Vet Claims Vast Mustang Experience, Challenges Winand

Horseback Magazine

Challenges Winand's Right to Speak Out

The following is from Dr. Don Hoglund, MS, DVM. He has asked that we print his letter using full paragraphs if we quote him.

Hoglund is writing in response to my recent article in Horseback Online quoting Dr. Nena Winand of Cornell University regarding what she claims is BLM’s incompetence in caring for the wild horses in captivity.. While we firmly believe she can defend herself and her words with erudition, we believe her detractor clearly missed her point by taking umbrage at her characterization of the gather of wild horses in Nevada and their later treatment as an “outrage” as quoted in Horseback Online. She is speaking of wild horses developing metabolic disorder in captivity saying:
“How does the BLM propose to manage upwards of 30,000 horses out East, and presumably rely on private individuals to supervise them?” she asks. “Not all Mustangs would be predisposed to develop this problem, but certainly some will if not managed with insight and oversight. Who pays for that?”
Winand says there are also genetic issues she has raised with other vets.
In short, she sums up her feelings regarding BLM’s veterinary treatment of wild horses in four words.
“It is an outrage,” she says.”
Hoglund charges Winand is out of line in expressing her First Amendment right to free speech in describing her feelings toward what she perceives professionally to be incompetence on the part of BLM veterinary practices. In fact, we wish more courageous veterinarians would speak up when they see callous disregard for the wellbeing of horses, or outright professional incompetence on the part of veterinarians who are charged with their care.
We strongly disagree with Hoglund and fully support Winand’s courageous stand.
Finally, Hoglund criticizes Horseback Online for our use of the term “Mustang” in describing the wild horses of the West. Perhaps he should also include the BLM itself which sponsors “Extreme Mustang Makeover” events in partnership with the respected Mustang Heritage Foundation from coast to coast to encourage adoption of some of the horses it takes from their native habitat. Horseback Magazine has enthusiastically supported this program since its inception and continues to do so. And yes, we’ll continue to call them Mustangs like the rest of America.
We happily print Hoglund’s letter to us in full. We also welcome reader comments. Send your thoughts to texasmagazine@hotmail.com.
Steven Long, Editor

_________________

Dear Mr. Long,
If you plan to harvest my statements for publication, I presume you will print in full paragraphs, all of my e-mails.
With reference to your article Jan 3, 2010 "Cornell Vet Raises Concerns...":
Let's begin here, and do check with Dr. Winand on my first remark, below;
"In short, she sums up her feelings regarding BLM’s veterinary treatment of wild horses in four words. "“It is an outrage,” she says."
When you state ["In short,...]" I am assuming you are paraphrasing Dr.Winand. Since I conducted 7 annual federal competitive bid contracts for veterinary care with the BLM/prison Inmate horse training programs and was, as a result, nominated by Bill Richardson (D) New Mexico as Congressional Veterinarian of the Year for 1988, I hope you are not also referring to my veterinary treatment then - as an outrage. In defense of the current veterinarians on BLM/USDA staff, it is highly unlikely that Dr. Winand is referring to the veterinary treatment partof the captures as an outrage. However, if she stands by that statement in your article then we can contact the dean of her college, the dean of the biomedical college at Cornell, and the state of New York veterinary medical board and find out if she actually meant "Veterinary treatment," or actually she was referring to the "means and manner of capture" as outrageous. I will look into this quote because veterinarians use their states' board of veterinary medical examiners to conduct review of performance and do not rebuke colleagues in professional or lay-market articles. I'd check into this if I were you, Mr. Long.
I have no problem with the "metabolic syndrome," argument that Dr. Winand described. Once adopted into the domestic population I've seen more potential metabolic syndrome cases in the pony and northern European breeds and in the outer banks horses of the east coast than in formerly free-roaming horses. Over-feeding is a problem in all horses, just as is the polar-opposite - starvation.
 
I disagree with the use of the term Mustang. If we agree that mustang derives from mustaño, meaning - loosely - owner-less, then owner-less is not really a term that describes the horses that Dr. Winand mentions. Tribal horses are Native American horses and horses on military reservations are military horses. The other free-roaming horses are state or federal public horses, even if crossing onto or through private land. None are really owner-less. They are free-roaming and not all are protected by the federal "Wild Free-roaming Horses and Burros Act of 1971, as amended." Feral is a construct used by stategovernments meaning estray, usually falling under estray laws, to describe a once domesticated, gone-loose animal.
With respect to the humanitarian Pickens initiative; per your article - "Winand has high praise for Madeleine Pickens plan to house wild horses captured by the BLM on a million acre facility in the West.
Thus far, the billionaire wife of philanthropist T. Boone Pickens hasbeen rebuffed by the BLM." There are at least two problems with this paragraph. All of us, with you included I presume, thought that the Pickens initiative was to be self-funded from their personal treasury. 
We were all very impressed by that humanitarian effort. 1) When the Pickens platform suddenly asked for a federal stipend, they left out the federal bid legal requirements. If the federal government had paid the $500 per horse per year fee requested and the Pickens's took all 33,000 captured, formerly-free-roaming horses, that would be a (33,000 times $500 per year =~ $45,000 per day) stipend. Now, I ask you, what ranch owner from North Carolina to California would refuse that contract? It would be better located in the grasslands states since the horse is a grasslands animal. So, just as the law requires of the BLM, the BLM requested bids and smartly limited the number of horses per bid. 2) The BLM did not rebuff the Pickens effort. It was not legal to have the taxpayer dollars pay for horse maintenance unless a competitive bid was called for, posted, and legally executed. You forgot to mention that fact in your article.
Since the horse is a grasslands animal, decades ago I advised the BLM to set the sanctuaries in grasslands states. They didn't need my advice, they chose smartly and placed them in Oklahoma and Kansas.
I agree, cold weather is not a great time to capture any horse. How many cold-weather captures have you attended?
In my estimation, the free-roaming horses should me managed in the
wild, using fertility control and other non-lethal measures for population control, studied by taxpayer funded research through the 10 state universities where free-roaming horses live, managed by the 
Natural Resource departments, and if a free-roaming horse is captured it should be trained by one of the active four remaining prison inmate horstraining programs. The free-roaming horse population should never drop below 26,000 in the ten western states, where they currently exist.

