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

org>
Date: Mon, Apr 18, 2016 at 7:27 PM
Subject: Mare Sterilization Research - Follow Up
To: Lisa Grant <lgrant@blm.gov>, Robert Sharp <rsharp@blm.gov>, dbolstad@blm.gov, "Griffin, Paul"
<pgriffin@blm.gov>
Cc: iacuc.chair@oregonstate.edu, Rebecca.Henry@oregonstate.edu, Helen.Diggs@oregonstate.edu,
Rich.Holdren@oregonstate.edu, IACUC <IACUC@oregonstate.edu>, "eklei@earthlink.net"
<eklei@earthlink.net>

Dear Lisa,
You had told my colleague Eric Kleiman in a phone conversation today, April 18, that
the concerns about this research expressed by AWHPC are being "blown out of
proportion." That is hardly the case.
As we have stated repeatedly in various complaints and comments, the outcome of
the spay workshop is directly relevant to the BLM's analysis of the proposed action.
The EA on page 36 states:
In September 2015, the BLM solicited the USGS to convene a panel of veterinary
experts to assess the relative merits and drawbacks of several surgical
ovariectomy techniques that are commonly used in domestic horses for
application in wild horses. A table summarizing the various methods was sent to
the BLM (Bowen, 2015) and provides a concise comparison of several methods. Of
these, 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 the operation. 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. (Emphasis added.)
You now know that the expert panel relied on inaccurate and/or incomplete
information to make its conclusion that ovariectomy "appears to be relatively safe
when performed by an experienced surgeon" and that, in "marked contrast to a
suggestion by the NRC, this panel of experts identified evisceration as not being a
risk..." The EA repeatedly cites the expert panel's conclusions in support of the
proposed action.
This is the very definition of flawed. You now know that a substantial, statistically
significant number of the animals on whom Dr. Pielstick, presumably the
"experienced surgeon" referenced by the panel, operated suffered complications that
required extensive post-surgical care. You now know that at least two of the animals
died as a result of the surgery - one burro and one mare that Dr. Pielstick failed to
disclose, even though the expert panel was specifically assessing "spay techniques
for mares in field conditions." His failure to report this mare and the outcome (her
death) severely undercuts his credibility.
The expert panel noted, “one of the major complications could have been the training
itself.” That conclusion would not have been reached had the panel been informed by
Dr. Pielstick about the mare, her death and the fact that Dr. Pielstick was the only
person involved with her surgery.

At a recent BLM meeting, Dr. Pielstick told us that he didn't think that information was
relevant and that he doesn't know why the horse died two days after surgery. No
post-mortem exam was performed to determine cause of death. If he had accurately
reported the outcome of the spay workshop, it is highly doubtful that the panel have
sustained its conclusion that ovariectomy via colpotomy was relatively safe and that
evisceration was not a risk. (The horse was tied up to a wall to prevent that something that cannot be done in wild horses.)
If this is the outcome of surgeries performed by your "reliable" and "experienced"
surgeon with whom the BLM has worked for decades, then clearly the NAS' 2013
conclusion that "the possibility that ovariectomy may be followed by prolonged
bleeding or peritoneal infection makes it inadvisable for field application" should be
the standard given the completely, flawed and inaccurate information upon which the
"Assessment of spay techniques for mares in field conditions" panel made its
assessment. The EA in turn relied on this flawed, faulty assessment , thereby
invalidating the EA's conclusion and rendering the Administrative record inadequate,
incomplete and unable to sustain a Decision Record based on it.
At minimum, the BLM should stop the decision making process and amend
this EA to reflect accurate and complete information in compliance with the
law.
Regarding your statement to Mr. Kleiman that these gave concerns "are being blown
out of proportion," I point you to not only AWHPC's comments, but also those of
the U.S. Cattleman's Association - hardly a pro-wild horse organization. Although we
do not believe with the Cattlemen’s overall perspective on how to manage wild
horses, we do agree with their assessment of Ovariectomy via Colpotomy, and do not
believe that the Cattlemen are blowing concerns over the procedure out of
proportion. The Cattlemen write:
“This procedure, as outlined in the EA, appears to be the least humane
of the three methods proposed. Individual mares selected for inclusion
in the ovariectomy procedure would be held without feed for 36 hours
prior to surgery. As hindgut herbivores, horses are designed to be
foragers. Withholding feed for 36 hours can cause undue stress on the
individual mare and increase the risk of painful abdominal pain, or
colic, which can result in fatality.5 Ovariactomy via colpotomy suggests
that mares be kept standing for 48- hours after the surgery is
completed. Due to the inherent nature of wild horses, USCA has serious
doubts that this task can be properly carried out to ensure a successful
operation. Because of the perceived inability to keep wild horses
standing for up to 48 hours, we would expect the mortality rate to be
much higher than cited in the EA. Additional post-operative
complications include pain, colic, pawing, refusal to eat, bleeding,
infection, or signs of abortion.
When my colleague Eric Kleiman brought up to you, during this same telephone
conversation today, the failure to report the mare colpotomy, or the complications
and death suffered by this mare (or how Dr. Pielstick did not address the
complications for the burros asked by the expert panel), or how whether or not this
mare was part of the "training" or not it was still extraordinarily serious and would be
a subject for the NIH's Office of Research Integrity, if NIH-funded, for investigation of
scientific misconduct, you told him you would "ask Leon" about it. As he told you, and
I will reiterate, Dr. Pielstick has a vested interest in putting the best possible face on
this glaring failure to report the mare surgery itself, the bad condition the horse was

in post-surgery (see Simone Netherlands declaration), let alone her death. You told
Mr. Kleiman that Dr. Pielstick was “reliable.” On the contrary, his credibility is
severely undercut by the documentation that BLM now possesses. Because
the EA relied on flawed information and withheld information, at a
minimum, it must be amended and BLM must interview the eyewitnesses,
again at a minimum. A sworn affidavit is considered evidence that the BLM
cannot ignore. The foundation of this EA is based on this fatally flawed,
incomplete and withheld information and must be withdrawn.
Again I ask that this be included as part of the administrative record and that you
confirm receipt of this email and the three emails I previously sent you today,
forwarding the information I have sent to the OSU IACUC on this subject.
Sincerely,
Suzanne Roy
Attachments area