Professional Documents
Culture Documents
10,
2016
Mare
Sterilization
Research
Project
Lead
Burns
BLM
District
Office
28910
Highway
20
West
Hines,
OR
97738
Via
Fax:
541-573-4411
(27
pages)
and
email
(with
attachments)
To
Whom
It
May
Concern:
The
American
Wild
Horse
Preservation
Campaign
(AWHPC)
is
a
non-profit
organization
whose
mission
to
protect
and
preserve
Americas
wild
horses
on
public
lands
in
the
West
is
endorsed
by
a
national
coalition
of
more
than
60
organizations.
AWHPC
has
reviewed
the
Bureau
of
Land
Managements
(BLMs)
Mare
Sterilization
Research
Environmental
Assessment
(DOI-BLM-OR-
B000-2015-0055-EA)
and
offers
these
comments
on
this
document,
which
we
find
to
be
grossly
deficient
and
misleading.
I. Overview
Nearly
21,000
individual
citizens
have
submitted
comments
in
opposition
to
the
Bureau
of
Land
Managements
(BLMs)
proposal
to
conduct
dangerous
sterilization
experiments
on
wild
mares
held
at
the
Burns
Corrals
in
Oregon.
AWHPC
joins
these
citizens
in
strong
opposition
to
this
research.
The
EA
states
on
page
5:
The
BLM
will
decide
whether
or
not
to
proceed
with
one
or
more
of
the
proposed
sterilization
procedures
at
the
BLMs
Oregon
Wild
Horse
Corral
Facility
and
under
what
terms
and
conditions.
AWHPC
has
reviewed
the
Environmental
Assessment
(EA),
the
National
Academy
of
Sciences
(NAS)
National
Research
Council
(NRC)
2013
report,
Using
Science
to
Improve
the
BLM
Wild
Horse
and
Burro
Program:
A
Way
Forward,
and
the
NRC
review
of
the
research
proposals
(EA
Appendix
B),
as
well
as
consulted
with
numerous
experts
in
the
field
of
equine
veterinary
medicine
and
reproduction
and
concludes
that
the
weight
of
scientific
evidence
clearly
supports
a
BLM
decision
NOT
to
proceed
with
any
of
these
sterilization
procedures
in
wild
mares.
American
Wild
Horse
Preservation
Campaign,
1025
Alameda,
#633,
Belmont,
CA
94002
WildHorsePreservation.org
-
-
-
Ovariectomy
is
not
an
appropriate
management
tool
for
wild
horses
due
to
behavioral
changes
and
social
disruption
it
will
undeniably
cause
when
implemented
on
the
range,
as
well
as
the
health
risk
this
surgical
procedure
poses
for
mares
and
their
unborn
foals.
The
BLM
should
focus
on
non-surgical
methods
of
fertility
control
that
preserve
the
natural
behaviors
that
distinguish
wild-free
roaming
horses
from
domestic
horses
and
are
protected
under
federal
law.
The
BLMs
pursuit
of
ovariectomy
in
wild
mares
directly
contradicts
the
recommendations
of
the
NAS/NRC
which
concluded
that
ovariectomy
was
inadvisable
for
a
field
setting.
Ovariectomy
via
colpotomy
is
risky
and
largely
outdated
procedure
that
has
been
supplanted
by
more
modern,
laparoscopic
techniques.
The
risks
of
this
procedure
are
increased
when
performed
on
wild
mares,
who
cannot
be
handled
or
confined
and
therefore
cannot
be
provided
with
required
post-operative
care.
These
risks
include
serious
and
potentially
life-threatening
complications
including
hemorrhage,
evisceration
(intestines
protruding
through
surgical
incision)
and
infection.
The
use
of
pregnant
mares
in
this
sterilization
research
is
unacceptable.
The
experiments
and
the
stress
and
trauma
related
to
them
will
cause
many
of
the
mares
to
abort
their
unborn
foals.
According
to
the
EA,
the
majority
of
the
225
wild
mares
to
be
used
in
these
experiments
will
be
pregnant.
The
two
less
invasive
procedures
--
tubal
ligation
and
hysteroscopically-guided
laser
ablation
should
be
tested
in
domestic
horses
before
being
attempted
in
wild
horses,
as
recommended
by
the
NRC.
Neither
procedure
has
ever
been
performed
in
horses.
Both
are
of
questionable
feasibility
in
a
field
setting
due
to
the
cost
of
equipment,
lack
of
trained
surgeons
and,
in
the
case
of
laser
ablation,
cannot
be
performed
on
pregnant
mares.
It
is
unconscionable
that
the
BLM
is
proposing
to
subject
wild
mares
to
painful
and
risky
experiments
that
present
grave
risks
to
the
mares
and
their
unborn
foals,
particularly
when
a
proven
non-invasive
and
safe
fertility
control
method
exists
in
the
readily
available
PZP
birth
control
vaccine.
Instead
of
wasting
millions
of
tax
dollars
to
fund
experiments
on
inhumane,
impractical
and
invasive
surgical
sterilization
experiments,
the
agency
should
instead
focus
resources
on
vaccinating
sufficient
numbers
of
mares
with
the
PZP
fertility
control
vaccine,
which
is
documented
through
30
years
of
experience
and
published
science,
to
be
safe,
cost-
effective
and
successful
in
managing
wild
horse
populations.
The
Environmental
Assessment
(EA)
for
these
experimental
proposals
is
grossly
inadequate
because
it
glosses
over
the
real
risks
of
the
procedures
identified
by
the
NRC
and
published
science,
and
fails
to
adequately
consider
the
alternatives
to
and
impacts
(including
social
and
economic)
of
these
procedures.
Instead
it
selectively
quotes
from
NRC
findings,
utilizes
unpublished
data
and
relies
on
observations
from
unnamed
veterinarians.
Although
the
EA
states
that
the
BLM
will
make
the
decision
about
whether
or
not
to
proceed
with
these
procedures
based
on
the
analysis
o
f
their
impacts,
its
clear
that
the
EA
has
been
crafted
to
support
the
foregone
conclusion
that
these
experiments
will
be
conducted.
Finally,
because
the
Proposed
Action
could
set
precedent
for
the
implementation
of
highly
controversial
methods
of
wild
horse
population
control
on
the
range,
an
Environmental
Impact
Statement
(EIS)
is
required,
The
Wild
Free-Roaming
Horses
and
Burros
Act
requires
BLM
to
manage
wild
horses
and
burros
in
a
manner
that
protects
their
wild
and
free-roaming
behavior.
While
Section
3(b)(1)
as
modified
by
the
Public
Rangelands
Improvement
Act
of
1978,
does
specify
options
for
population
management
that
include
sterilization,
it
states
that
such
determinations
must
be
made
in
conjunction
with
other
wildlife
agencies
and
experts
independent
of
government,
such
as
those
recommended
by
the
National
Academy
of
Sciences.
In
2011,
the
BLM
requested
and
paid
for
an
NAS/NRC
scientific
review
of
its
Wild
Horse
and
Burro
Program.
In
February
2011,
then
BLM
director
Bob
Abbey
announced
that
the
NAS/NRC
review
was
a
cornerstone
of
the
agencys
accelerated
reform,
stating
that
the
NAS/NRC
findings
would
determine
how
the
BLM
should
proceed
in
light
of
the
latest
scientific
research.
(Attachment
1)
In
the
study
scope
as
defined
by
BLM,
the
NAS/NRC
was
specifically
asked
to
evaluate
ovariectomy
as
an
option
to
managing
wild
horses:
Managing
a
portion
of
a
population
as
non-reproducing:
What
factors
should
the
BLM
consider
when
managing
for
WH&B
herds
with
a
reproducing
and
non-reproducing
population
of
animals
(i.e.,
a
portion
of
the
population
is
a
breeding
population
and
the
remainder
is
non-reproducing
males
or
females)?
When
implementing
non-reproducing
populations,
which
tools
should
be
considered
(geldings
(castration),
sterilized
(spayed)
mares
or
vasectomized
stallions
or
other
chemical
sterilants)?
Statement
of
Task
(Attachment
2)
In
its
final
report
entitled
Using
Science
to
Improve
the
BLM
Wild
Horse
and
Burro
Program:
A
Way
Forward,
June
2013
(Attachment
3)
the
NAS/NRC
concluded
that
spaying
was
inadvisable
and
also
recommended
against
gelding.
The
possibility
that
ovariectomy
may
be
followed
by
prolonged
bleeding
or
peritoneal
infection
makes
it
inadvisable
for
field
application.
(p.130)
Surgical
ovariectomy
and
ovariohysterectomy
are
commonly
used
in
domestic
species,
such
as
cats
and
dogs
(including
feral
cats
and
dogs),
but
seldom
applied
to
other
free-ranging
species.
(p.
114)
Ovariectomy
during
the
first
2-3
months
of
pregnancy
results
in
abortion
because
of
the
loss
of
progesterone
from
the
corpus
luteum
(Holtan
et
al.,
1979).
(p.
115)
Typical
side
effects
associated
with
ovariectomy
in
many
species
include
decreased
activity
and
weight
gain.
(
p.
115)
Despite
the
scientific
recommendation
from
the
NAS/NRC
AGAINST
ovariectomy
(even
laparoscopic)
as
a
method
to
control
population
growth,
despite
the
public
urging
the
BLM
NOT
to
pursue
spaying
mares,
despite
the
overwhelming
controversy,
the
BLM
is
nevertheless
pursuing
this
dangerous,
precedent-setting
and
extreme
plan
to
sterilize
wild
horses.
The
EA
has
failed
entirely
to
accurately
and
forthrightly
address
the
NAS
recommendation
AGAINST
ovariectomy
as
a
management
tool
and
is
completely
inadequate
in
its
assessment
of
the
procedures
impacts
on
wild
free-roaming
horses.
