More comments on BLM’s plan for cruel sterilization experiments on wild mares

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                 Leon Pielstick, DVM, performing an ovariectomy via colpotomy on a mare

Our thanks to contributing author and advocate Bonnie Kohleriter for sharing her excellent comments with our readers.                                          

by Bonnie Kohleriter

COMMENTS ON MARE STERILIZATION RESEARCH ENVIRONMENTAL ASSESSMENT

ENVIRONMENTAL ASSESSMENT: DOI-BLM-OR-B000-2015-0055 EA

THIS EA IS INADEQUATE AND CONCERNING BECAUSE OF THE FOLLOWING:

  1. In your EA the BLM processes for selection of population suppression experiments smacks of manipulation and non-transparency in regard to the public presenting falsities and omissions which, as such, results in potential dangers and not advances for the future well-being of our wild horses and burros.
  • In 2013 The National Research Council of the National Academy of Sciences recommended SpayVac, PZP 22, GonaCon and chemical vasectomies only as possibilities for fertility control. (p 134: Using Science to Improve the BLM WHB Program)
  • In 2013 the NRC stated “colpotomy” surgeries were less risky which is in your EA you need to complete the NTC’s discussion… compared to what? “transabdominal” surgeries, and (is)”not without risk.” The EA appears to minimalize risk.
  • The BLM issued a Request for Information but the EA does not tell us from whom and what information. Then, receiving information in response to the RFI, the EA again does not tell us from whom and what information.
  • The BLM issued a Request for Applications and received 19 separate research proposals but the EA does not tell us if any had to do with mare sterilization except for the 3 from Oregon State Univ.
  • The NRC with its experts returned critiques of the 19 proposals to the BLM but your EA says the public was denied access to these critiques of the 19 with the BLM saying “This full report has been an internal document in order to protect proprietary information of proposed authors.” On the other hand, the EA gives us privy to the critique of your 3 projects in Appendix B redacting authors’ names.
  • 4 of the 19 research proposals with 1 contingent on the results of the other 3, are all methods of” permanent sterilization” in wild horses. Do the other 16 proposals have merit to control population but not necessarily to be permanent? The EA makes no critiques, comments, or comparisons with the other 16 projects giving me the question, “Did Dean Bolstad and company pick 3 from Oregon because of favoritism as an Oregonian and/ or because he just wants permanent sterilization?” It seems the public has the right to know of the other 16 projects with critiques and comparisons of their safety, potential efficacy, and costs.
  • Who are the surgeons to do the 3 sterilization experiments and what are their qualifications?
  • Interesting that 3 of the 19 projects chosen for sterilizing horses are from Oregon to be done simultaneously in Oregon. Dean Bolstad, the Acting Director of the WHB Program is from Oregon. Dr. Leon Pilstick is from Oregon and is involved. Leon has already done multiple covert colpotomies and chemical vasectomies on the unprotected Oregonian
  • Sheldon horses, who then were sent by John Kasbohm, the Director of Sheldon, to slaughter telling the public he, the Fish and Wildlife Services, would find safe, good adoptive homes for the horses. The BLM recently gathered 1050 horses from Beaty’s Butte in Oregon as the specimens ready for experimental sterilization. Dr. Julie Weikel, a predominantly cattle veterinarian, from Oregon, recently submitted a public letter to Dean Bolstad, saying in effect,’ the BLM should consider to immediately gather all horse herds in Oregon bringing them down to low AML through vasectomies, geldings, and sterilization to serve as a model for the other States. Shockingly she poses as the Wild Horse and Burro Representative on the SE Oregon RAC and as a Board Member on the National Advisory Board. Does the Cattlemen’s Association have a horse invested person on their boards posing as having an interest in cattle? The public is told their comments for this EA are due February 3rd, but the experiments are to start in February. Are these comments to be taken seriously or is the WHB program, our government, just going through the motions and blowing off the public?
  • It appears that all of these connections to Oregon and actions within Oregon are saying to the broader group of citizens of the United States who pay the taxes for the horses ‘ care and who have an interest in these horses as a part of our heritage,” BE DAMNED, WE’RE DOING WHAT WE WANT, WE’LL PRETEND TO INVOLVE YOU LETTING YOU COMMENT ON AN EA BECAUSE IT IS GOVERNMENT PROTOCAL, BUT WE’VE BEEN INVOLVED A LONG TIME IN PLANNING AND SLOWLY EXECUTING QUIETLY AND COVERTLY WHAT WE WANT AND NOW WE WILL DO IT.” This appears to be manipulation, non-transparency and wrongdoing.

