July 15, 2013 Mr.

Randy Swick, Area Manager Spring Mountain National Recreation Area 4701 North Torrey Pines Drive Las Vegas, NV 89130-2301 Via Web Comment Form and Facsimile: (702) 515-5447 Dear Mr. Swick: These comments on the Spring Mountains Wild Horse and Burro Complex Project Scoping are submitted on behalf of the American Wild Horse Preservation Campaign (AWHPC) and endorsed by xx citizens. (See Attachment 1 for list of endorsers.) AWHPC is dedicated to preserving the American wild horse in viable free-roaming herds for generations to come, as part of our national heritage. Our grassroots efforts are supported by a coalition of over fifty historic preservation, conservation, horse advocacy and animal welfare organizations.

I. Overview
The U.S. Forest Service (FS) and the Bureau of Land Management (BLM) are proposing to create the Spring Mountain Wild Horse and Burro Complex by consolidating the Red Rock Wild Horse and Burro Territory (WHBT), the Red Rock Herd Management Area (HMA); the Spring Mountains WHBT; the Wheeler Pass HMA; the Johnnie WHBT; and the Johnnie HMA. The Herd Management Area Plan (HMAP) described in the Scoping Report would set allowable management levels (AMLs) for wild horses and burros living in the complex and establish federal manage policies for these areas for the next 10 or more years. The plan would establish an unnaturally low AML of just 77-127 horses and 103-192 burros for the entire 784,325-acre complex. At the maximum levels, this equates to just one horse or burro per 2,459 acres! Further the plan, if adopted, would reduce the estimated wild horse and burro population in the complex by 85 percent or more, resulting in the removal of as many as 921 wild horses and burros from the area.

American Wild Horse Preservation Campaign, PO Box 1048, Hillsborough, NC 27278

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 2

II. HMAP Perpetuates Failed Approach to Wild Horse and Burro Management
The HMAP, as outlined in the Scoping Report, would result in the removal of as many as 921 wild horses and burros from the Spring Mountain Complex, in an effort to bring the population to the low to mid-range of the newly established AMLs for each management area. According to the Scoping Report, periodic removals would take place in order to maintain the population at this low to mid-range. Unfortunately, fertility control, at this point, does not appear to be an integral part of the proposed management plan. Instead the Scoping Report states that fertility control could be used on wild horses within the complex; no use of fertility control is envisioned for burros living in this area. In this manner, the HMAP perpetuates the failed approach to wild horse management that was designated as expensive and unproductive by the National Research Council (NRC) of the National Academies in its June 2013 report, Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward. It concluded that the BLMs policy of maintaining artificially low wild horse population levels and conducting frequent removals of large numbers of horses actually increases wild horse reproductive rates and worsens agency management problems. (See Attachments 2 and 3 for report and summary.) Regarding the practice of maintaining wild horse populations at unnaturally low numbers and conducting frequent, large-scale removals, the report states: Management practices are facilitating high rates of population growth.Thus, population growth rate could be increased by removals through compensatory population growth from decreased competition for forage. As a result, the number of animals processed through holding facilities is probably increased by management. p. 5-6 (Emphasis added.) Free-ranging horse populations are growing at high rates because their numbers are held below levels affected by food limitation and density dependence. p. 5 The indirect effects of management are considerable. One likely response is compensatory population growth as a result of reductions in numbers. P. 94 Removals are likely to keep the population at a size that maximizes population growth rate (see Figure 3-2B), which in turn maximizes the number of animals that must be removed and processed through holding facilities. P. 94 (Emphasis added.) Indeed the proposed action could add over 900 wild horses and burros to a holding

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 3 system already overburdened by the warehousing of 50,000 of these animals in government holding facilities (Attachment 4) at a cost to American taxpayers of $120,000 per day. Only a small fraction of those horses will be adopted. BLM Deputy Wild Horse and Burro Division Chief Dean Bolstad stated in a news article (Attachment 5): "Adoption [as a population control strategy] is no longer a logical way to proceed. We cannot continue to increase the numbers of horses in captivity." Yet the HMAP described in the Scoping Report, which will set policy in this area for the next decade or longer, will do exactly that: increase the number of wild horses in captivity while at the same time continuing management practices that are fueling population growth on the range and worsening the BLMs and FS management woes.

