Creek HMA
January 23, 2015
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AWHPC believes that costly and traumatic helicopter roundups should be used only as a last
resort and instead supports the use of bait and water trapping and remote darting as the priority
management tool over the next ten years, as outlined in Alternative 2. Concerns about the
negative animal welfare implications of helicopter roundups are particularly acute in winter,
when heavily pregnant mares will be subject to helicopter stampedes over miles of difficult
terrain. Previous BLM data indicate that these mares suffer a high level of spontaneous abortions
and the number of foal deaths can also be high. (See Attachment 4)
AWHPC recommends that fertility control be administered through remote darting and/or bait
and water trapping – however, if a helicopter is to be used, we ask the BLM to consider and
implement the following additional humane standards to improve standards for a helicopter

Limit the distance horses may be chased by a helicopter to no more than five (5) miles.

Require that the helicopter not chase/move horses at a pace that exceeds the natural rate
of movement of the slowest animal in the band. Every effort should be made to keep
older, sick and young animals together with their bands as they are moved into the trap. If
there are compromised, old, weak or young animals in a small band – the helicopter
should not move or capture those animals.

Establish strict parameters for suspending helicopter roundup operations in temperatures
below freezing or over 95 degrees F.

Implement AWHPC’s Catch-Treat-Release (CTR) draft SOP (Attachment 5) to ensure
humane treatment by maintaining the integrity of wild horse social bands. Tenets
included in the CTR SOP should be incorporated into non-CTR helicopter roundups.
Maintaining social groups of the captured horses will reduce the stress and trauma of the
roundup. Horses are highly social mammals; indeed wild horses are well documented as
having strong social bonds. The separation of bonded horses – or those in social groups
either harem bands or bachelor bands – is highly stressful and traumatic. In order to
increase the success of the future recapture of horses for future applications of PZP
fertility control, AWHPC strongly urges the BLM to undertake capture operations in a
manner that keeps the social groups together.

The distance, pace, and temperature issues outlined in the BLM’s helicopter SOP, (EA at 1089), and animal welfare policy is inadequate. For example, chasing wild horses with helicopters
for “ten miles or more” is not acceptable in any situation. Equally inadequate is the lack of
definition of when “operations may case based on temperature” – specific temperature
parameters are needed rather than relying on inconsistent, subjective personal opinions. We urge
the BLM to adopt the above stated specific and quantifiable humane standards rather than
allowing the current inadequate standards and policies to stand.

AWHPC comments on EA Fish Creek HMA
January 23, 2015
Page 6

In addition, the EA must analyze the humane recommendations made by the Humane Society of
the United States (HSUS) regarding roundups. If helicopters are used, the BLM should install
real-time video cameras on helicopters and at trap and holding corral locations. (Attachment 6)
This recommendation of real-time cameras is also supported by a report commissioned by
Cattoor Livestock Roundup, a long-time roundup contractor hired by the BLM which states,
“Video monitoring of animal operations is a good way to ensure humane handling is taking
place on a daily basis. Video cameras mounted in helicopters and in the capture and holding
pens can also render the activists videos as simply nothing more than proof that your business
‘walks the walk’ when it comes to upholding animal welfare standards.” The report was prepared
by Mark J. Deesing, Animal Behavior & Facilities Design consultant for Grandin Livestock
Handling System. Deesing is an assistant to the highly-regarded livestock industry consultant Dr.
Temple Grandin.
Video cameras will improve the transparency of roundup operations and enable the BLM and the
public to monitor the direct impact that motorized vehicle usage has on wild horses and the
environment. In addition, real-time cameras should be installed on the trap, the corral and
temporary holding pens, again, so that BLM personnel, public and media can monitor the entire
roundup operation and treatment of the horses. AWHPC would be happy to provide technical
assistance and financial assistance to establish these real-time cameras as described above.
3. The BLM Should Reduce or Suspend Livestock Grazing in Order to Accommodate the
Current Wild Horse Population
a) Livestock Grazing Poses a Greater Threat to Public Rangelands than Wild Horse
The BLM asserts that the removal of horses is necessary to a establish a “thriving natural
ecological balance” as well as “to achiev[e] and maintain[] wild horse populations within the
established AML so as to manage for a healthy wild horse populations and healthy rangelands,”
(EA at 4-5). As a result, the BLM allows only a maximum of 170 federally protected wild horses
to live in the 230,675-acre Fish Creek HMA, while authorizing more than twice as many Animal
Unit Months (AUMs) of forage to livestock (5,279 AUMs for livestock in the four grazing
allotments that lie partially or wholly within the HMA vs. a maximum of 2,040 AUMs for wild
horses). Indeed, BLM states that livestock grazing is expected to “continue at similar stocking
rates and utilization of the available vegetation (forage) would also be expected to continue at
similar levels,” (EA at 99). We acknowledge that the actual use of livestock AUMs within the
HMA is reduced from the permitted numbers. However, the permitted AUMs must be more fairly
allocated. Voluntary retirement opportunities should be explored with permittees to determine an
equitable means to achieve a fairer allocation of resources for wild horses on public lands.
A recent study conducted by Public Employees for Environmental Responsibility (PEER), and
hereby incorporated in these comments, found that the BLM’s method in assessing rangeland
conditions is seriously skewed toward minimizing impacts from domestic livestock and
magnifying those from wild horses and burros, (see BLM Weighs Wild Horse Impact Much
More Heavily Than Cattle, available at

