---------- Forwarded message ---------From: Suzanne Roy <sroy@wildhorsepreservation.

org>
Date: Fri, Apr 8, 2016 at 10:16 PM
Subject: Animal Welfare Concerns: OSU/BLM Wild Horse Sterilization Research
To: iacuc.chair@oregonstate.edu, Rebecca.Henry@oregonstate.edu, Helen.Diggs@oregonstate.edu,
Rich.Holdren@oregonstate.edu
Cc: Cynthia.Sagers@oregonstate.edu, Mark.Peters@oregonstate.edu

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-frontoffice/projects/nepa/56292/67242/73184/MareSterilizationResearchEA_12172
015.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.
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 complete
a 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 postsurgery.

 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