Best,

Don

MANAGEMENT OF THE FREE-ROAMING HORSE

At the beginning of the nineteenth century nearly two million wild horses, or mustangs, graced the western ranges, the rearing stallions – tails and manes flying – were almost mythical symbols of freedom, independence, and endurance. By 1970 free-roaming horse numbers on western states’ public lands were pared down to nearly 20,000 animals. The Wild Free-Roaming Horses and Burros Act of 1971 (Public Law 92-195) was enacted to protect the remaining wild horses where then found on forty-seven million acres which became divided into three-hundred and three herd management areas.
Sadly, within the last thirty years, some members of congress have worked tirelessly to zero-out over a quarter of the originally preserved acreage and have eliminated one hundred and eleven of the wild horse herd areas. The traumatic capture and adoption of free-roaming horses have been so successful, that six of the original sixteen western states that were home to wild horses in 1971 no longer have herds. Due to recent federal legislation by politicians beholden to private enterprises, free-roaming horses could vanish from the American west. What will the future hold for these noble creatures who are direct descendants of horses that once hauled us across the frontiers of America and helped us build a nation?
Today, the attitude of “Live and let live,” when applied to the environment, just doesn’t work. Human population growth, urban sprawl, and natural resource development have made it necessary to manage everything – even wild things. So, to preserve the wildness and the world we love, we must intervene to save these free-roaming horses. The first intervention might be to detoxify the vocabulary.
If you ask anyone vaguely familiar with horses about free-roaming American equine issues, be prepared to spend considerable time in debate. There are plenty of valid viewpoints, several of which are quite emotional. The multitude of positions has created a deafening whirl in the halls of Congress as well as out on the western rangelands. Concerns for and about wild horses pit urbanites against ranchers, public servants, and horsemen. For instance, just referring to free-roaming horses as wildlife is a great way to get bogged down in arguments, even law suits, about definitions. What distinguishes wild from exotic, mustang, feral (ranch horses gone loose), or indigenous? The truth is that, when cornered, free-roaming horses have plenty of equine wildness in their behavior, and it is that very wildness that captures the human imagination. Calling them ‘free-roaming’, as found in federal language, allows the discussion to concentrate on the horses themselves as a unique environmental and national treasure. The key is to find palatable, long-term solutions to preserve them, while at the same time protecting the environment and the interests of private citizens.
As an equine veterinarian and professional horse welfare advocate with 23 years experience in dealing with and training thousands of un-gentled horses captured in western and eastern states, I completed seven annual contracts as the attending veterinarian with the Bureau of Land Management and New Mexico prison inmate horse training programs. I also provided the onsite technical support, veterinary care, and adoptions program for the rescue of the White Sands Missile Range horses from which Nobody’s Horses arose.
From my perspective, in order to comprehend this often emotional debate, we must understand that there are two major horse populations in the United States; the domestic, private property horses and the publicly-owned, free-roaming horses found in the wild in many states or held in federal captivity awaiting fate. Only some of the free-roaming horses in the western states fall under the federal protections of ‘wild’ horse law. The other free-roaming horses, east or west of the Mississippi River, are on sovereign lands, military reservations, park service lands, federal lands not covered by ‘wild’ horse law, or on private property. In these various places the horses are either not protected by any law, as in the feral designation, or they are only protected by state and/or local laws. I consider only the federally protected, free-roaming horses in this discussion.
At first glance and because Nobody’s Horses is a book about free-roaming horse rescue, the domestic group of equine might easily lope out of this discussion because they fall under the purview of domestic property law. Not so fast. Though the domestic population of 9 million horses is privately owned, current congressional potential for prohibiting horse slaughter for human consumption is locked between forces supporting and opposing such federal legislation. Because debate revolves around the acceptability of the slaughter of any horses, the fate of free-roaming horses enters the fracas. The publicly owned, free-roaming horse populations – hoofing out a living mostly on public lands – counts at about 64,000 head total. About one-half of these highly regarded horses – in effect, John Q public horses and taxpayer assets – range freely in ten western states. The discussion will return to their destiny later. The other 30,000 head, to the disquiet of some vocal sympathizers, are imprisoned in protected holdings called sanctuaries or in federal stockyards awaiting adoption to loving homes or death by law.
As of this publication and regardless of logical or emotional perspective, three statements can be made. Free-roaming horses are still being captured even though 30,000 are already detained and munching out a life in taxpayer funded holding areas. Some captured, free-roaming horses are not federally protected from commercial slaughter. Domestic horses including some of the refuges from the wild life are not protected from human consumption. How did this trifurcation and resultant anxiety come about, this time? I say Senator Burns and his colleagues in Congress forgot about the determination of wild horse advocates. Or did they?
In 2004, due to the Burns Amendment change in wild horse law, 8,000 of the imprisoned equine captives that are deemed not-adoptable are likely headed for a cold meat-hook. As the Burns Amendment would have it, regulatory protections for wild horses managed by the staff at the Bureau of Land Management and its counterpart in the Department of Agriculture were changed. Senators had written into the 3,300-page federal budget a mandate that the BLM sell to the highest bidder wild horses deemed not-adoptable. In April of 2007 the House of Representatives passed H.R. 249 which would restore the prohibition of the commercial sale and slaughter of captured, free-roaming horses and burros. That bill would overturn the Burns Amendment and it currently resides in the Senate Energy and Natural Resources Committee.
Ultimately, like it or not, the fate of those currently corralled, but not adopted, 30,000 free-roaming horses revolves around potential adoption, commercial slaughter, or daily confinement at a taxpayer expense predicted at $2,700 per horse for the remainder of his life. The Burns Amendment remains intact and that is a dilemma for taxpayers, federal officials, lawyers, and animal advocates.
My current concern is for the destiny of the few remaining free-roaming horses that fall under the often amended and notably weakened protections of the Wild Free-Roaming Horses and Burros Act of 1971. Their fate gyrates about the phrases “capture for adoption,” versus “in-the-wild” management.
Dr. Kathleen Fagerstone of the USDA Wildlife Services tells us that “for most of the last century, federal and state wildlife conservation agencies in the United States have focused on conserving or increasing populations of many species of wildlife. The changing cultural values and increasing urbanization of the United States are curtailing traditional wildlife management tools used to effectively manage conflicts between human and wildlife populations. A growing interest in non-lethal methods for [animal] population control [in-the-wild] of nuisance or damaging wildlife species has fostered research in wildlife contraception.” Due to the fact that contraception for wild or other free-roaming animals is now possible, thanks to advances in scientific research, this method of population control is gaining favor in the hearts and minds of horse advocates and wild horse critics alike.
Dr. Gary Killian, a distinguished professor and fertility control expert, notes, “There are lots of factors that need to be considered, not to mention the fact that mares that are contracepted tend to live longer. Decreasing the death rate will add to the total population. I guess if fertility control of free-roaming horses were easy, it would have been done already. At least we have some tools now like immunocontraceptives that have potential to be useful if we could overcome the politics and figure out how best to apply them.”
So what are equine immunocontraceptives? How do they act to reduce birth rates? Who is against their use, and why?
USDA Wildlife Services at the National Wildlife Research Center in Fort Collins, Colorado began developing wildlife contraceptives in 1991. Scientists both here at affiliated universities and private companies have steadily worked toward developing and registering contraceptive products that are practical and safe for animals and humans. In 2005, the regulatory authority for wildlife contraceptives was changed from the Food and Drug Administration (FDA) to the Environmental Protection Agency (EPA).
Currently, two immmunocontraceptive vaccines, the Gonadotropin-Releasing Hormone (GnRH) and the Porcine Zona Pellucida (PZP) vaccine have been tested to prevent pregnancy in free-roaming horses. Both come in a liquid form for injection by needle or bio-bullet. (Inter-uterine devices (IUDs) have also been tested, but with only limited success.) These two vaccines use the animal’s immune system to produce antibodies against reproductive hormones, gamete (egg) proteins, and other proteins essential for successful reproduction. In other words, the antibodies interfere with the natural activity of the reproductive agents. The vaccines can now be made so as to be effective contraceptives for 1 to 4 years or longer. Neither is a hormone, nor does it have hormone-like activity.
GnRH Vaccines are not hormone injections
The GnRH vaccine creates antibodies that interfere with the reproductive hormone in both sexes by causing blocking of biologically active GnRH. The result causes a reduction in the release of other reproductive hormones and silencing the activity of the gonads.
