Dear Mr. Guevara: 

Our organization, Friends of a Legacy-McCullough Peaks Mustangs (FOAL), is hereby providing comments pertaining to the Scoping Notice of January 2023 for “Population Control  Measures and Removal of Excess Wild Horses in the McCullough Peaks Herd Management  Area,” reference 4700 (WYR020). 

FOAL was organized in 2005 with our Mission Statement to protect and preserve the wild horses  of the McCullough Peaks. We signed our first Memorandum of Understanding with the BLM  Cody Field Office on July 27, 2006 as a formal means of partnering with the BLM to help  manage the wild horses and enhance their habitat, to the benefit of all the creatures that live there  and to the benefit of the public. We are pleased to note much success in our partnership with the  BLM during the last 17 years.  

And it is our intent to maintain a positive working partnership with the BLM going forward. Please know that our comments are meant as helpful suggestions. 

If, as stated in the first paragraph of the Scoping Notice, this EA is to be the guiding document for management of the wild horses for the next 10 years, then it makes sense that great care must be taken in planning the alternatives. We suggest that a thorough, comprehensive analysis of past and present practices for range management and wild horse population control must be considered in order to inform the best alternatives going forward. In particular, all documentation which pertains to the use of immunocontraceptives, starting with the gather in  2004, should be studied. 

Analysis of this information, especially since 2011 when porcine zona pellucida (PZP) inoculations were delivered more consistently and to most of the mares, will point out what  worked and what did not work in reducing the number of foals born each year. This should help in forming plans for the use of immunocontraceptives or alternate fertility control measures  during the next 10 years. 

Past, present and projected (future) ages of the horses should be considered in the EA. It has been noted that the mares which have responded to the fertility control (i.e. those mares that have  been inoculated with PZP and have not been foaling every year) are now living longer, but we may be very near that tipping point at which even those mares will die off in greater numbers. This expected attrition should be factored into the projections for removal of horses. 

Factors which relate to herd health should also be considered. Genetic diversity should be  maximized within the herd by analyzing genotypes during the selection process for the removal  of horses following any bait gathers. Behavioral changes in individual horses and general changes in herd dynamics should be mitigated whenever possible through the utilization of safe  fertility control operations as well as through the careful selection of horses to be removed from  the herd. 

“The BLM is proposing to gather and remove excess wild horses to the low AML.” This  sentence, directly quoted from the Scoping Notice, demands explanation. 

It may be interpreted to mean that the BLM proposes to remove over 100 horses in order  to bring the herd number close to the low AML number of 70 horses. When we questioned the  Cody Field Office about this interpretation it was explained to us that their intention is to reduce  the number of wild horses in the HMA with the use of bait trap gathers, over time, to close to 140  adult horses. FOAL agrees with those intentions, but we submit that this should be clarified in  the EA. We further recommend the removal of no more than 20 horses in the first bait trap  gather and that further analysis of the efficacy of the fertility control program and the total  number of wild horses on the HMA be taken into account in order to determine how many  horses, if any, should be removed in subsequent bait trap gathers. 

“The BLM also proposes to use alternate fertility control for those mares not responding to PZP treatments.” Please consider our suggestions concerning this direct quote from the  Scoping Notice:  

1. We recommend adherence to a stricter schedule for field darting mares with PZP, with emphasis on targeting those mares which have not been responding to PZP treatments in recent years. Our research indicates that during the early years  when the PZP field darting program was fully implemented (2011-2014), most of  those same mares that are currently classified as “non-responder” did respond to  the PZP treatments by not producing a foal in a given year. It is noted that in those cases the responding mares were inoculated with their third dose or fourth dose of PZP within nine months of the time when they had received their previous  dose. We conclude that inoculating the non-responding mares within nine months  of their previous inoculation may cause the desired response.  

2. We have learned that an alternate form of PZP, namely PZP22, is available upon request. It can be produced by the Science and Conservation Center in Billings, which has also been our source for the standard PZP inoculant that has been used to date in field darting the McCullough Peaks mares. PZP22 has proven to be longer acting in preventing conception; therefore, we recommend its use when  treating those non-responding mares.  

We note that the vaccine GonaCon has also been considered for fertility control. Our research shows that GonaCon is apt to cause persistent cysts or oozing abscesses at the injection site, when injected into males it causes sterilization, and that it causes behavioral changes in the mares. We do not recommend the use of GonaCon. 

We know from experience that successful field darting in the McCullough Peaks herd requires a  large block of personnel time as well as a resource commitment. Please know that FOAL, to the  best of our ability, is offering to continue to provide assistance in the form of volunteers and other resources to be utilized to carry on the immunocontraceptive program into the foreseeable future. We submit that the intent of this project might be stated as: Maintaining a stable, appropriate number of healthy wild horses in the McCullough Peaks HMA while concurrently meeting high standards for range conditions. 

We commend the BLM Cody Field Office for their foresight in proposing that this project be accomplished in phases over a 10-year period. We believe this approach will prove to be a viable and humane way to manage wild horses in the McCullough Peaks HMA. 

Thank you for considering our comments. 

Sincerely yours, 

Mary Scuffham

President  

Marshall Dominick 

On behalf of FOAL Board of Directors