Discussion of the pesticide begins at the bottom of page 21 in the Final EA (page 29 in the pdf).
To wit, “GonaCon-Equine is approved for use by authorized federal, state, tribal, public and private personnel, for application to wild and feral equids in the United States (EPA 2013, 2015).”
The 2013 and 2015 versions were superseded by a 2017 amendment that changed the interval between primer and booster from 30 days to 90 days.
The BLM has adhered to 30 days, representing unlawful use of the product.
If the DNA is put out for public review, you could argue that the EA does not adequately cover the Proposed Action, as claimed therein.
Western Horse Watchers Association 