Fagerstone et al report that blockade of mammal GnRH is effective in reducing fertility in most mammals, including rodents. The contraceptive effects of a single-shot GnRH vaccine lasts for at least four years. As of October, 2006 in the fourth year of Dr. Killian’s well-refined study of the GnRH vaccine GonaCon ™ , half of the mares are still open (not pregnant). In preliminary studies with white-tailed deer using a modified GnRH vaccine, GonaCon-Blue™, 80% of the females are infertile four years following a single vaccination.
A recent USDA “Target Safety Study” completed for the FDA in collaboration with Dr. Killian’s group at Penn State University, “did not find any contraindications associated with GonCon use.” GnRH vaccines can cause sterilization, but only if administered repeatedly. Hence, GnRH vaccines need to be used judiciously by knowledgeable, experienced handlers. The GnRH vaccine has been submitted (approved 2009) to the EPA for registration.
PZP Vaccines – currently are 1-2 years in duration
The Zona Pellucida (ZP) is a naturally produced glycoprotein layer located on the outer surface of the egg which is produced in the ovary of the mare. Use of the PZP vaccine results in infertility either by blocking sperm from penetrating the zona pellucida layer or by interfering with egg maturation. According to Fagerstone, “The advantages of PZP are that, because PZP is a protein broken down in the gastrointestinal tract when consumed, it does not enter the food chain [if a vaccinated horse were eaten]. Also, its effects are normally reversible. It is not species specific and is effective in reducing fertility in most mammals tested. The disadvantages are that PZP vaccines must be applied by injection.” Other significant disadvantages with PZP vaccines exist. The vaccinated mares continues cycling and thus remains a target for stallions, where as pregnancy would limit that harassment. Also, it is unknown if ovary destruction occurs as a result of the antibodies. In some instances, when the antibodies level drops below critical thresholds (as the vaccine effects wear off), late-term pregnancies may occur complicating the winter life of the mare and the new born foal.
Long-term studies involving GnRH and PZP vaccines on white-tailed deer (Miller et al. 1999 and 2000) showed no adverse effects on the animal’s health. For the GnRH vaccine, altered heat-cycles in the deer were seen and expected. The same can be anticipated for horses.
There are of course concerns that must be addressed when using contraceptives to control overpopulation in free-roaming horses. Any program will need to be funded, easy to administer, cost-effective, effective for multiple years, and have few or no known contraindications (adverse effects). Currently, since the vaccines are injectable, horses must be captured and processed or shot from a remote location with a dart or bio-bullet. Even though capture for processing is traumatic and inherently violent, study of vaccine efficacy and horse health necessitates a close relationship to the target animal. Aerial facilitated darting or use of bio-bullets can be inefficient, and these types of vaccination methods make research study of the health and biomedical effects of the contraceptive difficult. The darting process has the potential to leave a mechanical dart in the environment. Further, annual capture of free-roaming horses for booster vaccination usually becomes more difficult with each subsequent attempt. This is not economical and from a behavioral perspective it is not logical. A vaccine that is effective for multiple years is better and less costly than a one - or two-year vaccination.
There are other considerations to take into account when attempting to control herd size. Is the population “open” or “closed” to migration from other herds? What are the sex ratios, age structure, and the natural estimated increase or mortality of the targeted herd? Researchers have produced various models, some of which suggest that animals which give birth at 3 years of age, as horses generally do, will need more interventions than simply contraception in order to maintain a herd at a desired population. These additional interventions include capture and removal, redistribution of family groups to lands allotted for herd management, or in the case of game or nuisance wildlife, lethal control. Of course, lethal control was not an option for free-roaming horses, until recent legislation.
Contraceptive treatment to manage free-roaming horse populations in the wild must take into consideration the average age of the animals involved. Dr. Killian astutely observes that ‘if younger mares have had one or two foals, they have contributed to the gene pool, and additional foals with their genes are not needed” to keep the genetic pool intact. In addition, due to the difficulties of gathering an entire free-roaming herd for vaccination, there will always be a number of untreated mares in any given population.
I agree with Dr. Killian’s suggestion that “The bottom line is there are some reasonable one-treatment options that will be available for contraception of mustangs in the near future. These far surpass anything currently being used for mustang contraception. What has to happen is that the public needs to drive the course of action. In my experience, the people with the dollars and currently in charge of dealing with the [horse] problem are set in their ways and have different ideas about how to proceed.”
The wild horses of the Outer Banks of North Carolina, Virginia, and Maryland have set the precedent for true art in the fertility management and adoption of free-roaming horses. Thousand Welcomes Farm in Chapel Hill, North Carolina, the Foundation for the Shackleford Horse in Beaufort, North Carolina, the National Parks Service at Assateague Island National Seashore Trust in Maryland, and the Chincoteague
National Wildlife Refuge in Virginia are notable examples of farms and organizations who have proven their love and respect for historical America and free-roaming horses.
The American Wild Horse Preservation Campaign is correct when it writes that “Solutions need to be implemented that will allow wild horses to be managed in the wild, securing a place for our wild herds in the American landscape. AWHPC is calling for fair and balanced management decisions that are based on accurate, scientific information and that take into account the interests of all parties, including the horses, public land ranchers, and the American public.” AWHPC supporters are against the use of hormones as contraceptives.
I don’t know if all sides of the free-roaming horse debate can be placated, but I do agree with AWHPC when they say that ecotourism should also be given a chance to play a role in herd preservation. “Horse lovers, wildlife enthusiasts, as well as those with an interest in the history of the Old West, should be given the opportunity to enjoy wild horse excursions year-round. In addition to non-intrusive observation of wild horse behavior and herd dynamics, in-the-wild management itself could become part of a unique experience for visitors to herd management areas.”
As an equine veterinarian who has spent his professional life protecting the publicly owned free-roaming horse, I understand the legitimate concerns of all interested parties, cattlemen included. However, I feel that we need to protect our public property first, while we weigh the proper stewardship, transport, and disposition of this revered part of our American spirit. I am not accusing our Interior Department and USDA land managers of mismanagement. My experience with the staff in these entities has been trusted and respectful. Most public servants and land managers tell me that they want to manage the free-roaming horse in the wild. They need the proper laws, dedicated staff, time, and mandated funding to do it right and to study the effects of the management tools.
The agriculture and veterinary medical colleges in states with free-roaming horse populations are a great mechanism of public oversight and could be recruited to assist these agencies and keep academic research and influence involved. After all, we trust the schools to teach and lead our young people, and since we already employ the staff and faculty, why not trust them to care for our free-roaming horses, too? It would be a perfect outdoor laboratory and a good use of public funds.
Judiciously applied fertility control contraception will go a long way in maintaining horse populations at desired levels. However, when environmental study indicates that any given population of free-roaming horses needs to be artificially lowered by capture, I suggest the captives be remanded to the good and effective wild horse
prison inmate training programs. In this manner, free-roaming horses are gentled under a humane and controlled system before they are released into a domestic equine life.
Many cattle growers would applaud effective free-roaming horse population control. Animal advocates should be pleased with preservation and limited captures. Wildlife managers would welcome the funding needed to appropriately manage all of our important wild species. Slaughter of free-roaming horses would not be necessary because the horses would either be returned to freedom after being examined and vaccinated, or gentled in a prison training program and sold to responsible owners. One in ten thousand horses is truly not amenable to gentling. Those few might be neutered and returned to their original herds. We can’t manage one million free-roaming horses, but we can manage enough to be meaningful. Should we tolerate the possibility of zero free-roaming horses?
Even though emotion about the issue of free-roaming horse survival often takes us to places we do not want to go, we should allow reasoned passion from the heart to direct our efforts. We should protect all of our animal species from birth to death with intervention only when necessary and always as humanely as possible. If we choose to terminate animal life, we should do so humanely.
It is time for solutions: not finger-pointing; not just words. It is time for action. Funding will be required. Help save the free-roaming horse from destruction. Contact your elected representative and respectfully ask them to get involved in the management of free-roaming horses in-the-wild. After all, the horses belong to all of us, the land belongs to all of us, and the elected representatives who control our money work for all of us. These nobody’s horses are everybody’s horses.
This author does not consider hormone injections a viable option for contraception in free-roaming horses. Oral vaccines for fertility control in horses are not yet available.
™ - National Wildlife Research Center, 4101 LaPorte Avenue, USDA, Animal Plant Health Service, Fort Collins, Colorado.
 
