Breaking down the EA – part 1

Hello!  As promised, we will start breaking down the TRNP Draft EA that was released earlier this week.  There is A LOT in these 97 pages!  If you have specific questions, please continue to email them to us at info@chwha.org. We will respond as soon as we can, or we will make sure your questions are answered in a future blog post.

We want to start by saying that the park has a proposed action – total elimination of the horses.  We fully expected this document to support that, and it does – probably more than we even expected!

 The first couple of pages give a history and background that are self-explanatory. 

Page 3 is where the “good stuff” starts…

At the top of page 3, the park works to correct anyone who commented about the Park’s Foundation document during the previous comment period:

“while the 2014 Foundation Document for the Park describes horses as an “other important resource and value.” These are resources that are not fundamental to the Park’s purpose but are important to consider in planning processes (NPS 2014). In contrast, “fundamental resources and values” are those features, systems, processes, experiences, stories, scenes, sounds, smells, or other attributes determined to warrant primary consideration during planning and management processes because they are essential to achieving the purpose of the Park and maintaining its significance. Fundamental resources and values identified for the Park include native wildlife and habitat, the Little Missouri River, outstanding geological and paleontological resources, scenic views, wilderness and wilderness qualities, and built features related to Theodore Roosevelt’s time in the area.”

It seems that while the 2014 Foundation Document DID see the benefit of keeping the horses in the park, the Park is now making sure that we CORRECTLY understand that statement.

Page 4 talks about existing laws and policies.  For this section, we thought it would be helpful to have a copy of the full laws and policies, not just the parts the Park wants us to read.  We have added all of those listed here to the NPS Policy section of our website.

All I am going to say about this section is that we know for a fact that wild horses ARE allowed on National Park Service lands.  There is absolutely no talk about removing the wild horses from Assateague Island National Seashore or Cape Lookout National Seashore.  Quite simply, they do not classify their horses are livestock.  This park can do the same, if they choose. 

Page 5 is interesting because the “Purpose and Need” seems to have changed. 

Here is a screenshot of the original purpose and need we were given back in December of 2022. 

Compare that to the purpose and need we received in this EA:

PURPOSE AND NEED

The purpose of the proposed action is to address livestock—horse 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 a changing climate

• Align livestock management with relevant laws, regulations, and policies

• Emphasize bison management in alignment with Secretarial Order 3410

It seems that now, Secretarial Order 3410 has become part of the management of the horses?  We added this document to the NPS Policy page on our website.  Our guess is this means that the bison initiative is more important than the horses.  We are all for the bison, but not when less horses = more bison.  One species should never eliminate another. 

After the park maps, page 8 has a critical piece of information in this EA:

During public scoping for this EA the NPS identified Alternative C, Phased Reduction of Herds to No Livestock, as the proposed action. At this time the NPS has not identified a preferred alternative. The NPS will consider public comments on the EA and will identify the selected action in the finding of no significant impact (FONSI).

The Park states: “At this time the NPS has not identified a preferred alternative.”

*****Spolier Alert!*****

If you look at the last 2 pages of the document (arguably two of the most important pages), you will see that TRNP is telling us that they are NOT keeping horses in any capacity:

• Not as a nonreproductive herd
• Not as a reproductive herd
• Not as a genetically viable herd
• Not as a combination reproductive/nonreproductive herd
• Not as a historically or culturally significant herd
• Not at the Elkhorn ranch location

While they are NOT telling us yet what their preferred action is, they tell us very clearly what they will NOT be considering.

We will continue this discussion tomorrow starting with Chapter 2 of the EA. 

This EA is A LOT to read and there is A LOT to it.  Please try not to get discouraged.  We have a lot of work to do and we will need everyone’s help to save these horses!

Thank you for your support and have a GREAT day!

P.S. – Please don’t forget to bid on some of the amazing items in our very first online silent auction!  The auction ends on September 30^th!

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