Wait. They Wanna Do What When with Whom?!

So the time has come again for another episode of Rachel Has Loads of Feelings.  The BLM released a new Environmental Assessment (EA) regarding the PZP management of the Pryor wild horse herd. You can find it here.  I highly recommend that you read the EA yourself.  It is less than 20 pages long and a lot of those pages can be skipped, so it is a quick read.

It feels a little early for me to be writing anything about this subject.  But frankly, I suspect that the stud piles will soon be hitting fans on both sides of the aisle with the ‘Big Boys’ weighing in, so I figured that if I get my say out right away I might have just enough time to duck for cover.  Also, I did not want any of my conclusions to be biased by the opinions of others before I had a chance to take a hard objective look at the information myself… and isn’t that just a little hypocritical of me?

graciana and foal

Anyway, I hate change.  I just hate it.  When I was a kid, the major life changes I experienced were skewed towards the negative.  Heck, as an adult the changes I see are still overwhelmingly negative.  So my reaction to this news breaking went as follows:  fear -> concern -> curiosity -> misreading the EA -> hope -> realizing I misread the EA -> RAGE -> sleep -> MOAR RAGE -> flash of brilliance when I realize I can’t get a true picture until I play with the numbers.

So that is what we shall do.  Sort of.  The complicated stuff is going take me longer to work through.  If the Pryor herd is not your bag, then you may not want to read further.  However, if you do care for the Pryors, then I hope you can find this information useful whether you agree with my conclusions or not.  Please be warned that this is going to be long.  It is impossible for me to keep my opinions out of, well, anything I ever write or say aloud, but I do think you should be able to separate fact from opinion pretty easily in this.


We have to start by explaining the changes that the EA presents.  The first two changes you probably already know:  the BLM wants to dart all the yearlings in September, and they want to put the core breeding population back on PZP at the age of nine (used to be 10).


Page 6 of the EA also reveals some curious “thresholds”.  Thresholds are scenarios in which a mare may be taken on or off of PZP, whether they are in the 4-9 age range or not.  These caused me some confusion (probably because I was trying to read them while also responding to BBB complaints at work), so I will paraphrase them slightly, just in case you are also responding to BBBs at work right now.

  1. Mares who are in the 5-9 age range who have had two offspring that are one year or older are put back on PZP, unless both of said offspring were removed by the BLM.
  2. Mares who are 5-9, who have had two offspring over one year old, but only one is still wild on the range, will be placed back on PZP.
  3. If the herd as a whole is over the Appropriate Management Level (AML) then 90% of mares 1-19 will be put on PZP, regardless of age. The 10% who are not put back on PZP will be decided on the basis of bloodlines, that is, rarer bloodlines get priority to stay off the drug
  4. If the herd goes under 100 horses as a whole, the BLM will allow some 10 and 11 year old mares to be taken off PZP until such a time as the herd is within 5% of the high AML; that is, the herd gets up to 114 horses.

Feel free to freak out a little bit over thresholds 2 and 3 for a moment.  I know that I did.

We are going to start with threshold 3, because that is the easiest to comment on and also the most alarming to me.  The AML for the Pryor horse herd is 120 horses aged one year or older.  Why does that matter?  Because there has been more than 120 horses in the Pryors for as long as I have been alive.  Not even after a removal.

The Pryor herd will be over their AML Every. Single. Year.  So every single year, 90% of the mares aged 1-19 would be darted.  There will not be a year where the full roster of 5-9 year old mares would be kept off PZP.

navigator and morning dove

The challenge with percentages is that they are not tangible; they can be easy to misinterpret.  So to put this in perspective, in 2014 there were 76 mares between the ages of 1 and 19.  10% of 76 mares = 7.6.  So only 7-8 mares aged 5-9 would be kept off of PZP.  This actually works out okay for the current years of horses, but will get more problematic as we go on.  In general, on any given year in the future the BLM would allow somewhere in the realm of 3-12 mares to be kept off PZP.

That’s a problem.