Sterility and Lack of Equipment and Medications Concerns for the Procedures to be Done

These experiments are to be done in the Burns Short-term Corral. This is a non-hospital, non-sterile environment admitted in your EA, that is questionably not equipped with equipment and medications to deal with complications. Allowing these procedures to take place in this short-term corral sets a precedence for other sterilization procedures to be done in ‘back alley’ non-sterile short-term corrals in other States. This would questionably not be acceptable for domestic mares and should not be acceptable for wild mares as well. In a report issued by the American Association of Equine Practitioners in 2011 regarding wild horse and burro care, the observers reported the short-term corrals were performing gelding procedures potentially harmful to the life of the horses along with demonstrated castration complications and ineffectual use of anesthesia. What will we read if the BLM is allowed to sterilize mares in these short-term corrals? It needs to stop before it starts.

  • Procedures to be Performed Simultaneously

Proposal 19: Colpotomy: The committee of “experts” recommended this procedure, if it is to be done, should be done following the other two procedures. The other two procedures are less invasive. If successful, they would cover the non-pregnant and pregnant mares. The committee also recommended this procedure not be done at all as it has been done for 100 years. No new science is involved. In spite of it, Dean Bolstad directed it to be done simultaneously with the other experiments. It is recommended not to be done in the 1st 90 to 120 days as the fetus is dependent on the ovary’s hormones and will likely abort if done at that time. It questionably cannot be done in the last stage of the pregnancy as the uterus may block the view of the ovaries. It seems to test the first 120 days and the last part of the pregnancy is of what value? It’s just that different mares are different and a decision has to be made to do or not to do it in the 1st trimester because of the risk and to look at all or none of the mares in the last trimester. For example, in some you may not be able to see the ovaries and in others you can. So what new have you learned? Risks are involved in this procedure. This is a “blind” procedure wherein the surgeon feels rather than sees what he is doing. The artery along the vagina can be nicked with bleeding out and the intestines can eviscerate through the cut in the vagina. In domestic mares they are cross tied for two days so as to allow the vagina cut to heal, but cross tying can’t be done with a wild horse. There can be a risk of infection as this is invasive surgery. Risks are low but they are there. Antibiotics and intestinal light loading with lack of food will be done to address risks. Oregon State University will be subjecting mares to having abortions and to having foals in captivity. Attempts in the corrals may be made to impregnate the mares only to abort and to have foals to have a sufficient sample size. The foals then will likely spend the rest of their lives in captivity in short-term or long term corrals unadopted as 47,000 others are awaiting adoptions as well. This is wrong to have mares impregnated in captivity just to abort, or to have foals who will suffer just because some surgeon wants to do experiments that contribute no further to science.

Proposal 9: Tubal Ligation:   There is a risk again of infection as this is invasive surgery. Again, in the last stage of pregnancy the ovaries may not be seen because of the position of the uterus. Following this procedure exposure to stallions is suggested to determine potential conception rates for the mares and again this is wrong for the foals to be born and condemned to life-long captivity. Why can’t your field trials be done on domestic mares prior to being tested for the first time on wild mares and be peer reviewed? In testing on domestic mares, you could artificially inseminate the mares to see if they would conceive avoiding unadoptable foals in life long captivity.