III. HMAP Ignores Ecotourism Value of these Herds and Potential for Community Partnership for their Management
The proximity of the Spring Mountain Wild Horse and Burro Complex to Las Vegas, an international travel destination that attracts nearly 40 million visitors annually, makes this an ideal population for the promotion of ecotourism. In addition, the Spring Mountain Alliance has produced a detailed plan for partnership with federal agencies in this area for scientifically-sound management of a healthy range for recreation, wildlife and the last free-roaming bands of wild horses and burros in the in the Spring Mountains, west of Las Vegas; and for Increasing wild horse & burro viewing opportunities for future generations of horse & wildlife enthusiasts, photographers and American & foreign visitors. The proposal details six initiatives for proper management of the wild horses and burros in this area, beginning with the use of PZP fertility control to manage herds on the range. The Alliance has been identifying and documenting the movement patterns of wild horses in the complex and estimates that, within two years, 80 percent of the mare population could be vaccinated with PZP. To facilitate this process, several alliance volunteers have been trained by the Science and Conservation Center in application of PZP to wild horses via remote darting. The Alliance further proposes an experimental PZP program for burros in the area. The fact that the Scoping Report is silent on the ecotourism potential of these herds and the existence of a vibrant community organization offering partnership with the BLM and FS for on-the-range management defies logic. This is particularly true since the proposal offered by the Alliance is a win-win scenario for American taxpayers, our federallyprotected wild horses and burros, as well as for the growing eco-tourism segment of the economy. The final HMAP and EA should reflect these factors.

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 4

IV. HMAP Continues Practice of Under-Utilizing Proven Fertility Control Methods

For two decades, PZP fertility control has been used to successfully to manage the wild horse population in the Assateague National Seashore. (Attachment 6) Further, PZP has been utilized successfully on burros. (See Attachment 7.) The recent NRC report upheld the validity of PZP fertility control for use in wild horses: Tools already exist for BLM to address many challenges. p. 13 In the short term, more intensive management of free-ranging horses and burros would be expensive. However, addressing the problem immediately with a long-term view is probably a more affordable option than continuing to remove horses to long-term holding facilities. P. 306 (Emphasis added.) Most promising fertility-control methods for free-ranging horses or burros are porcine zona pellucida (PZP) vaccines and GonaCon vaccine for females and chemical vasectomy for males. This conclusion is based on criteria such as delivery method, availability, efficacy, duration of effect, and potential for side effects. Although applying these methods usually requires gathering horses and burros, that process is no more disruptive than the current method of population control gathering and removal without the further disruption of removing animals. Considering all the current options, these three methods, either alone or in combination, offer the most acceptable alternative to removing animals for managing population numbers. p. 3 of the brief Under the management regimes reviewed by the committee, BLM will have to remove free-ranging horses from western rangelands indefinitely unless very aggressive fertility-control programs are implemented (Garrott, 1991; Eagle et al., 1992; Garrott and Siniff, 1992; Gross, 2000; Bartholow, 2004, 2007). As briefly discussed in Chapter 2, there may be more horses in the short-term and long-term holding facilities than on the range. An average of more than 8,000 horses are moved from the free-ranging population to holding facilities annually, and almost 60 percent of the Wild Horse and Burro Programs budget was allocated to the care and maintenance of captive animals in fiscal year 2012 (BLM, 2012c). The amount of money needed to care for horses in the long-term holding facilities will continue to increase and, in the long run, could consume the entire budget allocated to the Wild Horse and Burro Program. P. 216 No method that does not affect physiology or behavior has been developed. The most appropriate comparison in assessing the effects of any fertility-control method is with gathering. That is, to what extent does the prospective method

