Mesa Verde National Park "Livestock Removal" Environmental Assessment

May 11, 2018

Mr. Cliff Spencer, Superintendent
Mesa Verde National Park
PO Box 8
Mesa Verde, CO 8330

Re: N-79-08-1-9-1.B (MEVE)

Dear Mr. Spencer,

We appreciate the opportunity to submit comments on the Livestock Removal Environmental Assessment, N-79-08-1-9-1.B (MEVE) and thank you for your consideration of our perspectives and ideas.


We believe the horses should remain within the park boundaries. We acknowledge the contents of page 41 in the Livestock Removal Environmental Assessment that state “managing trespassing livestock” is not an option that is available to this agency. However, we feel that these wild horses should not be considered livestock but a wildlife species. In the United States wild horses are not regarded as livestock, as they are not farm animals, and are not animals domestically raised for slaughter and human consumption. These animals are a returned native species to this land, and therefore we feel they should be managed by this agency.

Wild horses are successfully managed in Theodore Roosevelt National Park in partnership with a volunteer organization, using a fertility control vaccine, and are not considered “trespassing livestock” within those park boundaries. The wild horses within the Bighorn Canyon National Recreation Area (BCNRA) are the number one reason people visit the park, and are managed by BCNRA which does not consider them “trespassing livestock.”

Advancements in veterinary sciences have allowed for wild horse populations to be managed in a humane and cost-effective manner on the range with fertility control vaccines, and there are a number of volunteer organizations in the area that have stated they would help with a population management program in MVNP.

Wild horses have wandered the trails of Mesa Verde National Park (MVNP) for 400 years and are a valuable part of the ecosystem. Horses forage on dry woody plants, effectively diminishing the chance of forest fires. They are constantly on the move - unlike livestock - and revegetate the land through their droppings, making them positive contributors to rangeland. Wild horses are also an attraction at MVNP. Promoting the ability to see and photograph wild horses in their natural setting is an opportunity for the park, not a detriment. Wild horses boost local economies by creating increased tourism that brings money in to local businesses. In Colorado, wild horses are the main economic driver in the small town of Maybell, and are similarly impactful in the town of Lovell, WY. It is short-sighted for this agency to ignore the economic benefits of wild horses.


If the horses are to be removed, we support portions of Alternative B including the Partnership Option outlined in the Livestock Removal Environmental Assessment. We have some suggestions regarding the processes described in this alternative that we examine below:

  1. We urge this agency to revise Alternative B to remove the MVNP wild horses over a period of five years, rather than a period of two years. After conversations with knowledgeable wild horse advocates in the area, including the National Mustang Association, Colorado (NMA/CO) and Jicarilla Mustang Heritage Alliance (JMHA), we have been made aware that these organizations are interested in partnering with MVNP during this process in order to market and advertise wild horse adoptions. The Cloud Foundation (TCF) would be willing to support these efforts as well, advertising wild horse adoptions to our following of over 500,000 members across the country. Extending the period of roundup and removal in MVNP will allow for enough time to effectively market, evaluate, and build momentum for good adoptive home placement for these animals.
  2. We believe this agency should include the use of the Porcine Zona Pellucida (PZP) fertility control vaccine in Alternative B during the removal process for these animals. As it is likely this removal will not start for at least another year, and will extend over a period of two years at a minimum, this would provide an opportunity to slow the reproductive rate in this herd. By doing so, this agency will reduce the chance of young foals and pregnant mares being stressed during periods of roundup and removal, and will also reduce the total number of animals that will need to be removed.
  3. TCF feels that it is critical for the post-removal holding period to be extended for these animals. As these horses will be in captivity for the first time in their lives, the 30 day holding period suggested in the Livestock Removal Environmental Assessment does not provide adequate time for these animals to assimilate to their new environment and adjust enough to be viable, adoptable animals. Extending this holding period to six months is consistent with a similar removal and adoption program that exists in Theodore Roosevelt National Park in partnership with a volunteer organization. That program has been shown to be successful. Even an extension to a 90 day holding period would at least give these volunteer organizations time to market animals that have adjusted to their new surroundings in order to place them in good homes. Additionally, if this agency is serious about finding adoptive homes for these animals, geldings are far more adoptable than stallions. If these animals are gelded, it will require more time in holding than the suggested 30 days before they are ready for adoption.
  4. If an opportunity presents itself for a partnership with NMA/CO or JMHA, we feel it would be prudent to allow these organizations to help with the training of some of these animals to increase their adoptability. It would be even better if some of the trained animals could be folded back in to the MVNP mounted program.
  5. Beginning to habituate the wild horses now to the already existing baited trap sites in MVNP will make the entire process easier for all involved. If this agency begins to use these traps as soon as a final decision is released, placing water tanks within the traps, the horses will become acclimated to these sites and will be less stressed at the time of the roundup. Putting water in these traps as soon as possible will also make it easier for those tasked with rounding up the horses, and cameras placed at these water sources would help with getting an accurate population estimate as well as allowing trappers to know whether the horses are using these sites.
  6. We support this agency’s proposal to use the much more humane method of bait trapping for this roundup and removal process. We are also appreciative that this agency is placing importance on not targeting foals under four months of age for removal, as well as not separating mare/foal pairs.
  7. We are concerned that repairing and maintaining fencing along the park boundary has not been effective at preventing animals from entering the park, as stated on page 7 of the Livestock Removal Environmental Assessment. We feel that if this agency wants no wild horses to live within the boundaries of this park, and the fencing efforts have truly been unsuccessful at keeping animals from bordering territories out of the park, this agency will enter into a constant cyclical roundup process as the park will never truly be free of these animals. We hope the failure of fencing efforts will be taken into consideration as this agency considers next steps in this process.


We are very grateful for the opportunity to offer our comments and we appreciate your willingness to listen to our thoughts. We believe that MVNP presents a special opportunity to showcase forward-thinking, cost-effective, humane wild horse management within the boundaries of a United States national park. If the removals do take place, we are hopeful that you will take advantage of the wonderful volunteer resources surrounding you in NMA/CO and JMHA in order to find these animals good adoptive homes in a safe, humane, and effective manner. TCF will help you in any way we can.

Please feel free to contact us with any further questions about our comments.


Ginger Kathrens
Executive Director
The Cloud Foundation

Kayah Swanson