Wild Mare Sterilization – Burns, Oregon

January 15, 2016
Bureau of Land Management-USDI
Burns District Office
28910 Highway 20 West
Hines, OR 97735

email: blm_or_bu_mareresearchea@blm.gov

Re: EA-DOI-BLM-OR-13000-2015-0055-EA Surgical Sterilization of Wild Mares, comments due 2/3/2016

Link to EA:https://eplanning.blm.gov/epl-front-office/eplanning/projectSummary.do?methodName=renderDefaultProjectSummary&projectId=56292

Dear Public Official/Servants:

Thank you for sending your letter and a hard copy of the above named Environmental Assessment, which I have thoroughly read. As a wildlife ecologist concerned with the wild horses and their future well-being in the wild, I am very disturbed by your proposal to conduct sterilizations on ca. 225 captured wild mares. I consider these experiments to be both unjustified and contrary to the core intent of the Wild Free-Roaming Horses and Burros Act (WFHBA). I strongly urge you to adopt the No Action alternative and to consider the following important points in your deliberations (page #s provided):

Comments on Cover Letter:

p. 2: Although you state that these sterilizations will “provide long-term beneficial effects such as maintaining or improving overall body condition, since the physical burden of pregnancy and raising a foal would not occur,” you fail to adequately consider the vigor, vitality, and long-term well-being of the wild horses population in the wild, natural world. This is contrary to the pure core intent of the WFHBA that plainly states: “… wild horses and burros … contribute to the diversity of life forms within the nation … and shall be protected from capture, branding, harassment or death, and are to be considered in the area where presently found [signifying year-round habitat by any reasonable interpretation] as an integral part of the natural system of public lands.” Your proposed sterilization project also ignores the true meaning of the WFHBA’s mandate in Section 3 (a): “… to achieve and maintain a thriving natural ecological balance on the public lands.” Sterilization of wild mares is very unnatural and will upset the balance between and among species of plants and animals which the returned North American native horses should be allowed to establish through their natural integration therewith. Sterilization also ignores this same Section 3 (a)’s instruction to manage wild horses and burros “at the minimum feasible level.” Your proposal clearly violates the intent of the WFHBA by suggestion people experiment on the most intimate parts of the wild horses with a mind to creating unnaturally altered wild horses who would may in the future be set back to their herd areas. Here they would be thwarted in filling their ecological niche within these same areas. This would be a form of domestication of this “natural heritage” protected species and should be considered illegal.

p. 3: The assignment of the “overpopulation” qualifier upon the wild horse populations of Oregon is not objective, but based upon an arbitrary judgement that is convenient to the wild horse enemies’ view of them. Their view is that the mustangs are of little value and their well being on the public lands of little concern and consequence … and, so, they are to be dispensed with wherever necessary, either totally eliminated from their legal herds areas (BLM) or territories (USFS), i.e. “zeroed out,” or reduced to low crippled-population numbers with compromised reproductive systems. The latter herds basically become mere token herds lacking in that true wild vigor and exuberance that is so essential for their long-term survival and ecological adaptation. Ecological adaptation would permit them to “fill their niche” and “play their role” in nature. And, as I have learned in my studies of them, this niche – this role – is a great one! But mentalities that are controlled by vested interests seem to have become totally blind to the greatness of the wild horses living freely and naturally in the ancient land of their ancestors, presences dating back many millions of years.

When I think of their evolution and the universal justice that is embodied in their restoration to North America, I am inspired. A vision that rings true and uplifts me takes shape within my consciousness! But when I merely contemplate ever more intensive and pervasive operations for livestock, fracking and gas and oils wells and pipelines, open pit and other types of mining as well as Off-Road Vehicles’ ruining public land – more roads, fences, etc., I am horrified – very let down and depressed! For I see that this is all leading to a very tragic end for all concerned – including and perhaps especially our human kind.

