Public Comment of the Pryor Mountain Wild Horse Range

Jennifer Robin., WHBA. (2023, apr 28). Public Comment of the Preliminary Environmental Assessment (EA) for the Pryor Mountain Wild Horse Range (PMWHR) Joint Herd Management Area Plan (HMAP) Revision, Wild Horse Gather Plan, and Proposed Resource Management Plan (RMP) Plan Amendment to Management Decision (MD) WH-7.

ABSTRACT: The BLM Billings Field Office is preparing an Environmental Assessment that will consider several alternatives for a new Herd Management Area Plan and 10-Year Gather Plan for the Pryor Mountain Wild Horse Range, including objectives to manage the wild horse population within an Appropriate Management Level (AML) and to manage rangelands and riparian areas to maintain a thriving natural ecological balance. The EA will also analyze a proposed change to the RMP’s Management Decision Wild Horse (MD WH-7) with respect to managing genetic diversity in the Pryor Mountain Wild Horse herd.

WHBA – I oppose of this plan for multiple reasons. Removing the NEPA analysis requirement by issuing a long term 10 year plan of removal, you are eliminating my right to public participation and comment using current data and research relating to the land as required. You are “disregarding your statutory and regulatory obligation to undertake roundup-specific analysis of the horses and their habitat.” (FOA 2022). The WHB and the land are subject to environmental conditions that change over time due to climate (harsh winters/drought) and continuously changing herd structure due to man-made manipulation and removals, and ‘heavy use’ of fertility drugs. Due to this, and the small herd size that is practically non viable as, and the most recent genetics report is outdated from (2013), removal and current census should be evaluated prior to each roundup.

Considering we just had another massive ‘ungulate’ die (2023, April) off in Wyoming, Utah, and Colorado that estimates as many as “80% of ungulates may have perished due to harsh winter climates” and while those numbers have not been released, I see this as similar to the 1978 Pryor Mountain HMA die off of this here where 51% of the wild horses perished in one winter (“all the foals and old animals perished.” – TCF) , and in 1999,  4% of the Pryor herd died due to lightning strike from an electrical storm (Ransom 2016).  It has occurred multiple times with other herds on record too.

Environmental uncertainties make a long term plan foolish, and ill considered. To make plans ten years out is not basing anything on facts and reality. In terms of the horses (ungulates), many of these herds are so small, they are barely genetically viable as is, and also are treated heavily with fertility drugs. This herd is stated at 70% treatment (Sparks 2015).  This concoction of fertility treatments, natural deaths, predator, and unexpected winter dies offs like this could potentially eliminate entire herds and create a path to guaranteed extinction. That would be detrimental to all herds, particularly for the herds with unique, and rare Spanish heritage like this one.  While we have no control of the natural circumstances, we can control the rest.

A ten year plan is irresponsible and ill designed. This does not take any of these possibilities into consideration.  A small herd of 120 or less horse could not bounce back if they were to lose 50-80% of their herd, particularly if the only ones that survived a harsh winter have been ‘sterilized’ with Gonacon, or dosed with PZP (which has aloso been reported to cause sterilization, stillbirths, and out of season births).  Please rethink this plan and base management off of sound facts that are ‘current’, and not outdated by ten years. Friends of Animals v. Culver, Civil Action 19-3506 (CKK), 15 (D.D.C. Jun. 28, 2022)


PDF pg 8 The District Court found that BLM did not discuss the loss of patrilineal lines and established a one progeny rule without further discussion, suggesting to the court that BLM may have acted arbitrarily and capriciously by failing to consider the ramifications of the loss of horses it chose to remove.  / Although each individual represents a unique combination of available genetic material, maintaining a herd that largely retains the genetic material and diversity presently in the herd does not depend on each individual reproducing with each mate. Considering that there has been a history of interbreeding within this herd, one can understand that genetic information present in a specific mare and a specific stallion was also shared with their cousins, aunts, uncles, and more distant relatives.

WHBA –  It does if the herd is losing genetic viability annually. We see from records that 69 mares were treated with fertility vaccines in 2021 (BLM 2023). How many in this herd are producing foals in a given year, and how many foals survive to maturity and contribute. Where might we see this record of herd interbreeding, lineage and foal history?