  • Proposal 8: Hysteroscopic guided Laser Ablation: There is less risk of infection in this procedure as it is not invasive but there are other risks. This procedure can only be done on non-pregnant mares. If a mare is recently pregnant unknown to the surgeon, she may face a very painful tubal pregnancy. Again, why is this experiment not field tested initially in domestic horses as it has never been done before and as non- pregnancy can be more certain in the domestic mares? In wild gathered mares this may be very difficult to determine. It was suggested by the experts, this procedure be done in yearlings at 8 months old at 300 kg. However, that would mean they have not contributed to the gene pool. The question needs to be answered as to what is your targeted population in the wild and how does genetic contribution correlate with these experiments? This is not a part of your EA, but should be a part of the selection of your experiments as experiments may be great but not suitable or cost effective for the wild population. 
  • The costs of these procedures are minimalized and misleading to the public who are the taxpayers.

Costs include ( but are not complete here), are as follows:

  • Gather costs
  • Transportation costs to and from the surgical procedure site
  • Cost to house the horses both pre- and post surgery
  • Costs of personnel assisting the surgeon(s)
  • Costs of antibiotics, equipment, and sedation i.e. will need multiple endoscopes
  • Costs to deal with complications
  • Cost of chute upwards of $12,000+ per chute
  • Costs of injuries and of deaths (burial)
  • Surgeons fees and travel time
  • You may say these costs are not a part of these experiments alone, not part of the EA, but you are once again manipulating the public lulling them into thinking these procedures are not that expensive compared to other procedures. The EA is misleading manipulating the public once again. Your housing costs are already quoted by you as a half a million for 225 mares alone.
  • Social and Economic Values
  • In 2012 a sub-committee of the Advisory Board recommended ovariectomies be done. This committee was composed of Tim Harvey, an Eastener involved with domestic horses, whose experience re: ovarietomies was ‘He asked a racing horse friend, a vet, if ovarietomies were safe,’ Boyd Spratlng, a cattle veterinarian, whose experience re: ovarietomies was ,’He did one once,’ and James Stephenson, a pro advocate of horse slaughter who said he once spoke with a vet about ovariectomies. No discussion at the Board meeting was about the pros and cons of performing ovariectomies. The Board members blindly voted for it. It is well-known the majority of the Advisory Board members have ranching interests, not wild horse and burro well-being interests and don’t have a lot of knowledge about wild horses and burros so promoting Advisory Board members input on sterilization as the voice of the public is acrimonious to the public and misleading in your EA statements.
  • Darting costs compared to sterilizing costs need to be compared if you take in all costs to do the procedures. Using Rangeland Mgmt. Specialists as well as volunteers and using fenced known water holes for the horses on the range such as in the Pryors, Little Bookcliffs, Spring Creek Basin, and the McCulloughs entails mainly only the cost of the dart with the medications as opposed to the costs of sterilization listed above. Again your EA statements re: darting compared to sterilizing are misleading.
  • In your EA you said BLM has the challenging task of choosing wild horse population control methods that are financially viable, ecologically viable, and socially viable. I would add to this list genetically viable. The WHB Program needs to consider healthy horses capable of reproduction for continuing diversity and viability.
  • The following is outside of the scope of this EA, but should be addressed by the BLM WHB Program if these sterilization experiments are going to be more than just a surgeon’s frivolous experiment on some wild horses. It seems these experiments should have been selected on the basis of some consideration of their applicability to be useful in population suppression in the field while retaining genetic diversity and viability of the 179 herds of which the BLM speaks. With that said, it seems a preliminary study should be made before these experiments proceed to determine which HMAs have been evaluated more than once for their genetic diversity and viability quotients and which of those HMAs have diversity and viability components sufficient enough to be considered for sterilization of some of its mares. It seems if they have not been evaluated more than once for baseline and comparison purposes and if their diversity and continued viability numbers are questionable for continuance, then they should be eliminated for consideration of sterilization. Then the 3 proposed sterilization experiments have some groups of horses that are not candidates for sterilization. So taking that into consideration, you should take a look at the groups who may be candidates for sterilization from a diversity and viability standpoint, determine what groups of animals in those HMAs are not candidates for sterilization such as stallions or yearlings, determine the number of mares and age you would not want to sterilize in order to have genetic contribution or continued health of the herd, and finally do modelling as to what number of horses you would need to gather and sterilize to make a zero but healthy maintained population. Is sterilization through gathering, housing and sterilizing going to meet your objectives, doable in terms of your objective, namely population stabilization, and cost effective. So, for example, if you have a group of 50 horses in an HMA, is it cost effective to bring in all the horses you can get only to find out only 3 mares are candidates for sterilization given all the other considered factors and will those three sterilized really make for population stabilization. Which of your HMAs are already out, considering the limits of possible mares for sterilization among the three experiments, mares needed to be maintained for genetic diversity and continued viability, other horses in the herd not candidates for sterilization, and HMAs themselves not yet evaluated for their diversity and viability and not candidates given low diversity and endangered viability.