AWHPC comments on EA Fish Creek HMA
January 23, 2015
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releases/2014/09/16/blm-weighs-wild-horse-impact-much-more-heavily-than-cattle/). PEER
found that the BLM’s approach to range management targets scattered wild horses and burros
while ignoring far more numerous cattle. The organization based this finding on an appraisal of
the BLM’s report assessing the factors influencing the Great Sage-Grouse habitat. The BLM
found that twice the area of sage grouse habitat is negatively impacted by wild horses and burros
than the area negatively impacted by livestock. However, PEER’s review of this report
concluded that the agency did not use the same approach for calculating the area of influence of
livestock within BLM grazing allotments on sage grouse habitat as it did for wild horses and
burros. If it had, then the area of influence for livestock would be roughly 14 times that given in
the report and more than six times that of wild horses and burros.
Furthermore, the NAS also concluded that there are significant differences between grazing
habits of wild horses and livestock:
Cattle and horses are both primarily generalist grazers, consumers of palatable
herbaceous vegetation. Horses and burros, however, are able to use lower-quality forage
than cattle because of their cecal-digestive system (Hanley, 1982; Hanley and Hanley,
1982). Burros preferentially consume woody vegetation (shrubs, dwarf shrubs, stemmy
forbs, and small trees). Horses and cattle use similar habitats, but they also diverge with
respect to mobility and accessibility. Horses can travel great distances in a short time,
they can travel further from water, and they can use rugged topography more readily
than can cattle (Ganskopp and Vavra, 1987; Hampson et al., 2010).
Although it is often assumed that cattle, horses and burros, or wildlife always compete,
recent research on zebras and cattle and on cattle and donkeys (donkeys served as
surrogates for zebras in controlled experiments) showed that it is not always the case.
(NAS Report at 239)
b) BLM Is Statutorily Required to Protect and Preserve Wild Horses
AWHPC must remind the BLM that it has a statutory mandate under the Wild Free Roaming
Horses and Burros Act (“WFRHBA”) to protect and preserve wild horses, whereas commercial
livestock grazing is authorized at the discretion of the Secretary of the Interior.
Furthermore, the BLM’s multiple use mandate does not require livestock grazing, but rather can
be achieved through other uses of the public lands. BLM managers must manage the health of
our public lands with all conflicting land-uses and alternatives considered in a comprehensive,
common sense way. Instead, the BLM routinely presents the public with what amounts to
foregone conclusions to roundup and remove wild horses in contravention of the letter and the
spirit of the NEPA mandate to take a “hard look” at all reasonable alternatives.
Pursuant to § 1333(b)(1) of the WFRHBA, the agency must:
“make determinations as to whether and where an overpopulation exists and whether
action should be taken to remove excess animals.”

