Breaking Down the EA – part 3

So, what happened to all of the comments that 19,000 people submitted that we know overwhelmingly asked the park to allow the horses to stay?

You will find that answer in the last 2 pages of the Environmental Assessment – Appendix D: Alternatives Considered But Dismissed From Further Analysis

When you look at the last 2 pages of the document, 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

And yes, they do answer the question of why.  The following statement was added to the end of just about every alternative:

“This alternative would continue management not in alignment with NPS priorities to maintain the native prairie ecosystem. This alternative would not meet the project’s purpose and need, because it also would not address the livestock’s impacts on natural and cultural resources or comply with relevant laws, regulations, and policies. Therefore, it was not brought forward for further analysis.”

Let’s look at that:

This alternative would continue management not in alignment with NPS priorities to maintain the native prairie ecosystem.

What IS a “native prairie ecosystem”?

We have no idea.  The Park has not defined that for us.  How can we, as part of the general public, comment on something that has not been defined? Maybe they will discuss this in their Civic Engagement meeting.  At this time, we don’t know when that will be.  The Civic Engagement meeting scheduled for next week has been cancelled due to the scheduling conflict we brought to their attention with the Medora City Council meeting.  This is just another reason why this comment period needs to be extended.

The second part of the reasons that we are given why the Park will not allow horses in any capacity:

This alternative would not meet the project’s purpose and need, because it also would not address the livestock’s impacts on natural and cultural resources or comply with relevant laws, regulations, and policies.

They gave us their purpose and need statement at the beginning of the report:

1.3 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

We also discussed the policies in our previous posts and have listed the policies cited in this Draft EA on our website.

As we said before, since we know there is not a concerted effort to eliminate horses from other national parks, we know that the policy aspect of this argument is not valid.

What IS concerning is that under Appendix D, the section about reproductive herds in the park sounds A LOT like Alternative A – the “no action” alternative the Park has offered us, doesn’t it?:

Reproductive Herds Maintained in the Park—This alternative would require gathering and selling some young horses (three years of age or younger), fertility control of a subset of the herd, maintaining a representative group of reproductive horses, and release to the Park’s South Unit. The number would be maintained at 30–70 horses through reproduction and introduction of new reproductive horses. Cattle would be placed in a new pasture in the North Unit, separate from bison; the number would be maintained at 15–40 cattle by introducing additional reproductive cattle over time. The NPS would need to construct and maintain infrastructure, such as fencing and water pipelines, to implement this alternative in both units. The NPS would also need to provide forage and water in both units. A genetic management plan would need to be developed for both species in both units.

This alternative would continue management not in alignment with NPS priorities to maintain the native prairie ecosystem. This alternative would not meet the project’s purpose and need, because it also would not address the livestock’s impacts on natural and cultural resources or comply with relevant laws, regulations, and policies. Therefore, it was not brought forward for further analysis.

It is somewhat contradictory that they give us Alternative A, which would allow for a reproductive herd in the park and then in Appendix D tell us that they are NOT considering keeping a reproductive herd in the park. 

We will ask again, is the park engaged in an OBJECTIVE NEPA process?

We will list Appendix D at the end of this post because it is extremely important for everyone to read. 

Tomorrow we will go through the rest of the EA and wrap up this series. 

This series is meant to help shed light on some areas where people had questions and help you digest the EA in smaller pieces.  We strongly encourage you to read the entire document for yourself so you can remain educated on what the park is proposing and why. 

As always, feel free to continue to send us your questions.  You can email them to us at info@chwha.org.

Thank you for your support! 

P.S. Reminder: Our online silent auction ends TOMORROW (9/30/23) at 8 PM MST – have you checked your bid lately? https://chwha.betterworld.org/auctions/chwha-september-2023-silent-auct

APPENDIX D: ALTERNATIVES CONSIDERED BUT DISMISSED FROM
FURTHER ANALYSIS

The project planning team considered the following alternative methods for removing livestock, but dismissed them from further consideration, as described below.

Nonreproductive Herds Permanently Maintained in the Park—This alternative would manage nonreproductive herds of horses and cattle in various locations in the Park (North Unit, South Unit, or Elkhorn Ranch Unit). This would require gathering and selling young horses (3 years of age or younger) and implementing fertility control of the remaining horses, whether they are pastured or released to roam the full extent of the South or Elkhorn Ranch Units. Cattle would be placed in a new pasture in the North Unit or Elkhorn Ranch Unit, separate from bison, and replaced with additional cattle as older cattle die. The NPS would need to construct
and maintain infrastructure, such as fencing and water pipelines, to implement this alternative in all units. The NPS also would need to provide forage and water.

