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.
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