Carter Reservoir EA Refers to Old GonaCon Registrations

From page 49 in the Draft EA (page 50 in the pdf): “GonaCon-Equine is approved for use by authorized federal, state, tribal, public, and private personnel, for application to wild and feral equids in the United States (EPA, 2013; 2015).”

An updated registration was issued in 2017.

On page 178 in the pdf: “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 2017 amendment extended the interval to 90 days.

Page 179 mentions the certification requirement for PZP: “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.”

The 2017 update dropped the certification requirement for GonaCon-Equine.

But it should be there if they’re following the 2013 or 2015 registrations.  A search of the document for “certification” yielded only one result, the remark about PZP above.

Today is last day to comment on the project.

RELATED: Carter Reservoir EA Out for Public Review.

DOGE Establishes Outpost in Congress

The House Oversight and Accountability Committee is expected to approve a Delivering on Government Efficiency (DOGE) Subcommittee when it meets in January to ratify its rules according to a November 22 report by The Hill.

The new subcommittee will support the Oversight and Accountability Committee’s mission to root out waste, fraud and abuse in the federal government.

Public-lands ranching is one example.

For every AUM assigned to livestock in areas identified for wild horses, the BLM collects $1.35 in grazing fees while it spends $150 to care for the horse displaced thereby.

Messrs. Burgum, Musk and Ramaswamy, are you listening?

RELATED: DOGE Seeks Cost-Cutting Ideas, Hiring High-IQ Individuals.

Foal-Free Friday, Crime and Punishment Edition

Shooting wild horses and burros is a matter for law enforcement.  The cases are usually not solved but at least they’re investigated.

What about these actions?

  • Referring to outdated pesticide registrations in official planning documents when you knew they had been superseded
  • Following the directions of outdated pesticide registrations in the field when you knew they were no longer valid

Welcome to Gonacongate.  Unlike the shootings, there’s lots of evidence in these cases.

RELATED: Foal-Free Friday, Catching Them Red-Handed Edition.

Short List of Probable GonaCon Crime Scenes

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:

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?

New Path Forward?

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.

Use PZP 11-21-24

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.

Pryor Management Plan Refers to Old GonaCon Registrations

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.

Poseurs Boost Onaqui Reward to $30,000

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.

NDA Installing Fence Around Washoe Lake?

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.

Washoe Lake 11-19-24

DOGE Seeks Cost-Cutting Ideas, Hiring High-IQ Individuals

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?

How to Help the Clan Alpine and Desatoya Permittees

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.

Better Way 10-25-23

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?

Clan Alpine and Desatoya Christmas Trees 11-16-24

Foal-Free Friday, Catching Them Red-Handed Edition

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.

GonaCon Violation of Federal Law 08-05-23

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:

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

Pesticide Patrol 08-16-23

What Are Musk and Ramaswamy Being Told About Wild Horses?

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.

BLM Acknowledges Onaqui Wild Horse Shooting

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.

Cumberland Island Horses Safe for Now

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.

BLM Earmarks $25 Million for Wild Horse Outplacement

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.

Onaqui Stallion Found Dead

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.

Statutory Basis for Warning on Pesticide Labels

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.

Statutory Basis for Warning on Pesticide Labels 11-11-24

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?