Wild Horse Management Plan – Comment time

The wild horses have been part of Theodore Roosevelt National Park from the time they were accidentally fenced in when the border fence of the park was put up in the 1950’s. 


That is all changing NOW!

Theodore Roosevelt National Park announced the initiation of the new management plan for the wild horses.  I will add the links, but please note, I have had issues with the links opening in Chrome but have not had issues in Internet Explorer.  If you get an error page, please try a different browser.

First things first – there is a Zoom Meeting on March 30, 2022 at 6 pm MST.  You can pre-register for the event here: https://empsi.zoom.us/webinar/register/WN_Xm0AeNRoQ5G2-9NAwDEC5Q

Second, there are several different proposals in their newsletter that announces this new management plan.  Please note: Our legal team, that is very well versed in all aspects of wild horse management and wild horse advocacy, calls this their “scoping document”.  What is listed here as part of their “options” does NOT mean that ANY of these will end up being the final plan.  This is where public comment becomes sooooo important!

Our lawyers have done their homework, so we have a lot to cover here.  We want to note a few things about this public comment process:

  • Chasing Horses Wild Horse Advocates will be creating a very long submission with documentation to support what we are asking to be considered in this management plan.  We are including a condensed version of that here.
  • PLEASE submit any supporting documents that you may have that support any suggestions you are making.  THEY WILL NOT CLICK ON LINKS!!!! If the supporting document, you have is on a website – YOU HAVE TO CREATE A PDF FILE FROM THE WEBSITE AND SUBMIT THAT!  Think of this as submitting “evidence” – EVEN if you KNOW the park has a copy of something or even if it is document they produced themselves – YOU HAVE TO ENTER IT HERE TO MAKE SURE THAT IT IS LOOKED AT FOR THIS PROCESS!  The Administrative Procedure Act protects us during this process but ONLY if your information is submitted properly. Your comments on the planning page have NOTHING to do with the virtual meeting!  MAKING A COMMENT DURING THE VIRTUAL MEETING DOES NOT REPLACE THE IMPORTANCE OF YOUR COMMENTS ON THIS PUBLIC COMMENT WEBSITE!!
  • What we are offering here are suggestions for you to submit.  Some/All/None of these may be important to you – and that is fine!  We ARE asking that you do not simply cut and paste all of this and put it into a comment.  “Blanket” comments are not going to be as impactful as your own unique comment.
  • A website has been created where all public comments will be taken throughout this process.  The current public comment period is open through APRIL 15, 2022 at 11:59 PM MST. https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=119270&fbclid=IwAR2FTyFLa2gOMqgcw39Qtb_EjFcCoKkZIhVvN-nkGnXZkdMFv8oKc8MP8nY

Key points to make:

(1) Although the Park considers these horses to be “livestock,” it has never explained why they are designated as such, especially since these animals have been roaming free there since well before the Park’s establishment. The distinction is important.  The wild horses in TRNP are VERY different than the long horns.  We believe that there should be a separate wild horse management plan, more importantly the park should clarify how the horses got this distinction.  This is one point that we did not get a response from in our FOIA (Freedom of Information Act) request.  This is important because it dictates the way the horses are managed.  Here is one of many citations from our legal team discussing this point:

  • The TRNP’s classification, however, runs counter to the plain language of the NPS’s implementing regulations. Although those regulations do not define “livestock,” that term generally refers to domesticated animals. See Livestock, Webster’s New Collegiate Dictionary (7th ed. 1967) (“[A]nimals kept or raised for use or pleasure.” (emphasis added)); see also 43 C.F.R. § 4100.0-5 (BLM regulations defining “livestock” as “species of domestic livestock – cattle, sheep, horses, burros, and goats.” (emphasis added)). By contrast, here, there is no indication that the wild horses found in the TRNP are domesticated in any way; that is, they have never been fed, sheltered, or cared for in any way by the Park. And, while these horses may be descendants of domesticated animals, the Park itself refers to the modern population as “feral”— a term that, by definition, means these horses are no longer “domesticated or cultivated.” See Feral, Webster’s New Collegiate Dictionary (7th ed. 1967) (“[O]f, relating to, or suggestive of a wild beast”); see also Wild Horse EA at 1 (characterizing the TRNP herd as “feral”); Foundation Document at 36 (same). Moreover, as mentioned above, wild horses have roamed free across North Dakota’s Badlands (and, specifically, the Park area)—without human intervention—since well before the TRNP even existed. See Horse Background, supra.

