January 7, 2016

Cliff Spencer, Superintendent

Mesa Verde National Park
No.1 Navajo Hill
Mesa Verde National Park, CO 81330
Sent via FedEx
Re: Scoping notice for the Mesa Verde Livestock Removal Environmental Assessment
These are the public comments on the scoping notice for the Mesa Verde Livestock Removal
Environmental Assessment (EA) submitted on behalf of the American Wild Horse
Preservation Campaign (AWHPC). Please include with these comments the 8,982 comments,
which were sent from The American Wild Horse Preservation Campaign (AWHPC) under
separate cover via FedEx. (Attachment 1) These 8,982 comments, which were submitted to you
Mr. Spencer, were signed by American citizens who want the National Park Service (NPS) to
consider their wishes for how the Mesa Verde National Park is managed as per the NPS
mandate: The NPS has a dual mission to preserve unique resources and to provide for their
enjoyment by the public.
Clearly the public is an important aspect of the NPS mission we therefore trust that you will
not dismiss the publics input into the environmental analysis process.
AWHPC is dedicated to preserving Americas wild horses and burros in viable free-roaming
herds for generations to come, as part of our national heritage. Our grassroots efforts are
supported by a coalition of over 60 historic preservation, conservation, horse advocacy and
animal welfare organizations.
I. Overview
The horses of Mesa Verde National Park (Park) are part of the area's natural landscape and
history. Each year, thousands of park visitors enjoy viewing the horses, as evidenced by the
videos and photographs of these beautiful animals that are regularly shared online. The horses
are an important part of the visitor experience.
In addition, the horses are important to the parks history. AWHPC urges the Park Service to
protect and humanely manage the Mesa Verde horses and promote to these living legends as
one of the Park's natural, cultural, and historic resources.
AWHPC further urges the NPS to create a humane management plan for the horses that
preserves this unique and historic herd in Mesa Verde National Park and protects their freeroaming behaviors, while managing their numbers through the use of humane and reversible
fertility control and taking concrete actions ensure their well-being, including providing access to

AWHPC Comments Mesa Verde Horses Removal EA

Page 2

reliable water sources for horses that are fenced within the boundaries of the park.
II. Management of the Horses as a Recreational Resource is Within the Park Service
Authority
It is within your authority to manage the horses of Mesa Verde within the Park and to
"designate[d] [them] ... as a necessary and integral part of a recreational activity or required to
maintain a historic scene."
The horses of Mesa Verde -- whether you refer to them as "feral" or "wild" -- have inhabited the
Mesa Verde National Park and surrounding areas since before the Park's inception in 1906.
Visitors throughout the history of the Park have undoubtedly enjoyed seeing the horses -- just
as visitors today enjoy witnessing their majesty and rugged ability to live free and wild. The
history of the horses is intimately tied to the history of the region, local tribes and the settling of
the West.
III. NPS 36 CFR 2.60 Mesa Verde Horses Are Not Defined as Livestock
The NPS regulation 36 CFR 2.60 cited for the removal of the horses only refers to domestic
"livestock" and is not applicable to the Mesa Verde horses.
The Park's scoping notice incorrectly labels the Mesa Verde Horses as "livestock" which NPS
recently defined as "any domestic animal raised for the production of food or other
agricultural-based consumer products." (Special Regulations; Pets and Service Animals:
National Park, 2014 http://www.regulations.gov/#!documentDetail;D=NPS-2014-0002-0001)
Under 36 CFR 2.60 the horses living in the Mesa Verde National Park do not meet the NPS
definition of livestock. They do, however, fall under the NPS definition of wildlife:

Wildlife means any member of the animal kingdom. National Park Service
(https://www.gpo.gov/fdsys/pkg/CFR-2015-title36-vol1/pdf/CFR-2015-title36-vol1-sec14.pdf) 36 CFR Ch. 1.4 (https://www.gpo.gov/fdsys/pkg/CFR-2015-title36-vol1/pdf/CFR2015-title36-vol1-sec2-60.pdf).

Additionally, there is strong scientific evidence indicating that horses are native to North
American and that they are appropriately considered a native, reintroduced North American
wildlife species. (See Attachment 2) This must also be considered before taking the drastic
action of eliminating this wildlife species from the Park.
IV. Mesa Verde Horses Are Necessary and Integral Part of Recreational Activity
As is evident from other NPS units horses provide a valued recreational activity for the visiting
public. Horses and ponies currently reside in about 20 NPS units; 10 units contain donkeys and
burros. The NPS was formed under the Organic Act of 1916 with the mission to conserve the
scenery and the natural historic objects and the wildlife therein and to provide for the
enjoyment of the same in such manner as to leave them unimpaired for the enjoyment of
future generations. The Mesa Verde horses have lived in the Park since before the NPS was
founded in 1906. Eliminating the horses would eliminate one of the wildlife species that has
been a part of the publics enjoyment of the park for decades.