Safety and Toxicity Evaluation of GonaCon TM Immunocontraceptive Contraceptive Vaccine in White-tailed Deer (Odocoileus virginianus)
 
SpayVac ™, a long acting PZP vaccine, is not currently in production (personal communication).

Preliminary Report from the Calico Round-up

This is only an UNOFFICIAL report of what is going on out at Calico from advocates who were there ( Willis and Craig). It is only  a preliminary report but is very well detailed so please read carefully.Thanks! (From Charise!)


PRELIMINARY REPORT:  12/31/09 Calico Gather Observation Trip Please note:  This is a preliminary report, subject to revision and/or addition information.
Objective.
The objective of this observation was to get an "eyes on the ground" look at the region and gather activities, and to better understand the planning and rational behind this particular gather design and strategy.  It is not the intent of this report to delve into land use priorities, overall herd management strategies or political issues, although some options are discussed later in this report.
Background.
The Calico Mountains Complex is a very large and in some instances a diverse region that includes several distinct herd management areas. Trapping operations have been scheduled to take place in multiple locations, with the trap site corrals and related equipment being relocated throughout the complex throughout the gather period..
Environmental conditions can vary between the locations where horses are to be gathered.
Geography, range size and other factors (e.g., weather, impacts on wildlife) appear to make water trapping not a desirable or practical option for this complex.  As we are all aware, BLM decided to conduct gathers using aircraft in this complex.
Observations.
The Dec. 31 gather location was on private land in an area known as Paiute Meadows.  This is a semi-arid mountainous open range that is roughly north of, and relatively close to, the Black Rock Desert.  It consists primarily of steep, rugged hills separated by relatively wide valleys.  Vegetation is limited to floor level plant species such as grasses and sage.  The area has no natural trees.  On December 31, the valley floors were covered with about two inches of powder snow so identification of the various types of available forage was not practical.
The footing in this area is generally rocky, although by Nevada standards I wouldn't describe this particular area as being overly rocky.  The snow pack was light and relatively moist (as opposed to melted and refrozen ice slicks) and traction was surprisingly good.
The trap site appeared to take advantage of natural land forms and an accessible road.  Trap wings were placed at the easterly down slope end of a broad valley that had a relatively light longitudinal slope.  The topography allowed the trap and sorting corrals to be connected as one large unit (as opposed to remote trap sites where horses have to be loaded into trailers, then trucked down to the sorting corrals to be sorted and loaded again for transport.)  What appeared to be a significant amount of private fencing (fence wire and posts) had been temporarily removed to facilitate orderly movement of the horses.


