If the volunteers and contractors applying two doses of GonaCon Equine to wild or captured mares are not certified according to EPA standards, they, and the agency overseeing the work, are following the 2017 registration.

If they are certified or they’re applying the doses 30 days apart, they’re following the 2013 or 2015 registrations.

As of today, the product is not an RUP, persons applying it need not be certified and the minimum interval between treatments is 90 days.

Mares in these herds were likely subject to the 30-day window, contrary to federal law:

• Bordo Atravesado HMA
• Red Rock HMA
• Calico Complex
• Clan Alpine HMA
• Antelope HMA
• Reveille HMA

If the field office overseeing the work did not require the persons applying the pesticide to be certified applicators, then they were following the 2017 registration and should have known about the 90-day window.

HMAs subject to field darting, such as Hog Creek, Cold Springs, Sand Springs and Coyote Lake/Alvord-Tule Springs in Oregon, Piceance-East Douglas in Colorado, and Onaqui Mountain and Range Creek in Utah should also be investigated.

RELATED: Gonacongate: What Did They Know and When Did They Know It?

Do you think you can get an accurate picture of the situation on public lands in the western U.S. from an agent that facilitates and profits from real estate transactions involving ranchers and ranching sympathizers?

If so, you’ll want to read the latest installment of “Wild Horse Tales,” starting at the bottom of page seven in the November edition of Horse Tales.

The writer, a PZP darter and close supporter of the Campaign Against America’s Wild Horses, calls for a New Path Forward that prioritizes the well-being of the animals while balancing the needs of ranchers, wildlife, and the public lands that belong to all of us.

It’s a shameless attempt to promote their pest control services and supplant helicopter roundups with mass sterilization.

The original Path Forward, a 2019 plan for ranching superiority in the lawful homes of wild horses, offered ideas for achieving and maintaining AMLs.

RELATED: If You Want to Help the Ranchers Give Money to the Advocates.

Appendix I asserts on page one that the WHB Act provides for contraception and sterilization in §1333 section 3.b.1.  The reference probably should be §1333(b)(1), which states that “…appropriate management levels should be achieved by the removal or destruction of excess animals, or other options (such as sterilization, or natural controls on population levels).”

A search of the statute for “contraception” and “fertility control” yielded no results, so the discussion of population suppression—the subject of the appendix—starts with a faulty premise.  (The warrant for pesticide application may have been fabricated by the bureaucrats as a federal regulation or they classified them as sterilants.)

On page two, under the heading of Fertility Control Vaccines, “Fertility control vaccines (also known as (immunocontraceptives) meet BLM requirements for safety to mares and the environment (EPA 2009a, 2012).”

The first citation refers to GonaCon Equine and the second is for Zonastat-H.

On page three, “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.”  Because Zonastat-H (PZP) was, and still is, a restricted-use pesticide.

That statement was prefaced with a remark about advisories on the product label which are actually requirements and if not followed constitute unlawful use of the pesticide.

Also on page 3, “GonaCon (which is produced under the trade name GonaCon-Equine for use in feral horses and burros) is approved for use by authorized federal, state, tribal, public and private personnel, for application to freeranging wild horse and burro herds in the United States (EPA 2013, 2015).”

Now they’re referring to the 2013 and 2015 registrations, according to which ConaCon was an RUP.  There should be a similar statement about applicator certification but it’s not there.

Near the bottom of page three, “GonaCon-Equine contraceptive vaccine is an EPA-approved pesticide (EPA, 2009a) that is relatively inexpensive, meets BLM requirements for safety to mares and the environment, and is produced in a USDA-APHIS laboratory.”

Back to 2009.  They’re all over the map!

The appendix is silent about the 2017 registration, which dropped the RUP designation and increased the minimum interval between treatments from 30 days to 90 days.

Reports from roundups suggest the BLM’s GonaCon protocol is based on an à la carte reading of the registrations: The 30-day window of the old ones and the certification-free policy of the new one, which, of course, is unacceptable.

The agency indicated in the Buffalo Hills DNA that it had asked the EPA to reduce the interval to seven days, which may indicate it was aware of the new registration but ignored the parts it didn’t like.

RELATED: Pryor Management Plan Moves to Protest Stage.

A report by Fox News puts the breakdown as follows:

• Onaqui Catalogue Foundation – $1,500
• Wild Beauty Foundation – $2,500
• Bureau of Land Management – $5,000
• Red Birds Trust – $5,000
• Wild Horse Education $5,000
• Rewilding America Now – $5,000
• American Wild Horse Conservation – $6,000

One of these groups is known for its obsession with pesticides, opposition to principal use and a bogus land trust where livestock are welcomed but horses are not.

Do you know which one?

RELATED: BLM Acknowledges Onaqui Wild Horse Shooting.