The
importance
of
assessing
the
viability
of
a
fertility
control
method
by
its
effects
on
natural
behavior
was
affirmed
by
the
NAS/NRC
multiple
times
in
its
2013
report:
often-stated
public
interest
in
maintaining
natural
behaviors
in
free
roaming
horses.
(p.
123)
The
most
appropriate
comparison
that
should
be
made
in
assessing
the
effects
of
any
method
of
fertility
control
is
with
the
current
approach,
gathering
and
removal.
That
is,
to
what
extent
does
the
prospective
method
affect
health,
herd
structure
and
the
expression
of
natural
behaviors
relative
to
the
effects
of
gathering?
The
EA
wrongly
states
that
impacts
of
ovariectomy
are
outside
the
scope
of
this
EA.
However,
there
can
be
no
doubt
that
ovariectomy
will
impact
the
natural
behaviors
of
mares
and
this
goes
to
both
the
need
for,
and
feasibility
of
the
proposed
procedure,
which
is
clearly
NOT
outside
the
scope
of
analysis
in
this
EA.
Indeed
it
supports
the
No
Action
alternative
as
clearly
superior,
because
none
of
the
experiments
proposed
will
produce
data
on
feasible,
safe
and
humane
population
management
tools.
According
to
Robin
Kelly,
DVM,
whose
northern
California-based
equine
veterinary
practice
includes
care
of
240
wild
horses
and
burros
at
the
Montgomery
Creek
Ranch
sanctuary
in
Elk
Creek
I
am
concerned
about
the
use
of
this
procedure
in
the
wild,
due
to
the
concerning
potential
disruption
of
the
normal
social
behaviors
of
post
ovariectomized
mares
and
how
this
will
affect
their
role
within
the
herd
once
they
return
to
their
families.
According
to
the
reproductive
specialist
I
consulted,
while
estrogen
is
secreted
by
multiple
tissues,
progesterone
is
only
produced
by
the
ovaries.
Since
progesterone
is
the
hormone
that
prevents
mares
going
into
estrus,
ovariectomized
mares
frequently
act
like
they
are
in
heat
all
the
time.
Putting
ovariectomized
mares
back
on
the
range
could
create
social
havoc
within
wild
herds.
Stallions
instinctively
know
which
mares
are
fertile/receptive
and
which
are
not.
The
stallions
job
is
to
breed
and
impregnante
mares
after
they
deliver.
If
he
has
a
number
of
ovariectomized
mares
in
his
harem
who
act
llike
they
are
in
estrus
continuously
but
canot
become
pregnant,
or
some
of
the
time
would
not
accept
his
advances,
the
stallions
social
behaviors
could
be
severely
disrupted
or
over
used
inappropriately.
In
addition,
ovariectomized
mares
may
act
sexually
but
my
not
want
to
breed,
raising
the
potential
for
serious
kick
injuries
to
stallions
and
mares
if
a
stallion
attempts
to
breed
an
unreceptive
mare.
Ovariectocmized
mares
may
also
lose
their
status
within
the
mare
band.
Lead
mares
would
be
unlikely
to
retain
that
position
post-
ovariectomy.
Social
ostracism
is
certainly
possible
for
hese
post
operative
if
they
are
no
longer
accepted
by
the
herd.
Dr.
Kellys
statement
has
been
submitted
separately
as
comments
on
the
EA
and
is
provided
with
AWHPCs
comments
as
Attachment
4.
Ovariectomy
will
cause
profound
behavioral
changes
in
wild
horses.
Although
the
EA
states
than
an
ovariectomized
mare
may
show
signs
of
estrus
behavior,
the
EA
also
cites
reports
that
60%
of
mares
cease
estrus
behavior
after
ovariectomy.
The
cessation
of
estrus
behavior
will
obviously
have
impacts
on
the
natural
free-roaming
and
social
behaviors
of
these
mares.
Wild
horses
typically
live
in
reproductive
bands
consisting
of
adult
mares,
their
dependent
offspring,
and
one
or
more
stallions
who
lives
revolve
around
trying
to
protect
mares
from
harassment
by
other
stallions
and
securing
exclusive
reproductive
access
to
the
mares
for
themselves;
Mares,
meanwhile,
simultaneously
bond
to
one
another
and
compete
with
each
other
for
access
to
water,
food,
and
other
resources
for
themselves
and
their
foals.
Neither
geldings
nor
spayed
mares
participate
in
these
fundamental
processes
of
wild
horse
behavior.
Allen
T.
Rutberg,
Ph.
D.,
Assistant
Director,
Center
for
Animals
and
Public
Policy,
Tufts-
Cummings
School
of
Veterinary
Medicine.
(Attachment
5)
However,
an
equally
problematic
and
unquestionably
significant
impact
is
raised
by
the
BLMs
own
expert
panel,
convened
on
September
24,
2015
to
evaluate
various
methods
of
spaying
horses
(Attachment
6).
Spayed
mares
can
be
receptive
all
year
round.
Typically
can
not
even
put
them
with
geldings
as
they
would
be
mounted.
If
given
the
opportunity,
a
spayed
mare
would
tolerate
the
sexual
advance
of
an
amorous
gelding.
Sue
McDonnell,
Ph.D.
,
equine
behavior
and
reproduction
expert
from
the
University
of
Pennsylvania
and
member
of
the
BLM
Wild
Horse
and
Burro
Advisory
Board.
Another
panel
member,
Patricia
Sertich,
V.M.D.
an
equine
reproductive
specialist
from
the
University
of
Pennsylvania
confirmed
this:
Teaser
mares
(stimulus
mares
for
semen
collection)
are
ovariectomized.
They
are
sexually
receptive
to
stallion
advances
every
day
for
the
rest
of
their
lives.
Dr.
Robin
Kelly
consulted
with
Mary
Scott,
DVM,
Diplomate
with
the
American
College
of
Theriogenologists,
regarding
her
opinion
of
the
proposed
experiments.
Dr.
Kelly
reports:
Please
see
Attachment
7
for
copy
of
Journal
of
Equine
Veterinary
Education
article.
In
addition
to
the
above
concerns,
it
is
likely
that
the
presence
of
ovariectomized
mares
displaying
prolonged
estrus
behavior
and
sexual
receptivity
will
attract
stallions
from
outside
the
band
and
result
in
increased
stallion-stallion
aggression.
This
is
another
significant
impact
that
must
be
fully
disclosed
and
analyzed
in
the
EA.
It
is
well
known
that
mares
especially
lead
mares
play
a
strong
role
in
wild
horse
natural
behaviors
and
social
structure.
Altering
mares
hormones
via
ovariectomy
would
result
in
the
consequent
reduction
in
or
complete
loss
of
natural
lead-mare-type
behaviors
necessary
for
maintenance
of
social
organization,
band
integrity,
and
expression
of
a
natural
behavior
repertoire.
In
fact,
the
impacts
of
sterilization
on
wild
horses
can
be
severe,
affecting
their
physiology
and
ability
to
survive,
as
well
as
their
behavior
and
therefore
impact
on
the
herd.
Since
the
wild
horse
and
the
domestic
horse
are
the
same
species,
there
is
no
reason
to
believe
that
the
physiological
effects
of
ovariectomy
will
differ.
As
a
result,
there
is
no
question
that
spaying
wild
mares
will
inalterably
change
their
wild
free-roaming
behaviors,
which
are
protected
under
federal
law.
Removing
a
mare's
ovaries
is
a
permanent
way
of
altering
her
estrous
cycle
and
behavior.
-
The
Spayed
Mare,
Horsekeeping.com
(Attachment
8)
Such
behavioral
changes,
when
induced
via
ovariectomy,
will
have
serious
consequences
for
mares
returned
to
the
range,
and
to
the
social
dynamics
of
individual
bands
and
entire
herds.
NEPA
requires
the
BLM
fully
research,
document,
and
analyze
the
proposed
action
of
spaying
mares
especially
because
this
would
be
a
precedent-setting
proposed
action.
This
EA
has
failed
to
comply
with
this
requirement.
We
strongly
urge
the
BLM
to
remove
this
as
an
option
for
research
as
it
is
ill-advised
for
wild,
free-roaming
horses,
is
highly-controversial
and
counter
to
the
Act.
At
minimum
an
EIS
that
fully
discloses
and
analyzes
the
impacts
of
this
proposed
action
A. Overview
The
BLM
intends
to
use
100
mares
in
this
ovariectomy
experiment.
Since
the
procedure
chosen
-
ovariectomy
via
colpotomy
-
is
a
rudimentary,
but
established,
method
of
spaying
mares,
the
research
aspect
involves
the
testing
of
the
effects
of
this
invasive
surgical
procedure
on
75
pregnant
mares.
As
described
in
the
EA
(p.
13-17)
this
procedure
involves:
- Holding
mares
off
feed
for
36
hours
before
surgery
to
empty
the
intestines
of
food
contents.
- Restraining
the
mares
in
chutes
and
sedating/anesthetizing
them
- Preforming
a
rectal
exam
to
evacuate
the
rectum
and
determine
pregnancy
status
and
gestational
stage.
- Making
a
1-3
centimeter
incision
in
the
vagina,
enlarging
it
with
the
surgeons
fingers,
and
perforating
the
perineum
to
allow
the
surgeons
hand
and
arm
to
enter
through
the
vaginal
channel
into
the
abdominal
cavity.
- Manually
palpitating
(blindly)
the
abdominal
cavity
to
locate
the
ovaries.
- Injecting
local
anesthetic
into
each
ovary.
- Removing
the
ovaries
with
a
chain
ecraseur,
a
rod-like
device
with
a
chain
on
the
end,
which
is
used
to
encircle,
crush
and
sever
the
ovaries.