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 5 affect health, herd structure, and the expression of natural behaviors compared with the effects of gathering? The selected methods are considered the most promising because they have the fewest and least serious effects on those parameters. Their application requires handling the animals (gathering), but this process is no more disruptive than the current method for controlling numbers and does not entail the further disruption of removal and relocation to long-term holding facilities. Considering all the current options, these three methods, either alone or in combination, offer the most acceptable alternative for managing population numbers. P. 7 Yet not only does the proposed HMAP continue the practice of removing horses from the range an approach to wild horse management that has been deemed to be costly and unproductive by an esteemed independent scientific body -- but also it continues the BLMs failure to utilize PZP fertility control in a manner that will substantially impact herd reproductive rates. Rather than stating that fertility control could be used on the wild horse population in this complex, the use of PZP fertility control in partnership with community organizations should be an integral part of the plan. Such a model is readily available and working in other BLM wild horse management areas, including the McCullough Peaks HMA in Wyoming. It is critically important to note that if PZP treatment of most mares had been continued after the 2007 roundup, the Spring Mountain Complex wild horse population could have been sustained close to AML without need for another costly roundup in 2014.

V. Alternatives that Must be Considered and Pursued

On behalf of the AWHPC coalition and the xx citizens who have endorsed these comments, we request that the following alternatives and initiatives be incorporated into the final HMAP and EA: A. Higher AMLs Establish a more genetically viable Allowable Management Levels (AMLs) for wild horses and burros living in this complex. The proposed AMLs are too low to ensure genetically viable and thriving populations. The low population numbers will also destroy the great ecotourism potential of these herds, which live near Las Vegas, an international tourist destination. At one horse or burro per 2,459 acres it will be difficult to even spot, let alone observe, wild horses living in this area. The following are the AMLs proposed for the management areas within the complex: Red Rock - 16-27 horses and 29-49 burros Spring Mountain/Wheeler Pass - 47-66 horses and 20-35 burros

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 6 Johnnie: 14-34 horses and 54-108 burros Total for Complex: 77 - 127 horses and 103 - 192 burros By setting and maintaining such unnaturally low allowable population levels far below levels where horse and burro populations would exhibit density-dependent regulation, the FS/BLM are continuing a practice that the NRC has identified as contributing to higher reproductive rates on the range. Further the levels are too low to maintain the genetic viability of these herds. The genetic viability issue is particularly critical for wild burros, of which an estimated 5,800 are left in the U.S., despite federal protections. The NRC report highlighted the precarious state of burros in the U.S. today, concluding that if BLMs population estimates are correct, removing burros permanently from the range could jeopardize the genetic health of the total population. The NRC advised that "the BLM may also need to assess whether the AMLs set for burros can sustain a genetically healthy total population. (p. 304) The NRC report would indicate that any burro removals from the range are ill-advised, save for verifiable emergency situations. In addition, plans to randomly introduce horses or burros to these populations to improve genetic variability are not sufficient to protect their genetic viability. Equine genetics expert E. Gus Cothran of the Texas A&M University College of Veterinary Medicine has informed AWHPC (personal communication) that introduction of outside animals to genetically compromised populations can take generations to have an effect. Populations that have lost genetic diversity to the degree that the long-term survival of the herd is compromised may not have time to wait generations for improvements to genetic diversity. Therefore, this approach cannot be used to justify such low, genetically unsustainable AMLs. B. Manage Horses on the Range with Fertility Control As stated above, PZP fertility control is an available tool for managing these herds on the range and minimizing the need for removals. A comprehensive PZP program should be implemented immediately for wild horses in this complex, and a pilot program should also be launched for burros. Both should be done in conjunction with Dr. Jay Kirkpatrick of the Science and Conservation Center in Montana, and in partnership with the Spring Mountain Alliance, which has already undertaken much field work to identify individual horses, bands and herds and monitor their movement patterns. SMA volunteer PZP darting teams are already trained and certified to dart as early as September 2013. As stated above, SMA believes that 80 percent of the mare population in this area could be vaccinated with PZP within two years. This level would be effective in achieving zero population growth of this herd within several years.