Located at the southwest corner of the Virginia Range, the barrier will increase public safety and protect wild horses from harmful human interactions according to a report by KOLO News but the advocates say it will separate them from a key water source.

Details about the project have been kept under wraps.

NDA shared a map with the reporter and the advocates but not with the public.

Western Horse Watchers was unable to find an announcement at the NDA news page.

The article said the plan will be discussed on December 6, probably at the next regular meeting of the Nevada Board of Agriculture, but as of today no agenda has been posted.

The third quarter meeting was cancelled.

The dispute over the fence marks the latest chapter in the lover’s quarrel between NDA and the Campaign Against America’s Wild Horses, the NGO “hired” by NDA to sterilize the Virginia Range mares.

RELATED: Goicoechea’s Focus on Virginia Range Not About Public Safety.

Musk and Ramaswamy will review the top 1% of applicants according to a November 17 story in The Hill.

Consider one AUM, the amount of forage necessary to keep one wild horse or one cow/calf pair on the range for one month.

If the bureaucrats assign it to a rancher, he’ll pay $1.35 to the government while it spends $150 to care for the horse displaced thereby.  This is current practice.

If the bureaucrats assign it to a horse, the government saves $150 in holding costs while forfeiting $1.35 in grazing fees.

You don’t need a high IQ to realize that best option is the latter, to be achieved by confining the ranchers to their base properties in a year-round off season.

The advocates, not known for superior intelligence, claim that the problem can be solved by shooting the mares with pesticide-laced darts.

RELATED: What Are Musk and Ramaswamy Being Told About Wild Horses?

The simplest way is to give money to the advocates.

They oppose principal use and management at the minimum feasible level.

They’re always talking about wild horse removal.

They want the ranchers to win.

There is another option that requires more effort on your part but the pass-through cost is zero.

Go cut a Christmas tree in one of the HMAs.

You’ll need a permit as explained in this announcement.

Only pinyon pines and junipers may be taken.

The Pine Nut Mountains and Virginia Range are off limits.

These trees are subject to hand thinning, mastication, chaining and “lop and scatter” because they crowd out forage preferred by livestock.

The projects are usually peddled as sagebrush restoration and fuels reduction, as in this example by the Ely District Office.

Junipers would not make very good Christmas trees in this writer’s opinion but pinyon pines would make a nice addition to your holiday decor.

Better yet buy some land in Nevada and you can decorate them in place year after year.

RELATED: Who Benefits from Cheatgrass Mitigation Projects?

Field audits are a good way to ensnare the advocates in their own destructive activity.

A pesticide label (PZP | Gonacon) tells you how the product can be used.

The first requirement is that the field workers have it with them.  Ask to see it.

Are they wearing the proper PPE?

Are they following the specified interval between doses?

Are they adhering to the approved uses of the pesticide?  For example, PZP can only be used on female horses and burros capable of doing environmental damage.

The Salt River advocates say the horses are good for the environment but they’re using the product to shrink the herd.

Not only do they contradict themselves but thinning overpopulated herds is not an approved use of the pesticide.

Using it to control herds that interfere or could interfere with animal agriculture is not an approved use.  Same for herds that pose safety hazards to motorists.

Referring to pesticides as vaccines may constitute misbranding, another unlawful act.

The EPA offers several options for reporting illegal use:

• Contact your state regulatory agency
• Send an email to report.pesticide.incident@epa.gov
• Fill out a report online

RELATED: Foal-Free Friday, Army of Nitwits Edition.

President-elect Donald Trump announced on November 12 that Elon Musk and Vivek Ramaswamy will lead a new task force on government efficiency according to a report by AP News.

The Department of Government Efficiency will work outside the bureaucracy to drive large-scale structural reform and create an entrepreneurial approach to government.

You can be sure the farm bureaus, stock grower’s associations and public lands councils, already circling their wagons, will point to the wild horse and burro program as wasteful government spending, when most of its costs are incurred because of them.

The same is true for wildfire restoration, fuels reduction, cheatgrass mitigation, predator control and pinyon-juniper management on America’s public lands.

Hundreds of millions of dollars spent every year on affluent ranchers who pocket the profits and pay almost nothing for the services, as nearly 70,000 wild animals rot in government holding.

If Musk and Ramaswamy understood the waste and sleaze, and they had the authority, they’d kill this boondoggle Monday morning and put those animals back on the range.

The agency has offered a $5,000 reward for information leading to the arrest and conviction of the person(s) responsible according to today’s news release.

In an effort to trick you into thinking they care about wild horses, the pesticide pushers and ranching sympathizers have pledged $14,000, bringing the total to $19,000.

They know they won’t have to make good on their promises.

RELATED: Onaqui Stallion Found Dead.