- Leaving
the
incision
open
and
returning
the
mare
to
her
pen
once
she
awakens
from
surgery.
The
BLMs
livestock-based
approach
to
wild
horse
management
contradicts
the
mandate
of
the
Wild
Free
Roaming
Horses
and
Burros
Act,
which
mandates
that
these
iconic
animals
be
managed
as
an
integral
part
of
the
natural
system
of
the
public
lands.
This
approach
not
only
ignores
what
makes
these
wild
animals
different
from
their
domestic
counterparts,
it
aims
to
destroy
it.
The
American
public
demands
higher
standards
for
the
management
of
wild
horses
-
-
wild,
free-roaming
animals
with
complex
social
behaviors
that
distinguish
them
from
domestic
horses.
The
BLM
is
charged
with
managing
wild
horses,
yet
it
continues
to
ignore
the
importance
of
the
very
thing
that
makes
them
wild,
setting
the
remaining
wild
horse
herds
in
this
country
on
an
inexorable
path
toward
destruction.
2. OUTDATED
PROCEDURE
Veterinarians
contacted
by
AWHPC
indicate
that
ovariectomy
itself
is
an
uncommon
procedure
in
mares,
and
if
done
today,
is
performed
by
modern
laparoscopic
techniques,
not
via
colpotomy.
According
to
Dr.
Kelly:
Historically,
colpotomies
had
been
done
occasionally
in
some
practices
to
manage
adverse
behaviors
of
mares
(or
tumors),
but
with
less
invasive
procedures
currently
available
and
pharmaceutical
options
(Altrenogest
and
Regulate)
surgical
management
of
adverse
behaviors
has
significantly
declined.
When
ovariectomies
need
to
be
done
(to
manage
granuloma
cell
tumors
for
example)
Laparoscopy
is
the
procedure
of
choice
unless
the
tumor
is
too
large
in
which
case
a
ventral
midline
or
flank
approach
would
be
chosen.
Only
the
affected
ovary
would
be
removed
typically.
Incisions
with
Laparoscopy
are
small
and
external.
Surgical
prep
is
much
less
complex,
visualization
of
the
procedure
is
constant
(not
blind)
and
the
risks
of
complications/bleeding
are
much
lower
(compared
to
Colpotomies).
(Attachment
4)
As
Dr.
Kelly
later
states,
ovariectomy
is
also
used
on
a
limited
basis
for
jump
or
teaser
mares
used
to
collect
semen
for
artificial
insemination.
Colpotomy
is
a
blind
procedure
wherein
the
surgeon
manually
enters
the
abdominal
cavity
through
an
incision
in
the
vagina
large
enough
to
accommodate
his/her
hand
and
arm.
Because
the
surgeon
cannot
see
the
internal
structures,
the
risk
of
cutting
an
artery
or
the
bowel
is
high.
In
addition
to
the
ability
to
visualize
the
internal
structures
through
the
use
of
small
cameras,
modern
laparoscopic
techniques
also
offer
the
advantage
of
much
smaller
incisions,
make
this
the
gold
standard
for
this
procedure
in
todays
veterinary
community.
As
Dr.
Pamela
Corey
states
(Attachment
):
Culpotomy
is
the
removal
of
an
ovary
through
an
incision
via
the
vaginal
area
of
a
horse
and
in
order
to
access
the
organ,
the
abdominal
cavity
is
entered.
Numerous
loops
of
intestinal
tract
have
to
be
identified
to
ensure
only
the
ovary
is
accessed
for
surgical
removal.
The
mare
is
restrained
in
stocks
and
local
anesthetic
and
sedation
is
used
to
enable
the
procedure
to
be
performed.
The
American
College
of
Veterinary
Surgeons
(ACVS)
states
that
standing
laparoscopic
access
to
the
mare's
ovaries
is
the
gold
standard
for
this
surgical
procedure.
This
approach
is
more
direct
than
via
the
vagina
as
it
is
through
the
flank
of
the
mare
and
a
camera
is
used
to
ensure
that
the
appropriate
organ
is
identified
before
removal.
Pain
management,
sedation,
anesthesia
and
post
operative
antibiotics
for
the
horse
are
not
optional
in
this
procedure.
They
are
vital.
Horses
are
extremely
sensitive
to
pain
and
to
peritonitis
(infection
of
the
abdomen)
and
as
a
species
are
more
likely
to
form
adhesions
after
abdominal
surgical
procedures
than
cattle
are.
A
BLM
proposal
to
"spay"
(surgically
remove
ovaries)
wild
female
horses
by
a
method
which
is
called
inferior
by
the
ACVS
is
unconscionable
and
doomed
to
failure.
The
wild,
untrained
mares
will
not
have
adequate
veterinary
medical
care
during
and
after
the
surgery
and
will
be
at
risk
of
fatal
complications
due
to
the
lack
of
laparoscopic
equipment,
which
is
the
gold
standard
for
this
procedure.
This
is
an
uncommon
surgery
not
performed
by
any
significant
percentage
of
equine
practitioners
in
the
United
States
because
horse
owners
do
not
need
to
sterilize
their
mares
unless
they
have
disease
of
the
reproductive
tract,
such
as
an
ovarian
tumor.
In
summary,
the
vaginal
culpotomy
procedure
(without
laparoscopic
equipment)
performed
on
wild
female
horses
in
a
field
setting
(as
opposed
to
an
equine
hospital
facility)
does
not
meet
the
accepted
standard
of
veterinary
care
in
this
country.
According
to
the
American
College
of
Veterinary
Surgeons
(Attachment
10):
with
the
advent
of
laparoscopic
(keyhole)
surgery,
the
gold
standard
technique
is
laparoscopic
ovariectomy
in
which
the
ovary
is
removed
from
a
standing
sedated
horse,
through
a
small
incision
in
the
flank.
This
technique
is
both
minimally
invasive,
avoids
risks
of
general
anaesthesia
and
cosmetically
very
acceptable
and
therefore
makes
all
other
approaches
inferior.
(Emphasis
added.)
Use
of
laparoscopes
could
significantly
improve
the
safety
of
the
ovariectomy
procedure:
Inexplicably,
the
EA
does
not
contain
a
single
mention
of
laparoscopic
technology,
and
the
failure
to
consider
more
modern
alternatives
renders
this
document
completely
inadequate.
Further
the
EAs
analysis
of
the
risks
to
the
mares
of
hemorrhage
and
evisceration
through
the
surgical
incisions
is
completely
inadequate
as
well.
C.
High
Risk
Procedure;
Outcome
Dependent
on
Skill
of
Surgeon
In
its
assertion
that
ovariectomy
via
colpotomy
is
a
safe
procedure,
the
EA
relies
on
unpublished
data
and
personal
communications
from
Leon
Pielstick,
who
may
be
the
only
veterinarian
in
the
U.S.
who
has
done
this
procedure
on
wild
mares.
Dr.
Pielstick
also
reports
on
the
results
of
a
training
he
conducted
on
donkeys
in
Arizona,
which
he
claims
had
a
1
in
5
mortality
rate.
The
lack
of
trained
veterinarians
and
the
difficulty
in
learning
how
to
perform
this
invasive,
blind
surgical
procedure
is
a
major
drawback
of
this
method.
The
BLM
has
not
adequately
addressed
the
impacts
to
wild
horses
of
being
subjected
to
ovariectomy
via
colpotomy
by
inexperienced
veterinarians
in
training.
10
In
September
2015,
BLM
convened
an
expert
panel
to
discuss
various
methods
of
spaying
mares.
This
information
was
referenced,
but
not
included
in
the
EA.
It
was
provided
to
AWHPC
by
the
BLM
after
we
requested
it,
and
it
is
included
here
as
Attachment
12.
From
the
expert
panel
discussion:
It
is
also
worth
noting
that
the
number
of
learning
surgeons
entering
the
body
cavity
of
those
burros
could
have
contributed
to
the
one
in
five
mortality
rate
for
those
burros.
Dr.
Asa
noted
that
one
of
the
major
complications
could
have
been
the
training
itself.
Julie
has
taught
numerous
vets
to
spay
heifers.
Only
a
small
percentage
are
still
spaying.
All
found
it
to
be
quite
difficult.
Adopting
colpotomy
for
wild
mares
means
that
we
need
to
find
people
who
have
gone
through
the
steep
learning
curve.
Some
people
can
develop
a
good
feel
to
correctly
assess
what
tissues
you
have
hold
of,
but
it
takes
experience
to
learn.
While
Julie
has
usually
required
100
heifers
to
train
a
veterinarian
to
spay
heifers,
100
mares
may
not
be
necessary
to
train
an
already
accomplished
equine
surgeon
to
perform
colptotomies.
Training
will
vary
with
the
individuals
involved
and
hopefully
could
be
accomplished
with
many
fewer
animals,
maybe
5-10,
with
time
to
rest
between
surgeries
for
reflection
during
training.
Dr.
Katrin
Hinrichs
suggested
that
3-5
colpotomies
should
be
done
under
supervision
while
Julie
Weikel
noted:
People
who
were
good
had
it
after
1-2
animals.
There
are
others
who
still
wouldnt
get
it
after
100.
You
need
people
with
experience
or
competence.
Dr.
Kelly,
in
her
statement,
confirms
this:
The
success
and
safety
of
colpotomies
is
partially
dependent
on
the
extensive
surgical
experience
of
the
operator.
Every
board
certified
surgeon
I
spoke
with
expressed
concern
over
Colpotomies
being
performed
on
these
wild
mares
and
in
the
proposed
setting
(BLM
facilities)
instead
of
in
a
surgical
facility.
Each
of
these
surgeons
reported
experience
with
or
anecdotal
reports
of
complications
to
mares
during
and
after
Colpotomies.
Each
questioned
the
validity
of
using
this
procedure
when
less
invasive,
less
painful,
safer
procedures
could
be
chosen
for
these
mares
in
the
study.