View of wings and entrance to the corral structure.

 As expected, the trap site and main corral system included connecting holding pens for separating "special needs" horses from the general population.


View of pens near the loading chute.

Shortly after our arrival we experienced a snow squall that grounded air operations so actual observations were limited to the trap site layout and configuration.
This particular trap site appeared to be configured according to expected standards, making effective use of local topography, placed in an area where horse travel did not require movement over steep terrain and where the helicopter pilot could observe, and not lose sight of, all the horses in a band being brought in.  If actual air operations are conducted as they should be, this particular site should not require the running of horses over long distances as a competent pilot could "herd" them down the length of the valley at a relatively easy walk, at least until the horses reached the trap wings.
I observed no unusual circumstances or safety problems with the trap site layout.


Overall trap site layout.
Discussions and other issues.
Since there were no active gather operations this day, some of the on-site time was spent in Q & A and discussions between observers and BLM personnel.  Some of that information is relevant to understanding BLM's strategy with respect to this gather and therefore I am including it in this report.
Craig Downer raised questions relative to the standing of the horses on BLM public lands, particularly in regards to their status as defined by Congress.
BLM explained that there is a difference in standing with respect to herd areas (areas managed primarily for horses) and herd management areas (multiple use areas where horses are present, but not managed as the primary component.)  In the herd management areas horse management priorities fall within a much larger matrix of land use and management laws and regulations.
The issue was raised relevant to some herd areas being redesignated as herd management areas.  That was not a topic that the field personnel were prepared to address since such decisions came out of Washington, DC.
The issue was raised relevant to gathering in the winter.  BLM's position was that throughout most of this complex, it was safer to move the horses in winter than in late summer (after the spring foaling season) due to heat and in some instance alkali dust and rocky valley floors.  So long as traction remained good in the snow, it resolved the dust problems and provided a cushion over the rocks.  Being relatively flat terrain where the horses would likely be moved, this explanation appeared to have merit.
Craig Downer raised the question of the helicopter producing flying snow from the rotor wash and its potential impacts on the horses' respiratory system.  The APHIS veterinarian on site acknowledged that this could be an issue, but suggested that the incidence of airborne snow should be minimal, and less problematic than summer dust.  In my opinion if aerial operations are conducted correctly, the amount of "exposure" to wind blown snow would be less than that experienced on a typical Nevada windy day with powdered snow on the ground.
A discussion took place regarding an aged mare that had been euthanized.  This was one of a few areas where different personnel had a different take on what actually took place.
What was consistent in the explanations was that an aged and debilitated mare had been observed nearby that had become disassociated with her band.   (This is typical situation involving  elder "end stage" horses who eventually can no longer keep up with their bands and there was no evidence that this was an instance where her band had been driven away and she had been left behind.)  The mare was moved to the trap site where the veterinarian determined that the mare was well into her twenties, had naturally declined and would not survive the winter.  The mare was then shot and disposed of.
The decision to euthanize this mare was not unreasonable.  Later discussions revealed that she also had what was described as a long yearling colt with her.  Being disassociated from he protection of their band, the colt was also vulnerable to predators.  While it clearly is a myth that older horses (aged 10 or older) cannot adapt to a managed enclosed environment or even successfully be adopted, the relocation outcome for debilitated elder horses is seldom good and it may not only be inhumane, but illegal in Nevada to load a severely debilitated horse into a transport along with robust horses for a several hour trip.
Since each circumstance is unique and since it is not always easy to administer IV injections to a wild horse at a trap site, I am not going to speculate over the decision to use a rifle rather than barbiturates to euthanize this mare.
My personal problem with this euthanasia is that the carcass was buried which in my opinion was a waste of otherwise available nutrition for wildlife.  If the mare had been allowed to die of natural causes, her protein would have been available to the ecosystem.  Since the mare was not euthanized by use of barbiturates, a more eco-appropriate disposal would have been to relocate the carcass to an suitable location available to wildlife.
Another discrepancy arose as to the condition of the horses coming in.  The veterinarian graded the horses as being in poorer condition than did the personnel who were actually receiving the horses.  (We were given permission to go to Fallon to view the horses that had just been shipped to the facility, however I experienced mechanical problems with my truck and will have to reschedule that visit.)  This is a minor issue since the criteria for BLM's decision in removing horses is based on population, not body condition, however I would like to view the horses to resolve these inconsistencies.
A third discrepancy arose regarding possible upper respiratory issues with the horses. In my opinion the APHIS veterinarian was not candid on this issue and appeared to have selected his words carefully, that he had not diagnosed any upper respiratory issues with the horses that were gathered.  I have a personal problem when public officials try to tell us one thing when our years of experience have shown the facts to be otherwise.
There is some latent disease in some of the herd areas.  Disease is part of the environment and is one of the natural forces that cull weaker members of a herd.  One of the more notable events in this region involved the Jackson Mountains salmonella outbreak in 2007.  http://www.kbrhorse.net/news/pvcsalm07.html
Some of the horses in this region occasionally exhibit some signs of an upper respiratory condition often referred to as "strangles." This is an illness that is caused by the streptococcus equi bacterium.  The disease got the nickname "strangles" as it can produce swelling of the lymph nodes in the horse's throat latch area and in some instances produce noisy respirations.  http://www.ag.ndsu.edu/pubs/ansci/horse/v541w.htm
This disease isn't some horrible plague.  It is limited to horses.  The disease spreads by direct contact, generally among members of a band.  While the bacteria don't live long in the "environment," it can be present in locations such as watering holes that are frequented by various horse populations.
Strangles is generally not a serious threat to healthy mature horses.  It can be harder on younger horses that have not developed immunity to the disease and to debilitated horses that are immune compromised.  BLM's horses are not going to become vectors and spread the disease to the domestic horse population.
However in a closed facility where a great number of horses are sharing the same space, feeders, waterers, and are in contact with each other, the horses can experience what is sometimes described as a "flare up" of the disease until it runs its course and the population's immunity levels are sufficient to curb the bacteria's spread.  The epidemiology here is not that much different than school children coming together in a classroom and "sharing" a cold, except that strangles is bacteria caused and most "colds" are virus caused.
The relevant issue here is that by going to the Fallon facility, any horses that come in from the Calico that may be carrying strangles will be isolated from the horses that are coming in from other regions to Palomino Valley Center.
Other issues and opinions.
AML, AUMs, et al.
BLM reports that the number of horses found in the Calico Mountains Complex is 5.5 times the "low range," and 3 times the full carrying capacity of the complex.  Since most of the area is open range, I will assume that these population estimates are reasonably correct.  This is one basis in which BLM justifies such a large gather target.
To be fair, a large number of cattle have also been removed from the public lands within the complex.  It was explained that most of these reductions were voluntary.  There is an assumption that in some instances putting the cattle out was not economically feasible.
In the discussion the usual confusion over AML, AUM and related terms arose.  I will try to explain in simple terms a complex process.
AML is the appropriate animal maintenance level for horses in a herd area or herd management area, typically expressed as a range from minimum to maximum population levels.
AUM is an animal unit month, or the grazing allocated to a particular animal unit for one month.  One horse grazing for one month will consume one AUM.  Because of a lower metabolism, one cow and her calf will consume one AUM.  Smaller livestock such as sheep and goats could reach 6 or 7 animals per AUM.
