Writing Your Comment Letter: The Bison Initiative

Hello again! 

As promised, we will be covering another point that you can use in your comment letter to Theodore Roosevelt National Park.  The current comment period ends in just 14 days on October 25, 2023.  We have asked for an extension, we have yet to hear back from the Park if they will grant this extension. 

As we talked about yesterday in our comment blog, and our lawyer Matt from Eubanks and Associates talked about in our Horse Talk last week, EVERY comment will go back to the Purpose and Need statement in the Draft EA.  What you comment has to be in line with their purpose and need statement.  Yesterday we talked about how narrow that focus was and other things you could comment. 

Today we will talk about the last part of the Purpose and Need and what prompted our Call to Action to Secretary Haaland today

This line was added to the Purpose and Need statement for this comment period:

“Emphasize bison management in alignment with Secretarial Order 3410”

What IS Secretarial Order 3410?  You can read it here:

This order calls for the “Restoration of American Bison and the Prairie Grasslands.

The Park stated in their call last night that this initiative “just came out this past March”.

As they stated, they have been and will continue to be transparent with the public.


It IS true that Secretary Haaland signed Secretarial Order 3410 in March of 2023. 

It is ALSO true that The Bison Conservation Initiative (BCI) was created in 2008.  It was renewed in 2020 and is led by the Bison Working Group (BWG). 

It goes on:

“The BCI represents nearly two decades of concerted coordination, investments in science-based management, and partnership development to advance the conservation of American bison. This includes working closely with stakeholders to promote herd health and to manage risks that diseases in bison may present.”


Also we get the Secretary’s definition of “grassland” “grassland ecosystem” and “prairie grassland” (which for her office seem to be interchangeable):

“The term “grassland,” “grassland ecosystem,” or “prairie grassland” means a landscape where the natural plant community is dominated by grasses that coevolved with bison.”

Well….we know that Theodore Roosevelt National Park is filled with nutrient rich soils and even without our science caps on – it appears that since the 1950s, the bison seem to be thriving on the forage in the Park.


Check on returning bison to the native prairie ecosystem

Check on having “prairie grassland”

It appears that Theodore Roosevelt National Park gets an A+ for the Bison Initiative! 

Seriously, GOOD JOB TRNP!!!!

To be clear – we are NOT anti-bison here.

Actually, here are some fun facts for you about the bison in Theodore Roosevelt National Park:

  • There are over 600 bison in the SOUTH unit of the park
  • The target goal for the South Unit is 300-500 bison

So, less horses DOES NOT equal more bison. 

So, what gives?

My simple answer is….

Toilet paper math.   I think I have talked about that before.

Remember when we could just go to the store and buy a package of toilet paper and when you looked at the package and it said you were buying 12 rolls, when you looked at the package, you could see there were 12 rolls. 

Today, when you buy toilet paper, it says things like 6=18 or 18=72 or 12=36 – and you look at the package and DO NOT see 18, 72 or 36 rolls of toilet paper.  But the toilet paper company wants you to believe that buying these 12 rolls is the same as buying 36 rolls of toilet paper. 

Why do we have to overcomplicate things?

Same with this.

What does the bison initiative have to do with the wild horses in Theodore Roosevelt National Park?

I think Blake said something about that “native prairie ecosystem” again in the meeting last night.

The thing is – when you read Secretarial Order 3410 NO WHERE within that document is the word “horse/horses” even mentioned. So there absolutely is no mention of needing to get rid of horses to fulfill this bison initiative.  I searched within the document for “native prairie ecosystem” and came up with nothing there either.

So what is the answer?

Toilet paper math.

That is my new standard answer to something that makes no sense, but we are being forced to try to believe it anyway.

The inclusion of this order looks good at face value.  I mean, if Secretary Haaland is telling the Park they have to do this – who are we to question that?

WE are the tax-paying public.  We have a right to question our government AND get real truthful and TRANSPARENT answers. That is REAL transparent answers – not the ones Superintendent Richman told us last night that the Park has been and will continue to give us.

There is no more truth to this as a reason why the horses have to go than there is any other NPS policy that they have cited throughout this process.  We know this because somehow, other national parks are allowing wild horses in their parks and are NOT breaking any NPS policies or laws. 

How can that be?

Toilet paper math.

It’s the only logical answer to any of this.

Thank you for your support and have a great night!

2 thoughts on “Writing Your Comment Letter: The Bison Initiative

  1. I think Ms. Richman needs to go on to her 11th park. Seems her jobs have not lasted long. She can go and we will keep OUR park the way the people want it.

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