The
EA
must
assess
the
impacts
and
feasibility
of
this
approach
given
a)
the
lack
of
veterinarians
trained
to
perform
this
procedure;
and
2)
the
steep
learning
curve
for
veterinarians
attempting
to
master
this
blind
surgical
procedure
that
is
rarely
performed
in
horses.
The
steep
learning
curve
will
involve
the
deaths
of
many
horses,
as
the
one
in
five
mortality
rate
reported
by
Leon
Pielstick
in
his
training
of
nine
veterinarians
in
Arizona
in
the
Expert
Panel
report
documents.
This
is
unacceptable.
The
final
EA
must
fully
disclose
the
likely
deaths
of
untold
numbers
of
horses
in
training
exercises
and
must
fully
analyze
the
impacts
of
the
lack
of
trained
veterinarians
and
the
steep
learning
curve
involved
in
training
new
veterinarians
in
the
procedure.
D.
Health
Increased
by
Colpotomy
Performed
on
Wild
Mares
11
The
BLM
is
proposing
to
conduct
surgical
ovariectomies
in
a
barn
at
a
BLM
holding
facility
under
conditions
that
may
not
be
entirely
sterile
(p.
14)
on
wild
free-roaming
mares
who
can
not
be
handled
or
confined.
This
increases
the
risk
of
the
colpotomy
procedure
to
unacceptable
levels.
1. SEDATION
AND
RESTRAINT
As
Dr.
Kelly
states,
based
on
her
experience
treating
wild
horses:
Sedative
levels
required
to
perform
a
painful,
standing
procedure
vary
greatly
in
wild
horses
(often
requiring
2-3
times
(or
more)
doses
used
in
domesticated
horses.)
With
painful
stimuli
or
over/under
sedation
levels,
some
wild
horses
sit
or
lay
down
in
the
chute
(very
dangerous
if
the
procedure
is
underway).
Other
horses
tend
to
explode
in
the
chute
regardless
of
of
the
squeeze
being
implemented
and
heavy
sedation
on
board.
In
either
case,
if
the
ecraseur
was
being
crimped
and
the
mare
reacted
adversely
resulting
in
dislodgement
of
the
ecraseur,
excessive/life
threatening
hemorrhage
could
result.
The
operators
arm
could
also
be
at
risk
of
serious
injury
if
the
mares
position
within
the
chute
cannot
be
maintained.
(Adding
an
abdominal
strap
to
hold
the
mare
up
would
potentially
compress
the
abdominal
contents/pregnancy
and
make
surgical
approach
even
more
difficult/more
risky
that
abdominal
contents
(bowel)
would
be
forced
up
in
abnormal
positions.
The
EA
is
silent
on
the
risks
of
conducting
this
procedure
on
wild
mares.
The
final
EA
must
consider
the
different
sedation
requirements
of
wild
mares,
and
behaviors
of
terrified
horses
in
a
hydraulic
squeeze
chute
and
how
those
behaviors
may
impact
the
outcome
of
the
procedure
on
the
horses.
2. INABILITY
TO
PROVIDE
POST-OPERATIVE
CARE
Ovariectomy
in
horses
is
a
serious
procedure
that
requires
careful
post-operative
monitoring
and
care.
Dr.
Michael
Ball
described
the
risks
of
ovariectomy
in
horses
in
TheHorse.com
(Attachment
13_:
Regardless
of
the
method
used
for
ovariectomy,
this
procedure
is
generally
a
painful
one
and
the
use
of
peri-operative
analgesics
is
important.
The
horses
often
are
hospitalized
for
3-7
days
and
very
carefully
monitored
in
the
immediate
post-operative
period
for
any
signs
of
hemorrhage,
which
is
a
serious
complication
that
can
occur.
The
NRC
in
its
2013
report
also
discussed
these
risks:
Although
the
risks
are
lower
than
with
transabdominal
surgery,
episioplasty
(suturing
to
close
the
vulva)
and
stall
restriction
for
2-7
days
are
recommended
to
reduce
the
chance
of
evisceration.
Monitoring
for
24-48
hours
for
signs
of
hypovolemic
shock
due
to
external
bleeding
is
also
recommended.
The
procedure
is
not
without
risk.
(p.
98-99)
(Emphasis
added.)
12
In
its
review
of
this
research
proposal
(EA,
Appendix
B),
the
NRC
also
discusses
post-operative
care
requirements
of
this
procedure.
Domestic
mares
are
typically
cross-tied
to
keep
them
standing
for
48
hours
to
prevent
evisceration
through
an
unclosed
incision.
That
protocol
would
not
be
possible
for
free-ranging
mares
because
they
cannot
be
held
still
for
so
long.
Therefore,
there
is
some
concern
that
the
investigator
may
see
more
fatalities
than
the
1%
quoted
in
the
protocol,
which
is
based
on
domestic
mares.
(Emphasis
added.)
Mary
Scott,
DVM
Diplomate
with
the
American
College
of
Teriongenologists
was
consulted
by
Dr.
Kelly,
and
offered
these
comments
confirming
the
risks
to
wild
mares:
My
opinion
is
that
the
predominating
concern
with
the
proposed
study
is
the
significant
risk
of
Colpotomy
to
the
health/life
of
the
mares
during
the
surgery
and
post
operatively,
because
they
are
wild
animals
and
cannot
be
handled
or
treated
in
the
same
manner
as
domesticated
mares.
To
reduce
the
risk
of
evisceration
of
bowel
through
the
colpotomy
incision,
it
is
recommended
that
mares
should
be
maintained
in
a
tie
stall
for
up
to
7
days
and
then
restricted
to
a
small
paddock
turn
out
for
two
weeks
following
the
surgical
procedure.
These
guidelines
were
developed
because
the
risk
of
post-operative
hemorrhage
or
evisceration
are
real.
(Emphasis
added.)
When
discussing
the
risks
of
colpotomy,
the
University
of
Minnesota
(Attachment
11)
writes:
However,
ovary
removal
is
done
blindly.
This
can
result
in
damage
to
the
intestines
or
other
structures.
The
vaginal
incision
is
generally
not
closed.
This
means
bacteria
can
enter
the
abdominal
cavity
and/or
intestines
can
slide
out
through
the
incision.
The
mare
may
need
to
stay
in
cross
ties
for
a
few
days
to
allow
healing
and
prevent
intestinal
herniation.
Complications
include
hemorrhage
since
the
vessels
are
not
ligated,
peritonitis
(infection
of
the
abdominal
cavity),
or
vaginal
abscesses.
Despite
the
documented
risks,
the
wild
mares
in
these
experiments
will
not
be
provided
with
any
of
the
follow
up
care
required
of
this
procedure,
including:
stall
confinement,
including
a
period
in
crossties
to
prevent
lying
down
or
rolling;
careful
monitoring
for
hemorrhage;
pain
relief
and
antibiotic
treatment.
Once
the
procedure
is
completed
and
the
mare
has
recovered
from
a
sedated
state,
she
would
be
returned
to
her
corral
and
provided
with
adequate
feed
and
water.
It
has
been
suggested
that
keeping
the
mare
standing
for
2-4
days
after
surgery
could
be
used
to
prevent
evisceration.
However
this
risk
is
rare,
and
in
the
veterinarians
experience
withholding
feed
for
36
hours
prior
to
surgery
creates
empty
intestines,
decreasing
the
risk
for
evisceration
either
during
surgery
or
post
surgically.
Here,
the
EA
focuses
solely
on
evisceration,
offering
an
unsubstantiated
theory
that
keeping
the
mares
off
feed
for
36
hours
will
reduce
the
risk
of
evisceration.
Even
if
true,
this
does
not
address
the
significant
risk
of
hemorrhage
or
infection
associated
with
this
procedure.
And
13
while
empty
intestines
could
reduce
the
risk
of
the
surgeon
accidentally
(and
fatally)
mistaking
a
fecal
ball
for
an
ovary,
it
would
not
entirely
eliminate
the
risk
of
the
intestines
eviscerating
through
the
relatively
large
vaginal
incision,
which
will
be
left
open
post-surgery
when
the
mares
are
returned
to
their
pens.
In
her
statement,
Dr.
Kelly
further
explains
the
implications
of
the
BLMs
inability
to
provide
post-operative
care
to
the
mares
who
will
be
ovariectomized:
The
post
operative
management
proposed
for
these
mares
is
minimal
compared
to
significant
post
operative
recommendations
for
domesticated
mares.
These
recommendations
include
keeping
mares
tied
in
a
tie
stall/tie
line
to
prevent
them
from
laying
down/rolling
to
reduce
risk
of
post
operative
hemorrhage
or
herniation
of
bowel
through
that
that
must
be
left
open
to
second
intention
healing.
These
measures
are
advised
since
extensive
post-operative
hemorrhage
or
herniation
of
bowel
thru
incisions
would
not
be
survivable.
.Domesticated
mares
would
be
treated
with
a
more
aggressive
antibiotic
choice
for
7-10
days
post
operatively
(monitoring
daily
for
complications).
Insufficient
anti-microbials
could
result
in
peritonitis
(also
likely
not
surviveable).
.
.
.
The
wild
mares
will
not
be
provided
with
post-surgical
pain
relief,
according
to
the
study
description,
and
presumably
[will
be]
turned
out
in
a
communal
paddock
with
no
restraint.
3. PAIN
All
veterinarians
AWHPC
consulted
with
confirmed
that
ovariectomy
is
a
painful
procedure
which
requires
careful
monitoring
and
pain
relief
post-surgery.
This
was
confirmed
by
the
expert
panel
report
provided
to
AWHPC
by
the
BLM.
In
the
report,
Dr.
