The International Society for the Protection of Mustangs and Burros sued the U.S. Forest Service (“Service”) and its parent agency, the U.S. Department of Agriculture, to stop the Service’s planned capture, removal, and sale of feral horses from the Apache National Forest in Arizona. Plaintiff seeks declaratory judgment that the Service has violated the National Environmental Policy Act, the Wild Free-Roaming Horses and Burros Act of 1971, and the Administrative Procedure Act.