PDF pg 9 Dr. Cothran recommended that no action was needed in 2013 to maintain adequate genetic diversity levels but suggested that the herd could drop below the mean heterozygosity for feral herds by 2023 if trends continued.  / However, it is not necessary to wait until the results of that fecal DNA-based monitoring effort are available for the agency to make decisions about herd management. The results of current and future genetic monitoring efforts, along with previous monitoring results, would indicate if loss of genetic diversity is a concern and if any of the management actions as noted in the proposed amendment would need to be taken.

WHBA – The year is currently 2023, and if Cothran’s suspicions were correct, the mean heterozygosity for herds may already show a significant drop. You stating ‘It is not necessary to wait until the results’ seems like you’re rushing to remove horses quickly, without having current facts. We request a new genetic report prior to any roundup.

PDF pg 10Maintaining desirable levels of genetic diversity would also assure a variety of colors are maintained in the Pryor Mountain horse herd. Pryor Mountain horses exhibit a variety of colors with common colors including dun, grulla, bay, black, and roan. Less common colors that appear in the herd include red or apricot dun, chestnut, sorrel, palomino, and buckskin. A 1970s report on the Pryor Mountain Horse Range by BLM biologist Ron Hall noted that palominos, pintos, and appaloosa were not present on the PMWHR at that time. However, palominos are present on the range today, as result of the introduction of mustangs from other HMAs. Color is a phenotypic representation of dominant or recessive genes passed through generations. A horse that is a rare color may or may not produce offspring that are also a rare color (Sponenberg 1996). MD WH-2 provides that BLM shall Maintain a wild horse herd that exhibits a diverse age structure, genetic diversity, and any characteristics unique to the Pryor horses, and BLM is addressing color in the Selective Removal Criteria. Horses of common colors would be prioritized for removal, whereas horses of less common colors would be given preference to be retained on the range.

WHBA –  In Cothran 2000, he stated ”the majority of wild equid populations managed by the BLM are kept at population sizes that are small enough for the loss of genetic variation to be a real concern. Because a loss of genetic variability can lead to a reduction in fertility or viability of individuals in a population, it is critical that genetic considerations be included in management plans for wild equid populations”and “Genetic variation is the amount of inheritable diversity in a population or an individual. It can be observed as morphological variation in size, conformation or color, but we are actually concerned with variability of genes, whether we can observe an effect of this variation or not.”


PDF pg 16 – Of all your Alternatives, ‘Alternative 3 – Lineage based decisions’  (with revisions needed) seems the best choice. Due to BLM’s “The ambiguous criteria for selection decisions”

WHBA- BLM needs to work with Pryor Wild Mustang Center as they have true and factual lineage going back 50 years and also the Cloud Foundation as they also have valuable long term knowledge of this herd as is noted in their 2018 court ruling.)

PDF pg 19 – Implementation Objective(s
Repair and maintain North Boundary Fence
•Construct drift fence at south entrance
• Layout Creek – Move northern Park Service horse range boundary fence closer to horse range boundary

WHBA – I agree with your plans to repair the water sources, potholes, riparian areas, adding guzzlers for better water access, and creating horses use to utilize other areas.

As for the fence projects, where can we see the present fence lines throughout the entire WHB range and territory?
I have only located one map that shows a few small fence projects (south admin pasture, turkey flats), but according to docs, there are 11 miles of fences surrounding. Where is the north boundary fence located and what is its purpose? An advocate (Cloud 2013) stated that the forest service built “a two mile long, buck and pole fence on the border between BLM and FS lands atop East Pryor Mountain. The fence was completed in 2011 and it denies wild horses access to thousands of acres of high quality, late summer and fall meadows.”  Is this the north boundary fence mentioned? Have horses lost more historic ground in the forest service? Where can I locate mention of this?
And will the Layout Creek Plans to relocated fenceline also contribute to them losing more of their rightful lands, pastures, and water sources?  

PDF pg 27BLM would continue to collect fecal samples and hair samples to monitor Observed Heterozygosity (Ho). If Ho drops below thresholds identified in the BLM Wild Horse and Burro Handbook, then BLM could take one or more actions to maintain or increase genetic diversity, including introducing wild horses from other herds with similar characteristics, including but not limited to the Sulphur herd in Utah, the Cerbat herd in Arizona, or others.

