Writing Your Comment Letter – Economic Impact    

One of the biggest arguments advocates have to fight with as we urge Theodore Roosevelt National Park to keep the wild horses IN the Park is the negative economic impact that removing the horses will have on the state of North Dakota, and ESPECIALLY the town of Medora and the surrounding communities.  This is no doubt one of the biggest driving forces that is getting state and federal legislators to advocate with us.

We KNOW this – but how do we PROVE this?

Even the North Dakota Department of Tourism struggled with this.  As much as they, and every business owner in Medora knows that the removal of the horses will have a negative impact on the horses, even the Tourism Department, with all of the resources they have at their disposal could not find quantitative FACTS to share regarding the impact the horses have on tourism in our state. 

The answer is now within the Draft EA that the Park released to the public. 

The Park has to answer why they believe that removing the horses will NOT have little or no economic impact on the state or the town of Medora.  Their answer was found in a document that they have already accepted as quantitative fact.  They hired people to do an “official” survey of visitors to the Park and those responses were put into a nice little document that we now know as the Brownlee study.  This document is available to download from the Park’s planning website.  We also downloaded it – you know, just in case more documents start disappearing or in case the Park decides “oooppsss!  THAT was an “internal” document that should not have been released to the public.” Which was the answer they gave at their civic engagement meeting last week when asked about NPS 2022h.

Within that document, on page 57 we see the following chart:

THIS is the Park’s BIGGEST argument for why it won’t matter if they remove the horses. 

The Park states on page 63 of the Draft EA:

“According to a 2020 survey, 49 percent of the 1,474 visitors interviewed supported the ongoing presence of the horse herd in the South Unit (Brownlee et al. 2020).”

First, I am going to discuss a simple research method.  What threw up red flags for our lawyer Matt and I as we initially skimmed through the Draft EA was the Park stating that only 49% of visitors supported the ongoing presence of horses in the South Unit of the Park.  Not only did they mention it – they cited the Brownlee report as their source for their factual statement. 

Chasing Horses Wild Horse Advocates sent an email to Angie Richman because any documents cited within the Draft EA HAVE TO be made available to the public.  The Park complied a week later and the documents are listed on the Park’s planning website. 

As you are going through the Draft EA writing your comments, you can now see where the Park is getting the information they are giving to the public and go to that document and look at what they cited. 

When CHWHA did this with the Brownlee study, we found that while within the Brownlee study, it WAS true that 49% of visitors supported the ongoing presence of horses in the South Unit, we also learned that was NOT the full story!

When all of the varying degrees of support were added together, we learned that the full story was that 89.13% of people surveyed for the Brownlee study – which again, the Park has accepted as a FACTUAL study – actually support the ongoing presence horses in the South Unit.  


ONLY 4.38% OPPOSE the ongoing presence of horses in the South Unit.

But wait – there is more….

On page 57 of the Brownlee report, we also see this at the top of the page:

“Note: The highest value in each row has been highlighted”

When you look at the Brownlee study you will see that NOT ONLY did 89% of people surveyed support the ongoing presence of horses in the South Unit, BUT of the 22 scenarios given to the people taking the survey, #1 out of ALL 22 in responses received for “STRONGLY SUPPORT” was the ongoing presence of wild horses in the South Unit.

THE HORSES ARE WHAT PEOPLE ARE COMING TO TRNP TO SEE!  This report, again, that the Park has deemed factual in their Draft EA, gives us the quantitative facts to prove this. 

Remember, NEPA requires federal agencies to take a “HARD LOOK” at the impacts of their proposed action. 

The Brownlee report calls into question IF the Park did in fact take a HARD LOOK at the economic impacts of their proposed action.

AND remember:

When the environmental assessment (EA) is written, the agency has to determine if there are going to be significant impacts or controversy involved in the proposed action. If no significant impacts or controversy exist, then the EA is written with a Finding of No Significant Impact (FONSI) and agency action occurs – in this case removal of the horses from the Park. If significant impacts or controversy exist, then the agency must do an environmental impact statement (EIS).

I would say that it appears that some controversy exists – wouldn’t you say? 

Your comment letter should also include that for these reasons, the Park MUST prepare an Environmental Impact Statement (EIS).

We hope that helps with this part of your comment letter.   This week is filling up quickly for me and I will do my best to share updates, but we have some real hard deadlines we are facing this week that are driving our time this week.  We have also reached out to Superintendent Richman requesting a response to our extension request. 

To recap:
The statements that the Park made in their Draft EA with regards to their attempt to minimize the negative impact removing the horses will have on the local economy of the state of North Dakota, specifically, the town of Medora and the surrounding communities, is refuted by the very document they cited as their defense. 


That document – which they have vetted themselves as an acceptable factual document, can now be used to support our argument as advocates on the negative impacts we KNOW will happen if the horses are removed.


This topic is now showing proven controversy within the Draft EA and the Park NEEDS to perform an Environmental Impact Statement (EIS) instead of coming back with a Finding of No Significant Impact (FONSI).


THIS does NOT mean the horses are saved.  This does NOT mean the Park will do an EIS. 

THIS is something everyone needs to add to their comment letter – in your own words with other facts we are sharing with you through our blogs. 

The more the Park hears this, the less they can ignore it!

See? This Draft EA is NOT as cut and dry as the park would like us to believe.

We will also be talking to our friend Heather at Save Our Wild Horses in a Zoom THIS FRIDAY (10/20/23) at 6 pm MST. This event is FREE, but you must email Heather to receive the zoom link: kaya97524@yahoo.com.

Equine Collaborative International has also released the video of our Zoom with them this past Friday. Thank you to Barbara at ECI for hosting us and making this video available! You can view the whole video here:


Passcode: k!1qDdXU

You are also always welcome to email us your questions at info@chwha.org.

Thank you for your support and have a GREAT day!

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