Meyer Glitzenstein & Eubanks LLP 4115 Wisconsin Avenue, N.W,, Suite 210 245 Cajetan Street Washington, D.C. 20016 Fort Collins, CO 80524 Telephone (202) 588-5206 Telephone (970) 703-6060 Fax (202) 588-5049 Fax (202) 588-5049 Imink@meyerglitz.com beubanks@meyerglitz.com September 22, 2015 Sent By Electronic and First Class Mail Horst G. Greczmie! Associate Director of NEPA Oversight ‘Council on Environmental Quality 722 Jackson Place, N.W. Washington, DC 20503 Re: — Bureau of Land Management's Violation of NEPA in Connection With “Pilot Program” To Use Untested Birth Control on Wild Horses Dear Mr. Greezmiel: Lam writing on behalf of my client, American Wild Horse Preservation Campaign (AWHPC), requesting that the Council on Environmental Quality (CEQ) review, on an expedited basis, a recent precedent-setting announcement by the Bureau of Land Management (BLM) to begin what itis calling a “Pilot Program” to reduce the number of wild horses on the public range through use of GonaCon™ — a controversial and experimental form of immune- contraception. As explained in the attached letter to BLM officials, in selecting this method for management of the wild horses, BLM has violated the National Environmental Policy Act (NEPA) in myriad ways. It has failed to adequately consider the environmental effects of this drug, including, but not limited to, its adverse effects on the natural behaviors of the wild horses = which under the Wild Free Roaming Horses and Burros Act are to be preserved in their natural state as “wild,” “free-roaming” “components of the public land..” 16 U.S.C. § 1333(a). Further, although BLM itself refers to the proposal as a “Pilot Program,” it has also failed to design the project as a formal research study with an accredited institution in order to determine the effects of the experimental vaccine on wild, free-roaming horses, and it has also failed to prepare an & Teevcled paperEnvironmental Impact Statement (“EIS”) for this program, despite the fact that BLM’s proposal implicates several of the significance factors under 40 C.F.R. 1508.27(b). Rather than repeat all of AWHPC’s concerns and legal arguments here, please see the attached letter, which I hereby incorporate by reference. My clients would very much like the CEQ to consider this matter on an expedited basis and to advise the BLM that it must reconsider this proposed action, conduct a more thorough review of the environmental impacts of the proposal, and proceed with the use of this experimental drug only pursuant to a formal research study. Our best information is that the BLM may start the program as early as the first week of October, 2015. Please let me know if you have any questions or I can provide you with any additional information. Ce: Dean Bolstad, Senior Advisor BLM Division of Wild Horses and Burros