Katrin
Hinrichs,
a
reproductive
specialist,
stated
that
she
has
observed
mares
in
pain
at
night
after
surgery;
she
now
gives
butorphanol
for
24
h
after
surgery,
or
morphine
+
detomidine
epidural
at
the
time
of
the
surgery.
While
Dr.
Weikel
asserted
that
she
did
not
observe
mares
in
pain
after
ovariectomy
at
the
Sheldon
Refuge,
Dr.
Pielstick,
who
performed
the
surgeries,
noted
that
surgeries
were
not
completed
until
4
pm,
so
there
was
not
a
lot
of
light
for
observations
after
that.
(Expert
Panel
Report
p.
5)
The
EA
fails
to
analyze
the
risk
of
post-operative
pain
in
these
mares
and
the
impact
of
the
BLMs
inability
to
provide
post-surgical
pain
relief.
The
EAs
lack
of
honest
and
adequate
analysis
of
the
risks
of
this
procedure
to
wild
mares
who
cannot
be
provided
with
required
post-operative
care
is
blatant
and
shocking.
The
only
evidence
the
EA
can
muster
in
support
of
this
dangerous
experiment
is
unpublished
and
undocumented
results
from
the
spaying
of
mares
at
the
Sheldon
National
Wildlife
Refuge.
However,
Sheldon
officials
have
stated
publicly
that
no
follow
up
studies
of
spayed
mares
were
14
performed,
no
records
were
kept
on
the
number
of
mares
who
were
pregnant
at
the
time
of
spaying,
and
no
data
has
been
published
based
on
the
Sheldon
Refuges
spaying
of
mares.
The
EA
concludes
that
of
the
ovariectomy
methods
discussed
by
the
expert
panel,
ovariectomy
via
colpotomy
appears
to
be
relatively
safe
when
practiced
by
an
experienced
surgeon,
and
is
associated
with
the
shortest
duration
of
potential
complications
after
operations.
In
marked
contrast
to
a
suggestion
by
the
NRC
Review
(2013),
this
panel
of
experts
identified
evisceration
as
not
being
a
risk
associated
with
ovariectomy
via
colpotomy.
It
is
important
to
note
that
the
conclusions
of
this
expert
panel
regarding
risk
of
coplotomy
were
based
on
domestic
mares,
who
are
ovariectomized
to
be
jump
mares
or
for
ovarian
pathology,
not
on
wild
horses.
Further
the
EA
fails
to
note
the
lack
of
veterinarians
trained
in
this
outdated
procedure
and
the
steep
learning
curve
necessary
to
train
them
to
perform
it.
Again,
the
EA
focuses
on
the
risk
of
evisceration
while
paying
no
attention
to
the
significant
risk
of
hemorrhage
(increased
by
the
plan
to
use
pregnant
mares
see
below)
or
infection.
It
is
clear
that
the
NRC
panel
that
reviewed
this
research
proposal
viewed
these
risks
to
be
significant.
That
panel
concluded
that
the
less
invasive
procedures
of
tubal
ligation
and
hysteroscopically-guided
laser
ablation
would
be
safer
with
less
risk
of
hemorrhage
and
evisceration
and
probably
less
painful.
(Appendix
B)
This
EA
is
grossly
inadequate
in
its
assessment
of
the
impacts
of
ovariectomy
via
colpotomy
on
wild
mares,
particularly
with
regard
to
the
difficulties
of
sedating
and
confining
wild
horses
in
a
chute
and
the
inability
to
provide
wild
mares
with
required
post-operative
care.
E.
Impacts
on
Pregnancy
in
Mares
not
Adequately
Analyzed
Since
ovariectomy
is
an
established,
if
outdated,
procedure,
the
research
question
here
is
the
impact
of
this
procedure
on
pregnant
mares.
According
to
the
EA,
Of
the
100
mares
used
in
this
experiment,
75
will
be
pregnant
in
three
stages
(0-4
months,
4-8
months,
over
8
months)
of
the
335-340
day
gestation
period.
The
EA
states,
There
are
few
peer
reviewed
studies
documenting
the
effects
of
ovariectomy
on
the
success
of
pregnancy
in
the
mare.
(p.
31).
1. ABORTIONS
The
EA
refers
to
the
NRC
review
of
this
research
proposal
that
predicted
ovariectomy
performed
on
mares
in
the
first
120
days
of
pregnancy
will
result
in
abortions,
because
the
mares
ovaries
and
their
production
of
progesterone
are
necessary
to
sustain
pregnancy
in
its
early
phase.
For
those
mares
who
do
not
abort
their
fetuses
due
to
ovariectomy,
the
risk
to
their
unborn
foals
from
the
procedure
is
unknown.
The
EA
states
(p.
32),
For
those
pregnancies
maintained
after
the
procedure,
likely
those
past
120
days,
the
development
of
the
foal
is
not
expected
to
15
be
affected.
However,
because
this
procedure
is
not
commonly
conducted
on
pregnant
mares
the
rate
of
complications
to
the
fetus
has
not
been
quantified.
There
is
a
possibility
that
entry
of
the
abdominal
cavity
could
cause
premature
birth
related
to
inflammation;
however
after
five
months
the
placenta
should
hormonally
support
the
pregnancy
after
removal
of
the
ovaries.
(Emphasis
added.)
As
support
for
this
claim,
the
EA
cites
pers.
comm.
principal
investigator,
which
the
BLM
has
not
included
in
this
EA
or
otherwise
provided
for
public
review.
As
stated
above,
the
BLM
intends
to
use
100
mares
in
this
study,
with
25
less
than
four
months
pregnant,
25
from
4-8
months
pregnant,
25
over
8
months
pregnant
and
25
not
pregnant.
Given
the
EAs
statement
that
the
ovaries
are
necessary
to
sustain
pregnancy
through
120
days,
and
its
later
statement
a
pregnant
mares
placenta
will
produce
the
progesterone
necessary
to
sustain
pregnancy
after
five
months,
it
is
likely
that
more
than
a
third
of
the
pregnant
mares
used
in
this
experiment
will
suffer
from
abortions.
The
EA
fails
to
analyze
this
significant
impact,
including
whether
this
pregnancy
loss
rate
is
medically
or
socially
acceptable.
Instead,
the
EA
states
that
the
NRC
did
not
give
a
recommendation
to
the
BLM
on
what
rate
of
abortion
might
be
acceptable
for
ovariectomies
at
various
stages
of
gestation.
However,
this
is
not
a
question
of
science;
it
is
a
question
of
BLM
policy
and
the
social
values
and
public
input
surrounding
this
issue
must
play
a
significant
role
in
the
agencys
decision.
Although
BLM
has
precluded
public
input
into
this
EA
by
declining
to
conduct
a
scoping
period,
the
agency
must
seriously
consider
the
prevailing
social
preference
that
is
evidenced
by
the
over
20,000
public
comments
the
agency
has
received
on
this
EA.
There
is
an
additional
impact
that
the
EA
did
not
consider,
and
that
is
the
likelihood
that
the
stress
of
the
experiment
including
restraint
in
the
hydraulic
chute,
sedation
and
an
invasive
surgical
procedure
on
mares
in
later
stages
of
pregnancy
will
cause
them
to
abort
their
foals.
As
Dr.
Kelly
writes:
I
have
consulted
with
Dr.
Mary
Scott
(a
Diplomate
with
the
American
College
of
Teriongenologists)
who
also
expressed
experienced
concern
with
the
safety,
efficacy
and
need
of
this
procedure
proposed
in
the
projected
study
and
setting.
She
confirmed
that
ovariectomy
performed
before
50
days
of
gestation
will
cause
pregnancy
loss.
If
Ovariectomy
occurs
between
days
50-70
of
gestation,
many
mares
will
abort.
By
100
+
days
of
gestation,
the
feto-placetal
unit
is
providing
significant
hormonal
support
of
the
pregnancy
and
by
that
stage
the
ovaries
are
not
essential
to
maintain
pregnancy.
Research
mares
ovariectomized
at
140-210
days
of
gestation
did
not
abort.
However,
in
a
wild
mare,
the
stress
of
surgery
(particularly
a
painful
standing
procedure)
and
potential
for
post-op
infection
are
significant
risks
to
the
maintenance
of
the
pregnancy.
Either
or
both
could
precipitate
an
abortion.
Abortion
in
later
stages
of
pregnancy
can
have
its
own
set
of
complications.
The
BLM
has
not
addressed
this
risk
or
considered
how
post-procedure
abortions/retained
placentas
resulting
in
complex
care
complications
from
retained
placenta
(necessitating
16
uterine
lavages
to
remove
retained
placenta
remnants)
or
the
management
of
compromised
foals
born
prematurely
would
be
cared
for.
The
final
EA
must
address
the
risks
to
mares
at
all
stages
of
pregnancy
and
explain
what
steps
will
be
taken
to
aid
mares
who
suffer
abortion-related
complications
and
foals
who
are
born
prematurely
as
a
result
of
the
experiment.
2. INCREASED
RISKS
TO
PREGNANT
MARES
IN
ADDITION
TO
ABORTION
As
Dr.
Kelly
noted
(pers.
Comm)
during
pregnancy,
the
tissues
of
the
reproductive
tract,
including
the
ovaries
and
the
ovarian
pedicle
are
engorged
with
blood
and
hormones,
elevating
the
risk
of
hemorrhage
caused
by
ovariectomy.
In
addition,
25
of
the
mares
will
be
in
the
late
stage
of
pregnancy.
According
to
the
expert
panel:
At
7-8
months
pregnant
it
gets
harder
to
move
the
intestines
to
reach
the
ovaries
so
it
is
ore
difficult
to
keep
the
intestine
out
of
the
ecraseur
tool.
Puncturing
or
cutting
into
the
intestine
with
the
ecrasur
tool
would
be
a
deadly
mistake.