A federal judge has dismissed the case seeking their removal from the barrier island off the coast of Georgia, according to a report by The Atlanta Journal-Constitution.

The original article was placed behind a paywall but was reprinted in full by the Union-Bulletin of Walla Walla WA.

The writer said the court ruled against them because the do-gooders in the coalition named them as plaintiffs.

RELATED: Coalition Seeks Removal of Cumberland Island Horses.

Five new public-private partnerships could place an additional 11,000 wild horses and burros into private care over the next five years in exchange for $25 million in funding, according to today’s news release.

That’s on top of the existing adoption program.

Leading the way is Forever Branded, a Texas nonprofit that will receive over $16 million.

Western Horse Watchers believes that these programs will not reduce expenditures for off-range holding but will accelerate turnover so more wild horses can be removed from their lawful homes.

The off-range corrals could be emptied several times over by confining the ranchers to their base properties in a year-round off season.

The agency spends tens of millions of dollars every year stockpiling wild horses so it can collect a few million dollars in grazing fees from the ranchers.

Nobody in the private sector would do that.

He was found in the HMA on November 10 according to a report by KSL News, killed by gunfire.

Your host was unable to find a statement from the BLM at their news site.

The HMA is subject to permitted grazing.

Advocates with the Wild Horses of America Foundation are poisoning the Onaqui mares with PZP and Gonacon Equine.

They should be investigated for unlawful use of pesticides.

RELATED: Reward Offered as Two Onaqui Stallions Found Dead.

Refer to §136j(a)(2)(G) in FIFRA.

If the Gonacon label says a second dose can be given 90 days after the first and you give it after 30 days, you violated federal law.

If the Zonastat label tells you what PPE to wear when applying the product and you don’t, you violated federal law.

If persons using these products don’t have the labels in their possession when applying them to equines, they’re violating federal law.

These requirements are easy to check during field audits.

RELATED: There’s a Cancer on the Wild Horse and Burro Program.

ALLEGATION: The federal agencies responsible for wild horses and burros knew about the 2017 labeling amendment for GonaCon Equine but ignored the parts they didn’t like, referring instead to specifications of the 2013 and 2015 registrations which better served their anti-horse agenda.

In the 2017 edition, persons injecting the pesticide need not be certified applicators, which they liked, but the minimum interval between treatments was 90 days, which they didn’t like.

In the previous editions, persons injecting the pesticide had to be certified applicators, which they didn’t like, but the interval between treatments was 30 days, which they could tolerate.

So they invented a hybrid registration, without the consent of the EPA, consisting of certification-free application with 30 days between treatments and fed it to the public through the planning process.

Let the denials and coverups begin.

RELATED: Gonacongate: What Did They Know and When Did They Know It?

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?

Some headlines said he died, such as this one by WITN News, but he was killed by the advocates.

Seems like there’s a steady stream of negative results coming from areas where the advocates are involved.

The winner for 2024 will likely be the loss of 24 Virginia Range mustangs in a botched attempt to rescue them from a construction area in south Reno.

RELATED: Advocates Let Currituck Stallion Die Naturally?

How do you know an idea is bad for wild horses?  The advocates support it.

Two examples in the legislative arena are the Wild Horse and Burro Sterilization Act and the Veterans for Pesticides Act, which should expire when the 118th Congress terms out at the end of the year.

RELATED: HR 3656: Windfall for Advocates, Bad for Wild Horses.

The Campaign Against America’s Wild Horses, a leader in nonmotorized removal and fierce opponent of principal use, reported today that 107 mares received 108 doses of PZP during the month, 19 given as primers and 89 as boosters.

Over the life of the program, which began in 2019, 2,068 mares have received 9,967 doses of the pesticide, for an average of 4.8 doses per mare.

The results fell 33 doses short of the 10,000-dose milestone predicted for October.

The epicenter of the program is in and around the Tahoe Reno Industrial Center, listed as USA Parkway in the page 3 chart.

Since the beginning of the year, 165 foals have been born and 66 died.

The current population is thought to be 3,465 with 294 horses listed as missing, compared to 3,501 with 299 horses listed as missing in September.

The population was 3,515 with 302 horses listed as missing in August and 3,548 with 311 listed as missing in July.

The Year 6 agreement with NDA has not been posted to the darting resources page.

The Year 5 summary has not been posted to the monthly reports page.

A goal for November is to maximize booster treatments so the herd will continue to shrink and to complete the training of newly certified darters.

Not discussed in the October update:

• Long-term population goal
• Number of viable mares
• Size of breeding population
• Loss of genetic diversity
• Changes in death rate and sex ratio
• Unlawful use of pesticides

The report will be submitted to the Nevada Department of Agriculture.

RELATED: Virginia Range Darting Update for September 2024.