Wild Horse Education

2 comment periods

There are 2 active comment periods gaining a lot of attention in the world of wild horses.

Both are very unique situations that deserve scrutiny. As you craft comments (if you decide to participate) keep in my that both are not representative of the vast majority of comment periods you have participated in for most herds the last couple of years. Please take time to review linked material if you decide to comment. 

We added info below on Theodore Roosevelt (NPS) and McCullough (BLM) for those of you requesting where and how to comment. Both of these removal plans will have one more round of “public comments” before any removal happens. 

Theodore Roosevelt, National Park Service (NPS):

Update, 1/22/22: North Dakota State Representative Josh Boschee, District 44, has asked NPS to extend the comment period for 60 days. Many constituents have reached out asking that they state become involved to protect the only wild horse herd in the state and the tourism it provides. The state rep has asked for the extension to determine if this is a matter the state will comment on. (more here)

EDIT, 1/25: The request for extension was denied by the park. 

EDIT, 1/26: A letter was introduced by the North Dakota Senate in support of keeping wild horses in the park. You can read the resolution HERE.

At this time, public comments are still due January 31. 

Last spring the National Park Service (NPS) began a scoping process to create a “livestock plan” for the park that currently maintains both a herd of horses and about 12-30 longhorn cattle. At the beginning of the process there were 6 alternatives under discussion and it appears they have narrowed it down to three; two of which involve removing horses and cattle completely.

An “info” meeting was held last week where NPS essentially simply explained what they wrote in this informational pdf that outlines the 3 alternatives and deadline for comment submission (January 31). Click here for pdf. 

NPS is not required to comply with the 1971 Wild Free-Roaming Horses and Burros Act.

However, the park manages the only wild horse herd in the Dakotas. The small herd is in a unique legal jurisdictional bind as NPS has no legal requirement under the 71 law.

Relevant comments could reflect something like:

Please consider expanding Alternative A to include managing a genetically viable reproductive population of 160-200 wild horses within the park and establishing an annual adoption program in partnership with advocate organizations. The park has consistently recognized the historic value of maintaining wild horses in the Dakotas. Removing this herd would deprive the public of the ability to experience the park in historical context. 

In addition, new research has demonstrated that the designation of “livestock” for horses in the Badlands is scientifically unsound and should be changed to “native horse” or “reintroduced native.” 

All materials relevant to the planning process can be found at:  https://parkplanning.nps.gov/LP However, the site has been malfunctioning all week. We suggest sending comments through the mail to: Superintendent, Theodore Roosevelt National Park, PO Box 7, Medora, ND 58645

This herd is very unique and has an organization devoted solely to helping you understand the specifics of this herd. They keep an archived page of relevant documents and contact info. North Dakota Badlands Horse

2 young fillies leaving area of the water trough

McCullough Peaks, Bureau of Land Management: 

McCullough is a smaller HMA in Wyoming that covers about 120,000 acres. BLM has the AML set at a range of 70-140 wild horses. The population has reached 179 wild horses.

BLM has opened a “scoping period” prior to crafting the gather-ea.

The BLM proposes removing the herd to low AML of 70 wild horses and changing the method of fertility control used on the herd. The smaller size and almost two decades of agreements with local groups make this herd (and comment period) different than the vast majority of Gather-ea comment periods.

Since 2005, BLM partnered with a local group (Friends of a Legacy, FOAL) and allowed the group to clean and maintain 3 water sources. In 2011, the agreements began to use darting of PzP for fertility control. BLM now proposed to add additional types of fertility control that are likely to include substances and methods aimed at permanent infertility.

Definition of this scoping period from BLM letter: The BLM will utilize information presented from the scoping to prepare an environmental assessment (EA). Scoping activities identify reasonable alternatives to be evaluated in the environmental analysis that meet the purpose and need for the project. Through this process, environmental issues related to the proposed gather are identified, the depth of analysis for issues addressed in the environmental document determined, and potential mitigation for population control are identified. The EA will identify all practicable means to avoid or minimize environmental harm from the project and alternatives and provide the responsible official with information upon which to make an informed decision regarding the project as well as affording the public an opportunity to provide comments and input. The EA will be prepared by an interdisciplinary team of BLM resource specialists.

All comments must be received by Feb 7.

Written comments will be accepted at the address below or through the BLM’s NEPA register at https://eplanning.blm.gov/eplanning-ui/project/2022012/510.

Please refer to Project Number DOI-BLM-WY-R020-2023-0003-EA.

Our team has not completed review of environmental information and historic documents. It can take us a couple of weeks to craft a substantive comment.


Our teams are working on various projects and coordinating our formal statements for 2023.

As many of you are aware, it is going to be a roller-coater of a year. Heck, even disgraced former Secretary of the Interior Ryan Zinke is back in Congress spewing propaganda to hide the fact that there is evidence of ethics violations against him.

Hang on, 2023 is set to be a bumpy ride.

More coming from WHE soon.

Categories: Wild Horse Education