American Wild Horse Preservation Campaign 1025 Alameda #633, Belmont, CA 94002

AWHPC Comments Mesa Verde Horses Removal EA

Page 3

The nearly 9,000 American citizens who took the time to submit comments through AWHPC on
this scoping notice (Attachment 1) are further testimony to the status of the horses as an
integral part of the recreational activity that occurs within the Mesa Verde National Park.
V. The Environmental Assessment (EA) Must Disclose, Consider and Analyze
Alternatives and Impacts to the Proposed Action
The EA must include the following:
1. Outline site-specific archeological locations that are of concern and are the basis for the
proposed removal.
2. Provide detailed evidence that horses have caused each of the alleged archeological
damage as identified in #1 above.
3. Provide detailed rationale and analysis regarding why each of the sites disclosed by the
NPS addressed in #1 and #2 above cannot be remediated through protective fencing or
other measures to prevent harm to archeological sites.
4. Disclose, detail and analyze archeological damage caused by vehicles and other human
activities which occur in the Park in order to put in perspective the multiple uses and the
significance of impact of each of the uses.
5. Outline specific locations of all public safety concerns regarding the horses and analyze a
variety of possible mitigating actions that would address the specific concern and promote
safety for the horses and public.
6. Analyze mitigating actions that could be taken to prevent horses from being removed from
the Park, including:

Protect archaeological sites by creating fence barriers to keep horses away from
sensitive areas and allow them to remain in the Park.

Repairing and restoring water sources to help distribute the horses more evenly
across the entire Park.

7. Analyze and identify as the proposed action a management program that humanely controls
population numbers and reduces it over time through the use of the PZP fertility control
vaccine. (Consider and analyze the data supporting this proposed alternative see
attachment 2 and attachment 3.)

Accommodate the present horse population and reduce its numbers over time
though implementation of a PZP fertility control program. The goal of the PZP fertility
control program should be to avoid the removal of horses.
PZP has been successfully used for more than two decades by the National Park
Service to manage a population of wild horses in the Assateague Island National
Seashore without a single horse removal. (See Attachment 3: USGS Economic
Benefits of Fertility Control and Turner/Kirkpatrick Fertility Control)

8. If the Park Service determines that the current population of horses must be reduced, then

American Wild Horse Preservation Campaign 1025 Alameda #633, Belmont, CA 94002

AWHPC Comments Mesa Verde Horses Removal EA

Page 4

analyze an alternative involving the use of PZP (to quickly attain zero population growth)
and natural attrition to reduce, and if necessary, humanely phase out this population. If the
park insists on removing horses, then incremental small removals of younger, more
adoptable horses can be incorporated into a population reduction and/or phase-out plan.
Given the 100+ year history of horses in the Park, it is reasonable to allow the horses who
reside there now to live out their natural lives in the Park.
8. Analyze and consider, given the horses unprotected status, other means of sterilization to
phase out horses from the Park over time.
9. Analyze an alternative to establish a public-private partnership for the implementation of a
rigorous and humane PZP fertility control program in conjunction with the local National
Mustang Association/Colorado Chapter or other interested and qualified organizations. This
could help offset management costs and increase community involvement in Park
operations.
10. Include the following provisions in any alternative that includes removals:
a. Bait trapping as a less traumatic alternative to helicopters;
b. Incremental removals of younger horses with better adoption potential over time;
c. Strict adoption criteria to ensure placement of horses into quality adoptive homes
so that they do not end up in the slaughter pipeline.
d. Working with the State Agriculture Department and local community
organizations, including NMA/CO, to establish an agreement that allows for the
adoption of horses and prevents their shipment to and sale at a livestock
slaughter auction.
11. Analyze the societal opposition to the removal of horses, as evidenced by the thousands of
letters that the Mesa Verde National Park has received over the past several years urging
protection of these horses.
VI. Adaptive Management Strategy Must Be Fully Analyzed
According to the 2015 NPS NEPA Handbook, (46.30) Adaptive management addresses the
fact that our knowledge of natural systems is incomplete and uncertainty often exists with
respect to whether actions will achieve desired 59 2015 NPS NEPA Handbook outcomes.
Through use of adaptive management, it is possible to adjust management actions over time as
knowledge of the natural system is gained through monitoring; thereby allowing management
actions to more fully achieve the intended results.
At a minimum, an adaptive management framework must include (ESM 13-11):

Desired outcomes of the management actions that are clearly defined;

Initial management actions aimed at achieving the desired outcome;
Activities that are monitored to determine whether the desired outcome is being
achieved; and
Adaptive actions that will be taken if monitoring indicates that desired outcomes
are not being achieved.

American Wild Horse Preservation Campaign 1025 Alameda #633, Belmont, CA 94002

AWHPC Comments Mesa Verde Horses Removal EA

Page 5

There are numerous reasons why the NPS should apply its adaptive management policy to the
proposed action of removing horses from the Park.
VII. Conclusion
It is imperative that the National Park Service fully analyze the impacts and alternatives,
including mitigating actions, listed above. It will not be sufficient to eliminate these
alternatives from consideration without serious analysis.
The National Environmental Policy Act (NEPA) requires Federal agencies to consider
environmental effects that include, among others, impacts on social, cultural, and economic
resources, as well as natural resources. The above-mentioned concerns, data and information
must be fully analyzed in the forthcoming EA.
The Mesa Verde horses add recreational enjoyment for Park visitors and offer a glimpse at the
living history of the Park and region. I hope you listen to the American public's strong support for
humanely managing and ensuring the well-being of the Mesa Verde horses within the Park.
Thank you.

Deniz Bolbol
American Wild Horse Preservation Campaign
1025 Alameda, #633, Belmont, CA 94002
Tel: 650.248.4489
Email: deniz@wildhorsepreservation.org
Attachments:
1. Grace Kuhn, AWHPC letter dated January 7, 2015
2. Kirkpatrick, Fazio, Wild horses as a native North American wildlife, 2010
3. Kirkpatrick, Turner, Achieving population goals in long-lived wildlife species (Equus caballus)
with contraception 2008

American Wild Horse Preservation Campaign 1025 Alameda #633, Belmont, CA 94002