AWHPC comments on EA Fish Creek HMA
January 23, 2015
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Therefore the simple fact that a population is over the arbitrarily established AML does not
automatically equate with an “excess” determination. Instead, the BLM could accommodate the
current wild horse population living in the HMA by temporarily suspending commercial
livestock grazing, pursuant to 43 C.F.R. 4710.5(a) and (c), which authorize the BLM to
temporarily or permanently close a public land area to livestock grazing "[i]f necessary to
provide habitat for wild horses or burros, to implement herd management actions, or to protect
wild horses or burros, to implement herd management actions, or to protect wild horses or
burros from disease, harassment or injury. Livestock grazing in this HMA is extensive, and BLM
has disproportionately allocated resources on these public lands to private livestock instead of
federally protected wild horses.
It is unreasonable of the BLM to continue to allocate to livestock thousands of AUMs while
continuing to enforce the unreasonably low AMLs established in wild horse and burro HMAs.
The law does not require that the BLM remove horses merely because they are over the
arbitrarily set AML. Rather, the law requires BLM to show that the existence of the horses on the
range – as opposed to livestock or other factors – are causing harm to the "thriving natural
ecological balance" in an HMA. As detailed above, the damage to public rangelands caused by
livestock greatly outweighs any damage caused by wild horses. Therefore, we maintain our
strong opposition of the removal of any horses from this HMA.
c) The Alternative that Includes Suspension or Reduction of Livestock Grazing Must Not
be Dismissed
As mentioned above, the WFRHBA is clear that the preservation of wild horses must take
precedence over access by livestock on public lands. Accordingly, if the agency believes that the
range is being damaged, it should first eliminate or reduce substantially the private livestock
from these areas before resorting to removing more wild horses. In fact, the annual equivalent of
thousands of livestock which continue to be permitted to graze within the HMA should
temporarily be suspended in order to provide forage for wild horses until the populations can be
controlled through the use of humane PZP fertility control.
The BLM authorizes livestock grazing on four allotments within the Fish Creek Complex, which
are allocated a total of 8,855 AUMs. As stated in the EA, approximately 55 percent of these
allotments overlap with the Fish Creek HMA. According to the percentages these allotments
overlap with the Fish Creek HMA (see EA page 64), approximately 5,279 AUMs within the
HMA are allocated to livestock grazing. Combining the permitted livestock AUMS (5,279) with
the 2,040 AUMs (170 wild horses) and equitably allocating the AUMs the high AML for wild
horses would be 305 horses. While we understand the altering of livestock permitted AUMs is
outside the scope of this EA, we want to highlight that we, along with the majority of the
American public, support a more equitable allocation of resources for America’s wild horses and
burros. That nearly 2,000 AUMs of actual use of livestock grazing occurred in the HMA in each
of the last two years (2013 and 2014) suggests that the BLM believes the range can continue to
support adding private, commercial livestock to this specific area. (It’s unclear what actual
grazing occurred in 2014 as only billing rates were provided in the EA).