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 7

C. Range Improvement Keep wild horses and burros within the Complex by repairing and expanding water sources and implementing other range improvements to help the animals utilize all suitable habitat areas. Habitat improvements suggested by the Spring Mountains Alliance include the following, which should be incorporated into any HMAP and EA: 1. Building water guzzlers and retention basins across the range to disperse the grazing impact of elk and wild horses. 2. Fencing off ecologically sensitive areas like riparian habitat; 3. Building blinds or road pull-outs for safe viewing access to wild horses/burros; 4. Patrolling roads to prevent illegal or undesirable human interaction with wild horses/burros. 5. Implementing various range improvement strategies (seedings, etc.) to improve habitat conditions for wild horses, burros, elk and deer in the area and to enhance wildlife viewing opportunities in the area. D. Prohibit Helicopter Roundups Helicopter roundups are traumatic and dangerous for wild horses and burros. Heartbreaking video footage has shown wild horses and burros being injured, harassed, beaten and killed in helicopter roundups. (Please see NBC News report, Cruel or necessary? The true cost of wild horse roundups at this link: http://investigations.nbcnews.com/_news/2013/05/14/17588942-cruel-or-necessary-thetrue-cost-of-wild-horse-roundups?lite) The plight of burros in helicopter roundups is particularly concerning. These steadfast animals react differently than wild horses to helicopter drives. They scatter and resist the chase instead of staying with the herd. (Please see video and report by NBC News, The Battle Over Burros at this link http://www.nbcnews.com/video/nbcnews/51524838#51524838) Passive bait trapping operations are less traumatic for wild horses and burros and are also more protective of the environment by avoiding the trampling of sensitive plant and animal species that occurs during helicopter stampedes of wild horses or burros. Therefore, the HMAP should designate that, if any wild horses or burros are to be removed from the Spring Mountains Complex, less traumatic bait trapping methods will be utilized for the well identified and easily captured animals living there. In addition, the HMAP should specify that the BLM and FS work with community groups (Spring Mountain Alliance) to identify and remove only the most adoptable horses and burros and conducting vigorous local adoption drives.

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 8

However, the HMAP should specify that BLM and FS will resort to removals only as a last resort, after all on-the-range management strategies have been implemented and given the necessary time to work. This strategy is mandated by both the current stockpiling of 50,000 wild horses and burros in government holding facilities and the NRC finding that frequent removals of horses from the range may cause compensatory E. Maintain natural sex ratios The Scoping Report indicates that the HMAP will include artificial skewing of sex ratios for wild horses. The EA must adequately evaluate the impacts of this proposed action, as well as present evidence that this strategy will a) be effective in lowering population growth rates; and b) will not impact the natural behaviors of individual wild horses, social bands and the herds as a whole. In fact, no scientific data exists regarding the impact of sex ratio skewing on individual horses, bands and/or herds. This element of the HMAP should not be implemented without adequate scientific information to understand the implications of sex ratio skewing on the range. In addition, there is no science that shows that the artificial skewing of natural sex ratios contributes to population suppression. In fact, anecdotal evidence suggests that sex ratio skewing interrupts natural social structures and that due to this disruption, mares may begin to breed at younger ages due to the lack of females on the range. This would result in an overall increase in reproductive rates. The EA should consider the findings of BLM field offices regarding sex ratio skewing: BLM Beatys Butte EA DR FONSI 2009 [http://www.blm.gov/or/districts/lakeview/plans/files/Revised_BButte_EA_FONS I_DR_09012009.pdf ] (page 33) states,"If selection criteria leave more studs than mares, band size would be expected to decrease, competition for mares would be expected to increase, recruitment age for reproduction among mares would be expected to decline, and size and number of bachelor bands would be expected to increase. . . ." The BLM EA for the South Steens Wild Horse Gather [http://www.blm.gov/or/districts/burns/plans/files/SSteensGatherEAandFONSIFi nal.pdf] (page 41) states,Skewing the sex ratio of stallions v. mares would result in a destabilization of the band (stallion, mare and foal) structure moving it from five to six animals to three animals. Social band structure will be lost resulting in combative turmoil as surplus stallions attack a band stallion trying to capture his mare. This could result in the foal being either killed or lost. The mare and foal will not be allowed to feed or water naturally as the stallion tries to keep them away from the bachelor bands of stallions, resulting in stress to the mare during her lactation condition.