This alternative would continue management not in alignment with NPS priorities to maintain the native prairie ecosystem. This alternative also would not meet the project’s purpose and need, because it would not address the livestock’s impacts on natural and cultural resources or comply with relevant laws, regulations, and policies. Therefore, it was not brought forward for further analysis

Reproductive Herds Maintained in the Park—This alternative would require gathering and selling some young horses (three years of age or younger), fertility control of a subset of the herd, maintaining a representative group of reproductive horses, and release to the Park’s South Unit. The number would be maintained at 30–70 horses through reproduction and introduction of new reproductive horses. Cattle would be placed in a new pasture in the North Unit, separate
from bison; the number would be maintained at 15–40 cattle by introducing additional reproductive cattle over time. The NPS would need to construct and maintain infrastructure, such as fencing and water pipelines, to implement this alternative in both units. The NPS would also need to provide forage and water in both units. A genetic management plan would need to be developed for both species in both units.

This alternative would continue management not in alignment with NPS priorities to maintain the native prairie ecosystem. This alternative would not meet the project’s purpose and need, because it also would not address the livestock’s impacts on natural and cultural resources or comply with relevant laws, regulations, and policies. Therefore, it was not brought forward for further analysis.

Allow for a Minimum of 150 Horses in the Herd to Maintain Genetic Diversity—A decision was made in the 1960s to limit herd sizes in the Park to approximately 40 horses in the South Unit. Based on the analysis of impacts from horses in the Park, the 1978 EA selected an alternative to maintain the horse herd at 35–60 head (NPS 1978). An alternative to manage for a herd of 150 horses would not fall within the allowable numbers of horses identified in the EA. There is no cattle component to this alternative. This alternative would continue management that is out of alignment with NPS priorities to maintain the native prairie ecosystem. It also would not meet the project’s purpose and need, because it would not address livestock’s impacts on natural and cultural resources or comply with relevant laws, regulations, and
policies. Therefore, it was not brought forward for further analysis.

Manage a Reproductive and Nonreproductive Herd in Separate Areas—This alternative would require infrastructure to separate reproductive and nonreproductive herds of horses and cattle in both the South and North Units, as described above. It would continue management not in alignment with NPS priorities to maintain the native prairie ecosystem. It also would not meet the project’s purpose and need, because it would not address the livestock’s impacts on
natural and cultural resources or comply with relevant laws, regulations, and policies.
Therefore, it was not brought forward for further analysis.

Manage a Herd for Historical and Cultural Significance—Horses and cattle existed on the landscape during the time that Theodore Roosevelt resided at Elkhorn Ranch. While horses and cattle are identified as part of the area’s cultural history, there is no NPS statute, regulation, or policy requiring the Park staff to manage horses or cattle at the ranch. This alternative would continue management out of alignment with NPS priorities to maintain the native prairie ecosystem. This alternative also would not meet the project’s purpose and need, because it would not address the livestock’s impacts on natural and cultural resources or comply with
relevant laws, regulations, and policies. Therefore, it was not brought forward for further analysis.

Manage a Nonreproductive Herd at Elkhorn Ranch—This alternative suggested having nonreproductive herds of horses or cattle at the Elkhorn Ranch Unit. This would solve some of the management issues, such as eliminating the need for roundups, while keeping herds on the landscape to fulfill the interpretive and historic vision of having cattle on the landscape, as when Theodore Roosevelt resided at Elkhorn Ranch. This Unit is highly forested with juniper, and only about 150 acres are available for forage. This alternative would require supplemental feed for cattle, and it would not be conducive to horses. In addition, there are currently no horses,
cattle, or necessary facilities at Elkhorn Ranch. The Park staff would have to move livestock and build infrastructure, which would continue management not in alignment with NPS priorities, to maintain the native prairie ecosystem. The alternative would also add impacts on resources where infrastructure is built (parking, fencing, bathrooms, hay storage, etc.). Because this alternative would not meet the project’s purpose and need to address NPS priorities to maintain
the native prairie ecosystem, it was not brought forward for further analysis.


Leave a Reply

%d