We thought it might help give some insight into this wild horse management planning process, which we expect will take two years to complete.
We are currently in the beginning stages of the horse management planning process. TRNP has come forth with “Draft Alternatives,” which are merely proposed strategies for managing the herd in the future. Importantly, the list of alternatives proposed by TRNP is NOT exhaustive; members of the public have been explicitly invited by TRNP to propose additional alternatives. We are NOW in the middle of the public comment period where we can (and should) propose different alternatives than those listed by TRNP (i.e., how and why you think TRNP’s wild horses should be managed going forward).
TRNP’s development of the wild horse management plan, including its alternatives analysis, is proceeding according to a federal law known as the National Environmental Policy Act (“NEPA”). Under NEPA, TRNP is required to take a “hard look” at ALL of the environmental impacts of and alternatives to its proposed action (i.e., the development of a management plan). For proposed actions that have a “significant” environmental impact, like this one, the agency MUST prepare an Environmental Impact Statement (“EIS”). Where it’s unclear if the environmental impact will be significant (which is not the case here), federal agencies may prepare an Environmental Assessment (“EA”).
Since the TRNP’s plan entails long-term management of horses that are historically important to the Park, unique to North Dakota’s Badlands, and have long been a controversial subject, we contend that this plan will in fact entail “significant” environmental impacts. As such, we believe that the park should be encouraged to conduct an Environmental Impact Statement (EIS) instead of an Environmental Assessment (EA). An EIS is typically a more in-depth environmental review than an EA. For example, when TRNP developed an Elk Management Plan in 2008-2010, they prepared an EIS. You can view the EIS that was prepared for the Elk Management Plan here: Parkplanning – Final Elk Management Plan/EIS (nps.gov)
Once the current public comment period closes, TRNP will begin analyzing and comparing the environmental effects associated its proposed alternatives, as well as those alternatives proposed by members of the public. Once TRNP has completed this analysis, which they said will be in Spring of 2023, they will share their DRAFT NEPA document with the public (AGAIN WE WOULD ENCOURAGE YOU TO COMMENT THAT YOU PREFER THEY CONDUCT AN EIS INSTEAD OF AN EA!). This will begin the second and final public comment period for this management planning process.
During this second public comment period, they will let us know which of their proposed alternatives they decided to carry forward for further analysis in either a Draft EIS or Draft EA (although we think an EA would be inappropriate). We will have the opportunity to comment on that document once it has been published by TRNP, and we will go into more depth about their analysis at that time.
Once the second public comment period has been completed, they will begin preparing a final NEPA document. That final document will be accompanied by either a Record of Decision (for an EIS) or a “Finding of No Significant Impact” (for an EA) where they will let us know which of the alternatives they decided to implement as their new horse management plan and why.
We have two chances to voice our opinions on the way we would like TRNP to manage the wild horses. While Chasing Horses Wild Horse Advocates is very excited about the initiation of the highly anticipated wild horse management plan, we also know that navigating through this process is extremely complex. THAT is why we have retained Eubanks & Associates, PLLC to help us navigate through this entire process. If you look at the EIS developed for the Elk Management Plan, we think you will agree that the wild horses of TRNP need someone on their side to help make sure that the best possible management plans are put in place to ensure that the wild horses of Theodore Roosevelt National Park continue to survive and thrive for generations to come.
As always, please feel free to ask us any questions during this historic process. We will do our best to answer you personally or create a post based on your questions and concerns during this process.
Thank you for your support!