April

8, 2016

Oregon State University Institutional Animal Care and Use Committee
Oregon State University Vice President for Research
Oregon State University Office of Research Integrity

To Whom It May Concern:

The American Wild Horse Preservation Campaign (AWHPC) and the Salt River Wild Horse Management
Group call on you to intervene to halt the Bureau of Land Managements (BLMs) proposed sterilization
research on wild mares held at the agencys Wild Horse Corrals in Hines, Oregon. This research is
conducted in conjunction with Oregon State University (OSU) and is currently under review by the OSU
Institutional Animal Care and Use Committee (IACUC). The proposed research is described in the
Environmental Assessment (EA) available at this link:https://eplanning.blm.gov/epl-front-
office/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172015.pdf

The BLM intends to subject 100 wild mares held at its Wild Horse Corrals in Hines, Oregon to a surgical
procedure known as ovariectomy via colpotomy, in which the ovaries are accessed and removed
manually through a mares vaginal canal. This invasive procedure presents an unacceptable risk of death
to wild mares from hemorrhage, evisceration (protrusion of bowel through surgical incision) and
infection, because they cannot be provided with the post-operative care that is required when domestic
mares undergo the procedure. 75 percent of the mares used in the experiment and the procedure will
cause many to suffer abortions.

Nearly 21,000 American citizens have submitted comments to the BLM in opposition to this proposed
research. In addition, video evidence and an eyewitness account raise serious animal welfare and
scientific integrity concerns about the conduct of this procedure by its most outspoken advocate, Dr.
Leon Pielstick, an Oregon livestock veterinarian who may be associated with the proposed research,
since he is self proclaimed as the only person with enough experience performing this procedure on wild
horses.

We believe that your IACUC must withhold its approval of this research and that OSU should
disassociate itself from the conduct of these experiments for the following reasons:

1. The well-being of wild horses used in these experiments cannot be ensured.

a. Post-operative care cannot be provided to wild horses.

The possibility that ovariectomy may be followed by prolonged bleeding or peritoneal infection
makes it inadvisable for field application. National Research Council, 2013.

American Wild Horse Preservation Campaign, 1025 Alameda, #633, Belmont, CA 94002
WildHorsePreservation.org


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 domestic mares. To
reduce the risk of evisceration of the 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 2 weeks following the surgical procedure. These guidelines were developed
because the risks of post-operative hemorrhage or evisceration are real. Mary A. Scott, DVM,
PhD, DACT, equine reproductive specialist. [Emphasis added.]

Dr. Pielstick himself affirmed the importance of post-operative confinement at an Arizona workshop he
conducted last year. While performing an ovariectomy via colpotomy on a horse, Dr. Pielstick told
attendees that the horse had to be restrained from lying down to prevent her intestines from coming
through the incision. She was tied tightly against the stall wall after the surgery. (Affidavit of Simone
Netherlands, attendee at workshop, attached).
No such restriction is possible in wild horses. Nor will wild horses be provided with post-operative
antibiotics or pain relief despite real risk of infection and discomfort post-procedure. These facts elevate
the risks of complications and resulting mortality to unacceptable levels and provide clear cause for your
IACUC to reject the experiments.
2. Outcome of Dr. Pielsticks training workshop in Arizona provides further cause for withholding
approval of this research.
The Southwest Wildlife Conservation Center near Phoenix sponsored Dr. Pielsticks training workshop
last year. The Centers director, Linda Searle, informed AWHPC that she does not support spaying
mares as a method for population control due to the complications suffered by burros and the horse
used in the workshop and the extensive aftercare the surviving animals required. Dr. Pielstick reported
to BLM that he conducted the procedure on five burros. Of these, one burro bled to death, one burro
aborted her 50-70 day old fetus, and other burros suffered from post-operative infections, meaning
most if not all of the animals used in the workshop suffered from complications. (See Expert Panel
attachment). The burros and horse used in this procedure were tame. The post-operative care they
required could not have been given to wild, untamed burros or horses.
Video taken of the workshop shows Dr. Pielstick operating on burros who are clearly inadequately
sedated and anesthetized. In her affidavit, Ms. Netherlands recounts witnessing burros visibly reacting
to pain and struggling to get out of the chute. She also recounts Dr. Pielsticks comments on the difficulty
of sedating wild horses and burros.
At the workshop, Dr. Pielstick performed ovariectomies via two methods: colpotomy and flank incision.
He informed participants that he had a higher death rate associated with colpotomy than with flank
incisions, because the internal incisions with colpotomy cannot be sutured. This fact was not considered
by the BLM in its EA analysis of the ovariectomy via colpotomy experiment.
3. BLMs analysis of the research was based on inaccurate and incomplete information.
The BLM EA relies on information from the expert panel it convene to evaluate different spay methods.
In fact, the EA uses the panel notes in an attempt to directly rebut the 2013 NAS study that took two
years to completea rebuttal that simply collapses under the weight of the fundamental flaws,
omissions and scientific integrity questions cited below. Dr. Pielstick was part of that panel. According to
the BLMs notes, Dr. Pielstick did not provide adequate or accurate information to that panel.