CONCLUSION

You have done a lot of work on this EA, but I find you’re a) misleading information, falsities and omissions, b) the WHB program putting their cart before the horse not considering numbers of herds suitable for sterilization to make the experiments beneficial and cost effective, c) not field testing first on domestic horses with tests that have never been done, d) not heeding the advice of the experts on the lack of a need to do colpotomy experiments, e) not considering what is in the animal welfare interest of the mares and foals and taking the value of their lives into account, and not providing for a sterile test setting, are reasons these experiments should be delayed and should not go forward at this time until these matters and concerns have been addressed.

___________________________________________

Write to the BLM and demand Alternative A – NO ACTION to stop this.

Public comments will be accepted on the EA through February 10, 2016. Comments can be emailed, mailed or faxed to the BLM Burns Office at the addresses below. Entire comments – including personal identifying information – may be published as part of the EA and Decision Record process. Mail or deliver to:
Mare Sterilization Research Project Lead
(541) 573-4411 BLM Burns District Office
28910 Highway 20 West
Hines, Oregon 97738
Fax: (541) 573-4411 — Attention: Mare Sterilization Research Project Lead
Lisa Grant
BLM Burns District Office
Mike Tupper
Dean Bolstad
Comments can also be made online here:

Call and write your Congressional leaders and demand a stop to this.

16 comments on “More comments on BLM’s plan for cruel sterilization experiments on wild mares

  1. I find this whole thing smacking of Dr Mengele, the infamous Nazi medical experimenter in the concentration camps. It is a well known fact, whether functionaries will admit it or not, that the social structure of these horse herd families are shattered irrevocably by this kind of sexual reproduction manipulation. All herd, band, and flock animals have a social structure that is damaged when such fundamental drivers of behavior are shot full of holes. Foals born out of season, strange disruptions of family loyalties, and compensatory reproduction that reverses the very thing the BLM says it wants. The NAS report mentioned that last aspect, as well as the late geneticist Kirkpatrick. Karen Sussman’s intact herds have shown the real numbers are no where near the platitude BLM rolls out all the time—“herds double every 4 years.” I can hardly believe the government is paying for this invasive surgical procedure as some kind of crude “population control” The image it conjures up is laughable, as if hundreds of horses would be lined up on a conveyer belt so some goon could cut into them using a cookie cutter approach going right down the line. These folks are mendacious and depraved.

    Liked by 1 person

  2. Excellent job thank you for this!
    Here is how to send your comments in:
    Public comments will be accepted on the EA through February 3, 2016. Comments can be emailed, mailed or faxed to the BLM Burns Office at the addresses below. Entire comments – including personal identifying information – may be published as part of the EA and Decision Record process. Mail or deliver to:
    Mare Sterilization Research Project Lead
    (541) 573-4411 BLM Burns District Office
    28910 Highway 20 West
    Hines, Oregon 97738
    Email: blm_or_bu_mareresearchea@blm.gov
    Fax: (541) 573-4411 — Attention: Mare Sterilization Research Project Lead
    Lisa Grant
    BLM Burns District Office
    Email: blm_or_bu_mareresearchea@blm.gov
    Mike Tupper
    Email: mtupper@blm.gov
    Dean Bolstad
    Email: dbolstad@blm.gov