For one thing, there is no guarantee that the 7-8 mares kept off PZP in 2015 would conceive and carry a healthy foal that survives.  For another, we know that a mare who is kept on PZP for more than 5 years in a row has a reasonably high probability of being rendered permanently infertile.  So if the herd was to ever dip down below that 100 mark and mares were taken off PZP, there is no guarantee that the herd could be brought back up again without losing some bloodlines.

Half Moon

Okay so that was the easy part of this “lesson”, or the short one anyway.  Now let’s a closer look at what Thresholds 1 & 2 really mean.  Number 1 is pretty self explanatory.  If a mare has at least two surviving kids who are 1 year old or older by the time the BLM is darting, they will be given PZP.  Well, okay, I don’t know how I feel about making two offspring the cut off, but I guess that’s not too crazy unreasonable, since there is a decent chance that mare would have a foal at their side or be pregnant at the time they are darted, meaning she could potentially get three offspring.

We will casually ignore the part where the 10% rule would mean that a number of these mares could be on PZP even before they have their allotted two, because this blog is complicated & long enough as it is…

Threshold 2… well, that is another matter.  There are two scenarios with the second threshold.  Either one of the mares offspring died after the age of 1 (ala Demure, whose daughter Kindra died at 2 years of age), or one kiddo was captured and removed by the BLM.


A  positive spin sees threshold 2 as upholding a survival of the fittest mentality.  The BLM is not going to grant any special exceptions if a mare’s offspring can make it through their first year but cannot survive or thrive on their own.  Essentially, the BLM would not interfere with nature weeding out the weaker lines by allowing that mare to keep trying until she has the same number of offspring as the “healthier” ones who get to have two or three. And yes, I realize that is not coming out quite right, and feel free to blast me in the comments section.  Hopefully most of you sort of understand what I am trying to get at with this line of thinking?

Then there is the dark side of threshold two:  roundups.  The BLM does not make any exception for mares whose offspring were perfectly healthy but removed.  Obviously natural selection does not apply to horses that are captured by man.  Thus, the positive intentions of # 2 could be overshadowed by the problematic outcomes that arise after the BLM removes horses.

Santa Fe

There is a big difference between one offspring and two, especially if that one baby is a stallion.  There is no guarantee that a stallion will be able to successfully win a mare and reproduce.  These strict PZP guidelines would only further decrease a stallions chances at passing on their genes, since a stallion not only has to deal with winning a mare but has to have the “right mare” at the “right time” – an increasingly difficult task as the PZP regulations tighten.

Consider Jackson versus Santa Fe.  Jackson has a good number of offspring on the range because he attracted mares who were in that window of time where they could reproduce.  He deserves to have multiple offspring on the range because he was a powerful, dominant stallion and the mares recognized that and stayed with him.

By contrast, Santa Fe has only one son – Mandan.  Yes, Jackson’s personality and dominance increased the likelihood of him attracting enough mares to carry his lines, but Santa Fe was successful in his own way too.  Only with Santa Fe, the BLM removed his offspring until only Mandan was left.  Man is the reason why Santa Fe only has one horse out there to represent him, not nature.  Many more stallions will be facing that situation, be they dominant and powerful like Jackson or quiet lovers like Santa Fe.


What is more, a person who is suspicious of the government and all they do might also take this to be an extremely convenient loophole that would allow the BLM to intentionally only leave one offspring per mare on the range.  Personally, I’m not quite that suspicious – pay no attention to the tin foil hat I’m wearing – but I think it is important to point out what a huge loophole Threshold 2 creates.  This could get ugly, and if it did, there would be nothing the public could do to stop it.

Galadriel with Ketchikan (and Chance's nose)
Galadriel with Ketchikan (and Chance’s nose)

Okay, now we get to the statistics (sort of).  Yay!!!!

In order to get a better feeling for what thresholds 1-3 actually mean, I took a look at the mares who were not given PZP in 2013 aka the D-H’s.  I chose 2013 because it gives me more to work with – we know which of these mares had foals in 2014 and how these changes would have an impact.  I am working on modeling what it would mean as the I-M’s cycle through and grow older, but those numbers are not finished yet and will probably not hit this blog unless someone really, really wants them.

