Word of the day: SUBSTANTIVE

Hello and Happy Monday to everyone!

Now that we have been granted an extension to this public comment period, we have plenty of time to discuss how to make an impactful comment!  Comments are NOW due to Theodore Roosevelt National Park by November 24, 2023.  For clarification, the Park’s Planning website is the ONLY place that your comment counts!  Chasing Horses Wild Horse Advocates is NOT collecting comments to send in and none of the comments or emails that we receive will be submitted to the Park on your behalf.  YOU have to do that yourself.  This can ONLY be done on Theodore Roosevelt National Park’s planning website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035

We are going to start the week talking about what your comment should look like.  We have 32 days left to get comments into the Park.  Please do not make this something that you rush through to simply check off a list! 

I want to start this conversation by saying what your comment should NOT look like:

“I will never return to Theodore Roosevelt National Park if the horses are removed.”

If that is ALL that your comment says, I will tell you right now you have NOT helped the horses in ANY WAY and the Park DOES NOT CARE!


The town of Medora, where the Park is located, is going through a major overhaul as they get ready for the Theodore Roosevelt Presidential Library to be completed in 2026.  They have stated in the Draft EA and in the Civic Engagement Meeting, that they will NOT lose any visitors to the Park if they remove the horses.  They believe any people who are lost will be gained with the expected increase in traffic from the library. 

That does not mean that you cannot add that statement to the whole of your comment letter.  It just CANNOT be your WHOLE comment letter. 

This is your LAST chance to be the voice for these horses.  “Short & sweet” does not help them. 

Your comments need to be substantive! The NUMBER of comments does not matter if your comments are NOT SUBSTANTIVE!

What does that mean?  We added a handout we received from our friends at Oregon Wild Horse Organization shared with us to the section of our website where we have reference materials you can use in your comment letter: https://chwha.org/save-the-trnp-wild-horses/

From the document:

Substantive Comments
“To be most helpful, comments should be as specific as possible. A substantive comment provides new information about the Proposed Action, an alternative or the analysis; identifies a different way to meet the need; points out a specific flaw in the analysis; suggests alternate methodologies and the reason(s) why they should be used; makes factual corrections, or identifies a different source of credible research which, if used in the analysis, could result in different effects.”


Excerpts from the NEPA Handbook

Substantive comments do one or more of the following:

  • question, with reasonable basis, the accuracy of information in the EIS or EA.  
  • question, with reasonable basis, the adequacy of, methodology for, or assumptions used for the environmental analysis.
  • present new information relevant to the analysis.
  • present reasonable alternatives other than those analyzed in the EIS or EA.
  • cause changes or revisions in one or more of the alternatives.

Comments that are not considered substantive include the following:

  • comments in favor of or against the proposed action or alternatives without reasoning that meet the criteria listed above (such as “we disagree with Alternative Two and believe the BLM should select Alternative Three”).  
  • comments that only agree or disagree with BLM policy or resource decisions without justification or supporting data that meet the criteria listed above (such as “more grazing should be permitted”).
  • comments that don’t pertain to the project area or the project (such as “the government should eliminate all dams,” when the project is about a grazing permit).
  • comments that take the form of vague, open-ended questions.

If you have already commented, you CAN comment again.  There is no limit on how many times you can comment.  We suggest making a word document and adding to it as we continue discussing the Draft EA and what your comments should look like.  Your comment letter can be as short or as long as you like.  We have seen impactful comment letters that from 1 page to 60! 

Just under 200 horses are counting on you to speak up for them!  Make your comment count!

While we cannot tell you what to comment however, following are a few topics that Chasing Horses Wild Horse Advocates believes that your comment letter should state/challenge:

  • Theodore Roosevelt National Park must explore an alternative that allows for a genetically viable herd of horses to remain in the Park
  • The abrupt reclassification of these horses to “livestock” is unsupported and violates NPS policy
  • The Purpose & Need statement is too narrowly focused
  • TRNP did NOT properly review the historic and cultural significance of the horses
  • TRNP did NOT properly review the negative economic impact of their decision
  • Removing the horses will have a negative impact on the Park as an ecosystem

We will be discussing these topics (and more) in the coming days through our blog posts along with where to get the supporting documentation to make your arguments in your comment letter. 

We also have some talking points listed on our website: https://chwha.org/save-the-trnp-wild-horses/

We had a Zoom on this topic last Friday with our friend Heather at Save Our Wild Horses.  That video has been uploaded to their YouTube channel.  Many of the topics above were discussed Friday.  You can view the video here: https://youtu.be/dwORiJMflCw?si=_6_Z_myC7kroSvf9

We also spoke with Carol Walker from Wild Hoofbeats last week. She released our talk in her NEW podcast today! Thank you for helping to spread the word about the current plight of these amazing wild horses, Carol! You can listen to it here: https://www.wildhoofbeats.com/podcast/horses-theodore-roosevelt-national-park

Since we are hearing that these Zooms are helpful to you, we will be hosting another Horse Talk this FRIDAY with me – Chris Kman to answer any questions you have about this process or this comment period.  The event is FREE but we do ask that you register in advance: https://secure.everyaction.com/smU9KC-nNkyPAevZYGFDEA2

Other ways you can help right now:

Share our social media posts!

Share our YouTube videos!  These are GREAT ways to spread the word about the current plight of our TRNP wild horses!  The video is available in wide screen: https://youtu.be/WD1qw_9CA1U and mobile format: https://youtube.com/shorts/JCysrji51-w.

Donate to Chasing Horses Wild Horse Advocates – we need your support to continue Fighting for the Spirt of the Badlands!

Sign our petition:https://secure.everyaction.com/Af1717oXqU2wTrcB0Yz6jw2

Email Deb Haaland: https://secure.everyaction.com/5pWZb1KoLUO0EDlYwRHEMA2

Let us know if you would like our brochures or stickers to pass out!  Be sure to let us know how many of each you would like!  Email your requests to us at info@chwha.org!

We will be receiving NEW 6×6 stickers TODAY as many of you requested larger stickers for your vehicles! 

We can get yours by making a donation of $10 or more!  We ask that once you make your donation you email us with your address that you would like your sticker(s) sent to and how many you would like us to send.  Donations can be made by clicking the donate button on any of our social media posts or by any of the ways listed on our website: https://chwha.org/support-chwha/  Please email us at info@chwha.org once you made your donation.

We will continue the comment conversation tomorrow so be sure to check back!

Thank you for your support and have a GREAT day!

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