If there’s one message I’d like you to understand, it is that the wild horses living in their natural habitat (in this case the Oregon mountains, valleys, and high deserts) should not be overly restricted by fences or deprived of adequate resources for their survival as viable populations. They should be free to resume their age-old lifestyle and relation to the other species. This would be a restorative, quality-of-life phenomenon, supremely important for the horses and many other species, including humankind. For in honoring, rather than subverting, the noble commitment of the WFHBA, humanity would pull itself out of a rut that has grown so deep today that It threatens to engulf the whole of life on Earth! For we would be successfully learning how to truly respect another fellow highly evolved presence upon the Earth! This we would do by sharing this home Earth and its natural freedom, justly and thoughtfully with the horse. Horses thrive in natural freedom and become inspirations to all of us in so doing. This freedom is not the freedom to crassly control and manipulate, alter and destroy our fellow, co-dependent creatures. It is a freedom that recognizes the true worth of each and every kind, of each and every conscious one, and uplifts our relationships to the highest plane. This is True Freedom and a gateway to a more fulfilled and glorious life for All!

p. 3 of cover letter: Under Social and Economic Value, you take an overly constricted view of the alternatives, or possibilities, that are open to you in both protecting and managing the wild horses. Your definition of Thriving Natural Ecological Balance, for example, seems to automatically exclude the possibility that the wild horse could ever achieve their own part, or role, in this. As a wildlife ecologist who has studied the horses in nature, I consider this to be extremely unjust and unfair!

Why are you ignoring Reserve Design as a pre-eminent course of action that could be adopted for the wild horses? It would allow for long-term viable, ecologically adapted, and naturally self-stabilizing populations of wild horses, but would mean biting the bullet and actually providing adequate natural resources to accommodate a much higher, truly viable mustang population. It involves the design of a bounded reserve that provides the space, water, forage, shelter, mineral sources, seasonal migratory amplitude, both vertically and horizontally, etc., within which the wild horses could fill their ecological niche. This they should do as mature social units that are not frequently broken up by violent roundups. Reserve Design would permit the wild horses to level their population numbers in equilibrium with available resources and within a more-or-less bounded area. Reserve Design is the benign way to proceed and honors the true meaning and intent of the WFHBA. Please consider my peer-reviewed article that explains Reserve Design in considerable detail and my book that does the same. Sterilization is a grave transgression against these wonderful animals. We two-leggeds can do much better than this! Here are the links: Article: The horse and burro as positively contributing returned natives in North America: http://www.sciencepublishinggroup.com/j/ajls doi 10.11648/j.ajls.20140201.12. And my book The Wild Horse Conspiracy: www.amazon.com/dp/1461068983. Pay particular attention to Chapter IV & look up Reserve Design in the thorough Index for all discussions of it throughout the book.

p. 3, point 4: Regarding opposition to sterilization not being supported by peer-reviewed science, I suspect there has been much filtering of what the preparers reviewed so as to support their agenda. You should consult Veterinarian Bruce Nock about peer-reviewed publications that indicate the adverse effects of sterilization upon the horses.

p. 4, point 9: Regarding endangered species, subspecies, and populations, all are covered by the Endangered Species Act. Oregon’s wild horse populations themselves should be classified as endangered, as they have been over managed and reduced to sub-viable levels and represent unique and valuable horse lineages that have adapted over the generations to the various ecosystems where their small remnant herds survive.
point 10: Your “overpopulation” determination is arbitrary and not true overpopulation. Objectively, these wild horses are very underpopulated and at risk.

p. 5. The U.S. Fish & Wildlife Service has recently decided to eliminate its , e.g. the recent removal of the historic herd in Sheldon NWR and in spite of scientific studies that showed these wild horses were a positive element in their refuge, complemental to the pronghorn antelope (Meeker).
Bottom Paragraph: On the contrary, an environmental impact statement is certainly warranted for this project. To conduct sterilization experiments on ca. 225 wild mares including ovariectomies involves considerable pain and a significant probability of death and sets a dangerous precedence. This sort of experimentation on wild horses and burros should be considered as illegal under the WFHBA, which clearly states that “wild free-roaming horses and burros shall be protected from capture, branding, harassment, or death.” (End of Comments on Cover Letter)
Comments on Mare Sterilization Research Environmental Assessment, dated January 5, 2016

p. 1. BLM is here ignoring the sound alternative: Reserve Design for long-term viable and naturally self-stabilizing populations.