There were 21 mares who were not given PZP in 2013.  I am not considering Dove & Demure, since they were given PZP in 2014.  Similarly, there are no surviving ‘E’ mares, so none of these mares would be darted in 2015 under the existing plan.  So we are considering 19 mares total.

Let’s break these thresholds up by mare as it would apply in 2015:

Threshold 1 (2 offspring, still on range):  Feldspar, Felicity, Firestorm, Gabrielle, Galena, Greta, Halcyon – 7 total

Threshold 2 (2 offspring, counting those the BLM removed):  Fool’s Gold, Graciana, Half Moon, Hopi – 4 total

No Threshold/No PZP:  Fresia, Gaelic Princess, Galadriel, Shadow, Halo, High Noon, Hera, and Honey – 8 total plus the I’s and the J’s – 7 horses for a total of 15 mares.

Threshold 3: With 15 mares not falling under #’s 1 or 2, half of the mares would be put on PZP anyway under the 10% rule.  Per that rule, these mares would be:  Fresia, Gaelic Princess, Galadriel, Shadow, Halo, High Noon, Hera, and Honey aka every mare that does not meet thresholds 1 & 2.

So in other words, the only mares who would not be given PZP in 2015 would be the I’s and the J’s.  This is because the BLM chooses which horses go back on PZP on the basis of age – 9 year olds first, then 8, and then 7.  Uh oh.


That’s a pretty staggering bit of information, especially given what we are used to.  So let’s take a step back to consider what the BLM could possibly be thinking.  Obviously, I am not the BLM’s biggest fan.  Yet it is important to put my personal feelings and assumptions aside when looking at data like we are.  The BLM is not trying to zero this herd out.  If they wanted to do that, they would just pull something the way the Rock Springs office did with Divide Basin & Salt Wells.  There would be no need to make it slow.  I recognize that they are trying to find a solution that is feasible for them and that the public can live with.

That objectivity is important when puzzling everything out at first.  I am always going to miss things when studying a problem, but I will miss a heck of a lot more if I come at the problem wearing my blinding bias blinkers that make half the story disappear.

try saying bias blinkers that blind three times fast!
try saying blinding bias blinkers three times fast!

The BLM is making an assumption with the first two thresholds.  The key point here is that the mare has to have two offspring that are one year or older.  Foals are not counted by the BLM.  So the BLM is making this decision with the idea that a mare who meets those first two criteria will either have last spring’s foal at her side or will already be pregnant with that years foal.  In other words, the BLM has written this measure no with the intention that each mare only gets 1 foal, but rather that a majority of mares will ultimately have 2-3 offspring left on the range.

(They also assuming that mares who are on PZP will still foal which is true for some, but I don’t really have time to go into that right now)


To an extent, I can empathize with that philosophy.  If a mare has two offspring, then over the long-term you will have a herd that maintains a reasonably stable level with minimal, if any, roundups.  I don’t like roundups.  Even bait trap removals are traumatic, and roundups have led to just as many lost bloodlines as the PZP experiment in the early 2000s did.  What is more, the demand for Pryor horses is low.  2011 showed us that at this point, most people who want a Pryor horse already have one.  Taking 20-30 horses every three years is just not feasible for the horse market as it is right now.

The problem is that words speak louder than intentions.  The BLM will be bound by these words, whereas an intention is worth about as much as some gently used toilet paper.   The BLM is using the same thought process that they have used with removals:  “Well, she’s young and will have more babies no matter what.”  That has not worked out so well for them in the past because some mares never did foal again.  Some have already died, taking a bloodline with them.  Challenger, Zeppelin, the Count… these horses have no legacy and their genes are forever lost to us.  When you add in the risk they are taking by darting yearlings the risk only increases that much further.

When I read this document, I can recognize what the BLM is going for, but I also see areas where corruption or internal BLM bias could cause disaster.

– Per # 2, the BLM could take all but one offspring per mare, and we would have no power to stop it because they’re “just following the EA”.

– Per #3 the BLM would get to cherry pick which horses are kept on or off PZP on any given year.

