Mare Sterilization Research Project Environmental Assessment
Bureau of Land Management
Mare Sterilization Research Project Lead
Attn: Mare Sterilization Research Lead
BLM Burns District Office
28910 Highway 20
West Hines, Oregon 97738
Email: email@example.com Feb. 2, 2016
Subject: Mare Sterilization Research Project Environmental Assessment DOI-BLM-O R -B 000-2015-0055-EA
Attn: Mare Sterilization Research Lead
On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit and our hundreds of thousands of supporters throughout the United States; Equine Welfare Alliance; Front Range Equine Rescue; Colorado Wild Horse and Burro Coalition; and the over 90 organizations represented thereby, we would like to thank you for the opportunity to comment on DOI-BLM-O R -B 000-2015-0055-EA.
It is unconscionable that BLM has not allowed for a Scoping Period so that the American public can comment on experimental research involving wild horse mares. It is particularly abhorrent when the research is invasive and likely lethal for at least some of the mares in the study as well as their unborn fetuses. Frankly, this proposed animal cruelty should never have seen the light of day, and the plug should be pulled immediately on this type of unnecessary, dangerous, abusive and inhumane “research” before even one wild horse mare is mangled by misguided intentions.
TCF also views the BLM’s proposal to explore Research on Sterilization of Mares as a violation of the 1971 Wild Free-Roaming Horses and Burros Act (ACT) . The ACT states “all management activities shall be at the minimum feasible level…” and “in a manner that is designed to achieve and maintain a thriving natural ecological balance on public lands.“ Furthermore, we believe it is a waste of taxpayer dollars.
Currently over 70% of wild horse herds are managed at artificially low numbers which endanger the herds’ genetic viability. Use of permanent sterilization as a method of population control will further endanger the future of North American Wild Horses, ensuring their eventual extinction.
The implementing regulation 43 C.F.R. § 4700.0-6(a) requires that activities affecting wild horses and burros shall be undertaken with the goal of maintaining free-roaming behavior. Sterilization destroys those aspects of wild horse behavior, developed over millions of years of evolutionary history in North America.
The implementing regulations require that “[w]ild horses and burros shall be managed as self-sustaining populations of healthy animals in balance with other uses and the productive capacity of their habitat.” 43 C.F.R.§ 4700.0-6(a). “. . .activities affecting wild horses and burros shall be undertaken with the goal of maintaining free roaming behavior.” Id. at § 4700.0-6(c).
Concerns with Transparency:
Assuming the public would be aware of these projects based on discussion and recommendations from the BLM National Advisory Board is unrealistic. Most people had no idea that a request for proposals had even gone out, let alone been apprised of the content of the request. This lack of transparency and the short time frame allowed for public comments raises grave concerns.
Plans which threaten the ongoing existence of North American Wild Horses must be made available through national media so that the public at large has the opportunity to understand what is being planned . The citizens of the United States to whom these BLM horses belong deserve to know of dangerous experimentation at taxpayer expense.
Safety Concerns regarding Mare Sterilization Research
(See also EXPERT COMMENTS of VETERINARIAN DON MOORE at the end of this letter)
The three methods proposed in this EA are: ovariectomy via colpotomy, minimally invasive tubal ligation, and minimally invasive hysteroscopically guided laser ablation. The first procedure, Ovariectomy, has been shown to have a high complication rate under sterile conditions per the EA. Why then would you want to conduct this procedure on wild horses using only aseptic techniques? You will be placing the horses at undue risk for infection and bleeding with no facilities to handle any emergency situation. This is totally unacceptable and an unsafe practice by any surgical standards. Ovariectomy is also known to cause behavioral changes and bone density loss. Why then would you subject wild mares to this technique?
The last two procedures, minimally invasive tubal ligation, and minimally invasive hysteroscopically guided laser ablation, are totally experimental and have not even been used on domestic horses per the EA—p.17/22. Wild horses should not be used as guinea pigs to develop new minimally invasive, low risk techniques for permanent sterilization. The proposal also plans to have a veterinarian on site for only two days following the procedure and proposes to turn the follow up care over to untrained BLM personnel. This practice also will put wild horse mares in harms way without adequate resources to care for the mare postoperatively.
You are not only willing to put wild horse mares at risk for death and injury but also their fetuses. You contend there is an “over population of wild horses,” yet you will intentionally impregnate mares to ensure you have the proper number of mares at different gestational stages. Then you will place the mares, and I assume any surviving foals, up for adoption. Based on current rates of adoption of wild horses, it is likely the subjects of this twisted research project will end up spending their lives in long term holding.