The
EA
fails
to
discuss
this
risk,
or
to
evaluate
an
alternative
that
would
exclude
mares
in
later
stages
of
pregnancy
from
these
ovariectomy
experiments.
3. EXPERT
PANEL
RECOMMENDATIONS
IGNORED
The
expert
panel
discussed
the
need
to
administer
progesterone
to
mares
in
the
early
to
mid-
stages
of
pregnancy
to
ensure
that
the
pregnancy
is
maintained
and
to
avoid
abortion
and
related
complications.
The
BLM
ignored
this
recommendation.
There
is
no
proposal
to
use
progesterone
in
this
experiment,
leaving
one
with
the
conclusion
that
the
loss
of
pregnancy
is,
in
fact,
the
BLMs
desired
outcome.
This
is
totally
unacceptable.
VI.
If
Tubal
Ligation
&
Hysteroscopically
Guided
Laser
Ablation
are
to
be
Tested,
They
Should
Be
Developed
in
Domestic
Mares
First,
if
Test
These
procedures
have
never
been
done
previously
on
horses.
A.
Description
of
Experiments
In
the
tubal
ligation
experiments,
the
BLM
intends
to
use
50
mares
in
the
tubal
ligation
experiment,
with
10
-15
in
each
of
the
following
categories:
pregnancy
of
less
than
four
months;
4-8
months
pregnant;
over
8
months
pregnant;
and
not
pregnant.
The
experiment
involves
the
following:
- mares
are
placed
in
a
chute
and
sedated
and
given
an
anesthetic.
17
-
-
-
-
The
veterinarian
then
inserts
his/her
hand
into
the
vaginal
vault
inserts
a
needle
attached
to
a
tube
is
inserted
through
the
vaginal
wall
into
the
abdomen.
The
tube
pumps
C02
gas
into
the
abdomen
to
inflate
it
and
make
the
structures
easier
to
visualize
with
the
endoscope.
This
process
is
called
insufflation.
Insufflation
can
be
an
uncomfortable
procedure
in
some
individuals,
so
if
a
mare
shows
discomfort,
she
will
be
given
epidural
anesthesia.
After
insufflation,
the
surgeon
manually
makes
a
10-12
mm
incision
in
the
vaginal
wall
and
inserts
an
endoscope.
Using
the
image
from
the
endoscope,
the
surgeon
guides
the
instrument
up
to
the
oviduct
and
using
a
laser,
damages
and
divides
it
to
cause
an
obstruction
and
prevent
pregnancy.
Following
the
procedure
the
mares
would
be
transferred
to
a
pen
with
other
recovering
mares
and
observed
for
a
period
of
2
weeks.
After
2-4
weeks
mares
will
be
re-examined.
Those
confirmed
not
to
be
pregnant
will
be
exposed
to
a
fertile
stallion
for
3-5
months
observed
for
mating
behavior
and
checked
for
pregnancy
rates.
This
procedure
is
commonly
performed
in
women,
but
the
endoscope
is
placed
through
a
small
incision
near
the
navel
as
opposed
to
through
the
vaginal
wall.
In
hysteroscopically
guided
laser
ablation,
the
BLM
will
use
25
or
more
mares
in
the
following
procedure,
which
also
has
never
before
been
performed
on
horses:
- mares
are
pre-treated
with
banamine
and
buscopan
delivered
intravenously
to
minimize
colic.
- Mares
are
placed
in
a
chute
and
sedated
and
anesthetized.
- An
endoscope
is
placed
into
the
vaginal
canal
and
advanced
through
the
cervix
into
the
uterus.
- The
uterus
is
partially
inflated
with
air
to
aid
in
visualization
of
the
structures
- The
oviduct
papilla
(entrance
to
the
oviduct)
is
injected
with
local
anesthetic
- A
laser
placed
through
the
endoscope
is
used
to
seal
the
oviduct
opening
by
creating
inflammation
and
scar
tissue.
- After
surgery
the
uterus
is
infused
with
an
antibiotic
and
saline
- Mares
monitored
for
24
hours
and
observed
fro
2
weeks
post
surgery.
- At
3
weeks
a
portion
of
the
mares
will
be
reexamined
to
determine
the
presence
of
scar
tissue
- At
4
weeks
up
to
50
operated
mares
will
be
exposed
to
fertile
stallions
to
determine
the
pregnancy
rate
and
effect
of
procedure.
- Due
to
invasion
of
the
uterus,
only
non-pregnant
mares
can
be
used.
- Because
this
procedure
has
never
been
performed,
the
extent
to
which
the
scarring
will
prevent
pregnancy
is
unknown.
B.
Risks
18
While
these
procedures
are
expected
to
have
fewer
risks
and
complications
than
surgical
ovariectomy,
the
EA
does
not
adequately
explain
the
BLMs
plan
to
deal
with
the
one
likely
side
effect
from
both
procedures
colic.
The
EA
should
provide
a
treatment
protocol
for
mares
suffering
from
colic
due
to
these
procedures.
C.
Feasibility
in
Field
Setting
The
EA
is
inadequate
in
its
analysis
of
the
feasibility
of
the
proposed
procedures
for
use
on
the
range:
Tubal
ligation
and
hysteroscopically
guided
laser
ablation
have
never
been
performed
in
horses
and
are
not
feasible
for
implementation
in
a
field
setting.
Implementing
these
theoretical
procedures
in
the
field
would
require
the
costly
purchase
of
a
large
number
of
endoscopes,
an
economic
impact
not
considered
in
the
EA.
In
addition,
no
veterinarians
are
currently
trained
in
these
procedures,
and
it
is
not
viable
for
BLM
to
believe
that
it
could
find
and
train
a
sufficient
number
of
veterinarians
to
implement
this
in
the
field
on
a
scale
required
to
impact
population
growth
rates.
In
addition,
hysteroscopically
guided
laser
ablation
is
infeasible
for
wild
mares,
according
to
the
NRC
review,
because
it
cannot
be
performed
on
pregnant
animals
without
causing
abortion.
Given
that
most
mares
captured
by
BLM
are
pregnant
when
they
come
off
the
range,
the
utility
of
the
procedure
would
be
limited
to
young
mares
under
the
age
of
2
and
subfertile
mares
who
would
be
of
lesser
concern
in
terms
of
reproduction.
Therefore
the
expenditure
of
resources
on
this
experiment
is
not
justified.
B. Should
be
Tested
in
Domestic
Mares
First
Because
wild
mares
cannot
be
handled
or
confined,
the
NRC
panel
that
reviewed
these
research
proposals
(EA,
Appendix
B)
suggested:
A
proof-of-concept
study
could
be
carried
out
quicly
with
domestic
mares
before
the
technique
is
introduced
to
the
[wild]
horses
in
Burns
[corrals]....
According
to
the
EA,
the
BLM
does
not
intend
to
evaluate
the
effects
of
the
procedure
with
the
exception
of
whether
the
mares
become
pregnant
or
not.
From
a
scientific
perspective,
it
would
be
necessary
to
evaluate
the
UTJ/uterus
post-laser
and
not
just
assume
that
it
will
be
ok.
Similar
answers
would
be
necessary
for
the
tubal
ligation
procedure
since
this
approach
has
not
been
reported
in
the
literature.
As
the
NRC
suggested,
the
endoscopic
procedure
and
the
tubal
ligation
procedure
should
be
performed
on
domestic
mares
first
in
order
to
evaluate
whether
or
not
there
are
any
adverse
effects
post-procedure.
There
opportunity
for
such
re-
evaluation
in
wild
mares
will
be
non-existent.
19
The
EA
does
not
include
an
honest
analysis
of
alternatives
to
invasive,
risky
and
painful
sterilization
procedures
for
wild
free-roaming
mares
as
recommended
by
the
NAS/NRC.
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.
p.
152
A.
PZP
Of
the
three
methods
recommended
by
the
NAS,
only
one
PZP
is
available
today
without
further
research.
Yet
the
BLM
has
never
adequately
utilized
the
PZP
vaccine
in
its
native,
dartable
form
or
in
the
pelleted,
injectable
PZP-22
form.
The
EAs
statement
regarding
the
PZP
vaccine
--
The
use
of
PZP
for
fertility
control
is
well
documented;
however
longer
lasting
formulations
have
not
proven
effective
at
population
growth
suppression
on
a
majority
of
HMAs.
is
misleading
on
many
fronts:
The
PZP-22
vaccine
has
never
been
utilized
in
the
majority
of
HMAs.
In
most
of
the
HMAs
where
BLM
has
utilized
the
PZP-22
vaccine,
it
has
done
so
in
a
token
fashion
by
not
vaccinating
enough
mares
to
impact
population
growth
rates.
In
the
limited
number
of
HMAs
where
PZP-22
has
been
utilized
more
widely,
BLM
wild
horse
specialists
report
success
in
slowing
population
growth
rates.
A
number
of
HMAs
(Pryor
Mountain
Range,
Little
Book
Cliffs,
McCullough
Peaks,
Spring
Creek
Basin)
are
successfully
managed
through
PZP
delivered
remotely
via
darting
in
programs
that
have
greatly
reduced
or
eliminated
the
need
for
removals.
The
use
of
PZP
is
well-established
as
an
effective
and
economical
method
for
wild
horse
management.
(See
Attachments
14,
15).
Yet
BLM
has
consistently
under-utilized
this
available
and
humane
tool:
2011:
BLM
promises
to
vaccinate
2,000
mares
per
year
as
part
of
its
accelerated
reform
program.
(Attachment
16)
2012:
BLM
vaccinates
1,051
mares
2013:
BLM
vaccinates
509
mares
2014:
BLM
vaccinates
384
mares
2015:
BLM
vaccinates
466
mares
2012-2015:
BLM
removes
17,577
horses
and
burros
from
the
range.