WHBA- This isolated herd, as you are aware, has unique genetics that will be seriously damaged forever by the allowance of outside genes to be brought into it their mix. Allowing dominant bloodlines to be intentionally ended is absurd. This is the worst thing I have ever heard. This is helping this unique and one of a kind herd with an almost extinct gene to do just that, internally combust.  / Prior to 1990, BLM did this by introducing 25 horses from outside herds (Sparks 2015) without consideration to their specific and rare DNA, and the herds genetics were corrupted, and now they are slightly less unique. Cothran says horses were brought in from Burns Oregon, and Rock Springs Wyoming. (Cothran 2000).  We should compare the genetic reports from over the years (Cothran 1991, and any earlier versions prior to the introduction of outside horses), then the damage you are causing may become more obvious. / Continuing to introduce unrelated herds whose alleles are not the same will ultimately destroy the historic and rare genetics of this isolated herd, and not having a genuine sustaining population size will create eventual extinction from inbreeding. Better management would ‘aim towards a goal’ of not letting this happen to begin with. You don’t intentionally break something, and then just attempt to glue it back together and think this is acceptable to the public shareholders. / Perhaps you could bring back horses that were originally taken from this land, that still ‘carry the same DNA’, for reintroduction, not just horses with ‘similar characteristics.’  Over 700 horses have been removed from Pryor since 1971 (Sparks 2015). There has to be some of these rare horses still out there with historic DNA, that haven’t ended up in slaughter pipeline, that could be used to increase diversity within this special herd.

According to (Cloud 2020) “Introducing outside horses must not be considered as a management tool. The Pryor Mustangs are unique. They exhibit primitive markings and stature reminiscent of equines from ages past. They cannot be replaced by the introduction of animals from other herds. / A healthy, self-sustaining population has no need for the introduction of outside animals. If this were to become necessary, it would indicate a failure in the management of this irreplaceable wild horse herd. If the Pryor herd is managed at the scientifically acceptable level to maintain genetic variability (150-200), then it should be able to survive, evolve, and adapt over the years without outside intervention”.

Even Cothrans 150-200 recommendation is bare bones minimum, and he eluded to this in a 2009 letter to BLM,

“I am writing in regard to the recent decision to lower the AML for horses on the Pryor Mountain Wild Horse Range to 95 individuals. I have been involved with work involved with genetic variability of the PMWH for many years. The most important single factor in maintaining genetic variation in a managed population is effective population size. This topic has been discussed for the PMWH many times. The minimum effective population size for maintenance of genetic variation in endangered species of managed populations is 50 but it must be understood that this number is what is required to keep the rate of loss of genetic variation at 1% per generation. Note, there is loss. Also, the key word is minimum and 50 is an absolute minimum. As has been stressed several times, the effective population is generally 1/4th to 1/3rd  of census population so that a census population size of 150 to 200 is required to achieve the minimum effective population size. It is not possible to accurately determine the real effective population sized of a wild population such as the PMWH so estimates such as those  above must be used. It is also important to understand that within a closed population, genetic  diversity does not increase without the input of new genetics from an outside source. What this means is that if the size of a population is lowered and genetic variation is lost, which is inevitable, then enlarging the population size does not increase the genetic variation, it only slows the rate of loss of existing variation. There is much else that could be discussed about this complicated subject but the above issues are the most significant. I want to emphasize that I fully understand that range conditions must be seriously taken into account in the management of the PMWH and population size clearly impacts range conditions. Loss of population size can occur by environmental conditions as well as by human interventions. My purpose here is to make sure that it is understood what the potential consequences of a reduction in population size are in terms of genetic diversity. Although genetic diversity in the PMWH has been relatively high, significant loss of genetic diversity can occur within a period of one of two generations within a small population. The PMWH has been one of the most important and visible herds within the BLM Wild Horse Program and its important that it stays viable.”  He stated in 2013. “Genetic variability of this herd in general is on the high side but compared to past sampling of this herd, variability levels for all measures has been in decline. This is likely due to the population size that has been maintained in recent years. Overall, the herd is showing evidence of Spanish heritage that is stronger than seen recently, although the known mixed ancestry is still apparent. This is possibly due to the efforts to remove horses derived from introductions”/ “However, there has been a general trend for a decline in variations levels of the herd. If the trend continues 5 the variability levels of the herd could drop below the feral average within the next five to ten years. The best way to maintain current levels would be to increase population size if range conditions allow.”

