Make a part down the middle, on top of her head. Make 4 ponies in the front (2 on each side.) Then, directly behind the 4 front ponies, make 4 more and add the first ones by crossing them. This is a side/top view.
Now, make 2 more ponies directly behind the middle row, on either side of the part (adding in and crossing the previous ponies.) Bring the 4 strands of hair together and combine into 1 last pony. If you wanted to get really fancy, you could make little crosses in the empty sections by splitting each pony in half. But, we're running short on time today, so this is as complicated as we got.
Do you see the 3 non O's?
And, don't mind the still wet hair!
The whole key to this one is the placement of the ponies. Normally, you would off-set them every other row. With this style, they are all lined up directly behind each other.