[Sources:
http://www.blm.gov/wo/st/en/prog/whbprogram/history_and_facts/quick_facts.html;
http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/
advisory_board_10_2011.Par.63582.File.dat/On
Range
Update
Presentation
9
2015.pdf;
http://www.blm.gov/wo/st/en/prog/whbprogram/herd_management/Data.html;
http://www.blm.gov/style/medialib/blm/wo/Planning_and_Renewable_Resources/wild_horses_and_burros/s
tatistics_and_maps/holding__adoption.Par.69288.File.dat/Facility
Report
FY-2015.pdf]
20
It
is
clear
from
the
above,
that
BLM
has
never
made
a
serious
attempt
to
utilize
this
available
tool
to
humanely
manage
wild
horse
populations.
Its
also
clear
that
the
BLM
is
intent
on
sterilizing
wild
horses
and
burros
on
the
range,
regardless
of
the
NAS/NRC
recommendations
to
the
contrary.
Native
PZP
and
PZP-22
are
both
effective
for
one
year
and
have
residual
efficacy
in
Year
2.
If
the
BLM
had
been
vaccinating
herds
every
2-3
years
(via
remote
darting,
or
where
that
is
not
possible
via
bait
trapping
or
even
improved
helicopter
drives)
the
agency
would
have
by
now
significantly
reduced
population
growth
on
the
range.
In
fact,
according
to
an
economic
model
created
by
the
Humane
Society
of
the
U.S.,
the
BLM
could
achieve
its
population
goals
within
12
years
AND
SAVE
TAXPAYERs
$200
million
by
utilizing
PZP
and
reducing
and
eventually
eliminating
removals.
(Attachment
17).
B.
GonaCon
The
NAS
report
recommended
more
research
into
whether
or
not
GonaCon,
another
immunocontraceptive
vaccine,
could
be
an
acceptable
tool
for
wild
horse
management.
While
AWHPC
has
grave
reservations
about
GonaCon,
we
note
that
the
BLM
has
begun
to
use
this
vaccine
in
a
pilot
program
without
a
research
study
protocol,
plan
for
follow
up
evaluation
of
the
mares
vaccinated
with
GonaCon,
and
in
the
total
absence
of
affiliation
with
an
academic
institution
that
could
collect
and
evaluate
data
and
quantify
the
effects
of
GonaCon
on
wild
mares
and
its
success
as
a
fertility
control
tool.
(Attachment
18)
C.
Chemical
Vasectomy
The
BLM
has
ignored
the
NAS
recommendation
to
conduct
research
into
the
feasibility
of
this
method,
which
would
preserve
natural
behaviors.
Instead
the
agency
is
galloping
with
research
on
the
behavioral
effects
of
castrating
(gelding)
by
castrating
70%
of
the
stallions
in
Utahs
Conger
HMA.
The
fact
that
the
BLM
is
proceeding
with
expensive
research
into
invasive
and
risky
permanent
sterilization
methods
that
will
destroy
the
wild
free-roaming
behaviors
of
wild
horses
instead
of
following
the
recommendations
of
the
NAS/NRC
directly
contradicts
the
BLMs
2011
commitment
that
NAS/NRC
findings
would
determine
how
the
BLM
should
proceed
in
light
of
the
latest
scientific
research.
The
EA/EIS
must
accurately
analyze
the
availability
of
alternatives
to
the
proposed
spaying/sterilization
methods
and
must
accurately
analyze
the
lack
of
feasibility
of
implementing
these
risky
and
invasive
measures
in
a
field
setting.
21
BLM
Oregon
did
not
provide
a
scoping
period
for
this
EA
process,
thereby
avoiding
the
flood
of
comments
opposing
these
experiments.
Doing
so
enabled
the
BLM
to
falsely
portray
in
its
EA
that
the
public
was
divided
on
the
topic
of
invasively
spaying
wild
mares.
The
lack
of
scoping
period
also
prevented
the
public
from
having
input
into
the
impacts
and
alternatives
analyzed
in
this
EA.
One
clear
social
impact
not
analyzed
is
the
importance
of
maintaining
natural
wild
horse
behaviors,
as
discussed
above
and
as
affirmed
by
the
NRC,
which
are
valued
by
the
public,
including
those
recreational
users
of
our
public
lands
who
engage
in
wild
horse
watching.
Another
social
value
not
analyzed
is
the
publics
tolerance
for
procedures
that
subject
mares
to
risky,
life-threatening
procedures
that
will
cause
pregnant
mares
to
abort
their
unborn
foals.
These
social
values
as
expressed
by
the
thousands
of
citizens
who
have
submitted
public
comments
on
BLM
EAs
in
Oregon
and
elsewhere
over
the
past
decade
and
by
the
nearly
21,000
citizens
who
have
submitted
comments
on
this
EA
-
should
have
been
addressed
in
this
EA.
The
economic
impacts
are
not
addressed
in
this
study,
including
the
feasibility
of
purchasing
expensive
equipment
and
training
large
numbers
of
veterinarians
to
be
competent
in
these
procedures,
including
those
that
have
never
been
done
before
in
horses.
In
conclusion,
the
EAs
social
and
economic
impacts
section
is
inadequate
because:
- It
minimizes
public
opposition
to
invasive
and
permanent
sterilization
procedures.
- Mischaracterizes
concerns
of
opponents
to
sterilization.
- Falsely
states
that
PZP
has
not
been
effective
across
most
HMAs.
- Lack
of
scoping
period
prevented
the
public
from
providing
evidence
regarding
the
success
of
PZP
in
multiple
HMAs
as
well
as
documenting
public
opposition
to
these
invasive
and
dangerous
procedures.
- Conclusions
regarding
the
publics
wishes
for
wild
horse
herds
based
not
on
scoping
comments,
or
on
public
comments
submitted
to
the
BLM
but
rather
on
Burns
BLM
staff
personal
communications
with
horse
enthusiasts
who
visit
local
herds.
(p.
42)
- Definition
of
inhumane
is
inadequate:
The
notion
that
surgically
sterilizing
wild
mares
is
inhumane
can
be
broken
into
two
parts:
1)
the
idea
of
permanently
removing
a
mares
ability
to
reproduce;
and
2)
the
effect
of
the
surgery
on
the
mares
behavior
and
social
status
once
returned
to
the
range.
This
definition
omits
important
considerations
regarding
inhumane
treatment:
the
pain
that
the
mare
will
suffer
as
a
result
of
the
surgical
procedures
and
the
risks
of
the
invasive
procedures
to
the
health
of
the
mare
and
her
unborn
foal.
Had
the
BLM
conducted
a
scoping
period
for
this
EA,
the
publics
concerns
about
inhumane
treatment
would
have
been
clear.
22
IX.
Experiment
or
Training?
Experiments
Use
Far
More
Horses
than
Required
for
Valid
Results
The
BLM
proposes
to
use
225
wild
mares
in
these
experiments
is
excessive.
Veterinary
experts
consulted
by
AWHPC
confirm
that
the
study
objectives
could
be
achieved
in
a
scientifically
valid
manner
with
far
fewer
horses.
The
proposed
use
of
such
a
large
number
of
mares
raises
questions
about
whether
this
Proposed
Action
is
actually
a
research
study
or
actually
a
training
exercise
for
veterinarians.
The
latter
would
indicate
the
BLMs
intent
to
implement
sterilization
procedures
on
the
range
regardless
of
the
outcome
of
these
research
studies.
The
EA
does
not
provide
a
valid
justification
for
the
use
of
an
excessive
number
of
horses.
An
EA
is
not
sufficient
for
these
Proposed
Actions.
An
Environmental
Impact
Statement
(EIS)
is
necessary
for
these
first-of-their-
kind,
research
action
that
involves
highly
uncertain
and
unknown
risks
and
may
establish
a
precedent
for
future
actions
and
threatens
a
violation
of
federal
law
including
the
Wild
Free-Roaming
Horses
and
Burro
Act,
which
was
established
to
protect
and
manage
wild
free-roaming
horses
as
an
integral
part
of
the
natural
system
of
the
public
lands.
The
National
Environmental
Policy
Act
(NEPA)
requires
agencies
to
prepare
an
EIS
regarding
all
major
Federal
actions
significantly
affecting
the
environment,
42
U.S.C.
4332(C),
and
the
CEQ
implementing
regulations
set
forth
a
number
of
criteria
governing
when
an
action
is
to
be
considered
significant
for
this
purpose.
40
C.F.R.
1508.27.
Here,
there
can
be
no
legitimate
doubt
that,
at
the
very
least,
there
is
certainly
a
substantial
question
regarding
many
of
the
CEQ
significance
factors.
Accordingly,
the
BLM
was
required
to
prepare
an
EIS
on
the
extreme
research
action
proposed.
First,
the
BLMs
research
action
to
spay
225
federally-protected
wild
mares
held
at
the
BLM
Oregon
Wild
Horse
Corrals
may
cause
loss
or
destruction
of
significant
scientific,
cultural,
or
historical
resources,
40
C.F.R.
1508.27(b)
i.e.,
the
very
wild
and
free-roaming
horses
that
Congress
has
declared
are
living
symbols
of
the
historic
and
pioneer
spirit
of
the
West,
that
are
to
be
considered
an
integral
part
of
the
natural
system
of
the
public
lands.
This
is
particularly
true
since
this
research
will
lay
the
groundwork
for
widespread
implementation
of
spaying
as
a
management
tool
for
wild
herds.
Second,
the
BLM
has
over
the
past
few
years
received
tens
of
thousands
of
comments
from
the
public
detailing
opposition
to
the
spaying
of
mares
and
permanent
sterilization
of
wild
horses
who
live
on
the
range,
including
over
20,000
comments
on
this
EA.
