PZP Scoping Letter Response

Well folks, I don’t know about you but I finally got a chance to mail my letter. Like I promised in my last post here it is:

Dear Mr. Jim Sparks,

I am contacting you regarding the scoping notice about the use of PZP in the Pryor Mountain Wild Horse Range. Although I think that the current plan is effective, I have several concerns that make me think that an even more effective plan is needed. My first concern is that without a strong PZP plan, there may be a need for another removal despite the fact that the last one was last summer.  My second concern about the current PZP plan is that it offers no flexibility in the way PZP is administered. Adaptability with the management of any type of species is needed to have a healthy population, and I believe if PZP is used to control the population to help alleviate the need for removals, then it will give the BLM and others time to plan so a more natural means of management can be utilized in the future.

One of the things I would like to see with PZP is adapting the system so it looks at each individual mare rather than a range-wide system. Madonna, for example, although the exception to the rule, clearly has shown that she does not take to PZP since she had her most recent foal last year at age twenty-three. In my opinion, it would be far better to focus time, energy, and money towards PZP on the mares that are more responsive to treatment than the ones that have had foals year after year despite treatment.

Another concern I have with the lack of flexibility of the current plan is the need for horses that have a reaction to the drug to be taken off the list of mares given PZP. Phoenix, for example, had an extreme case in 2007 where she even had to be taken off the mountain to be treated. I would hope that if a mare has that type of severe reaction to PZP she would automatically be taken off treatment. Even if the reaction was not as severe, I strongly recommend reevaluating treatment for a mare. At the very least, there should be research done to determine if a reaction was from PZP.

Something else that needs to be taken into account when determining how much mares should be treated with PZP is the number of foals they have had in their lifetimes. If a mare has many foals, yet none of them survive to adulthood, then she should be left out of PZP treatment. However, if a mare has foals several years in a row and all of them make it to adulthood, than she should be considered for more PZP. With such a small herd size, it is important to maintain genetic viability, and I think adjusting PZP in an adaptive manner will help increase genetic viability while still maintaining a responsible population.

However, I also recognize that there are only so many resources available to the horses at this time, which is another reason why I would like to see PZP temporarily increased. Keeping the population low enough that no removals are needed will provide time for more natural management techniques to be utilized. If this is allowed to happen, then natural selection could be used as the primary management tool, and there may even be an opportunity to raise the AML with careful planning.

In order for the ALM to be raised, more land needs to be given to the horses, and if more land is given to the horses, then PZP use can be decreased. Perhaps with more resources the horses will spread out more, putting less pressure on the range they use now. Not only that, but if the horses are more spread out, then stallions might feel less need to compete for mares since they will be more likely to be out of sight and out of mind.

Something that I would eventually want to replace PZP use is predation population control. To my knowledge, there have not been any studies done on mountain lions in the area. I would be interested to learn if there are any in the area, and if not, I would like research done to assess the reasons why there are none so that measures can be taken to improve habitat to make it more desirable for mountain lions. In the long run, I would imagine that this type of population control would be more cost-effective than PZP and a better use of the American public’s tax dollars than removals.

The bottom line is that, in order to have effective management of the Pryor horses, then adaptability of management tools needs to happen. Adaptability that the BLM was already used this past summer, when bait traps were used rather than helicopters to remove horses. Thank you for taking comments in this very serious issue.

Sincerely,

Livi

Kohl

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