On Page 11, you state that no mares will be returned to their HMA’s, but later on page 11 you state, “Some horses selected to be returned to the range may also be marked for monitoring purposes”. Which is it? This is unclear. You also state that post-procedure mare behavior is outside the scope of this EA. It should not be outside of the scope of this EA, particularly if these mares are to be offered for adoption.
The selection criteria on page 12 is very disturbing. You state “Horses chosen for the procedures would be adult females and immature females estimated to be older than 8 months and weighing 250 kg (551 lbs.) or more.” While we oppose the sterilization of all horses, we find the plan to sterilize young horses (immature females) particularly loathsome.
In discussions with our equine vet, Dr. Lisa Jacobson, she expressed concerns with both colpotomies and laproscopic surgeries, fearing that infection, bleeding from a severed artery, and prolapse of the intestines would most likely result in death in some cases.
Experimentation on wild horse mares is not needed. What is needed is a commitment to use the safe, reversible fertility vaccine PZP which is being used successfully in numerous HMAs lucky enough to have enlightened, caring BLM managers. The BLM has received offers of volunteer support to aid in developing the ongoing administration of fertility control programs in other wild horse areas but has more often than not ignored such offers of help.
The Cloud Foundation strongly urges the BLM and all government agencies dealing with wild horses, to abandon research plans involving sterilization of wild horses and immediately pursue sustainable, ethical, economic and humane methods which are already available and supported by the National Academies of Science.
Please feel free to contact us if you have questions or wish to discuss our comments. We are always open to partnering with BLM personnel who want to manage our wild horse herds on the range.
Volunteer Executive Director
The Cloud Foundation, Inc.
107 S. 7th Street
Colorado Springs, CO 80905
EXPERT COMMENTS BY VETERINARIAN DON MOORE:
Experimentation of 3 procedures for permanent sterilization of wild horse mares proposed by BLM Oregon. The three surgical procedures for permanent sterilization of mares described in the mare sterilization research project, ovariectomy via colopotomy, tubal ligation and hysteroscopically-guided laser ablation of the oviduct papilla all require certain preoperative considerations for aseptic surgical protocol and pain management. Preoperative bloodwork and a thorough examination are always performed on the few domestic mares which are spayed. Other options other than surgery are always considered first due to the risk involved with any of these procedures. Wild mares will not have their surgeries performed in a sterile surgical suite which is always afforded to domestic mares. Their surgery will be performed in a nonsterile chute or standing in stocks at the local BLM facility without benefit of routine standard of care. Unlike domestic mares who are easily handled, the very handling of these wild mares presents additional pre-operative stressors, which cannot be mitigated. In private practice, colopotomy is considered an inferior procedure with likelihood of post-surgical infections and complications (i.e., colic) especially during these unsterile conditions. Post-operative care usually lasts several days to often weeks and mares are monitored and in most cases are monitored in box stalls or cross ties, which cannot be accomplished with wild mares. Standard of care for tubal ligation and/or ovariectomy is performed aseptic conditions with a laparoscope and pain mitigation along with private confinement and treatment which can last days to weeks. Complications can also be colic, infection and pain mitigation is required. Hysteroscopically guided laser ablation is not a preferred method by board certified equine surgeons because it is considered experimental even under the best of conditions. Field veterinarians and veterinary students are woefully inadequate to perform any of these surgeries, which in my opinion should only be done by board certified equine surgeons in the appropriate surgical suites and post- operative care by educated and expert staff in an equine veterinary hospital setting. In recent conversations with Littleton Equine Medical Center veterinarians Scott Toppin, DVM, DABVP and Kelly Tisher DVM the following comments were made to me. Dr. Toppin stated he had serious concerns about the dangerous and inhumane conditions under which these surgeries would be performed. He also stated concerns about the sterility of the procedure and pre and post-operative pain control. Dr. Tisher shared that their practice equine surgeon, Dustin V. Devine DVM, MS DACVS, performs approximately 6 – 12 of these surgeries with a laparscope on annually year. Littleton Equine is the leading equine veterinary private practice in Colorado. Mass experimental surgeries performed under these conditions outlined in the proposal, amounts to negligence and abuse. I believe experiments such as this proposal are unethical, inhumane and unwarranted. Any veterinarian(s) who would perform these experiments is in violation of the oath taken as a graduating veterinarian, “above all else, do no harm”. If a veterinarian in private practice performed these procedures in the manner described in this document they would most certainly be reported to and disciplined by the regulatory board of that state. Disciplined would likely mean suspension of that veterinarian’s license to practice in that state.