These
comments
were
also
received
in
response
to
other
BLM
request
for
public
comments
including
those
received
in
response
to
Secretary
of
the
Interiors
Strategy
for
the
Future
of
the
Wild
Horse
and
Burro
Program
(June
2010
and
March
2011).
23
In
light
of
the
publics
opposition
to
this
research
proposal
and
particularly
the
NAS
recommendation
against
spaying
mares
on
the
range
and
concerns
about
the
dire
environmental
impacts
it
will
have
on
the
individual
horses
and
the
herds
as
a
whole,
it
is
clear
that
the
environmental
effects
of
the
BLMs
action
are
also
highly
controversial.
40
C.F.R.
1508.27(b).
Controversy
under
this
factor
also
includes
substantial
questions
are
raised
as
to
whether
a
project
.
.
.
may
cause
significant
degradation
of
the
environment.
Anderson,
314
F.3d
at
1018.
Here,
such
substantial
questions
are
raised
below
regarding
the
impacts
of
the
release
of
hundreds
of
geldings
on
the
environment
as
well
as
on
the
individual
horses
and
the
wild
horse
herds
in
general.
The
scientific
controversy
is
demonstrated
by
the
opinions
of
equine
veterinarians,
including
reproductive
specialists,
who
raise
questions
about
the
risks
of
the
proposed
procedures
and
their
behavioral
impacts
and
related
implications
for
the
social
integrity
of
wild
herds.
Third,
for
similar
reasons,
the
BLMs
proposed
action
also
involves
possible
effects
that
are
highly
uncertain
or
involve
unique
or
unknown
risks.
40
C.F.R.
1508.27(b).
Based
on
available
research
that
outlines
the
behavioral
changes
in
domestic
mares
after
spaying
and
the
NAS
recommendations
against
spaying
mares
on
the
range
due
to
the
inherent
dangers
involved,
it
is
clear
that
this
proposed
action
involves
unique
risks
and
BLM
has
no
idea
what
the
impacts
of
performing
ovariectomies
on
mares
the
majority
of
whom
will
be
pregnant
in
a
holding
corral
without
post-operative
care
will
be,
nor
does
the
agency
have
any
idea
of
the
implications
of
spaying
mares
on
the
the
individual,
band
and
herd
social
behaviors
and
structures.
This
is
precisely
the
kind
of
uncertainty
about
environmental
impacts
that
require
preparation
of
an
EIS.
See
Fund
for
Animals
v.
Norton,
281
F.
Supp.
2d
at
234
(uncertainty
as
to
the
impact
of
a
proposed
action
on
a
local
population
of
a
species,
even
where
all
parties
acknowledge
that
the
action
will
have
little
or
no
effect
on
broader
populations,
is
a
basis
for
finding
that
there
will
be
a
significant
impact
and
setting
aside
as
FONSI),
quoting
Anderson,
314
F.3d
at
1018-2.
Fourth,
the
Proposed
Action
may
establish
a
precedent
for
future
actions
with
significant
effects
since
this
is
being
conducted
as
a
population
management
research
study,
as
stated
in
the
scoping
notice.
Finally,
because
the
BLMs
action
here
is
completely
at
odds
with
its
obligations
under
the
WFRHBA
to
protect
these
wild
horses,
to
preserve
them
as
an
integral
part
of
the
natural
system
of
the
public
lands,
to
manage
them
in
a
manner
that
is
designed
to
achieve
and
maintain
a
thriving
natural
ecological
balance
on
the
public
lands,
and
to
employ
management
activities
at
the
minimal
feasible
level,
16
U.S.C.
1533,
it
also
necessarily
threatens
a
violation
of
federal
law
yet
another
of
the
significance
criteria.
40
C.F.R.
1508.27(b).
Therefore,
because
at
least
five
of
the
significance
factors
are
present
here,
and
particularly
because
the
proposed
action
represents
a
radical
departure
from
the
way
the
BLM
has
dealt
24
with
these
issues
in
the
past,
it
is
clear
that
the
agency
is
required
to
prepare
an
EIS
before
implementing
this
research
action.
According
to
the
federal
Office
of
Research
Integrity,
An
institutional
animal
care
and
use
committee
(IACUC)
is
required
by
federal
regulations
for
most
institutions
that
use
animals
in
research,
teaching
and
testing.
(https://ori.hhs.gov/education/products/ncstate/iacuc.htm)
The
IACUC
must
approve
protocols
utilizing
animals
to
ensure
that
the
animals
selected
for
a
procedure
should
be
of
an
appropriate
species
and
quality
and
the
minimum
number
required
to
obtain
valid
research
results.
The
IACUC
must
also
ensure
the
proper
use
of
animals,
including
the
avoidance
or
minimization
of
discomfort,
distress
and
pain
when
consistent
with
sound
scientific
practices.
(http://grants.nih.gov/grants/olaw/references/phspol.htm#USGovPrinciples)
The
IACUC
can
make
changes
to
animal
research
protocols
to
minimize
pain
and
distress
to
animals
as
well
as
to
require
the
utilization
of
fewer
animals
than
proposed
by
the
investigator.
The
BLM
has
not
received
approval
from
the
Oregon
State
University
(OSU)
IACUC
for
these
experiments.
(Attachment
19)
Given
that
the
agency
proposes
to
use
wild
mares
in
procedures
that
are
widely
acknowledged
in
the
veterinary
community
to
be
painful,
and
given
that
the
agency
proposes
to
use
large
numbers
of
horses
(225)
in
experiments
that
require
far
fewer
horses
(see
above),
there
is
a
likelihood
that
the
IACUC
could
impose
changes
to
the
experimental
procedures,
as
described
in
the
EA.
Therefore,
until
the
BLM
receives
IACUC
approval
for
these
experiments,
it
cannot
accurately
describe
the
proposed
actions
or
analyze
their
impacts.
Therefore
the
EA/EIS
cannot
be
considered
complete
until
the
IACUC
approval
is
received,
made
public
and
incorporated
into
the
EAs
description
of
the
Proposed
Action
and
analysis
of
its
impact.
XII.
Conclusion:
The
EA
is
Inadequate
-
Does
Not
Support
the
Conduct
of
the
Proposed
Experiments
In
its
EA,
the
BLM
says
that
it
will
decide
whether
or
not
to
pursue
the
proposed
experimental
sterilization
procedures
on
wild
mares
at
the
Burns
Corrals.
The
evidence
clearly
indicates
that
the
BLM
should
NOT
proceed
with
these
procedures
for
the
following
reasons:
1.
Ovariectomy
via
Colpotomy
- Well-established
and
significant
risks
of
hemorrhage
and
evisceration.
- Inability
to
provide
required
post-operative
care
including
stall
confinement,
restrictions
in
lying
down
and
pain
relief
to
wild
mares.
25
-
-
-
-
-
2.
Tubal
Ligation
&
Hysteroscopically
Guided
Laser
Ablation
- Fewer
health
risks
and
impacts
on
natural
behaviors
but
not
feasible
in
a
field
setting.
- Cost
of
equipment
including
purchase
of
numerous
expensive
endoscopes
for
use
in
the
field.
- Lack
of
trained
veterinarians
since
procedure
has
never
been
done
on
horses.
- Inability
to
perform
Hysteroscopically
Guided
Laser
Ablation
on
pregnant
mares,
eliminates
this
as
procedure
for
most
mares
captured
by
the
BLM.
For
all
the
reasons
stated
above,
AWHPC
finds
this
EA
to
be
entirely
inadequate
and
believes
that
the
BLM
must
drop
plans
to
proceed
with
experiments
on
costly,
dangerous,
invasive,
inhumane
and
impractical
sterilization
methods.
Thank
you
for
your
consideration.
Sincerely,
Suzanne
Roy,
Executive
Director
919-697-9389
sroy@wildhorsepreservation.org
Attachment
1:
BLM
Press
Release
2/24/11
Attachment
2:
BLM
Statement
of
Task
for
NAS/NRC
Review
Attachment
3:
Using
Science
to
Improve
the
BLM
Wild
Horse
and
Burro
Program:
A
Way
Forward,
NAS/NRC,
June
2013
Attachment
4:
Comments
of
Robin
Kelly,
DVM
on
BLM
Mare
Sterilization
Research
EA.
Attachment
5:
Statement
of
Allen
Rutberg,
Ph.D.
regarding
impacts
of
spaying
wild
mares
and
gelding
wild
stallions.
Attachment
6:
BLM
September
2015
Expert
Panel
on
Spaying
Mares
Attachment
7:
Can
Ovariectomy
be
justified
on
grounds
of
behavior?
Equine
Veterinary
Education,
(2016)
28
(1)
58-59.
Attachment
8:
The
Spayed
Mare,
Horsekeeping.com
Attachment
9:
Statement
of
Pamela
Corey,
DVM
26
Attachment
10:
ACVS
Standing
Equine
Laparoscopic
Ovariectomy
Attachment
11:
University
of
Minnesota,
The
Equine
Spay
Attachment
12:
Dr.
Michael
Ball,
TheHorse.com
Attachment
13:
Achieving
Population
Goals
in
a
Long-Lived
Wildlife
Species
(Equus
caballus)
With
Contraception,
Kirkpatrick/Turner,
2008
Attachment
14:
Economic
Benefit
of
Fertility
Control
in
Wild
Horse
Populations,
Barthalow.
Attachment
15:
An
Economic
Model
Demonstrating
the
Long-term
Cost
Benefits
of
Incorporating
Fertility
Control
into
Wild
Horse
Management
J.
of
Zoo
and
Wildlife
Medicine,
2013.
Attachment
16:
AWHPC
Letter
to
BLM
re:
Gona
Con
Pilot
Program,
2015
Attachment
17:
Email
from
Lisa
Grant,
BLM
re:
OSU
IACUC
Approval
of
BLM
Mare
Sterilization
Experiments
27