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 9 Black Mountain Hard Trigger EA, p.19 [https://www.blm.gov/epl-frontoffice/projects/nepa/22203/38764/40668/DOI-BLM-ID-B030-20120010_Wildhorse_Prelim_EA_Final.pdf], states, competition for mares would be expected to increase, recruitment age for reproduction among mares would be expected to decline [meaning younger mares would begin breeding] Fighting between band stallions and surplus stallions could result in the mares and foals not being allowed to feed and water naturally as the herd stallion tries to keep them away from bachelor bands.

VI. Impacts that Must be Analyzed in EA

A. Impacts of helicopter roundups on individual wild horses and burros, and on endangered plants and animals in the Complex. According to the scoping notice, numerous species of concern are present in this area and could be impacted by helicopter stampeding of burros. B. Economic impacts of the proposed action including disclosure of all costs associated with the capture and removal of operation itself, as well as the costs for short- and long-term holding and adoption preparation for the burros removed from the range. A comparison of costs for alternative actions suggested in these comments vs. the approach detailed in the Scoping Report must be presented. C. Genetic Impacts of the proposed removal of 85+% of the estimated wild horse and burro populations in the Complex and to establish AMLs of Red Rock 16-27 horses/ 29-49 burros (Red Rock); 47-66 horses/20-35 burros (Spring Mountain/Wheeler Pass); and 14-34 horses/54-108 burros (Johnnie) must be evaluated. All genetic reports should be included as an appendix in the EA. D. Social impacts of all proposed actions must also be analyzed. NEPA requires federal agencies to consider environmental effects that include, among others, impacts on social, cultural, and economic resources, as well as natural resources. Thus the FS/BLM must consider both legal and social factors and impacts, in making land use decisions, such as setting and maintenance of AML and grazing allocations. This was highlighted in a 1982 National Research Council report on the BLMs wild horse and burro program: Attitudes and values that influence and direct public priorities regarding the size, distribution, and condition of horse herds, as well as their accessibility to public viewing and study, must be an important factor in the determination of what constitutes excess numbers of animals in any area . . . [A]n otherwise satisfactory population level may be controversial or unacceptable if the strategy for achieving it is not appropriately responsive to public attitudes and values. . . .

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 10 Biologically, the area may be able to support 500 cattle and 500 horses, and may be carrying them. But if the weight of public opinion calls for 1,000 horses, the area can be said in this context to have an excess of 500 cattle. For these reasons, the term excess has both biological and social components. In the above example, biological excess constitutes any number of animals, regardless of which class above 1,000. Social excess depends on management policies, legal issues, and prevailing public preference.. The NRC Report released this month also highlighted the importance of public opinion as well as the BLMs failure to offer a collaborative policy making process in which the public can meaningfully participate. The NRCs findings regarding social considerations for BLM include: Horse and burro management and control strategies cannot be based on biological or cost considerations alone; management should engage interested and affected parties and also be responsive to public attitudes and preferences. Three decades ago, the National Research Council reported that public opinion was the major reason that the Wild Horse and Burro Program existed and public opinion was a primary indicator of management success (NRC, 1982). The same holds true today. p. 292 In 1982, the National Research Council noted that public opinion was the major motivation behind the wild horse and burro protection program and a primary criterion of management success, suggesting that control strategies must be responsive to public attitudes and preferences and could not be based only on biological or cost considerations (NRC, 1982, p. 54). p. 271 Thus, BLM should engage with the public in ways that allow public input to influence agency decisions, develop an iterative process between public deliberation and scientific discovery, and codesign the participatory process with representatives of the public. p. 13 and p. 288 BLM has involved the public in a consultative way in the past, but to move to the right in Figure 8-1 toward a collaborative process, BLM and the public must come together to work in new ways and with a new spirit. p. 289 The NEPA process provides for public comment and review and increases public participation in environmental decisions although the relationship is consultative rather than collaborative, tends to be bureaucratic, and does not foster deliberation (Hourdequin) p. 229 The committee believes that in the case of planning for the management of free-ranging horses and burros, substantive public participation is

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 11 warranted because of the depth and breadth of public concern and the need for a long-term, sustainable program. P. 280 However, given the high level of public concern regarding the management of freeranging horses and burros, the diverse values that come to bear on the issue, and the substantial scientific uncertainty that is inevitable in dealing with such complex issues, effective public participation practices are essential. Therefore, BLM should engage with the public in ways that allow public input to influence agency decisions, develop an iterative process between public deliberation and scientific discovery, and codesign the participatory process with representatives of the public. (p. 288)

