The case centers around the unlawful use of pesticides and falsification of government documents.
If BLM staff knew about the 2017 registration amendment, and recent EAs for wild horse roundups suggest they did, but referred to the 2013 and 2015 registrations because they better served their anti-horse agenda, that would constitute falsification of official government records.
The Kiger-Riddle management plan, published in July, is one example.
Initiated in early 2020, the project took over four years to complete.
The EA refers to the 2013 registration, according to which the product was a restricted-use pesticide requiring applicator certification, and the minimum interval between doses was 30 days.
But, unlike the discussion of PZP, the EA is silent about the certification requirement, which is consistent with the 2017 update.
The Pancake EA provides the same evidence.
In addition to dropping the RUP designation, the 2017 update increased the minimum interval between doses from 30 days to 90 days.
Yet the agency typically waits only 30 days to administer the booster, which constitutes unlawful use of the pesticide.
The driver may be cost avoidance—the goal is to spend more of your budget on wild horse removals, not temporary holding of mares that will go back on the range and rob the poor ranchers of their birthright.
How many of the GonaCon darters at Piceance Mustangs and High Desert Strategies are certified applicators? More evidence that our faithful public servants knew about the 2017 amendment but ignored the parts they didn’t like.
This is a matter for law enforcement.
The response to a comment in the Buffalo Hills DNA indicates they’re aware of the 2017 update but want to shrink the treatment window to 7 days.
Unfortunately for them, asking the EPA to change the registration does not absolve prior wrongdoing.
RELATED: Another Amendment to Gonacon Registration in the Works?
Western Horse Watchers Association 
That was my comment you’re referencing in the Buffalo Hills DNA. Appreciate you sharing the Gonacon information (and all information) initially—I’ve already included it in my Carter, Buckhorn, and Coppersmith comment, thanks to your heads-up on that one as well.