He failed to disclose that the Arizona workshop included a horse as well as the burros
and that the horse had to be tied to prevent her from lying down, which could cause
evisceration of the bowel through the internal incision (see attached Declaration; also
eyewitness under oath states that this horse was not doing well two hours after surgery,
with ears down, eyes half closed, neck hanging down appearing very lethargic. ). What was the
outcome for the horse?
He failed to discuss the post-surgical infections in the burros who survived the
procedure and what the ultimate outcome was despite the panels directly questioning
these infections.
Regarding his experience spaying mares at the Sheldon National Wildlife Refuge, he
noted that complications only arose within the first two days, but did not disclose what
those complications were and how many horses suffered from them.
He did not acknowledge what he said at the Arizona workshop (see Declaration) that
there was no follow up on the spayed mares at Sheldon, and other than the horses who died
during surgery, he had no idea how many had perished.
He stated that the pain levels for spayed mares at Sheldon were within acceptable
limits but then noted that because of low daylight, it was difficult to actually observe the
animals post-surgery.
He did not inform the panel that he had a higher death rate associated with ovariectomy
via colpotomy than with flank incisions.
These deficiencies render BLMs reliance on the Expert Panel report to justify proceeding with
ovariectomy via colpotomy experiments INVALID and raise serious questions about scientific integrity as
well as the outcome of all 188 colpotomies conducted at Sheldon and cited in the panel notes.

4. National Academy of Sciences National Research Council review of experiments not inclusive of
track record or animal welfare concerns.

The 2015 NRC panel that recommended funding the ovariectomy via colpotomy research proposal
asked to evaluate the proposals from a scientific quality perspective. It did not consider animal well-
being or the 2013 NRC recommendations. It was not privy to information from Dr. Pielsticks workshop
or prior experience indicating: 1) horses undergoing the procedure should be tied to prevent
evisceration; 2) flank incision was associated with a lower death rate than colpotomy; 3) the prevalence
of post-operative infections and extent of required after care.

Even still, its review of this research proposal concluded as follows, The Committee believes that this
procedure could be operationalized immediately to sterilize mares, with the caveat that fatalities may be
higher than the 1% reported in the literature. The sterilization techniques put forward [in the less
invasive research proposals] would be safer with less risk of hemorrhage and eviscerationand
probably less painful. Therefore, if the techniques in Proposals 8,9 or 12 prove to be successful after the
research is conducted, the committee thinks that these techniques should replace Proposal 19s method
of ovariectomy via colpotomy as surgical approaches for permanent sterilization.

6. The IACUC must withhold approval of the research.



Dangerous and impractical for field setting goes to need to use animals in the first place.
Cannot ensure the well being of the animals due to inability to provide with required post-

operative care.
Pain and suffering cannot be minimized due to 1) documented difficulty in adequately
sedating wild horses and burros; 2) inability to provide post-operative pain relief;
Ovariectomy will profoundly change natural behaviors and alter herd dynamics and social
organization on the range.
Based on data that lacks scientific integrity and is replete with glaring omissions and
unanswered questions that we believe merit an independent inquiry by OSUs Office of
Research Integrity

7. Included for your consideration:
Video of the Arizona spay workshop by Dr. Pielstick
o Edited: http://youtu.be/j6fJ8Ks8ciQ
o Uncut: https://www.youtube.com/watch?v=K0j3h8oqj7c
Declaration of Simone Netherlands, attendee to the spay workshop.
Public comments of AWHPC on BLM Mare Sterilization Research EA
Statement of Robin Kelly, DVM and Mary A. Scott DVM on BLM Mare Sterilization Research.
BLM Expert Veterinary Spay Panel.

Thank you for your consideration. I request confirmation of your receipt of this letter and urge you to
decline to approve this research proposal.

Sincerely,



Suzanne Roy, Executive Director
919-697-9389
sroy@wildhorsepreservation.org


Simone Netherlands, President
Salt River Wild Horse Management Group
simone@respect4horses.com