We have been asked this question several times. The library section of our website has a copy of our last 25 page letter that we mailed with 15# of supporting documentation. Please feel free to use any information from that letter to express your concerns. Due to the changes in the analyses that the park has given us to consider, the comment letter that Chasing Horses Wild Horse Advocates submits will be different than the first one.
What the park DOESN’T want:
DO NOT comment – I pick “A” – this is NOT a vote. The options the park has released are things that they will research when they move into the next step and do their environmental assessment. They DO NOT need you to tell them to consider Option “A” – they already are! THAT is what their press release informed us of! If there are OTHER options that you think they should consider ASIDE from what they have shared with the public – THAT is what they want to know.
They also don’t want a form letter. We are also working with two other national wild horse advocacy groups and will be having some talking points soon.
What your comment letter SHOULD say:
When you state alternative analyses you think they should consider, make sure they are reasonably attainable analyses. Saying that the park should eliminate all of the bison and only keep the horses is NOT realistic. We are not aware of any reputable documentation that will support that for you.
Here is an example of analyses we asked them to consider in the last public comment period. Yours does not have to be this long. There is no length requirement or limit. Again, please understand that what we are all asking in our comment letters is what we think they need to research further when they move to the next phase and start their Environmental Assessment:
V. ADDITIONAL ALTERNATIVES THAT MUST BE CONSIDERED FOR TRNP’S WILD HORSE MANAGEMENT PLAN
CHWHA believes that the following analysis should be included in this process. We will go over each point in detail and share the supporting scientific and/or policy data to support our claim.
1. Theodore Roosevelt National Park must allow an analysis that allows for a minimum of 150 horses in the herd to maintain genetic diversity.
2. Theodore Roosevelt National Park must allow and analysis that takes the historical and cultural significance of these horses into consideration.
3. Theodore Roosevelt National Park must allow an analysis that speaks to the methods of birth control that will be used to maintain a genetically viable reproductive herd.
4. Theodore Roosevelt National Park must allow an analysis that speaks to the methods and strategies that will be used if removals continue to be necessary after the successful implementation of a birth control program.
5. Theodore Roosevelt National Park must allow an analysis that speaks to the need for Park Management to publish an annual report for the wild horses in TRNP, similar to what is done at Assateague Island National Seashore and Cape Lookout National Seashore.
Then we went one by one and explained why:
A. Allowing a MINIMUM of 150 Horses to Promote and Maintain Genetic Diversity BLM and Gus Cothran have repeatedly stated that 150-200 wild horses are needed to maintain genetic diversity. E.g., BLM Handbook, 126.96.36.199, at 22. It is well documented that the TRNP horses lack genetic diversity, and the presence of the lethal white gene is a sign of inbreeding. To promote genetic diversity within this herd, TRNP should consider an alternative that tiers towards the high end of BLM and Gus Cothran’s recommendation. The number of mares foaling for the first time in 4-6 years is bringing some genetic diversity into this herd. There is also a large population of horses (approximately 40) that are age 15+ that we know will be dying in the near future. BLM states that there should be an equal balance of male and female horses in each of the following age groups: 0-4, 5-9, 10-15, 15+.
The National Academy of Sciences noted that through the success of the implementation of their Wild Horse Management Plan for the Assateague Island wild horses, new age categories of 15-25 and 25+ have been adopted for that 16 herd. TRNP needs to work to bring the sex and age ratios back into balance for the health of this herd.
The BLM Handbook also states that maximizing the number of breeding age horses (age 6-10 years) and “introducing 1-2 young mares every generation (10 years) from other herds living in similar environments.” will help maintain genetic diversity. The NAS Report, moreover, states that: The probability of natural gene flow in free-ranging horses and burros varies among herds. In some herds, management actions have included removals that had unknown effects on the levels and distribution of genetic diversity. Isolation and small population size in combination with the effects of genetic drift, may reduce genetic diversity to the point where herds suffer from the reduced fitness often associated with inbreeding. That would compromise the ability of herds to persist under changing environmental conditions. NAS Report at145.
For all these reasons, TRNP should develop and analyze an alternative in which the herd is managed to include a minimum of 150 individuals with an equal balance of reproductively viable male and female horses in each of the following age groups: 0-4, 5-9, 10-15, 15+.
If you note above, Gus Cothran, the National Academy of Sciences (NAS) Report and The BLM handbook are all reference materials that back up the analyses we proposed. Those works are available to the public. The BLM handbook is available in the library section of our website https://chwha.org/library/. Since the NAS report is something that has to be purchased, we cannot share that freely here.
Also DON’T get caught up in the research aspect of this. We are handling that at CHWHA. Putting together a commonsense comment is more important. They need to know how you feel about what they are offering. There are also examples of that in our previous comment letter that can be found in the library section of our website. There are literally a few pages within our letter that tell them why the option to eliminate the herd altogether is not an option that should be considered.
Our best advice is to use the time you have to give your comment some thought. There is no reason to comment RIGHT NOW. We have until January 31, 2023. In the coming days and weeks, CHWHA, along with other national advocacy groups, will be sharing information that you can easily share within your own comment letter.
For NOW please sign up for the public meeting:
The NPS will hold a virtual public scoping meeting on January 12, 2023. Attendees can join by computer or phone to learn about the Livestock Plan. You can find information about joining the meeting on the project Planning, Environment, and Public Comment (PEPC) website: https://parkplanning.nps.gov/LP. Please note that comments can only be accepted through the PEPC website or by U.S. mail and will not be recorded or documented during the virtual meeting.
And start getting your thoughts together on WHAT you want the wild horse herd at Theodore Roosevelt National Park to look like.
Lastly, I want to just remind everyone and share for those who may not know – in the 1970’s Theodore Roosevelt National Park tried to eliminate the wild horses completely from the park. Public outcry from the people of North Dakota won and the horses were allowed to stay. THAT was before the internet and before literally millions of people from all over the world fell in love with these horses.
Does that mean it will be easy?
We said it before and will say it again, the park has shown their intent – eliminate the wild horses COMPLETELY from Theodore Roosevelt National Park. We know what the fight is and now we have to fight as hard as we can to change that. THAT will take each and every one of us – NO MATTER WHERE YOU ARE! YOUR VOICE IS LITERALLY THEIR VOICE AND THESE HORSES NEED YOU NOW MORE THAN EVER!!!
Please share your comments no later than January 31, 2023, online through the PEPC website at: https://parkplanning.nps.gov/LP
Or in writing to:
Theodore Roosevelt National Park
PO Box 7
Medora, ND 58645
Thank you for your support and please make a donation of any size to help support our advocacy work. At this time the help we need for our legal expenses to protect this herd is critical!
Chasing Horses Wild Horse Advocates is committed to advocating for a wild horse management plan and protection for these unique wild horses that call Theodore Roosevelt National Park home! We are fighting for a management plan that is guided by science especially when it comes to decisions regarding the removal of horses and the administration of birth control. Many other wild horse management plans have proven to be successful with their science-based plans. We are asking for the same for this amazing group of wild horses that call Theodore Roosevelt National Park home.