WHBA – We request a ‘current genetic report’ prior to any removals, and an increase in population size for the small, genetically unviable herd to keep the genetics from declining further. In order for this increase to occur, allowing the horses onto their original lands that have been taken from them so that the lands do not continue to suffer from overuse.

According to world researchers (Beissinger, S.R.) and (Clabby, C. 2010). “A minimum population of 500 could guard against inbreeding”. The herds should be a minimum of 500 breeding pairs. Duncan, P. (1992) – IUCN Species Survival Commission is 2,500 individuals for the long-term survival of wild equid species.

We recognize that the land cannot support a herd of that size. But your own studies have shown that you have shrunk their lands, which created an overuse of other areas.


PDF pg 27  “Emergency gathers can be utilized in emergency situations when body conditions deteriorate and/or in response to an unexpected event that threatens the health and safety of the wild horse population or their habitat, including fire, insect infestation, disease, or other events of a catastrophic and unanticipated nature”.

WHBA – I do not agree with this policy. This basically gives free reign to ‘design any reason at all’ to remove even more horses without public oversight. Why would one need to remove horses due to insect infestation? 
We have repeatedly seen you do ‘emergency gathers’ of other herds, ‘claiming drought and lack of forage’, only to bring in thousands of livestock within days of the horses removal (Onaqui 2021 and Sand Wash 2022).  


PDF pg 29

•Treat mares ages 2 and 3 year with ZoneStat-H.
• Young mares in the 1-Year old age class becoming two years old could begin primer treatments in the autumn at 18 months of age.  Treating pubescent foals
• Mares ages 4 and older would not be treated until after they have successfully foaled once. Successfully foaling is defined as a foal living to 1 year of age. As such, the delay in bringing the mares back onto treatment could give them an opportunity to become pregnant with a second foal.

WHBA- Your statement is contradictory. You state mares ages 4 and older would not be treated until they successfully foaled once. But prior to that, you stated you would treat those younger between the ages of 1-3.  Which states none would even make to the age of four without having had treatment.  According to documentation “Two veterinarians (from Switzerland and Colorado) have independently expressed the same concern to us: mares not producing foals at a typically younger age (i.e. three-seven years) will have a more difficult time conceiving. / Of the 13 young mares that have foaled, eight foals have been born out of season / Photo evidence attests to the masculine and aggressive behavior of certain PZPed fillies / Aside from the cruelty of raising a newborn foal going into a Montana winter, the drug has had other negative side effects in the form of abscesses, bleeding, and swelling on the hips of field darted mares. Of the 54 mares listed on the PMWHR Injection and Reaction Observations – updated June 2007 (BLM-03262), 41 mares are listed with swelling, nodules, bleeding or a combination of all these. 20 mares still have visible signs of nodules even years after they were injected / The BLM has reported that density dependence (the ability for a wildlife population to self-regulate its numbers based on available resources) and compensatory reproduction (over-production by females to increase an under-represented population) have taken place on the Pryor Wild Horse Range. In other words the older mares that continue to reproduce despite the use of PZP are responding to an under-population”. (TCF 2013). 
Also, intentional and permanent sterilization is not a ‘reversible contraceptive’!

PDF pg 29  –  “Once a mare has received six consecutive treatments, she would be removed from the fertility control treatment unless she foals again, in which case she would then receive a ‘minimum of three more’ fertility control treatments or treated with another approved immunocontraceptive.”

In (2023) Appendix 1 – You state “Although a few, generally isolated, feral horse populations have been treated with high fractions of mares receiving PZP immunocontraception for long-term population control (e.g., Assateague Island National Park, and Pryor Mountains Herd Management Area), no studies have tested for changes in immune competence in those areas. Relative to the large number of free-roaming feral horses in the western United States, immunocontraception has not been, and is not expected to be used in the type of widespread or prolonged manner that might be required to cause a detectable evolutionary response)”

WHBA – You show that some horses may receive as many 9 doses, or more. How long does it take before the ‘pesticide/vaccine/fertility’ treatments they receive changes, or alters their bodies ‘evolutionary response’?  I think it’s time to have this study begun.