p. 3. Employing invasive drugs and surgery to interfere with the natural reproduction of the wild horses is contrary to the core intent of the WFHBA. Removal of a mares’ ovaries will have a terrible effect on the individual wild horses in the wild, their social relations, and their natural adaptations for survival, both in present and future generations.
The assertion that there are only two ways to achieve population stabilization: contraception or starvation, is egregiously wrong! Horses, as well as burros, are “climax species” in nature, capable of limiting their own population numbers. But we people have to give them the chance. The beauty of Reserve Design is that wild horses can and do self-stabilize as they fill their ecological niche in any given habitat. This they do as mature social groups, called bands (generally a sort of harem among horses) where mature lead stallions and mares inhibit and suppress reproduction in younger members of a band (Reference: ISPMB, publications, Lantry, SD). This also occurs physiologically as resources become more limiting and there occurs a natural reduction of reproduction. Forage and other resources govern this. Think about it this way: the horse and also the burro are ancient presences on Earth, dating back millions of years. If they were so wildly over-reproducing and unchecked as you suppose, they simply would not have survived, for they would have destroyed their habitat and become extinct long ago. Yes! There is a struggle for survival, but this is tempered by an ancient wisdom that is in balance with the whole life community. Your assertion that only contraception or starvation apply (and probably you meant to include here too killing as by predators) is a tendentious one that suits your agenda but overlooks the very important and proven, innate capabilities of horses to limit their own population numbers. Horses can and do balance themselves with available resources, including food, water, minerals, and shelter, because their consideration is not just for short-term but also for long-term survival. There is a great wisdom in these magnificent and ancient presences on planet Earth, and it is simply not right to ignore their ecological merits and multi-million year evolution.

p. 7: Please pay close attention to the 2013 National Research Council’s (NRC) admission that surgery on the wild horses carries serious risks and that all fertility control measures affect wild horse/burro physiology and behavior. This calls into question your assertion that wild horse sterilization will “improve the health of the wild horse and burro herds.” (See bottom p. 7 of the E.A.)

p. 8: 1. Issues. The Reserve Design option to invasive sterilization is ignored here. I have presented this repeatedly to BLM, but have yet to receive any indication that its valid points were even registered!

2. Issues Eliminated: Regarding the side effects of procedures and the social and behavioral effects on the wild horses returned to the range, your dismissal of these as “outside the scope of this E.A.” is erroneous. These effects on the wild horses in the wild should be carefully examined. Why should you subject the individual mares to such ordeals involving pain and even death if there is compelling evidence that their alteration will adversely affects them in the wild?

p. 9. Top: Again, you ignore Reserve Design as a sound alternative to invasive fertility control. The Wyoming proposal to study sterilized, including ovariectomized wild mares released back into the wild (BLM Rock Springs Field Office) is like gloating over mayhem caused to the horses rather than preventing it in the first place! This would be a sure prescription for decline and die out, as the horses are artificially imposed upon in order to accommodate the BLM-favored public lands users including ranchers, mineral and energy extractors, ORVers, hunters, etc. We should let nature show us what is the proper population level for the wild horses in any given area, not rashly impose our selfish and thoughtless will!
d. Scientific studies reveal the harmful effects of PZP on the individual well-being and long-term survivability of the wild horses (See studies by Ransom, Nunez, and others). PZPed mares are overly stressed and cause stress in stallions – and this disrupts both band and herd cohesion, the essential education of young horses by older horses, ecological adaptation to the unique habitat the horses inhabit, and very survival.

p. 10. Top: Yes, I agree, PZP implementation is unfeasible. Reserve Design is the way to go! But why are you ignoring Reserve Design?! It implements the true core intent of the WFHBA.