BLM is required by law to manage for a "thriving ecological balance."  One process in which BLM is supposed to achieve this objective is to assess the carrying capacity of specific ranges (available forage,) consult with wildlife officials regarding the amount of carrying capacity that is reduced by wildlife grazing, then determine what forage is left that can be assigned to the horse herd and calculated as AUMs allocated to seasonal grazing permits and leases.
Where things often mixed up are that an AML of 300 horses represents 300 horses grazing year-round.  An AUM of 300 for livestock means that a livestock permittee or lessee can graze 100 cattle during a three month grazing season.  So while it can be argued that private livestock significantly outnumber wild horses on public lands, the "face value" of  numbers when comparing AML to AUM statistics are far from representing accurate proportions of domestic versus free-roaming animals.
Birth control.
We were advised that BLM would be providing birth control for some of the horses.  Their strategy would be that those horses brought in that were in excess of the numbers scheduled for removal would be treated with PZP and released.  While these intentions are good, I have a fundamental problem with this strategy.
First of all, no agency is going to launch an effective program if it is carried out as an afterthought.  Applying birth control if "extra" horses are trapped is overly arbitrary and does not provide for a consistent representation of the horse population to be included in the program.
Understandably from BLM's position, they would be reluctant to birth control and release horses on a day when they experienced poor gather conditions and brought in few horses.  However there needs to be some consideration for daily PZP application rather than simply treating the "leftovers."  One alternative could be that on reasonably successful gather days, one or more bands that are representative of the herd profile could be held aside in one or more of the special holding pens.  If reasonable numbers have been gathered that day, the "reserved" bands could be treated, their backs marked with paint so they are not brought in again, and be released.
I also found it puzzling that the only immunocontraceptive birth control methodology that was being considered involved PZP.  I'm not here to disparage PZP, but the University of Nevada Reno and the UC Davis School of Veterinary Medicine appear to be making some advances in the area of longer term temporary equine birth control, both for mares and stallions, and BLM didn't seem to know anything about it.  From observing study horses both in our organization's possession and out on the range, some of the new formulations appear promising.  If BLM wants to get out of the long term holding dilemma, they have to take equine birth control more seriously.
Relocation strategies.  (or making use of available resources.)
Long term holding is becoming the most significant drain on the Wild Horse and Burro Program budget.  In Nevada there are opportunities to help mitigate this growing problem through more contemporary strategies.
In a cursory review of historic range data, there appear to be at least a few HMAs with low populations where predation and other natural factors keep the herds within, or occasionally below, the established AML ranges.  There may be locations where it is appropriate to boost stable populations with suitable horses from other ranges that would have otherwise gone to long term holding.  In such instances repopulations could help improve genetic viability.  Given the reduction in the state predator trapping workforce due to budget cuts, predation as a means of herd population regulation may improve incrementally.  While some special interests may object to horses being placed back onto public ranges, the expense of holding is a national issue and it makes practical sense to feed horses range grass that is already "bought and paid for" rather than board them with contractors.
There have been HMAs in which the herd has been zeroed out due to issues relating to herd management.  (Typically these have been areas where it is excessively dangerous to horses and/or personnel to periodically conduct gathers.)  An alternative would be to reintroduce stallions to areas sufficiently isolated so that mares won't migrate into the population.  Questions have been raised as to whether a herd of stallions would get along together.  Our experience has been that if mares are excluded from the immediate area, the stallions typically behave like youngsters.
http://www.wildhorseworkshop.org/whw03/whw03bf2.html
If you haven't seen the LRTC / Wild Horse Workshop video of the BLM Butterfield stallions, you need to.
Higher resolution (broadband) video:
http://www.wildhorseworkshop.org/mediafiles/butterfieldstallions.wmv
Lower resolution (YouTube) video:
http://www.youtube.com/watch?v=gOCSCwSKT0Q
Clearly there are some opportunities to return horses to the range and at the same time save money, without exacerbating the "recruitment" issue.
Resource issues.
BLM personnel agreed with our assessment that there were locations that had a great deal of range forage that could be available for horses and other animals however available water was the limiting issue.  BLM confirmed the problems the agency experienced in obtaining water rights.  In some instances water resource issues could be resolved through dual use (a use that was recognized by the Nevada Department of Water Resources that could also serve to water horses.)  Such projects might require private or non-profit assistance, however such opportunities need to be brought to the table.  Irrespective of population issues, the range habitat improves at low cost when those animals grazing the range can more evenly disburse their grazing pressure.  Furthermore not having large numbers of animals have to congregate at limited water sources could help mitigate some herd health issues.
Another option would be for Congress to assert its authority over water found on or under Federal public lands to the extent that the use of such water does not materially negatively impact other users of the aquifer.
Miscellaneous observations.
It was my impression that neither BLM or some of the out of state visitors really knew what to expect from each other.  BLM went overboard with security (which ironically was appreciated by me when I ran into vehicle trouble.)  The advocacy delegates present weren't from the Animal Liberation Front.  I do acknowledge that had horses actually been coming in, BLM's strict on-site safety protocols were relevant to insure the safety of the horses and people that would have been present.  I have to say that the implication that if observers didn't follow directions they could be led away in handcuffs was offensive and may have instilled jaded the perceptions in some observers.  BLM could benefit from adjusting its protocol message according to its "audience."
People who haven't seen Nevada gathers also tend to have an expectation of more drama than actually takes place out here.  While gathers aren't perfect and mistakes can be made, from my experience the Nevada crews deal with so many horses and so many gathers that they have learned how to organize things in a way that maximizes safety and minimizes risks to horses.  While the weather prevented me from observing actual activities, I saw nothing to suggest that this gather departed from Nevada's usual standards.  While horse advocates may not like to see so many horses permanently removed from western ranges, it is in the horses' interest for us to recognize, as well as insist on, safe and sane professionally designed gathers where those gathers have to take place.
Recognizing that safety is a critical concern during gather activities, I do wish to thank the Winnemucca District personnel for organizing what would have been a practical and realistic viewing opportunity, complete with a horse trailer that could have been used as a "viewing blind" next to the trap's wings where the most critical elements of the gather could be observed.
Brief summation.
The portion of the gather arrangement that I saw was reasonably well designed and did not require moving horses over extreme inclines and other avoidable  hazards.
The transportation of the horses to the new contract facility in Fallon is sensible from a number of aspects, including a shorter hauling distance for the horses.
Continuing to send horses to never ending long term holding is not a sustainable practice.  BLM needs to utilize available range resources where appropriate to reduce dependency on long term holding of horses.  There appear to be opportunities available that would not exacerbate BLM's concerns about population growth.
BLM needs to take birth control more seriously, and consider all viable and safe options for limiting herd population expansion while maximizing genetic diversity (e.g., leave a greater number of mares that each produce a fewer number of foals.)  It is probable that some cost effective solutions can be developed provided BLM isn't stuck on a myopic approach.
The Calico Mountains Complex appears to provide some opportunities where alternatives to removal (e.g., sex ratio adjustment, replenishment of depleted herds, introduction of stallion herds,  releasing of gelding bands, resource development, a greater commitment to contraception options, etc.,) could be attempted.  Practical and humane alternatives to sending more horses to long term holding should be encouraged by the wild horse advocacy community.
Finally, the people at BLM on the ground do not formulate national public lands policies.  Therefore advocates need to utilize every opportunity to encourage new horse management approaches within the parameters that field personnel are required to work within, and approach Congress to enact legislative changes that would clear some roadblocks that prevent other opportunities from being explored.
Willis Lamm,  January 1, 2010
- - -
Please note that this is a draft report, subject to revision and addition.