    Comments can also be made online here:
    https://eplanning.blm.gov/epl-front-office/eplanning/comments/commentSubmission.do?commentPeriodId=30676

    Liked by 1 person

  3. Thank you for the documentation. This sounds like a Frankenstein torture to me. They are not animals bought to be used in research. If you thought it couldn’t get a worse, no one had any idea. Who and what are they going to bank roll now at the expense of our Wild Horses, poor Burros and the American people? How dare they do this under the cover of “caring for the wildlife”. This crowd has GOT TO GO!! It’s just blatant and criminal!!

    Liked by 1 person

  4. GREAT letter! If only there was someone in power that listened & comprehended! This whole BLM attempt is so far beyond making any sense. As Gail said, did we actually think it couldnt get worse?? Well the BLM heard & made it worse.

    Like

  5. PREMEDITATION
    planning, plotting or deliberating before doing something. Premeditation is an element in first degree murder and shows intent to commit that crime.

    MALICE AFORETHOUGHT
    A predetermination to commit an act without legal justification or excuse

    BLM’s Final Solution for the Wild Horses and Burros
    December 22, 2009
    Internal documents from the Bureau of Land Management (BLM) shed light on the agency’s motives and plans for the wild horses and burros.
    http://animallawcoalition.com/blms-final-solution-for-the-wild-horses-and-burros/

    BLM knew the aggressive sterilization of mares would mean an increased death rate of at least 10% and admitted that “herd behavior would be out the window”. BLM admitted, in effect, these aggressive sterilization plans would not only be potentially dangerous to the wild horses and burros, destructive of their herds and families, but also illegal and ultimately cause their extinction.

    Like

  6. Excellent letter. I came to the same conclusions when reading the EA, but you correctly summarized the content and highlighted the questionable intent of these proposed actions brilliantly! Additionally, the BLM reported this in this EA:

    Table IV.1: Agencies, Tribes, Individuals, or Organizations Consulted

    Name: National Research Council of the National Academies of Science

    Purpose & Authorities for Consultation or coordination: BLM requested peer reviews of research proposals related to population growth suppression (contraception and sterilization).

    Findings & Conclusions: “Recommended (the NAS) the BLM fund the two minimally invasive procedures and that BLM could put ovariectomy via colpotomy into operation immediately as a tool to sterilize wild horse mares”.

    This was the only agency, tribe, individual, or organization consulted in the EA.

    I read the NAS report. There was nothing in the language that proposed that the NAS gave their “blessing” to fund any of these invasive procedures. The EA report is false in this statement at worst and misleading and arbitrary at the least. When reviewing the studies and science that would be the most beneficial the NAS report provided the following conclusions: “On the basis of the peer-reviewed literature and direct communication with scientists who are studying fertility control in horses and burros, the committee considers the three most promising methods of fertility control to be PZP-22, GonaCon, and chemical vasectomy. . . All three methods should preserve the basic social unit and expression of sexual behavior . . .”
    Much more was written – obviously – but in no sentence, phrase, or comment did I read that the NAS recommend funding of these procedures. Maybe that was the internal document they were referring to.

    Your letter puts the BLM on notice. Hope they pay attention. The false statement I mentioned here is one of many.

    Like

      • Sorry, Marlboro gave money to a group of volunteers to build new fences, repair old ones, paint buildings, and general handy-man work at the International Society of Mustangs and Burros in Landry SD

        Like

  7. The incision in the vaginal wall would not be stitched up , and it would be big to allow a man’s arm to enter or intestines to come out. Evidently that butcher vet has never even heard of stitches that dissolve. Of course they would cost a little and what’s the use anyway–the mares will die . This is as bad as chasing them off cliffs like they used to do before the slaughter option.

    Like

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