II. Description of Proposed Action and Alternatives:
As a wildlife ecologist who knows and cares about wild horses, I strongly urge you to adopt Alternative A: No Action. I implore you not to proceed with the proposed, cruel and unnecessary sterilization experiments on captured wild mares described in this E.A. Rather, work to restore more resources for larger wild horse populations. This would honor the true intent of the WFHBA & the will of the People.

p. 10. B. Alt. B. Proposed Action. 1. The proposal: Ovariectomy via colpotomy should be entirely cancelled! This is extremely cruel and would result in untold suffering and death to the victimized mares.

P. 11. 2 & 3: Though less cruel than ovariectomy, these other two methods of sterilization would still cause serious pain and suffering in the mares and would produce unnatural consequences for them when released back into the wild. I do not approve of any of these invasive sterilization procedures.

C.: Again, who defines overpopulation and by what standards? So often this is done arbitrarily in order to accommodate the continuing monopolization of the public land natural resources by livestock, mining, energy fuel extractors and other exploitive interests in our society, and n spite of the great aesthetic value of the wild horses, their true North American native status, their great contribution to restoring and healing ecosystems, e.g. soil building, plant seeding, and to preventing catastrophic wildfires by eating dry flammable vegetation over broad areas. These are tremendous ecological services that can be evaluated in the billions of dollars. (See my article and book, above cited.)

p. 13: Again I recommend the removal of ovariectomy. It is far too invasive and would lead to many serious complications for the horses. I suspect the accuracy of the 2% complications from the Sheldon NWR experiments on mares being ovariectomized, as per Bower (2015). I have received reports from Carol Walker and Tracy Mohr that reveal a much larger percentage of ovariectomized mares who have died during these surgeries that are in the order of 10% or more.

p. 16: Yes, death is the fate that could befall many of these “patients,” the ovariectomized mares!

p. 26: I very much oppose the Rock Springs Field Office Wyoming BLM’s proposed release of sterilized mares to White Mountain and Little Colorado HMA’s for study and have recently (1/11/16) sent in my written protest to this office. The AML in these wild horse HMAs is in no way commensurate with the amount of legal HA and even reduced HMA land where these wild horse should be the principle presences and recipient of resources according to Section 2 (c) of the WFHBA. It is ca. one individual horse per 6,000 legal acres! How can this be overpopulated?!

p. 27: Ca. 225 wild mares to be experimented upon is quite a sizeable number of living, breathing, suffering, highly evolved and sentient horses; and the stress, pain, suffering & even death caused to these beings is more than sufficient justification for the cancellation of the proposed experiments.

p. 30. No Action: Again I strongly favor No Action & the employment of Reserve Design which concords with the true core intent of the WFHBA, along with increasing AMLs and the securing of a full range of viable resources for the survival of naturally self-stabilizing, long-term viable wild horse populations.

p. 31: Again, I seriously doubt the one to two percent mortality figure for ovariectomized mares.

p. 32: I see that the NRC committee also questions this low percentage of fatalities associated with ovariectomies and other sterilization techniques, including ligation and ablation of fallopian tubes. All these are very unnatural and hardly the “minimum feasible level” of management that the WFHBA specifies in Section 3(a).

P. 33: You should seriously consider the professional recommendation of Veterinarian Dr. Bruce Nock (2013) and not merely single out one aspect of his findings (concerning bone density) to discredit, while ignoring all the rest of his valid points — particularly the serious stress caused by the manhandling and manipulation of wild horses.