AWHPC comments on EA Fish Creek HMA
January 23, 2015
Page 9

BLM wild horse roundups, removals and off-the-range warehousing of captured wild horses cost
taxpayers $60 million annually, while taxpayers pay in excess of $500 million per year to
subsidize livestock grazing on public lands. Yet, the BLM presents the public with what amounts
to a foregone conclusion to remove 200 wild horses from the Fish Creek HMA in contravention
of the letter and the spirit of the NEPA mandate to take a hard look at all reasonable alternatives.
Indeed, the BLM once again dismisses alternatives to reduce livestock grazing in the HMA,
despite the significant impacts of the Proposed Action, including the addition of 200 wild horses
to a holding system that is already overburdened by the warehousing of over 50,000 wild horses
at taxpayer expense. Indeed, given that that the 200 horses targeted for removal will, in all
likelihood, be warehoused in short-term facilities for at least the first year (and possibly for
many years to come) … at a cost of $1,500+ per horse per year … removing 200 horses will cost
in holding costs $300,000 each year. This staggering cost is in addition to the approximately
$100,000 it will cost to use a helicopter to remove the 200 horses.
The BLM asserts that, although the agency is authorized to remove livestock from HMA “if
necessary to provide habitat for wild horses or burros, to implement herd management actions, or
to protect wild horses or burros from disease, harassment or injury” (43 C.F.R. § 4710.5), “this
authority is usually applied in cases of emergency and not for general management of wild
horses and burros,” (EA at 27), and that reduction or elimination of livestock grazing would be
“inconsistent with the current LUP/RMPs and/or FMUDs for the grazing allotments within the
Fish Creek HMA or with multiple use management,” (id.).
The BLM cannot dismiss this alternative by claiming that its discretion under 43 C.F.R. §§
4710.3-2 and 4710.5(a) is limited to "emergency" situations, as there is no such restriction in the
regulations. Even if such a restriction did exist, an emergency does exist, since BLM holding
facilities are at capacity, with little room left to house more captured wild horses.
It is not acceptable – and is, in fact, a flagrant violation of NEPA -- for the BLM to dismiss this
alternative from consideration in the EA. The BLM has the clear legal authority to reduce or
eliminate livestock grazing in allotments associated with the Fish Creek HMA, pursuant to 43
C.F.R. §§ 4710.3-2 and 4710.5(a), in order to improve conditions and forage availability for wild
horses. An alternative that appropriately considers this approach within the EA of any wild horse
management proposal, which the public continues to demand, is clearly the most cost-effective,
humane and publicly supported approach.
4. NEPA Requires Further Analysis and Public Input Opportunity for Future Actions
The National Environmental Policy Act (NEPA) requires that BLM conduct further
environmental analysis and public comment for additional wild horse roundups and management
actions over the next 10 years. Due to changing environmental conditions, a blanket, ten-year EA
cannot be considered sufficient under NEPA.


AWHPC supports the BLM’s plan to use fertility control, both in the short and long-term, as well
as to maintain natural sex ratios for wild horses on the range. However, we oppose the removal

AWHPC comments on EA Fish Creek HMA
January 23, 2015
Page 10

of 200 wild horses in 2015 and any future planned removals. Further, AWHPC urges the BLM to
use bait and water trapping and/or remote darting to administer PZP fertility control and to only
utilize helicopters after trapping and darting are proven unsuccessful. If helicopters are used,
AWHPC strongly urges the BLM to adopt the humane distance, pace, and temperature standards
detailed above to reduce stress and possible injury to wild horses during helicopter roundups. We
strongly encourage the BLM to revisit the alternative that suspends or reduces livestock grazing
within the Fish Creek HMA to accommodate wild horses and to explore compensation
opportunities for permittees’ nonuse to accommodate wild horses. Such an alternative is within
the BLM’s authority and should be analyzed in the EA.
In closing, AWHPC strongly urges the BLM Battle Mountain District to take meaningful steps to
reform the wild horse program. In addition to the long-term plan to primarily utilize PZP fertility
control to manage population growth and maintain natural sex ratios, we strongly urge you to
implement the attach CTR SOP attached. At minimum, we urge you to implement this SOP with
portions of the horses targeted for the CTR portion of the roundup. There are always reasons why
now is not that right time to begin to do things differently. But if not now, when? Creative, outof-the-box approaches will be needed – and the ability to try new approaches and adjust to make
them as successful as possible is paramount. Now is the time, this is the roundup .. to start a new
chapter for the humane management of wild horses on the range. We look forward to working
with you and hope that you find a way to make this happen.

Suzanne Roy, Director
American Wild Horse Preservation Campaign
PO Box 1048
Hillsborough, NC 27278
1. “Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward,”
National Academy of Sciences, 2013
2. “An Economic Model Demonstrating the Long-Term Cost Benefits of Incorporating
Fertility Control Into Wild Horse (Equus Caballus) Management Programs on Public
Lands in the United States,” Journal of Zoo and Wildlife Medicine, 2013
3. “Achieving Population Goals in a Long-Lived Wildlife Species (Equus Caballus) with
contraception,” Wildlife Research, 2008
4. “BLM Calico Complex Roundup: A Case Study of a Broken System for Horses and
Taxpayers,” American Wild Horse Preservation Campaign, 2010.
5. “Draft Standard Operating Procedure for Wild Horse Treat-And-Release Gathers,”
American Wild Horse Preservation Campaign, 2012.

AWHPC comments on EA Fish Creek HMA
January 23, 2015
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6. “Recommendations on the Bureau of Land Management’s Standard Operating
Procedures for Wild Horse and Burro Gather Operations,” Humane Society of the United
States, 2011.