PDF pg 35 The wild horse population would incrementally be reduced to the lower range of AML (108 horses) to allow the population to grow to the upper limit over a 4 to 5-year period without interim gathers. With a current horse population of approximately 205 horses (January 2023), the BLM would initially gather and remove approximately 55 horses. / Strive for 50/50 male/female sex ratio, with no more than 60/40 in either direction.

WHBA – 205 horses at 50% / 50% ratio. we start with an average of 102.5 mares in 2023. You remove horses to a low aml of 108. If we do the math here, that would be 54 females left.  Your current records indicate 69 females were treated with fertility vaccines in 2021 (no records for 2022).  Will any breeding females even be left to contribute?

PDF pg 46 – Expansion of the PMWHR boundaries.

In your report (BLM. (2008). Pryor Mountain Wild Horse Range 2008 Gather Plan and Environmental Assessment MT-010-08-33.)  it states that in 1990, ‘the last adjustment occurred when the Sorenson Extension was not reauthorized by BCNRA

According to your reports (BLM., NPS., FS. (2008). Pryor Mountain Wild Horse Range Evaluation), you state “Ultimately, the Pryor Mountain Wild Horse Range (PMWHR) has the potential to support up to 179 wild horses yearlong. This assumes all areas now grazed by wild horses will continue to be available. However, the projected long-term population increase in this action is considerably less than the potential level of 179 head since no rotational grazing systems will be in effect.”

WHBA – With the herd genetics in such dire straits according to genetic reports and Cothran’s statements over the years, we feel it is necessary to not lower the AML, but in fact to raise it to sustainable numbers for the viability of the herds long term genetic structure of this unique and historic herd. To do this, open up more of their rightful lands for grazing access, and reintroduce natural predators to create a more ‘cost effective’ natural balance within the ecosystem.  In doing so, this will result in less roundups needed, less fertility treatments, and overall… less of our public money spent.

WHBA – we request that you make all of their rightful range land accessible, remove fences, and include all of historic pastures open (unless area is in critical eco state), so that the horses have adequate access to both summer and winter grounds.

PDF pg 46 – “The WHB Act was enacted Dec 15, 1971. Wild horses can only be managed on areas of the NFS and BLM lands where they were known to exist in 1971, at the time of the passage of the Act. For the USFS these are areas are known as territories and for the BLM they are known as herd areas. Under section 1339 “Limitation of Authority” the Wild Free-Roaming Horsed and Burros Act states “nothing in this act shall be construed to authorize the Secretary to relocate wild free-roaming horses or burros to areas of the public lands where they do not presently exist.” Until a change in the law allows for expansion of the Pryor Mountain Wild Horse Range onto additional national forest or BLM lands that are outside of the existing territory and herd area, the agencies have a legal obligation to follow the law to the greatest extent possible.” / Comprehensive agency inventories (Hall 1972), assessments, public involvement, and decisions (U.S. Department of the Interior and U.S. Department of Agriculture 1973, U.S. Department of Interior and U.S. Department of Agriculture 1974) provided the basis for the Bureau of Land Management herd area and Forest Service territory boundaries per the 1971 Act. Subsequent land use planning efforts in 1987 and 2022 by the Forest Service, and 1984 and 2015 by the Bureau of Land Management validated the same areas as being a wild horse territory and herd management area, respectively. If opportunities for private land purchase or lease present themselves, the agencies would consider them, especially if they involve winter range. Winter range is recognized by both agencies as being the limiting factor for overall population size. The 2009 Herd Management Area and Territory Plan environmental assessment provides a detailed history about the wild horses in this area, and how boundaries were delineated.

WHBA – Hall makes it very clear that he followed the guidelines in his report His recommendations tell us that the horse had historic use of these areas. According to (Hall 1972) “Expansion of the existing boundaries of the Pryor Mountain Wild Horse Range would be returning wild horses to areas of historic use. / Expansion is compatible with PL 92-195 and is also a sound management procedure.” “Wild horses have occupied all of the Pryor Mountain Complex in the past. Man has now eliminated the horses on most of these areas.”