The BLM Slaughter Conspiracy

By John Holland and Valerie James-Patton
Equine Welfare Alliance

December 20, 2009

 

“Pure propaganda” was Bureau of Land Management (BLM) spokesperson Tom Gorey’s reaction in a recent AP interview when asked about the growing accusations that his agency is in the process of virtually exterminating the very herds of wild horses and burros that it is supposed to protect.

 

However, Gorey’s denial of the BLM’s intentions rings false in the light of recently uncovered documents from the BLM itself and of its own published plans and estimates. It is not possible to interpret these in any way other than a plan to virtually eradicate the wild herds.

 

Two internal-use BLM reports were obtained earlier this year through the Freedom of Information Act; Alternative Management Options Plans from October 2008 and the Team Conference Calls Report from July - September 2008. In these documents, BLM members presented, analyzed and discussed several management plans aimed at reducing the population of the wild horses on the range as well as those in holding facilities.

Proposals for reducing the populations included adjusting herd sex ratios with some of the horses returned being gelded, and an increased use of the contraceptive PZP, the use of other unauthorized fertility drugs called Gonacon and SpayVac and even surgical sterilization of mares (a process that has resulted in 10% mortality).

Also found in the Team Conference Calls report were these notes submitted by Don Glenn:

 

"Sally had an e-mail from a person in Canada who wants 10,000 horses that he would slaughter the horses and send them to a third world country. Don is going to send the email. Jim said he has a demand for horses going to Denmark, but they are having a problem getting titled horses."

Adding further to the plan for sending wild horses to foreign countries, the following recommendations were submitted to BLM from BLM's advisory board members at the June 15th, 2009, Advisory Board Meeting held in Sacramento, Ca:

"that BLM advertise and market sale eligible animals (with the intent clause) in foreign countries with known good homes by offering "select sales" for sale eligible animals 11 years of age and over, and for younger animals that have been offered for adoption three times during a 90 day period and that BLM continue to explore opportunities to foster foreign aid by providing sale eligible animals (with the intent clause) to foreign countries for agricultural (nonfood) use."

The BLM's response to these recommendations was that it is considering these plans as part of a 5 year strategy plan.

Clearly, the BLM has already been corresponding with foreign countries to market the wild horses with the intent to send the horses to slaughter. The board recommendation that the sales include the “intent clause” was clearly a fig leaf. The BLM is well aware that it would be impossible to enforce the intent clause in foreign countries.

But if that were not an obvious enough fig leaf, then the reference to “countries with known good homes” is a laughable one. It comes as no surprise that the notes from Don Glenn, who is also a member of the advisory board, were not mentioned at the advisory board meeting.

While Tom Gorey may continue to claim that it's pure propaganda that the BLM is in the process of eliminating the wild horses, the notes regarding the slaughter of our wild horses in foreign countries, combined with the advisory board recommendation to sell the horses to foreign countries proves otherwise.

The BLM’s plan is now clear. They will first ignore the 1971 Wild Free Roaming Horse and Burro Act and gather virtually all the wild herds, working year-round until only a few small, sterile bands remain free. If delayed in one place, they will simply shift their schedule and gather at another as they did with Buckhorn when Calico was delayed.

The cost of feeding these captured horses, along with the 37,000 already in holding, will then precipitate an enormous financial crisis. This will leave the BLM with no option but to euthanize or ship to slaughter most of the horses in holding.

