Comment deadline extended until February 10. Our comments can be seen here.
Nothing in the current wild horse and burro program is creating more controversy in this moment than the surgical “spay” experiments announced in the Draft EA out for comment. Comments are due today. Documents can be found here: https://eplanning.blm.gov/epl-front-office/eplanning/projectSummary.do?methodName=renderDefaultProjectSummary&projectId=56292
Comments can be emailed or sent “snail mail” if postmarked today (extended Feb. 10). Comments should be sent to: firstname.lastname@example.org
WHE is completing our comments and will submit them this afternoon through process. We understand that the NEPA (paperwork process) is a bit confusing for the public. We created a page that explains the process here: http://wildhorseeducation.org/nepa/
If a substantive comment is made to the process by one, or ten thousand, it has the same effect to process. We have spent considerable time discussing this proposed project EA with a number of supporters. We have received dozens of emails from people that are rightly infuriated by this EA. They ask for advice on how to comment and have sent us copies of their letters. People are concerned not only by the experimentation, but the presentation of an almost arrogant disregard for true scientific process and statement of fact in the draft document.
Our overriding comment to this EA is that the process is flawed and incomplete. The project scope requires an EIS, not an EA. That is the comment to the paperwork. The comment to the “thinking?” Is that there really is none. Tool creation is important. But the tool must be appropriate for the job and then used. BLM fails to utilize appropriate tools (that they have had for decades) and then moves to create a sledgehammer when they need only a screwdriver. You can read WHE’s comments here Comments_DOI-BLM-OR-B000-2015-0055-EA
Once again BLM shows an addiction to the “management” concepts being pushed forward by a segment of the ranching community. Not only “on the range” but in all aspects of management in the wild horse and burro program you find the fingers of public land ranchers.
Bonnie Kohleriter spent a large part of her life teaching science. We are publishing the following comment letter written by Bonnie for two reasons; she shows logic and needs a place to be heard.
COMMENTS ON MARE STERILIZATION RESEARCH ENVIRONMENTAL ASSESSMENT
RE: ENVIRONMENTAL ASSESSMENT: DOI-BLM-OR-B000-2015-0055 EA
DATE: FEBRUARY 2, 2016
THIS EA IS INADEQUATE AND CONCERNING BECAUSE OF THE FOLLOWING:
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 NRC’s discussion… compared to what? “transabdominal” surgeries, and (is)”not without risk.” The EA minimalizes 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 Service, 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, certainly not democratic.
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. We’re told attempts in the corrals may be made to impregnate the mares for more mares to study only to have mares abort or 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 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 to be done 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:
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: ovariectomies was ‘He asked a racing horse friend, a vet, if ovariectomies were safe, Boyd Spratlng, a cattle veterinarian, whose experience re: ovariectomies 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 they 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 numbers 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 want not to sterilize in order to have genetic contribution and 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 to have population stabilization with healthy reproducing horses diversified and viable as a herd, and to be 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 HMA not candidates given low diversity and endangered viability.
You have done a lot of work on this EA, but I find 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. All these factors are reasons these experiments should be delayed and should not go forward at this time until these matters and concerns have been addressed.
An Environmental Impact Statement rather than an Environmental Assessment seems more appropriate to be done.
February 1, 2016
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Categories: Wild Horse Education