– There is absolutely nothing in this document that gives flexibility towards mares who do not foal in their 4 year window, or the barren mares of the early 2000s.

– I am not going to get into the darting yearlings debate in this post (I figure several others who get way more traffic than I do will spend time on that), but that cannot be ignored either.  It didn’t go so well the first time around.

Fool's Gold & Nighthawk
Fool’s Gold & Nighthawk

Ultimately, it is up to you as an individual to decide for yourself how you feel.  Personally, I don’t like it.  It has some good ideas, but is way too extreme as a whole.  I hope that you send in your comments to the BLM on this plan, regardless of whether you agree with me or not.

I am going to close this out with a case study on three mares that are currently off of and what this new EA would mean for each one.  If the middle of this post made you fall asleep, then hopefully this will be easier because hey, we all retain information differently.


Firestorm made this sample set by virtue of the fact that I think her name is really cool.  Firestorm would fall under threshold 1.  She has two offspring who are still wild, Maelstrom & Niobrara, who are over the age of one and doing well, as well as a 2014 foal named Okomi.  Two of her offspring were removed in 2011, and one was removed in 2009.  So to date, Firestorm has had 6 foals in her 9 ½ years of life.

Would anyone really be crying any tears if dear Firestorm was put back on PZP?  Frankly, the girl could use a break.  I have read studies that state that on average, 60-70% of mares in herds that are not given PZP do not foal for two consecutive years in a row.  Obviously mares are capable of foaling every year successfully, but year after year after year of babies can be hard on a gal.  This EA would put Firestorm  back on PZP which would make it more likely that the three kiddos who are still wild could stay wild.

If you support PZP in general, than Firestorm is an example of a positive change that this EA would provide.  In the current state of the herd, having three offspring left wild is better than most mares get.  It brings a high probability that at least one will go on to successfully reproduce themselves.

Barring a miracle, Firestorm is the only child of Velvet that is able to reproduce, since her half-sister The Black is barren.  The best chance of keeping Maelstrom, Niobrara, and Okomi on the range will be to prevent a roundup, since at least one of them would be removed.  Preventing Firestorm and the other fertile myrtles from knocking out babies every single year would be the first step to prevent that roundup.


I am choosing Ingrid (Innocentes. Whatever, she’ll always be cutie-patootey short & stocky Ingrid to me) because: 1. She is easily recognizable and even the most casual Pryor fan will probably know her.  2.  She is Leo’s half-sister and their similar outlook on life gives me feels and 3. It’s my blog; I do what I want.

To date, Ingrid has had two foals:  Lynx and Orielle.  Lynx was removed in the 2011 roundup.  Orielle is a foal who was born in October.  If Orielle survives the winter, Ingrid would fall under threshold 2 and would be put back on PZP in 2016.

It is a fairly safe assumption that Ingrid will not foal in 2015, due to how late Orielle was born.  Ingrid would in turn be bred during the spring and summer of 2015 before the BLM darted her the following winter.  This makes Ingrid a gamble.  She may have a foal in 2016 or she may not.  Similarly, there is no guarantee that this imaginary 2016 foal would survive, or that Orielle wouldn’t die later in life herself. Under the rules of the new EA, Ingrid could potentially end with one or, worst case scenario, zero offspring on the range.

Ingrid herself has one half-brother in the wild – Navigator.  Her dam, Felicity, is 10 years old and under the new rule would be placed back on PZP this year.  The Topper line is not well represented, and if the end result of the rule changes meant that Ingrid only ever got to have one foal remain in the wild then it would really stink.

In my opinion, Ingrid is an example of a negative change.  Even if there is a decent chance that Ingrid will have one more foal before she is put back on PZP, I don’t think it is worth the risk.  Your opinion may vary on this one, depending on your confidence in Ingrid’s ability to foal again before the 2016 breeding season.

Gaelic Princess
Gaelic Princess

To date, Gaelic Princess has had one offspring, Kelly, who was removed in 2011.  She has not foaled since then.  Gaelic Princess turns nine this year, and under the new EA changes she would be placed back on PZP in 2016 when she turns 10 years old.

