Breaking Down the EA – part 4

Hello again! We hope that these series of posts are helping you understand the Draft Environmental Assessment that Theodore Roosevelt National Park released on September 25, 2023.  We do want each and every one of you to read the Draft EA for yourself.  We also need EVERYONE to comment!  We will be going through points to make strong comments this week.  We will also be holding a Horse Talk THIS FRIDAY (October 6, 2023) where we will give a power point presentation and answer your questions on the Draft EA.  This event is FREE but we do ask that you register in advance.

In addition to that, we are working out details to hold weekly Zoom meetings hosted by other wild horse advocate friends to help answer questions and raise awareness on how and what to comment during this very critical public comment period.  Please watch for updates and announcements coming soon!

Today’s post will just go through the “fluff” within the Draft EA.  We do hope that you have taken the time to watch our Horse Talk from last week with Dr. Ross MacPhee.  He brought some great points up about the Draft EA as well as shared some fascinating FACTS about wild horses and research that has been done.  You can view the Horse Talk here:

We feel that it is very important to reiterate that there is currently no concerted effort by the National Park Service to eliminate wild horses from any other national park.  We also listed the policies they cited on our website for you to review.  We think after you look at them you will see that the park is NOT giving the full story about these policies. 

Secretarial Order 3410 – Restoration of American Bison and the Prairie Grasslands was also added to the “Purpose and Need”.  If you watch our Horse Talk with Ross, you will see how contradictory this is with the section of comments about global warming in this Draft EA.  Less horses obviously equals more bison.  More bison equals more methane gas, which we know IS actually contributing to global warming. 

The Park is not answering questions from anyone, including the North Dakota media, who is asking for clarification on a number of things.  They have been redirecting them to participate in the Civic Engagement meeting that was scheduled for this Tuesday, October 3rd but is now being rescheduled.  The meeting was moved when Chasing Horses Wild Horse Advocates brought to their attention that they scheduled a meeting during the same day and time that the Medora City Council was holding their monthly meeting.

One of the things that definitely needs clarification is in Alternative C – the Park’s original “proposed action”.  On page 10 they state that:

“A representative subset of nonreproductive (chemically or surgically contracepted) horses would be returned to the Park to live out their lives. It is anticipated that the phased reduction would occur over 10 years or longer.”

What procedure they plan to do and HOW they plan to do that needs to be explained to the public so that we can properly comment. 

What also needs to be addressed is WHERE is the money coming from for these surgical procedures and helicopter round ups?

Our guess is that they think the tax paying public will be footing the bill for this!  That seems quite ludicrous when the overwhelming majority of people do NOT support the Park’s plans to eliminate the horses.

Throughout the document the Park also states that there will be little to no environmental impact if they remove 200 horses from the landscape of Theodore Roosevelt National Park.  As Dr. Ross MacPhee said, we really don’t know what that impact would be, it has never been done.  During our Horse Talk with renowned ecologist, Craig Downer, he said the Park itself as an ecosystem would have a literal heart attack if the horses were removed. 

The Park wants to sell the public the narrative that removing the horses will have no significant impact on the environment because if they find that it would, which we KNOW it would, then they would have to do an Environmental Impact Statement (EIS) – which is a longer and more detailed report AND what we, the tax paying public deserve. 

A few other things to note:

The park cites a report done in 2020 by Brownlee.  They STILL have NOT made this report available to the public.  43 CFR § 46.135 states: Publications incorporated into NEPA analysis by reference must be listed in the bibliography. Such publications must be readily available for review and, when not readily available, they must be made available for review as part of the record supporting the proposed action.

We brought this to the attention of Superintendent Richman.  She told us last week they were working on a solution.

Throughout the document the Park also talks about the need to return to a “natural prairie ecosystem”.  They have NOT properly defined this for the public either. 

The gravity of this report, along with the two examples listed above that explain the need for further explanation on the park of the park before the public can properly comment, is why we are working with our legislators to get the comment period extended.  Until you hear otherwise from us, please know the clock is ticking and we only have 25 days left in this public comment period that ends on October 25, 2023. 

There are other things throughout this document that we know have been fabricated to fit their narrative. 

For example, on page 37, the park states this:

“Several studies have evaluated the impacts of horses on wildlife, with many focusing on the impacts of horses on soils and vegetation, with indirect effects on wildlife forage and habitat. Soil impacts from horses on ecological functionality may also adversely influence small mammal populations. Beever and Brussard (2000) investigated the response of small mammal communities in areas where horses were present and where horses were excluded. They found strong differences in vegetation and qualitative differences in small mammal activity between horse-grazed areas and horse exclusion areas; this suggests that impacts on small mammal communities were stronger in horse-grazed locations (Beever and Brussard 2000). Prairie dog towns and other small mammal communities in the South Unit may be vulnerable to impacts from horses.”

Just about anyone who has visited the park has probably seen Stallion Teton and now Stallion Nicols bands. 

Where are they often seen?

Right in the very first Prairie Dog Town as you enter the park.  They seem to be cohabitating this area of the park just fine, don’t they?  Right along with bison, elk, deer, coyotes, badgers and porcupines. 

ANYONE who visits the park can clearly see that the prairie dogs are THRIVING – and that is an extreme understatement!

Please make sure you take time to read this extremely important document.  It is filled with ridiculous accusations and false narratives.  Please educate yourself.  DO NOT take what they are saying as fact.  THAT is the one of the biggest problems we have with this Draft EA.

The Park is DEMANDING that the public give them SCIENTIFIC FACTS.  The public has scrambled to educate themselves and cite a variety of scientific papers throughout our public comments.  The Park is not giving the taxpaying public the same courtesy. 

This Draft EA is quite simply Theodore Roosevelt National Park TRYING to continue to do whatever it wants to do, despite overwhelming public outcry and local pressure.  This is just another example of federal government overreach.  The federal government is proposing an action that will be detrimental to the state of North Dakota. 

We will start talking about how to formulate your comment letter this week.  Please keep those questions coming – we will do all we can to help educate our followers and make sure you understand this process.  You can email us at

Lastly, if you are enjoying all of this information, please consider making a donation to help support our critical advocacy work!  As a 501(c)3 organization, your donation is 100% tax deductible.

We ONLY get one chance to save this herd! Just under 200 wild horses need you to be their voice now more than ever! The clock is literally ticking on their freedom!

Thank you for your support and have a great day!

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