The announcement earlier this week of three new off-range corrals and the expansion of a fourth complements the announcement earlier this year of the closure of three HMAs and downsizing of a fourth.

These short-term holding facilities are sometimes referred to as ‘concentrated animal feeding operations’ or ‘high-density feeding operations.’

Another such facility may be in the works, thanks to a rule change in Laramie County, WY that will streamline the approval of a CAFO near Burns.  Residents near the proposed feedlot opposed the change, along with the county planning commission.

The facility would have a capacity of 5,000 wild horses.

They dropped off the radar screen on August 11.  From that date onward, only ‘adults’ were captured.

Perhaps some of them transitioned but are still in the process of coming out.  Maybe the traditional stud / mare binary is just too damn divisive?  Or it doesn’t accommodate the full spectrum of possibilities?

As of today, the gather stats show 78 stallions, four horses with a cervix and 14 foals.

So much for transparency.  These data can’t be can’t be produced by a simple random process centered at 50% males / 50% females.  Try tossing a coin 82 times and coming up with no more than four tails.

RELATED: Saylor Creek Mares Not Taking the Bait?

The proposed incinerator, to be built in the Tahoe Reno Industrial Center on the north end of the Virginia Range, was approved this week by Storey County Commissioners, according to a report published this morning by The Nevada Independent.

The project was questioned last month in a planning commission meeting about emissions, traffic and possible collisions with wild horses.

Who raised the concerns?  Who’s worried about the impact on horses?

The PZP zealots, whose war on the Virginia Range mustangs has already caused more loss of life than an incinerator ever could.

She led the effort to ensure that Nevada’s wild horses got the top vote to adorn the state quarter, according to an obituary published yesterday by Nevada Appeal.

Today, the group advocates for smaller herds through application of contraceptives.

You see, the only other option is roundups.

Perhaps it was not like that when Bonnie was in charge.

Curiously, the group does not mention her passing at their home page.

Although the glorious ‘Path Forward‘ is designed to take America’s wild horses back to the ‘fast disappearing’ days, one change, just starting to happen when Velma died, is the use of political and legislative processes by ranching interests to undermine the WHB Act and advance their agenda.  It’s been going on for over 40 years.

Who do you suppose chased these horses to the edge?  Drillers and miners?

Do you think that only American companies want a piece of the action?

With its recent acquisition of Anadarko Petroleum Corporation, Occidental Petroleum Corporation became the largest private landowner in Wyoming.

The deal saddled Occidental with a large amount of debt, which it is trying to reduce through various divestitures, including properties in the Wyoming Checkerboard, a patchwork quilt of public and private lands in the I-80 corridor.

The Checkerboard is also home to hundreds of free-roaming horses.

The Rock Springs Grazing Association, whose lawsuit against the BLM became the driver of the Rock Springs RMP Amendments, leased some its land from Anadarko.  It also owns some of the private parcels in the Checkerboard.

Occidental is negotiating with a bidder and it’s not the state of Wyoming.  Those in the know aren’t talking.

What will be the impact of the sale on RSGA?  How might it affect the court order that’s forcing the closure of three HMAs and downsizing of a fourth?  Will BLM’s decision in the case be influenced in any way by the negotiations?

RELATED: Wyoming Not Top Bidder for Checkerboard Lands.

Refer to this report about the Salt River horses by KPNX News to find out what is.

Remember, there’s no such thing as birth control for horses, only safe and effective birth control for horses as stated in the report.

RELATED: What Constitutes Harassment?

Two applications have been combined into one, according to a BLM staff report posted yesterday.  The photo supplied with the announcement suggests that this will appeal to those who can’t get a horse to do anything without shoving multiple bits in his mouth?

A horse does what he has to do to save his life, don’t confuse it with your ability, my dear.

Keep in mind that the number of excess horses and burros on public lands in the western U.S.—animals destined for the WHB outplacement program—is directly related to the number of privately owned cattle and sheep allowed thereon, and that WHB stocking rates are often good indicators of magnitude of the problem.

The analyst, looking at data from a process, faces two problems:

• Searching for trouble that doesn’t exist
• Overlooking trouble that does exist

The statistical methods used by Western Horse Watchers are designed to minimize the losses from these mistakes.  There are no probabilities, no underlying distributions.

The formulas help you decide, by calculation, if the results from a process should be attributed to chance or whether they should be associated with one or more assignable causes (nameable, knowable, findable).

Do these data look like they were produced by a simple random process?

If you’re talking about the Assateague herd, the answer is ‘No.’

Data from the recently concluded gather at Nevada WHR look like they were.

This doesn’t mean that wranglers weren’t on horseback cutting mares from the herd, to skew the sex ratio, there’s just no evidence of that in the data.

RELATED: A Lesson from Industrial Quality Control.

Refer to this guest column, appearing this morning in the Las Vegas Sun.

If you believe that most of the problems on public lands in the western U.S. are due to privately owned livestock, why would you promote a technology associated with wild horse overpopulation?

The writer cites AWHC’s war on the Virginia Range mustangs as a PZP success story, but does not mention the disastrous long-term effects of PZP on the Assateague herd or the recent court order requiring the EPA to reconsider its registration of the pesticide.

Extended use, necessary for maintaining AMLs, leads to sterilization.  The horses are said to be ‘self boosting.’

PZP doesn’t protect wild horses, it prevents them.