At most, Gaelic Princess has the opportunity to have two foals.  Given her track record, it seems unlikely that she would foal in both 2015 and 2016. Gaelic Princess, even more-so than Ingrid, is looking at a situation where she would probably only have one living offspring on the range.  There is a chance she won’t have any.

It’s hard to see an upside to this new EA when you look at Gaelic Princess.  I suppose you could argue that she has a full sister in Limerick who is still wild and can pass on their parent’s line.  I’ve never been a big fan of that argument myself, since Gaelic Princess will pass on qualities that Limerick will not pass on and vice-versa.  Fifteen to twenty years from now the current generation of horses will be the grandparents and great grandparents.  We will see them the same way that we currently see Shaman, Mateo, and Bigfoot.  The talk will focus on how well they are represented, and we will care less about their ancestors.  Plus there is a better genetic mix for future generation if the grandkids have different dads.

I cannot support this new option.  My big complaint with the current 5-10 year plan is how inflexible it is. While I think the BLM has good intentions, this new plan is just as rigid. For at least the next four years, the mares would only be given two years off PZP each.  That’s it.  It won’t matter if that mare doesn’t foal in those two years because the herd will be over the AML, and the only way to make the 90/10% PZP ratio work in 2015-2018 will be to dart all of the mares aged 1-4 and 7-19.

There is playing God, and then there’s the BLM.


With some heavy handed changes to the thresholds, it could be a step in the right direction.  Unfortunately, EA’s don’t work that way.  The Action that the BLM chooses will stand unaltered.  For this reason, the best outcome at this time will be for the public to convince the BLM to choose the ‘No Alternative Action’.  This action would mean that the current plan of not darting mares aged 5-10 years of age or yearlings would remain unchanged.  It’s not a great plan, and the BLM can do better.  But this new revision?  NOT BETTER.

So I best get typing up my response to the BLM.  I wish you all the best of luck as we weather this poop storm together.


Published by Rachel Reeves

I am a photographer who currently lives in the great state of Colorado. I love going out and photographing wild horses in their natural habitat, and look forward to being able to share a glimpse their world with you.

13 thoughts on “Wait. They Wanna Do What When with Whom?!

  1. Rachel, I love a woman that speaks her mind! At first I thought I would have to get out the calculator and side rule to follow along .I’m so glad you know this horses well enough to explain it better. Sounds like same old double talk from BLM to cover their back side so they can do what they want. Oh, I thought our wild horses lived on American soil, not China(1 baby rule if you know what I mean). Keep up the good work. God Bless!

  2. Your passion and commitment to the American Mustang rings true. You made very real points with real horses–horses that deserve to stay on their land with no human interference. I will share your post–it is beautifully written, well illustrated and provides rational points for our comments to the BLM/Congress. Thank-You for sharing and caring. Keep writing!

  3. Thank you for breaking it down. As I mentioned on Facebook I haven’t had the chance to properly read through your post or the EA (just a couple quick read throughs). The thresholds really do make me nervous though. When you explain Threshold 3 as you did above I don’t know how it couldn’t be concerning! Manipulating numbers works in theory but may not go so well when put into play with actual live animals who live in such an unpredictable environment.

    I agree that Threshold 1 makes some sense. As much as I love Firestorm (and she’s my very favourite-although I also love Feldspar and Jacinta and Hailstorm and Jasmine and Icara and….well you get the point-I think they are all gorgeous 🙂 ) I really do think she could use the break. And I don’t think she would be allowed more than 3 offspring left on the range if they went with a more removal based system (I, too, think removals are bad news. I wish I could adopt a Pryor horse if more had to be removed and I’m sure many others do too but it’s not something that’s feasible for everyone!) so she’s probably in the best possible situation she can be when it comes to passing on her genes.