The prevailing public opinion that wild horses and burros should be humanely managed on the range is evidenced by thousands of citizens who have endorsed AWHPCs comments on this scoping, urging the FS/BLM to consider a humane costeffective alternative to the removal of large numbers of wild horses burros from the public lands. This strong public preference mandates that the FS/BLM fully consider all alternatives that would accomplish this goal and avoid the mass capture and removal of wild horses from their home in this public lands area. The NRCs review panel chair, Dr. Guy Palmer, summed up the situation well, commenting at a at a press conference on the reports release that No one really wants to see more horses in long-term holding just from an economic viewpoint. Secondly, this is not the vision that is associated with what the public wants to see with the horses on these wild lands. (See Attachment 8) The NRC report states explicitly: A program of continuing, ad infinitum removals may not be economically sustainable or socially acceptable. P 259 (Emphasis added.) The sum total of the points above indicates that the FS must ensure a change in direction with this HMAP that will set policy in this area for the next decade or longer. Continuation of the business as usual policies is simply not acceptable, scientifically sustainable or fiscally defensible.

VII. Information that Should be Provided

The EA for the proposed HMAP must include the following information in order to give the public the opportunity to comment in a meaningful way on the proposed plan: A. All forage allocations (AUMs) within the Complex. B. Range monitoring data, including a detailed breakdown data distinguishing wild horse impacts from impacts caused by other uses within the Complex. C. Documentation of herd population count/census numbers and a complete

AWHPC Comments on Spring Mountains Complex Scoping July 15, 2013 Page 12 demographic breakdown of the wild horse and burro populations. Detailed information on census methods underlying population estimates is particularly important given the NRCs finding that robust inventory procedures were adhered to on few HMAs during the most recent decade of population monitoring. The committee identified five primary weaknesses in inventory procedures: inconsistent methods, likely movement of horses among HMAs, little or no effort to quantify detection probability and apply corrections accordingly, no attempt to quantify precision of abundance estimates, and inadequate record keeping and database management. (P. 56) D. A complete listing of water sources available to wild horses within the Complex. A full disclosure of all fencing in and around the Complex. E. A list of all range improvements, such as water restoration and/or enhancement, both completed in the past 5 years and planned for upcoming years. F. Available scientific information on burros in the American West, including information on dietary preferences, relationship between reproductive rates and water availability, natural behavior and range usage data.

VIII. Conclusion
The NRC report clearly stated that the BLM's business as usual for managing wild horses and burros is expensive and unproductive and must immediately change. The proposal outlined in the Scoping Report omits these important and independent scientific findings that removal increases the birth rate in the remaining bands. If PZP treatment of most mares had been continued after the 2007 roundup, the Spring Mountain Complex wild horse population could have been sustained close to AML without need for another costly roundup in 2014. There is still time to change course to a more sustainable, humane and less taxpayer costly management approach for the Spring Mountains Complex. Due to their proximity to Las Vegas, an international tourist destination, these herds hold great ecotourism potential. On behalf of the AWHPC coalition and the thousands of citizens endorsing these comments, please take this opportunity to implement an experimental volunteer/agency plan that truly protects these national icons on the range so that they may live their lives as nature intended while being enjoyed and appreciated by visitors from all over the world. Thank you for your consideration. Sincerely,

Suzanne Roy, Director

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Attachments: 1. List of citizens endorsing AWHPC comments 2. Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward, National Research Council of the National Academies, June 2013 3. Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward In Brief, National Research Council of the National Academies, June 2013 4. BLM Facilities Report, June 2013 5. BLM wild horse management at a crossroads, Salt Lake Tribune, November 11, 2012 6. Achieving population goals in a long-lived wildlife species (Equus caballus) with contraception, Dr. Jay Kirkpatrick and Allison Turner 7. Turner, Liu and Kirpatrick, Remotely delivered immunocontraception in freeroaming feral burros, Journal of Reproduction and Fertility (1996) 107, 3135. 8. Panel: U.S. Should Let Nature Cull Wild Herds, Associated Press, June 5, 2013