●Mystic Allotment – Acreage 2054 – 332 HUM’s. Federal range is grazed by 150 cattle from 07/10 – 10/04 for approximately 182 AUM’s. The total carrying capacity of the allotment is 332 HUM’s. This allotment is adequately watered and will provide both winter and summer range for horses.
(WHBA – Do horse have access to this currently? Five horses wintered on a wind swept ridge on the Mystic Grazing Allotment north of the horse range. A limited amount of forage was available to them as the area had been grazed in the summer by cattle. These horses were trapped by snow above 8000 feet)

●Forest Service – Lost Water – Acreage 3948 – 40 HU’s. This area is composed of grassy ridges separated by timbered canyons. Vegetatively it is presently in excellent condition. Cattle have not made use of this area in recent years due to lack of water. If this area is to be utilized as summer range, it will be necessary to construct a watering facility. Excellent forage conditions. With the removal of the fence, this would provide an excellent addition to the wild horse range. (WHBA – Do horse have access to this currently? – used during the 1971-72 winter by eight horses)

NPS – North of Sorensen Ranch – Acreage 7040 – 35 HU’s. This area has been used in the past by wild horses. The Sorensen Ranch is located within Area 3. This land is mostly irrigated and supports grasses as well as alfalfa. A log cabin in excellent condition would provide a living area and administrative site for a Wild Horse Manager. This old ranch would fit very well into the management program on the wild horse range. It is presently controlled by the National Park Service. Saddle horses used in the management of the horse range can be held here. Pastures could be constructed to hold horses pending disposition, and this area could also provide buffer forage during years of low productivity.
(WHBA – Do horse have access to this currently? NO – The current boundary was established in 1990 when the Bighorn Canyon National Recreation Area did not re-authorize the Sorenson Extension )

BLM – Crooked Creek Allotment – Acreage 3560 – 6 HU’s. A variable number of cattle forage out into this area during the winter months from Tillett’s private land. Horses that belong to Lloyd Tillett have also utilized this area. They are of the same genetic background as the horses within the wild horse range and may be considered wild. Before construction of the boundary fence enclosing the horse range, horses made extensive use of this area. The State Section 36 was used by 30-35 horses during the winter months. Fencing off of this area removed considerable winter forage and resulted in overuse of other areas within the range. The State Section as well as Crooked Creek Allotment would make logical additions to the range. This area would supplement the Dryhead as a wintering area.
(WHBA – Do horse have access to this currently?)

BLM – Frail Lands and Demijohn Pasture – Acreage 7657 – 33 HU’s. These areas have been used in the past by wild horses. It is not known for sure whether wild horses were on this land on December 15, 1971. Excellent forage conditions exist on the Demijohn Pasture. The frail lands provide a smaller quantity of forage’.
(WHBA – There is spoken evidence from individuals that stated there were horses there, and in other areas (not noted by government workers) before, during, and after the law was passed. You basically told them their memories weren’t reliable. Our entire history of the human race has been based off of ‘individuals’ memories that were noted. These recounts aren’t any different.)

Crooked Creek Canyon essentially prevents movement of horses from the present horse range into the above areas. Trails could be constructed at two points to provide access for the horses to enter this area. Both of these areas are within the Gyp Springs Grazing Allotment and are used by cattle. An additional advantage of having horses on this area is increasing their viewability. Tourists driving down Crooked Creek would be able to view wild horses.
(WHBA – Do horse have access to this currently?)

Little Mountain Area -Small meadows located on the foothills provide substantial forage. Little Mountain could be used as a supplementary pasture or as an area to relocate older horses not needed in the Pryor.
(WHBA – Do horse have access to this currently?)

●Additional Areas – Wild horses can feasibly occupy any area within the joint planning unit. Two livestock allotments on BLM, Gyp Springs and Bluewash would make excellent areas to establish new populations of horses. They could, in effect, act as a pressure relief valve to the overpopulated situation in the present wild horse range. All of Custer National Forest is also potential wild horse range.  (WHBA – Do horse have access to this currently?)

