August 7th, 2012
BLM Landers Office
1335 Main Street
Lander, Wyoming 82520
phone 307 332 8400
fax 307 332-8444
Dear Scott Fleur,
First of all, it's detailed document with the exception of the difficulty of finding some very important information. That is, nowhere in the document can I find the percentage of livestock utilization though the number of AUM's allotted to livestock is well over 40,000 (over 3,333 cattle on the Lander's complex HMA's every month of the year). (Appendix 6)
I am always amazed at your agency's chutzpah when it comes to livestock. You simply don't seem capable of understanding that 40,000 AUM's allocated to livestock is NOT "evening out the use" as JoLynn Worley put it a few months ago. So, yes, you could consider at some point allocating more AUM's to wild horses and you certainly have the latitude to leave more than the minimum AML on the complex once the roundup is completed.
And like many advocates, I'm concerned about the SpayVac. I'm more than a little surprised its being considered for field use so soon since the Paul's Valley study started barely a year and a half ago and there are no published reports as of yet. (Or are there?)
I've also included quotes from BLM Press Releases and the BLM's own website that express reservations about using the vaccine until the results of the study become known.
Bureau of Land Management
Contacts: Paul McGuire (Oklahoma) (405-794-9624) Heather Emmons (Nevada) (775-384-7966) Tom Gorey (Washington, D.C.) (202-912-7420)
For release: Tuesday, April 26, 2011
"The goal is to see if SpayVac®, a novel formulation of a glycoprotein called porcine zona pellucida (PZP), will provide a longer-term effect than other PZP vaccines currently used by the BLM. If the vaccine is found to reduce foaling in this controlled setting, it will be considered for use with free-roaming horses to help control population growth rates on the range."
"SpayVac™ is an experimental fertility control vaccine using PZP antigens. A single vaccination with SpayVac™ has maintained a high level of contraception throughout the 4-year Nevada estray horse study. There is no regulatory approval for the management or investigational use of SpayVac™ through EPA or FDA. There is no SpayVac™ available for investigational use and no one is currently making it. Data is not available that describes the impact of SpayVac™ on the behavior and physical health of the mares. SpayVac™ may have potential for use as an effective, longer-lasting fertility control agent in the future. It may also offer an alternative to spaying mares in the future. However, additional research over the next 5-10 years would be needed before it could be used on a population-management basis."
My question is this. What do you know about the Spay Vac vaccine that would cause you to hurry up and test it for field use? And why are you testing it in a relatively large area like the North Lander Complex when fertility control projects are better tested in smaller HMA's like the Pryor Mountains?
What seems to be "out there" in terms of information is that Spay Vac is effective on reproduction rates but that its effects are not reversible in all mammals.
Because of those concerns, I would ask you to use the PZP-22 instead of the SpayVac until more information is known. I would also ask you, if you insist on using the SpayVac, to release more than the low AML.
While I'm sympathetic to the need for fertility control, I object to the counting those 60 SpayVac experimental mares as part of the low AML especially and in case many of the mares have their reproductive ability severely compromised.
I was also shocked that you would consider an Alternative that would geld stallions and return them to the HMA. While glad that is not the preferred alternative, returning geldings to the HMA is not very efficacious in lowering birth rates as your chart indicates, and is a direct violation of the viable herds mandate. So is sterilizing mares. Please be careful that you don't do either of those to the North Landers complex horses.