The wild horses of Theodore Roosevelt National Park need our HELP!
The National Park Service (NPS) is currently seeking public input on a Draft Environmental Assessment (EA) for a Livestock Plan for the wild horses of Theodore Roosevelt National Park (TRNP). They have gone from classifying them as Feral or Wild Horses to reclassifying them as Livestock in a plan to eradicate them entirely from the park!
The 97-page EA can be read by clicking HERE and then downloading the PDF under ‘Document Content’. We highly encourage you to read and try to understand it to the best of your knowledge.
(Please Note: This is NOT a public vote.)
Alternative A
No Action Alternative: Continued herd management under the 1978 EA and 1970 Management Plan. Stewardship would continue under current management plans with a population objective of 35–60 horses. The NPS would continue to use capture and contraceptive techniques to maintain horse numbers at the population objectives defined in the 1978 EA.
Alternative B
Action Alternative: Expedited reduction of herds to no livestock. This alternative would require the active capturing of horses in the park with the methods best suited to reducing the population to zero in an expedited fashion.
Alternative C
Proposed Action Alternative: Phased reduction of herds to no livestock. This alternative would also require active capture of horses with the methods best suited to reducing the population to zero but in a phased approach.
Although wild horses are a reintroduced native species, the NPS classifies them as “livestock” even though they have roamed the badlands for centuries, and the Park provides no care for them. The horses fend for themselves alongside bison, elk, and other wildlife. In addition, the NPS refers to them as a non-native species despite scientific evidence suggesting otherwise. Also, what is driving the removal of the wild horses is the Park’s need to align management of its bison herd with Secretarial Order 3410 which is a Department of the Interior’s initiative to restore wild and healthy populations of American bison and the prairie grassland ecosystem.
During the scoping period, 19,000 public comments were submitted, with the majority requesting the NPS maintain a genetically viable herd of at least 150 horses in the TRNP. North Dakota Governor, Doug Burgum, North Dakota State Legislation, and other non-profit organizations have offered resources to help the NPS maintain the wild horse herd at this level. The NPS, however, dismissed an alternative that would allow for a minimum of 150 horses in the herd to maintain genetic diversity!
Theodore Roosevelt wild horses need a better solution. Moving forward, the NPS must adopt a management plan that uses current science and herd data to maintain a healthy breeding population of at least 150 horses while maintaining vital bloodlines.
The park is currently asking for your input on the EA.
COMMENT NOWThe comment period is open until November 24th, 2023 at 11:59 PM Mountain Time.
This will be the last opportunity for the public to offer feedback on this EA.
All comments, challenges and arguments should refer back to the
“Purpose and Need Statement”
which reads as follows:
The purpose of the proposed action is to address livestock – horses and cattle herds – within the Park, under relevant laws, regulations, policies and management priorities, including the conservation of native species and natural prairie ecosystem functions.
The proposed action is needed to:
• Address operational commitments to livestock management.
• Address potential impacts of livestock on the landscape and natural resources, including native wildlife, native vegetation, and water resources.
• Address potential impacts of livestock on cultural resources including archeological sites and cultural landscapes.
• Provide resiliency for native ecosystems and species in the face of changing climate.
• Align livestock management with relative laws, regulations, and policies.
• Emphasize bison management in alignment with order 3410.
Tips For Commenting
Directly from the NPS website, here are TIPS FOR COMMENTING on Environmental Assessments (EA) and Draft Environmental Impact Statements (EIS)
You can examine and comment on sets of proposals (known as “alternatives”) when an Environmental Assessment or Draft Environmental Impact Statement for a project is released. Ideally, comments assess the adequacy of the document in disclosing and evaluating a project’s effects on the environment.
The following comments are most useful if they are as specific as possible and do the following:
• Discuss a particular plan element or alternative.
• Identify incomplete or incorrect information.
• Offer reasons why a particular alternative or plan element would or would not work.
• Offer a reasonable, new plan element or completely new alternative that could help accomplish the stated goals.
• Point out discrepancies between legal mandates and proposals.
• Highlight deficiencies in the analysis of environmental consequences.
• Discuss the efficacy of proposed mitigation measures.
• Provide information on how you use the park and how particular proposals in the planning document would affect that use.
For more information on Tips:
Writing a Substantive Comment
All comments received are considered within the designated comment period for any document, and analyzes those comments to determine which are “substantive”. All substantive comments are responded to, and comments that repeat the same basic message will typically be responded to collectively.
Substantive comments are those that:
· question, with reasonable basis, the accuracy of the information in the NEPA document;
· question, with reasonable basis, the adequacy of the environmental analysis;
· present reasonable alternatives other than those presented in the NEPA document; or
· cause changes or revisions in the proposal.
In other words, substantive comments raise, debate, or question a point of fact or analysis. Comments that merely support or oppose a proposal or that merely agree or disagree with NPS policy are not considered substantive and do not require a formal response.
Thank you for your support!
