While we are on the topic of a wild horse management plan for the herd in Theodore Roosevelt National Park in Medora, ND, we thought it would be a great time to share a document we received as part of our recent FOIA (Freedom of Information Act) request.
On August 18, 2020, then TRNP Park Superintendent Wendy Ross sent an email to us and other wild horse stakeholders:
“Hello Horse Stakeholders-
Theodore Roosevelt National Park has developed a communication portal where we will post all announcements/news regarding park horse management. The communication portal will answer questions in a continually updated FAQ page. The portal can be found here https://www.nps.gov/thro/learn/nature/feral-wild-horses.htm.
Thank you for your interest in Theodore Roosevelt National Park,
On September 9, 2020, they shared this announcement on their portal:
“September 9, 2020
To reduce foaling rates and minimize the number of animals that must be captured and sold annually to manage the demonstration herd size, Theodore Roosevelt National Park is administering GonaCon™ Equine immuno-contraceptive vaccine to all female horses ≥8 months of age. Contraceptives will be administered remotely by syringe dart, providing approximately two years of fertility control. The vaccine does not impact current pregnancies. Operations are planned to start in September of 2020 and be completed by December of 2021.
Most reproductive age female horses in the park have already received contraception as part of a study. Results of that research indicated that the vaccine is effective but temporary. This temporary fertility control will provide latitude as the park explores development of a new comprehensive herd management plan.
The vaccination does not preclude subsequent transfer of animals out of the park. Therefore, capture and auction operations will continue to provide ownership opportunities for interested parties.”
What we just uncovered through our FOIA request is this little piece of documentation that was NOT shared with the general public regarding the wild horses in Theodore Roosevelt National Park in Medora, ND:
When the park decided to administer GonaCon as a method of birth control to all of the female horses in TRNP, they chose to categorically exclude this action from NEPA review by filing this National Park Service Categorical Exclusion Documentation Form (CE Form). You will note that this document is dated and signed September 8, 2020 – one day before they TOLD us what they would be doing to our horses on their new horse communication portal where we were promised that TRNP park management would “post all announcements/news regarding park horse management.”
Apparently, the choice to give birth control, at an expense to the tax paying public of $7,575, to ALL female horses aged 8 months and up, is not an announcement TRNP park management felt warranted any public opinion or input.
Please note their CE justification:
“Though the CE specifically cites “removal of park resident individuals”, versus contraception, the proposed action will prevent additional genesis of resident animals that would have to be removed to protect the park from overgrazing.”
It would seem from that we do not have to concern ourselves with the park performing any captures of our horses this year.
We do not believe that for one second!
The CE Justification also states:
“This CE is appropriate in this situation because there are no extraordinary circumstances potentially having significant effects on the environment.”
Apparently giving two doses of GonaCon as a method of birth control to every female horse in the park is nothing to be concerned about.
This is just another example of the lack of transparency TRNP park management has been guilty of since it became a national park. Park management knew exactly what the public’s reaction would be to this decision, so moved forward with their clandestine contraception plan by utilizing this CE Form.
One has to wonder how many other CE forms exist with regards to the wild horses entrusted in their care.
Our FOIA request also asked for records with any data relating to the administration of GonaCon on the horses. Since the National Park Service considers our FOIA request fulfilled, and we did not receive any records of which fillies and mares have been given GonaCon, we have to assume that the management of Theodore Roosevelt National Park is not practicing proper record keeping when it comes to who has been treated with GonaCon since 2020. For clarity: IF the records existed, they would have to release them to us under the FOIA guidelines. If they have them, but are withholding them for some reason, that would have to be explained. Since neither were done, we are left to believe they simply are not keeping track of who they have given GonaCon to and when. You would think that makes it difficult to know when the booster should be given and to which horse.
IF there was a wild horse management plan in place, it would include a plan for humanely administering birth control using science and genetics instead of their latest tactic to continue to control the NUMBER of horses.
This CE form speaks to the lack of transparency that TRNP park management has with the public. While the limited information shared by Colorado State University (CSU) regarding their 11-year experiment on the wild horses of Theodore Roosevelt National Park suggests that GonaCon is effective but temporary, TRNP failed to share other CSU GonaCon “studies”. Specifically, from 2015-2020 experimentation was done on domestic horses that proved that 4 doses of GonaCon worked well to sterilize mares. That study has now given rise to a new experiment, as the BLM Wild Horse and Burro Research Background Materials for Advisory Board report that was released in June 2021 states (report can be found in the library section of this website):
“This study showed that this new type of fertility control vaccine could, in theory, sterilize mares. The four-shot version of the vaccine worked well, but now is being tested as a one-shot vaccine.”
The new experiment, as stated in this BLM report, explains:
“Pen trial building on project #5, test whether a one-dose version of the vaccine against BMP-15 and GDF-9 causes long-term infertility. BLM’s final Environmental Assessment (March 2020) describes the ongoing study at Northern Nevada Correctional Center. 16 mares were injected with vaccines and 16 with placebos, in May 2020. In theory, the mare may deplete her ovaries of fertile oocytes, thus becoming sterile.”
Data shows that GonaCon, SpayVac, GDF-9 and BMP-15 are designed to literally destroy the ovaries via injection of the substance there by shutting down a mare’s estrus cycle destroying the natural production of hormones which are known to have behavior consequences. https://www.thecloudfoundation.org/comments-and-articles/2021/4/23/draft-environmental-assessment-for-the-heber-wild-horse-territory-plan-18916
Further, TRNP Park Management failed to share this information from Dr. Dan Baker, who led the GonaCon experiment in TRNP from October of 2018 (https://cvmbs.source.colostate.edu/novel-study-shows-promise-for-managing-wild-horse-populations/):
“What’s the next step and ultimate goal?
Dan Baker, co-principal investigator and affiliate faculty member in the Department of Biomedical Sciences:
“This is an ongoing effort and additional research is needed to complete the study’s objectives. We now need to define the duration of effectiveness and determine if long-term or permanent infertility is a possible outcome. We also need to investigate the optimum revaccination schedule to maintain infertility and the safety of repeat vaccinations.”
“Ultimately, there is an urgent need to extend the results of our research with the individual horses at Theodore Roosevelt National Park to test of GonaCon’s effectiveness in suppressing growth rates of other free-ranging populations.”
The other National Park’s with wild horses that have successful horse management plans in place include solid birth control plans that take science and genetics into consideration. Why wouldn’t we want the same for the horses in Theodore Roosevelt National Park?
There are many other facts that support our concerns regarding why a wild horse management plan should be in place. It is safe to say that Theodore Roosevelt Park management is also aware of that they SHOULD have a wild horse management plan in place. Their standard answer to WHEN they would begin working on a wild horse management plan hasn’t changed in over 50 years: “We will begin working on the new wild horse management plan in the next 2-3 years.” The current timeline, as stated on TRNP’s wild horse “portal” states: “The NPS will be initiating a new horse management planning process during fall of 2021. Updates on timelines will be posted on the portal.”
Once again, the public and the wild horses of TRNP are left to wait for the management of Theodore Roosevelt National Park to simply do their job, per their NPS regulations, that they should have done 66 years ago.