    Threshold 2 is what really concerns me. Essentially, this proposal puts the herd at risk of allowing only one offspring per mare at it’s most extreme, something which simply doesn’t support the long term health of the herd. I am a cynic, so I worry about abuse of this threshold down the line. And it doesn’t support survival of the fittest when it is man doing the selection-as you pointed out. But when nature plays a role it’s not always the sickly or weak that are removed from the population, either. The stallion Pierre is thought to have died by falling off a cliff battling another stallion. A pure accident. Challenger was struck by lightning, also an accident. Life is tough in the wild, for all the horses and there just aren’t any guarantees.

    To me, this proposal is far too extreme. Basically, this comment is just one long way of saying I agree with your concerns about the thresholds! Hopefully I can put together something more eloquent soon!

    1. Thanks for your thoughts Abbie! You make some excellent points.

      One of the things that really helped me was to chart how the new EA would impact each mare F-O. When I sat down on Thursday, I assumed that it would give me things to think about and maybe I’d have enough of an opinion to share by Saturday. I was halfway through the H’s before I said, “Oh heck no” and knew I had to blog my feelings right away.

      I firmly believe that healthy cynicism is important when dealing with the government in any capacity. The best way to ensure there is no abuse is to to take away any level of power that gives the federal government opportunities for abuse. Maybe Jared would not follow this to the letter. Maybe he would ignore threshold 3 and choose to not PZP the 7-9 year old mares who hadn’t foaled yet. Maybe he wouldn’t leave a mare with only one offspring left on the range. Actually, scratch that, he’s already done that last one repeatedly… Anyway, the point I was getting to is: what if he does? Or even if Jared is fair in how he enacts this EA, what happens if he were to retire and be replaced with a Jerome Fox type?

      There is no perfect solution. In an ideal world, the Forest Service fence would be removed and judicious, careful use of PZP combined with the occasional small-scale removal would keep things at a happy balance. Since this isn’t a perfect world, that is not going to happen. It certainly won’t within the next three weeks. In the meantime, I would submit that it is better to err on the side of caution by not giving the BLM free rein & opportunity to follow thresholds 2 & 3 to the letter. If that means that we also don’t get thresholds 1 & 4, then so be it.

  4. Thank you so much..I think it is very important that this information be shared and people figure out where they stand and please write to the blm and tell them…It is one thing to have an opinion, it is a totally different thing to voice it….we need to do whatever we can to save our wild horses and burros without harming their future health and welfare..there is lots of information out there to read and there is also a lot of opinions…go find out for yourself what you believe is best and then go forward and get involved in speaking up…
    This post is great information and written by someone who knows what is going on…our wild horses and burros are well worth taking the time to make a decision that is in their best interest..no one else’s.

  5. Thanks for another excellent blog post. I have only been involved with the Pryor horses for three years and still feel like I have so much more to learn. I appreciate the great job you did of breaking down the facts. I will be sharing your blog on Facebook, with (offline) friends, and my grandma who LOVES to write letters regarding wild horses.

  6. This post breaks it down really well! I hadn’t had the time to thoroughly go through the EA when you first posted this, I had just done a quick read through. I think it’s really important for us to all discuss it together and everyone to get their ideas out there because everyone may see points differently. The first time I had read through the EA I hadn’t quite grasped the fact that technically there was a loop hole in that you could remove a mare’s offspring from the range and leave only one remaining and still be compliant with the EA. I had thought of it like “even if the BLM removes two, the mare will still get to keep two.” I’m glad that you brought my attention back to that. Relying on only my own interpretation I may have realized that upon further examination or I might not of. I think you brought up some very good and valid points at each point of concern you addressed.

    Also something that has me concerned is that this plan will be set in place for an indefinite amount of time, it doesn’t have an expiration date like the others have had. Having an expiration date REQUIRES the public and the BLM to discuss whether the current plan is working or if it needs adjustment. Without this requirement I worry that in the future they could say that there is no need for a discussion about any changes to the fertility program.

    1. To be honest, that loophole is hard to pick out even after a couple read throughs AND reading this post! I’m very glad I was made aware of it because it ( as well as Threshold 3) completely changed the way I look at the proposal!

      As far as the lack of expiration date goes, that is a really good (and really concerning) point. We could be stuck with this plan for ages.

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