(2) As far as all of their “proposals” with several different targeted herd sizes, Gus Cothran, the leading wild horse geneticist in the US, has stated time and time again that 120 horses MINIMUM are what is needed for a genetically viable herd.  If you mention this, please make sure you google Gus Cothran and submit one of the papers where he mentions this with your comments.  This point is also supported by Theodore Roosevelt National Park’s own 1978 Environmental Assessment, which they are currently using to manage this herd:

  • During its evaluation of the potential impact of different herd reduction strategies, NPS invited Milton Frei, a Bureau of Land Management (“BLM”) Range Conservationist specializing in wild horses, to comment on NPS’s proposed action. See BLM, Wild Horse Herd Evaluation Report for Theodore Roosevelt National Park (1977) [hereinafter BLM Report]. In broad terms, Mr. Frei observed that “[t]he habitat in [the TRNP] can best be described as excellent for wild horses,” meaning “that the park could support a much larger population of wild horses without adverse impacts upon the soil or vegetative resources as well as other wildlife species.” Id. at 1 (emphases added). He also noted that the NPS’s determination regarding the “‘optimum numbers’ of wild horses” on the TRNP is, “for the most part, an arbitrary and administrative decision” by the NPS. Id. at 3.

(3) The park has in the past tried to introduce “new blood” by taking horses that are not native to North Dakota and hoping they would be successful here.  These efforts have proven to be an epic failure every single time!  IF any horses are introduced as “new blood” we believe that Theodore Roosevelt National Park should ONLY consider the horses that help the park maintain it’s pledge for historical significance and re-introduce the Nokota horses to Theodore Roosevelt National Park.  I spoke with Frank Kuntz about this on Wednesday and he is STILL willing to work with the park to re-introduce the Nokota horses.  Both TRNP and Frank Kuntz have enough genetic information on their respective horses to make sound choices when it comes to the re-introduction of the Nokota horses in Theodore Roosevelt National Park.  Our lawyers further argue:

  • The TRNP is well aware of which types of horses best represent those that “existed in the park during the park’s period of historical significance,” or were “commonly used in the local area at that time.” Id. In the late 1980s, the Park commissioned a 300+ page study that investigated “the origins and history of feral horses in [North Dakota’s] Badlands,” and recorded “the genealogy of the extant herd.” See Castle McLaughlin, The History and Status of the Wild Horses of Theodore Roosevelt National Park at viii (Dec. 1989), https://bit.ly/365UtUy [hereinafter “Castle Report”]. Based on extensive archival research and numerous interviews, the report ultimately recognized that the horses found in the TRNP were descendants of two closely related stocks (ranch and Indian), which, together, represent a type of “original” Badlands horse. Id. at 244; NPS, Natural Resources Management Plan and Continued Environmental Assessment at 46-47 (1984) (referring to the TRNP horses as “a historic badlands horse herd, with the animals being direct descendants of the horses which were found here when the park was founded”).

This historical lineage traces all the way back to the horses surrendered by Sitting Bull in the late 1800s. See Castle Report at 70. For this reason, the Castle Report recommended that the TRNP take care to manage the herd in a way that preserves this historical lineage. See id. at 250-52.

(4) It is NOT specifically mentioned but needs to be addressed and voiced: the use of birth control.  We will NOT say that we are apposed to the use of GonaCon.  We are opposed to them using a one and done shot that permanently sterilizes ALL mares.  IF current experiments with this dosage prove to be safe for our horses, we believe this could possibly be a great alternative for older mares with bloodlines that are well represented.  We are opposed to the TRNP herd being the subjects of any further experimentation.  Other uses of birth control need to take genetics, and bloodlines into consideration.  Other wild horse programs have demonstrated the success of administering birth control to mares on a rotating basis.  This also helps prevent the risk of permanent sterilization known to be a concern of many forms of birth control for wild horses.

(5) A successful birth control program SHOULD mean that there is a reduced need to cull the herd.  We also understand that the herd may still need to be culled from time to time.  When the herd is culled, quite simply, science and genetics need to be the driving force in the decision-making process.  This is why the classification of these horses is important.  There are National Park Service polices that dictate proper management for every classification. TRNP needs to STOP managing these horses as if they are nothing more than a number. 

These are 5 points of many that we feel are important to be included in the new horse management plan.  Please feel free to use any or all of these in your own personal comments on their website.  Your comments and their newsletter can be found here: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=119270&fbclid=IwAR2FTyFLa2gOMqgcw39Qtb_EjFcCoKkZIhVvN-nkGnXZkdMFv8oKc8MP8nY



This is our chance to make sure that the wild horses of Theodore Roosevelt National Park continue to survive and thrive for generations to come!

After trying to work with the park on NUMEROUS occasions over the last few years for the proper management of this herd, we hope that the small snippets we have shared from our legal team help show the importance of having this team help us through this process.  Please consider making a donation to Chasing Horses Wild Horse Advocates to help support our advocacy efforts!! https://chwha.org/support-chwha/

Our lawyers have made it clear repeatedly in their communications with Theodore Roosevelt National Park that CHWHA is still committed to working WITH them to ensure the viability of the herd. 

Thank you for your support and feel free to email us or comment with any questions or concerns. 

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