The population level necessary for the horses to express their biotic potential is not known at this time. If we assume that horses in a free roaming state establish and maintain territories (Pellegrini 1970), then we can assume that something is wrong in the Pryor horse range. A logical assumption is that under the present vegetation condition with the present acres (approximately 32,000) 130 wild horses are too many. On the other end of the scale, there has to be enough horses interacting to establish competitiveness and natural selection. Severe inbreeding would also be a result of too low a population of horses. Competitiveness during the breeding season is absolutely essential. / A range survey has been conducted on the horse range which indicates a carrying capacity of 85 adult horses. The range trend has been steadily downward. Two options are available if the horse range is expanded. These were discussed under the objectives of expansion. If it is not expanded, the population must be reduced to 80-90 adult animals.” (Hall 1972)

WHBA- When I look at your maps on page, and read corroborating documents (Hall 1972), I have to ask, of their entire territory and range on all BLM, NPS, and FS land…. how much land do the horse still have ‘actual’ access too? Where are the sub herds located (pinpoint), how many herds are there, and how many are in each herd? Can the horses intermingle with other herds, or do fences keep this from happening?
Is there a MAP that lists:  the specifics of ‘sightings and counts (I’ve seen these on other herds), fences, accessible areas, non accessible areas?
Of the historic areas listed in Halls report, what areas do the horse still use of all and which areas have been removed? Sifting through your documents, and corroborating with advocates reports to get straight and factual answers is a difficult task.

I have read horses no longer have access to:  south admins pasture (summer pasture), have been removed from Custer NP in 2009, a two mile long fence on the border between BLM and FS lands atop East Pryor Mountain. Also Sorrenson Ranch, Crooked Creek, Demijohn Pasture, and the list goes on. Are horse allowed in the WSA’s?

Maybe it would be easier to show us where the horse can access, and if they can still intermingle between herds?

Is the continuous loss of so much of their historic grazing lands contributing to the overgrazing damage being reported in other areas from overuse due to intentional shrinking of lands?


PDF pg 48 –  The Pryor Mountain Wild Horse Range comprises about 42,000 acres in the southeastern portion of Carbon County, Montana and northern Big Horn County, Wyoming. / The other designations are the East Pryor Area of Critical Environmental Concern (ACEC) and the Crooked Creek Natural Area. The Lost Water Canyon Research Natural Area and the Lost Water Canyon Recommended Wilderness Area lie immediately adjacent to the PMWHR

WHBA – How much of this 42,000+ acres do the horses ‘currently’ (in 2023), and ‘actually’ have access to use on the three Agencies (BLM, NPS, FS) lands? Is there a location for a viewable map that shows this actual amount and specific details of the land like water, fences, horse sightings, seasonal use, etc.? Do horses have access to ‘the other designations’?


PDF pg 52 Genetic Similarity. As discussed under Alternative 1, the Pryor Mountain horses are of mixed ancestry with a measurable but not predominant Spanish component. They are genetically similar to over 145 HMAs they were compared to and do not comprise a genetically distinct population of horses. BLM would not manage them as an isolated population but would try to introduce horses with similar characteristics if it becomes necessary to reduce effects of inbreeding depression. The Pryor horses would remain a population of horses with mixed ancestry, which includes Spanish ancestral influence.

WHBA – Cothran is quoted in (French, B. 2009). “The concern in keeping only 120 horses on the range, Cothran said, is the threat of a potential die-off that could reduce the herd even further, reducing the herd’s genetic diversity.” / Cothran said the contraceptive has been used successfully. But he said there’s a danger in applying the drug to a small population of animals because it can control which genetics are passed on. / The Pryor Mountain wild mustangs have been shown to be descendants of old Spanish breeds, Cothran said. These are the horses first brought to the Americas by the Spanish. These genes aren’t pure, however. The Pryor horses probably bred with ranch stock and horses from other wild horse ranges were introduced out of concern over inbreeding in the Pryor horses, he said. “There are a number of different strains of the colonial Spanish horse, each of them are different genetically ‘now’ because they were isolated from each other,” Cothran said. He did say, however, that the breed brought over by the Conquistadors to Central America no longer exists. Despite any direct ties to a specific breed, Cothran said the Pryor mustangs are special horses. “There are not many herds out there now that have the old colonial Spanish-type horse,” he said. Because the Pryor herd contains this unusual genetic component, Cothran said they are unique. “I do agree that we need to try and preserve this herd.” Cothran recognizes that management of the Pryor horses can be controversial, with people on all sides of the issue concerned about the horses but with different ideas on how to best take care of them. The situation is further complicated by variables such as changes in the environment and within BLM’s management. There is one point maybe all can agree on. “They are one of the most significant, if not the most significant, wild horse herds in the United States,” Cothran said.


