Words Not in WHB Act

The Preliminary EA for the Antelope-Triple B pest control plan states at the top of page 169 that “The WFRHBA of 1971 specifically provides for contraception and sterilization (16 U.S.C. 1333 section 3.b.1).”  [It’s actually 16 USC 1333(b)(1), a comment you can submit on the EA.]

A keyword search of the statute yielded these results:

  • Contraception – Not found
  • Fertility – Not found
  • Vaccine – Not found
  • Pesticide – Not found
  • Growth – Not found

There is no warrant for the application of PZP and GonaCon Equine unless those products are used for sterilization.

Application to slow population growth, the oft-cited reason for their use, is not covered.

In the discussion of the effects of PZP on ovaries, the EA states at the bottom of page 177 that “…if some number of mares become sterile as a result of PZP treatment, that potential result would be consistent with the contraceptive purpose that motivates BLM’s potential use of the vaccine, and with Congressional guidance that condones such treatment in the management of wild horses and burros, in WFRHBA section 1333(b),” suggesting that sterility is a goal, not an unintended consequence of its use, as stated previously.

RELATED: Antelope-Triple B Preliminary EA Out for Review.

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