BLM Plan Could Make the Mustang as Rare as the Buffalo

Horseback Magazine

By Steven Long
HOUSTON, (Horseback) – Of the 14,000 wild horses the Bureau of Land Management will take from their wilderness homes next year, the agency will only return 2,200 to the wild.
A substantial number of the horses taken in BLM “gathers” will be mares. And of those, the agency says it will render 800 incapable of reproducing, or almost 40 percent of the heard strength returning to the wild. Equine geneticists claim the government’s plan is to eliminate wild horses from the American West in favor of cattle leases where ranchers pay a $1.35 per head per month.
Under this formula, there will be precious few Mustangs left in the West a generation from now. Wild horse lovers claim it is a rape of the national wildlife heritage comparable to the 19th century destruction of the buffalo herds that once roamed the land.
The BLM claims the horses are hard on the land, but currently there are only slightly more than 30,000 left in the wild according to the agency. That number is hotly disputed by animal welfare advocates. More than 1 million cows graze on the public acreage, yet the agency never complains of bovine damage to meadows and riparian areas.
The agency controls 262 million acres.
The government claims wild horses breed resulting in a 20 percent each increase in herd size each year resulting in an ever growing population. Yet entire foal crops are wiped out in some herd management areas each year by predators such as wolves and mountain lions. There are only slightly more than 60,000 wild horses left, and half are already in BLM holding pens eating government feed, hay, and grazing land at an ever growing cost to the taxpayer.
Sen. Mary Landrieu, (D) Louisiana, has called for the BLM to submit a report next year on how it plans to change what is currently perceived as gross mismanagement.
The agency says no herd management areas will be left bare of wild horses after next year’s roundups, however, anecdotal reports coming into Horseback’s offices this week tell another story. No wild horses can be found on a Nevada refuge after an October roundup, sources say, yet the BLM claims horses are still there? Perhaps they are ghosts who only appear to government bureaucrats? Observers suffering from eye strain wonder.
The drug of choice to render mares incapable of reproducing is PZP. It is provided to the agency in a cozy deal with the Humane Society of the United States. Activists charge the nation’s largest animal welfare operation has a conflict of interest when it comes to wild horses.
Some have become increasingly aggravated with a perceived lack of action on the part of the HSUS, as well as the Washington based Animal Welfare Institute to halt BLM’s aggressive roundup schedule. In fact, HSUS applauded a BLM plan announced recently by Interior Secretary Ken Salazar to remove wild horse herds from the west and place them as tourist attractions in the Midwest and East. Wild horse experts scoff at the plan.
Neither HSUS or AWI has lent their name or prestige to a petition demanding President Obama call a moratorium on BLM roundups of wild horses. The hard hitting petition has been submitted to the White House by The Cloud Foundation and the Equine Welfare Alliance.
Frustration with HSUS boiled over when EWA co-founder John Holland wrote last week to Wayne Pacelle, CEO of the Humane Society, regarding the perception that the relationship with BLM appears to be too cozy.
“ Have you given any consideration to how HSUS is gradually being made more and more complicit in this rapidly expanding assault on our wild herds? Are you comfortable with that complicity?” Holland wrote. “It is now clear that the BLM is planning for the elimination or eventual extinction of the herds.  I am deeply concerned that HSUS may be drawn into a ballooning potential scandal.”
Pacelle didn’t give Holland the courtesy of a reply, instead directing a wildlife scientist with HSUS to respond.
“The HSUS supports the use of contraception as a management tool to bring horses to, and maintain, viable populations on the range,” wrote Stephanie Boyles. “The HSUS does not support the gather and removal of any wild horse, except in cases in which the health or safety of an individual horse is in question, for which there is not the probability of locating an appropriate adoptive home.”

BLM Will Treat 3,000 Wild Mares with Fertility Drug After Decimating Herds by Capture

Horseback Magazine

By Steven Long
HOUSTON, (Horseback) – The year 2010 will mark an enormous turning point in the history of America’s wild horses and burros as their caretaker, the federal Bureau of Land Management, launches an aggressive campaign to remove them from their wilderness homes.
The agency claims the horses are breeding at an alarming degree, destroying the land, and starving.
Animal welfare organizations such as the Chicago based Equine Welfare Alliance and the Cloud Foundation of Colorado Springs disagree and have launched a global petition drive to force a president who was elected on a platform of change to halt business as usual at the BLM and halt the capture of America's wild horses.
If the roundups proceed, critics charge the herds may well be genetically bankrupt – unable to propagate in the wild. Horseback Magazine put the BLM on the record. The following is the response we got from national spokesman Tom Gory.
HORSEBACK MAGAZINE: How many wild horses will be left on BLM land after the 2010 gathers?
GORY: The on-the-range population will be approximately 34,000 after the 2010gather season.  This figure reflects the fact that herd populations grow atan average rate of 20 percent.
HORSEBACK: How many of the remaining mares in the wild will have been treated with fertility drugs?
GORY:  We are planning on treating approximately 3,000 mares for FY 2010.
HORSEBACK: Will any of the horse management areas set upin 1971 that currently serve as habitat to wild horse and burros be left bare of equines after the roundups?
GORY:  No HMAs that are currently maintaining horses will be bare of equines after the FY 2010 gather season.
HORSEBACK: What specifically is the relationship between the BLM and the Humane Society of the United States in terms of the use and supply of thefertility drug  PZP on wild horses?
Gory:  The BLM has an agreement with HSUS signed on 10/23/06.  The agreement states that the BLM agrees to:
      1. Continue a cooperative relationship with the HSUS concerning thefurther development of contraceptive vaccines for use in controlling wildhorse populations.
      2. Develop policies that promote and facilitate the use of contraception within the constraints of existing laws and regulations.  The goals of these policies are to:
      a. reduce the growth rate of wild horse populations;
      b. reduce the frequency of removal actions on wild horse herds;
      c. reduce the number of animals that must be removed from the public rangelands; and
      d. reduce the overall costs of wild horse management.
      3. Monitor the effects and effectiveness of the use of fertility  control vaccine on wild horse populations, and keep the HSUS informed ofthe results of that monitoring.
HSUS agrees to:
   1.   Ensure a reliable supply of contraceptive vaccine, including adjuvants and other components.
   2.   Improve preparation and delivery methods for safe and effective application of the vaccine.
   3.   Work towards increasing the effectiveness of the drug while ensuring its safety to humans and animals.
BLM and HSUS agree to:
   1.   Educate and inform the public on the role that contraception can play in the management and control of wild horse populations on publiclands.
   2.   Work toward meeting the EPA and/or the FDA requirements fornon-investigational use of the contraceptive vaccine.
   3.   Meet annually at a minimum to review progress of provisions agreed to in this Memorandum Of Understanding. Consistent with that agreement, the BLM has a cooperative research project involving two HMAs that is funded by an Annanberg Foundation grant to look at:
      1. What are the effects of the 22-month PZP vaccine on the population's foaling and growth rates?
      2. What are the effects of a PZP booster administered remotely in year 3 on the fertility of individual treated mares and on the population's foaling and growth rates?
      3.  What are the effects of PZP treatments on the health and social dynamics of treated bands?