The Campaign Against America’s Wild Horses, a thought leader in the wild horse world, has the answer, submitted as a comment on the Draft EA:
The recommendation was published in a document containing unique comments, according to the file name in the project folder.
Referring to it as original thoughts would be over the top.
The advocates, including the fanatics at the Virginia Range, are protecting their cherished wild horses from removal by getting rid of them with PZP.
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Western Horse Watchers Association 