The discussion of PZP and Gonacon begins at the bottom of page 146 in the Draft EA.
References to the EPA registrations appear on page 147:
- The EPA-required product label associated with the registration for ZonaStat-H is cited in the EA as EPA (2012)
- The EPA-required product label associated with the registration for GonaCon-Equine is cited in the EA as EPA (2013)
In 2012 Zonastat-H (PZP) was a restricted-use pesticide.
It’s true today and explains why the advocates spend three days at the Billings School of PZP Darting and Public Deception.
The EA reiterates the policy on page 148: In keeping with the EPA registration for ZonaStat-H (EPA 2012; reg. no. 6833-1), certification through the Science and Conservation Center in Billings Montana is required to apply that vaccine to equids.
In 2013 GonaCon was an RUP. There should be a similar remark about certification on page 148 or 149 but it’s not there.
The 30-day interval between doses on page 151 is consistent with the 2013 registration.
The RUP designation and certification requirement were dropped in 2017.
Like the Kiger-Riddle EA, the BLM appears to be crafting a plan based on an à la carte reading of the EPA registrations.
The advocates will likely dispute the claim on page 145 that contraception alone does not remove excess horses from an HMA’s population, as they are proving otherwise at the Salt River and Virginia Range.
Western Horse Watchers Association 