P. 35: Regarding both tubal ligation and tubal ablation, the mares’ ovaries would continue to recycle and the wild stallions would continue to mate with these mares, but without pregnancy. This would cause great anguish and stress, especially in mares and also in stallions. Wild horse social order both of bands and of the herds that contain them, would be seriously disrupted, their natural and age-old harmony, thrown into disarray! This entirely contradicts the true spirit and intent of the WFHBA!

p. 37, bottom: Yes, “repeated copulation through the breeding season” bears out what I just said.

p. 38. C. Cumulative Effects. No Action: Your statement is not true! BLM could do what’s right and adopt the Reserve Design approach. Your statement is much too simplistic and overlooks other sound alternatives.
Proposed Action, top: This statement is not true. PZPed mares have been observed with serious stress; and social disruption has been observed n their bands and herds.

p. 40, top. The pronouncements of “overpopulation of wild horses” are not based on objective appraisals, but are arbitrary and designed to justify ongoing monopolization of public lands resources by bullying vested interests. Furthermore you ignore the many mutualistic benefits of wild horses to the ecosystem.
bottom: This again expresses the negative, prejudiced view of wild horses that ignores and discounts their positive benefits to the ecosystem.

p. 42, top: Again you ignore Reserve Design.
bottom: This is a skewed argument that ignores the wild horses’ capability to self limit their population numbers (see points already made above).

p. 43, top: This is a convenient, overly simplistic interpretation of the situation. I disagree! Natural self-limitation by wild horses is both possible and compatible with the natural life community and would achieve a true Thriving Natural Ecological Balance (TNEB).
bottom: This is hyperbole! The AMLs that have been set are prescriptions for under-populated wild horses that would become genetically non-viable and ecologically non-adapted, because not so permitted by people! You ignore the need to reduce livestock on the public land along with other monopolizers and destroyers of the life of these same public land.. This includes mining and energy extracting industries as well as the ranchers.
p. 44: It is clearly the anti-wild-horse preservation group who are calling the proposed action a mere “baby step.” They are so smug and ignore so much!
3rd paragraph: This expresses a hysterical, target mentality on the part of other wildlife and natural resource organizations. These are people who deliberately ignore and scapegoat the wild horses because they don’t fit into their narrow-minded agendas, their confined and limited system of values! And they thus display their disrespect and disregard for the great majority of the General Public of the United States. It is supposedly true that we still live in a Democracy and that our public officials are our public servants sworn to fairly uphold all the laws of the land, and not play favorites.

p. 45, mid page: Yes, sterilization very much interferes with natural selection among the wild horses. And natural selection is key to ecological adaptability and long-term survival. For this reason alone, I oppose the proposed action and all three sterilization procedures.

P. 96, mid page: The sterilization by chemical injections of free-roaming stallions is outrageous and would cause enormous stress, suffering, anguish and social disruption among the wild horses! The Patrons, or lead stallions play an enormously important role in the well-being, education, and reproductive inhibition of immature horses.

P. 98: Inducing embryonic death is very cruel and unnatural and contrary to the WFHBA!

p. 99: I agree that tubal pregnancy caused by these experiments would be very probably and that it would be exceptionally cruel. For this reason, it is unacceptable!

p. 101: The committees suggestion that ovariectomy would be operational immediately is very alarming, and I greatly oppose this. This shows how little the committee cares about the wild horses! Ovariectomy should be totally cancelled out!

p. 104: Regarding American Indians: I disagree. Many traditional Indians would be very offended by these experiments on the wild horses — which they venerate. What is happening to these wild horses is very much like what happened to the Indians, i.e. broken treaties and broken, or ignored law: WFHBA!
Regarding Environmental Justice, I disagree. This sterilization project would be very unjust to wild horse advocates, and this includes many thousands, even millions in the U.S and worldwide.

p. 106: Regarding wild horses, yes, wild horses would be very detrimentally affected by sterilization, brought to dysfunctional and even non-viable population levels! This is not right!

p. 107: Regarding wildlife, I disagree: wild horses are wildlife, returned North American natives, and would be harmfully affected by this proposed sterilization project.
Closing: Though having much more to say, I will end my input for now. Please give careful consideration to the points I have raised and feel free to contact me for further questions, elaboration, and more detailed information concerning Reserve Design – the fair and intelligent way to proceed for the wild horses, their associated plants and animals as an ecosystem which they enhance, and all concerned, including us humans.

Sincerely,
Craig C. Downer,
Wild Horse and Burro Fund,
P.O. Box 456, Minden, NV 89423-0456. T. (775) 901-2094

CC: Various Interested Parties.