The #1 question we have been getting is about WHAT to comment.
Let’s look at what Theodore Roosevelt National Park has said they are looking for from YOU during this public comment period:
You are invited to submit comments on the information in this newsletter, the preliminary alternatives, proposed action, and what the EA should address and analyze.
THAT is what they want to hear from the public at this time.
Think to yourself – WHAT DO YOU WANT TO SEE WITH REGARDS TO THE WILD HORSES IN THEODORE ROOSEVELT NATIONAL PARK?
The park continues:
Comments that provide relevant and new information with sufficient detail are most useful. Comments that will be considered are those that present information that can be used when developing alternatives, present reasonable alternatives, or present information that can be used when the NPS considers impacts of alternatives.
This is the part we don’t want everyone to get bogged down with. If you aren’t or have never been a scientist, don’t try to be one now!
THAT doesn’t mean you can’t comment! You can have a great comment and still keep it simple!
Also know that Chasing Horses Wild Horse Advocates, American Wild Horse Campaign, The Cloud Foundation and other organizations and individuals WILL be submitting extensive comments to the park. That by no means is suggesting that you should NOT comment anyway!
So what should your comment letter look like?
For example, if you want to comment about the three alternatives the park gave and why those are NOT genetically viable options for this herd, one of the United States leading wild horse geneticists. Dr. Gus Cothran, answered that for all of us: https://www.kxnet.com/news/state-news/cutting-the-herd-size-at-theodore-roosevelt-national-park-could-be-bad/
The same link above will help you answer WHY Theodore Roosevelt National Park should consider an alternative that includes a MINIMUM of 150-200 ADULT horses in the park.
Those are not opinions that we made up. Dr. Gus Cothran weighed in SPECIFICALLY about the Theodore Roosevelt National Park wild horses.
Just make sure what you are sharing are FACTS – NOT OPINIONS.
American Wild Horse Campaign has also listed the following points that you can use for comments and things the park should be considering in their horse management plan:
Due to the controversial nature of the LMP and the myriad of legal, environmental, economic, and social issues it raises – which have not been evaluated, an Environmental Impact Statement (EIS) is required, and should consider and analyze the following alternatives:
- Change the designation of the Theodore Roosevelt horses from “livestock” to “wildlife.” The NPS has never explained why they’re designated as livestock and doesn’t acknowledge paleontological evidence and mitochondrial DNA analysis supporting the fact that wild horses are a reintroduced native species to this continent.
- Set a minimum herd size of 150 horses to ensure a genetically viable herd, as recommended by not only by Dr. Gus Cothran, geneticist and professor emeritus at the Texas A&M School of Veterinary Medicine but also as acknowledged in Bureau of Land Management’s Wild Horse and Burro Handbook.
- If “new blood” needs to be brought into the herd, introduce horses who are historically significant to the TRNP and prioritize the Nokota horses. A 2018 study from Texas A&M found that the historic herd is at risk of inbreeding (even at a number of 70-75 horses!) and recommended introducing new mares and changing removal strategies to preserve genetics and lineages.
- Given concerns about its potential for permanent sterilization and injection site abscesses, eliminate the use of GonaCon for the fertility control program. When administering any fertility control program, the NPS must consider the herd’s genetics and bloodlines as well as the safety of mares. Instead of GonaCon, the NPS should implement a fertility control program using PZP that has been proven to be reversible and safe for the mare.
You can sign AWHC’s letter here: bit.ly/3QONMJJ
The Cloud Foundation has also shared some good points for your comment letter:
– Preserving the TRNP horses MUST be a cornerstone of the Park’s livestock management plan, since they contributed to President Teddy Roosevelt’s wonder at the natural world, leading to his CREATION of the very FIRST NATIONAL PARKS.
– Horses have lived wild in TRNP for generations and MILLIONS of Park visitors view these animals as an integral part of the cultural heritage of the Badlands.
– These horses must be managed to preserve natural behaviors just as Teddy Roosevelt would have experienced. He would have seen stallions protecting their families, foals with their mothers.
– Protect the GENETIC HEALTH of the horses—the minimum population should be 150+. By allowing the horses to use additional areas of the Park, the herd can and should be managed at a HIGHER MINIMUM POPULATION LEVEL.
I was also talking to our legal team today and they said that since we sent in 15# of supporting documentation last time, we DO NOT have to send it again. We can assume the park has it and they have to reference it for this comment period too! That means you can quote from any of the documents listed in the Save the TRNP Wild Horses section of our website without having to send them in!: https://chwha.org/save-the-trnp-wild-horses/
Chasing Horses Wild Horse Advocates will be submitting a comment letter similar to our last one. Our legal team is working on updates to our comment letter so that it reflects the gravity of the new proposed alternatives. You can view our last comment letter here:
There are NO LIMITS on how many times you can comment. There is also no prerequisite for how long your comment should be. Please do not let yourself get bogged down because you think that you have to have a long scientific comment to submit. Your comments can be as simple as any or all of the bullet points above. Just make sure you are sharing FACTS on alternatives that you want them to consider. THAT is all they are asking for – WHAT ELSE SHOULD WE CONSIDER?
The park explained in their report about the last public comment period what they did with the comments they received:
The NPS developed a coding structure to help sort comments into logical groups by topics and issues. The coding structure was derived from an analysis of the range of topics discussed during internal NPS review, past planning documents, and the comments themselves. The structure was designed to capture all comment content rather than to restrict or exclude any ideas.
The NPS used its PEPC database to manage the comments. The database stores the full text of all correspondence and allows each comment to be coded by topic and issue. Some outputs from the database include tallies of the total number of correspondence and comments received, sorting and reporting of comments by a particular topic or issue, and demographic information regarding the sources of the comments.
The analysis of the public comments involved assigning codes to statements made by the public in their submitted letters. The NPS read and analyzed all comments, including those of a technical nature; those expressing opinions, feelings, and preferences of one element or one potential alternative over another; and comments of a personal or philosophical nature.
That being said, keep in mind the park has a SPECIFIC ask from the public at this time:
Comments that will be considered are those that present information that can be used when developing alternatives, present reasonable alternatives, or present information that can be used when the NPS considers impacts of alternatives.
The MOST IMPORTANT thing is to make sure you comment!
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:
Superintendent
Theodore Roosevelt National Park
PO Box 7
Medora, ND 58645
Thank you for your support!
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.