Warm Springs HMA Spay Experiment Scoping Comments
Wild Horse & Burro Specialist
BLM Burns District Office
28910 Hwy 20 West
Hines, OR 97738
Subject: DOI-BLM-ORWA-B050-2018-0016-EA Spay Feasibility and On-Range Behavioral Outcomes Assessment and Warm Springs Herd Management Area Population Management Plan
Dear Ms. Grant,
On behalf of The Cloud Foundation (TCF), a 501(c)3 non-profit and our hundreds of thousands of supporters throughout the United States, we would like to thank you for the opportunity to comment on DOI-BLM-ORWA-B050-2018-0016-EA.
Experimental research involving wild horse mares, especially in the unsterile Burns Corrals facility, is unconscionable. 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. 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.“ This research program does not fall within either of those decrees. Furthermore, we believe it is a waste of taxpayer dollars.
Currently over 70% of wild horse herds are managed at “appropriate management levels” which the National Academy of Sciences has deemed “not transparent to stakeholders, supported by scientific information, or amenable to adaptation with new information and environmental and social change.” The low appropriate management levels set for these herds endanger the genetic viability of the animals. 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. A Judge in the US District Court of Idaho ruled that sterilization removes an animal’s ability to be wild, in essence destroying the animal:
“… preventing births and reproductive capacity of the horses alters wild horse behaviors and the social structure of the herd. …. The NAS Report concluded that ‘absence of young horses itself would alter the age structure of the population and could thereby affect harem dynamics.’ …. Accordingly, the Court concludes the Defendants have violated NEPA by failing to take a hard look at these important aspects of its decision and failing to disclose and analyze the NAS Report in the FEIS.”
Case No. 1:16-cv-00001-EJL. United States District Court for the District of Idaho, 2017. Pg. 21-23.
The implementing regulations require that “wild 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). Sterilization of these animals does not honor either implementing regulation.
Safety Concerns regarding Mare Sterilization Research
Ovariectomies have been shown to have a high complication rate under sterile conditions per the EA. In the scoping notice, it states that this study will determine the feasibility of performing this procedure in a “BLM facility.” Because the Burns Corrals facilities are not sterile, the procedural risks will be even higher than the already demonstrable risks of performing the procedure in a sterile environment. Ovariectomy is also known to cause behavioral changes and bone density loss. Why then would you subject wild mares to this technique? Ovariectomies via colpotomy as proposed in the scoping notice are even more suspect. Expert equine veterinarian Don Moore notes that many professional veterinarians do not even consider ovariectomy via colpotomy as an option.
“In private practice, colopotomy is considered an inferior procedure with likelihood of post-surgical infections and complications (i.e., colic) especially in 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.”
Dr. Don Moore, Expert Equine Veterinarian
Additionally, in discussions with our personal equine veterinarian, Dr. Lisa Jacobson, she expressed concerns with colpotomies, fearing that infection, bleeding from a severed artery, and prolapse of the intestines would most likely result in death in some cases.
If private practice veterinarians feel uncomfortable performing this procedure on domestic mares in sterile conditions with substantial post-operative supervision, we cannot fathom how the BLM can set aside any compassion and concern for the wild mares as they will not receive the procedure in a sterile environment or receive the same level of observation postoperatively. Wild horses should not be used as guinea pigs to develop new minimally invasive, low risk techniques for permanent sterilization. This practice will put wild horse mares in harm’s way without adequate resources to care for the mare postoperatively.
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, and forward-thinking 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 most recent research shows that PZP-22 is now dartable and is very promising as a contraceptive with longer-term effects on wild mares. This kind of research should be the BLM’s focus, not the invasive experimental sterilization of wild mares that has been proven to be dangerous.
A U.S. District Court Judge has already struck down the approach of creating sterile herds of wild horses.
“The Defendants decision to manage the herd as entirely non-reproducing is arbitrary and capricious. The BLM failed to consider the impacts of maintaining the herd as nonreproducing and whether those impacts were consistent with the requirement that the herd maintain its free-roaming behavior.”
United States District Court for the District of Idaho, Case No. 1:16-cv-00001-EJL, Memorandum Order, Pg. 40.
Furthermore, professional veterinarians agree that mass experimental surgeries performed on wild mares amounts to negligence and abuse.
“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.”
Dr. Don Moore, Expert Equine Veterinarian
The Cloud Foundation strongly urges the BLM and all government agencies dealing with wild horses to abandon research plans involving sterilization of wild horses in an unsafe environment 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.
The Cloud Foundation