PDF pg 55 Genetic Similarity. As discussed under Alternative 1, the Pryor Mountain horses are of mixed ancestry with a measurable but not predominant Spanish component. They are ‘genetically similar’ to over 145 HMAs they were compared to and do not comprise a genetically distinct population of horses. BLM would not manage them as an isolated population but would try to introduce horses with similar characteristics if it becomes necessary to reduce effects of inbreeding depression. The Pryor horses would remain a population of horses with mixed ancestry, which includes Spanish ancestral influence.

WHBA – While they may be ‘genetically similar’ since your introduction of other herds, due to their isolation, they are still quite unique. While we regularly hear from Cothran and know of his veiws, Sponenberg, D.P. (1997). Pryor Mountain Horses as a Spanish Colonial Horse Genetic Resource and Sponenberg, D.P. (2000). Deciding Which Feral Horse Populations Qualify as a Genetic Resource seems to think they are something extremely unique as well. “A very few feral populations remain that descend from types and breeds now otherwise rare or extinct, mainly the Colonial Spanish type. These few populations (Cerbat, Sulphur, Pryor, Kiger, perhaps others) are genetic resources of significance to horse biodiversity and ‘warrant special consideration for conservation and management as unique resources’. The North American Colonial Spanish breed type is otherwise very rare globally, and only a small reservoir exists in domestication. / While breed origin makes some populations unique, all feral horses persist in environments in which natural selection is the major selection pressure. / Program selection environment is unique among equine environments, and its role in shaping the genetic composition of the herds is important as a biological process. While it shapes all populations, its role in shaping those that are unique by virtue of founder type is especially worth consideration since this phenomenon is an ongoing, if unplanned, experiment that cannot be duplicated should these populations become extinct.”
Even (BLM 2000) recognizes their unusual genes. “Young, fertile animals that are determined excess, can be sent to other wild horse herds (i.e. in Utah — Sulphur or other recipient HMA) to ensure that any unusual genes from the PMWHR JMA are maintained in other herds of wild horses.”


BLM (2009).  If predators can maintain the AML, BLM has no issues with allowing natural management as one of many tools.
WHBA – If this were true, why were predators killed in the territory when they were actively keeping the herd in check?
Predators need to be reintroduced!


(WFRHBA 1971) states “The Secretary shall manage wild free-roaming horses and burros in a manner that is designed to achieve and maintain a thriving natural ecological balance on the public lands… All management activities shall be at the minimal feasible level… wherein such lands are located in order to protect the natural ecological balance of all wildlife species which inhabit such lands, particularly endangered wildlife species.

WHBA – In Sparks, J.M. (2015).  It states that 70% of the females in Pryor are already being treated with PZP or ZonaStat-H, and removal of wild horses has occurred on average every other year since 1971. The PZP has been utilized on wild horse mares within the PMWHR through various treatments, prescriptions and intensities since 2001.

“Plans conclude that PZP contraception appears to be temporary and reversible. However there are several studies demonstrating that fertility control treatments may cause irreversible sterility in mares as well as out-of-season births, herd instability and general decline in immune function” (FOA 2021).

Removing horses every one – two years creates abundant stress on families, and herd structures. A 70% use of fertility vaccines… that doesn’t seem ‘minimally feasible’ to me.

As new studies (Taylor, W.T.T. (2023) are beginning to come out that corroborate that horses have never actually been extinct in Western America, we must begin to consider that they are the ‘endangered wildlife species’, and treat them as such.


Thank you for the opportunity to be heard and to put my thoughts on public record.

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