Due to their popularity, horses captured in these roundups had a very high adoption rate, 100% in some cases.
For this reason the BLM did not apply population suppression in the HMAs, such as fertility control pesticides, sex ratio skewing and castration of stallions.
You won’t find any remarks about that at the HMA pages [Kiger | Riddle] but you can still see them at the 2015 gather page:
That has changed in the new plan, issued in July.
The Decision Record authorized Alternative A, the Proposed Action, discussed in Section 2.2 of the Final EA.
The option, titled “Remove Excess Wild Horses and Implement Intensive Fertility Control Management over a Ten-Year Period,” includes the use of Zonastat-H and GonaCon Equine—a practice that’s been avoided for many years.
More troubling, however, are the inconsistencies in the discussion of these pesticides, starting at the bottom of page 149 in the EA (156 in the pdf).
Like the Buffalo Hills EA, the citation for GonaCon Equine is out of date:
“The EPA required product label associated with the registration for ZonaStat-H is cited in the EA as EPA (2012). That label states that ‘For maximum efficacy, ZonaStat-H is administered as an initial priming dose followed by a booster dose at least two weeks later.’ The EPA-required product label associated with the registration for GonaCon-Equine is cited in the EA as EPA (2013). That label states that ‘If longer contraceptive effect is desired, a second vaccination may be given 30 or more days after the first injection or during the following year with no known adverse health effects to the vaccinated animal.’”
The registration was amended in 2015 and 2017.
In 2013 (and 2015) GonaCon was a restricted-use pesticide. In 2017, that designation was dropped.
In 2013 the shortest interval between treatments was 30 days. In 2017, the EPA increased it to 90 days.
Zonastat-H is still a restricted-use pesticide, meaning it’s not available for retail sale and you must be certified to apply it. That’s why the advocates spend three days at the Billings School of PZP Darting and Public Deception.
The EA acknowledges the certification requirement on page 158 of the pdf: “In keeping with the EPA registration for ZonaStat-H (EPA 2012; reg. no. 86833 1), certification through the Science and Conservation Center in Billings, Montana is required to apply that vaccine to equids.”
But there is no such statement for GonaCon Equine, which should be there if they’re referring to the 2013 (or 2015) registrations!
The absence of that remark suggests they’re following the 2017 amendment but violating the 90-day interval between treatments.
Apparently, they want the 30-day interval of the old registrations and the certification-free policy of the new registration.
You can’t have it both ways!
These errors invalidate the EA in this writer’s opinion and the court should halt the roundups as the coalition requested.
RELATED: Coalition Tries to Block Kiger, Riddle Mountain Roundups.
Western Horse Watchers Association 