While that might appeal to some, the idea does not have broad support among ranching interests because darted mares still eat.  Removal, the centerpiece of the glorious ‘Path Forward,’ is still the best option.

RELATED: Management of Western Rangelands in 2018, Livestock Grazing in Nevada.

Refer to this press release by American Equine Awareness, issued yesterday.

Should Congress direct some of the money to a pilot program that tests the new system, so it can be refined for commercial use?  Would the Rolling Stones support the idea?

The House spending bill, which includes the amendment, still has to be considered by the Senate.

RELATED: If the PZP Amendment Carries, How Will the Money Be Used?

Consider two HMAs, each starting off at low end of AML.

HMA1

• AML 50 – 100 wild horses

HMA2

• AML 500 – 1,000 wild horses

Both HMAs will need to be gathered in five years.  Fifty wild horses will need to be removed from HMA1 and 500 from HMA2.

Which operation will cost less?  Which one will require more off-range holding?

If the goal is to save money, zero out all the HMAs and end the WHB program.

RELATED: Best Way to End Roundups?

Refer to this 13-minute interview posted today by Nevada Public Radio.  The segment about wild horses ends at 8:35.

The amendment is turning out to be a cousin of the glorious ‘Path Forward,’ another opportunity for ‘advocacy’ groups to throw in with the public-lands ranchers.

How exactly does the legislation fix the resource management plans that divert most of the forage on public lands to privately owned livestock?

RELATED: If the PZP Amendment Carries, How Will the Money Be Used?

Get rid of the horses.

The FY 2021 spending bill approved by the House last week includes the $11 million PZP Amendment, an idea so good that even the Rolling Stones would support it.

Anybody who reads these pages knows that overpopulation is not the problem, but the big-name ‘advocacy’ groups are trying to convince you otherwise.

This article by Nevada Current, published yesterday, is just one example.

What you’re getting from these groups is capitulation to the ranching agenda, as seen in the disastrous ‘Path Forward.’

They’re trying to ensure that livestock operators receive seventy, eighty, ninety percent or more of the authorized forage on land set aside for wild horses.

Don’t give them a penny!

RELATED: House Passes PZP Amendment to FY 2021 Spending Bill.

Why not take them on darting expeditions or travel to HMAs during grazing season to see all the privately owned livestock?  The two experiences would fit together perfectly.

Will it be spent on automatic darting machines or will it just line the pockets of those in the PZP supply chain?

The $11 million authorization still has to clear several legislative hurdles.

RELATED: Ties Between PZP Zealots and Public-Lands Ranchers Revealed.

There are four million permitted cattle and sheep on public lands in the western U.S., according to the writer of a letter to the Las Vegas Review-Journal, compared to 81,000 wild horses, but the horses need to be managed with PZP.

After all, it’s been used for 30 years.

Where?  Assateague Island.  Many wild horse ‘advocates’ point to the area as a paragon of wild horse management but the results have been disastrous.

RELATED: BLM Opinion Piece Acclaims ‘Path Forward,’ Ignores Livestock.

The current population at Saylor Creek is 131 wild horses.  The AML is 50.  How many excess horses are present?  The herd is 2.6 times over AML.

There are 81 excess horses on the HMA, per current wisdom.  It’s overpopulated.

The herd requires 13% of the authorized forage on the HMA but you’re not supposed to know that.  When the roundup ends, the horses will only need about 5%.

RELATED: Comments on Saylor Creek Wild Horse Roundup.

Exhibit A

16 USC 1332, Definitions, WHB Act, a duly enacted statute.

Paragraph (c) defines “range” as “the amount of land necessary to sustain an existing herd or herds of wild free-roaming horses and burros” that’s “devoted principally but not necessarily exclusively to their welfare.”  It stands as it did in 1971.

Paragraph (f), which defined “excess animals” as those “which must be removed from an area in order to preserve and maintain a thriving natural ecological balance and multiple-use relationship” did not appear in the original Act.  It was added by PRIA.

Exhibit B

CFR 4710.3-2, Wild horse and burro ranges, Part 4700, Subpart 4710, a federal regulation.

Accordingly, herd management areas, a term that did not appear in the original Act, “may also be designated as wild horse or burro ranges to be managed principally, but not necessarily exclusively, for wild horse or burro herds.”

Exhibit A lays down the law.  Exhibit B makes it tentative.

Which one prevails?  Can a regulation override a statue?

A project appears in BLM’s NEPA register (sometimes referred to as ‘ePlanning’) but no documents have been posted.

There are three levels of analysis in the NEPA process: Categorical Exclusion (CX), Environmental Assessment (EA) and Environmental Impact Statement (EIS).  Wild horse management actions often fall into the middle category but major changes, such as the Rock Springs RMP Amendments, require an EIS.

A project involving wild horses and burros may begin with a scoping request, to receive input from the public, followed by staff work to formulate an action plan and draft an environmental assessment.  The EA looks at the consequences of a preferred action and one or more alternatives.

The preliminary plan and EA are posted for public review and may be revised in light of substantive comments.

If there are no major issues, a decision record and finding of no significant impact may be is issued, allowing the plan to go forward.  This does not mean the roundup starts the following week!  There are priorities and funding is not unlimited.  The plan may face legal challenges.

The process can take several years to complete although it may be shortened or bypassed altogether in the case of emergencies.

The Sulphur HMA is in western Utah on the Nevada border.