Substantive Comment letter: Historical & Cultural Significance – Part 1

“After nightfall the face of the country seems to alter marvelously, and the clear moonlight only intensifies the change. The river gleams like running quicksilver, and the moonbeams play over the grassy stretches of the plateaus and glance off the wind-rippled blades as they would from water. The Bad Lands seem to be stranger and wilder than ever, the silvery rays turning the country into a kind of grim fairyland. The grotesque, fantastic outlines of the higher cliffs stand out with startling clearness, while the lower buttes have become formless, misshapen masses, and the deep gorges are in black shadow; in the darkness there will be no sound but the rhythmic echo of the hoof-beats of the horses, and the steady, metallic clank of the steel bridle chains.” Theodore Roosevelt from Ranch Life and the Hunting Trail, 64

Hello and Happy Tuesday to everyone!

We have just 24 days left in this public comment period.  We are asking our followers to make sure they are taking the time to make a SUBSTANTIVE comment to the Park.  We have offered several examples of information to share in your comment letter in our blog posts. 

Also remember:

” 43 C.F.R. § 46.110(c) states: “[t]he Responsible Official must, whenever practicable, use a consensus-based management approach to the NEPA process; see also Nat. Park Serv., National Park Service NEPA Handbook at 55 (2015). This means that NPS “should consider any consensus-based alternative(s) put forth by those participating persons, organizations or communities who may be interested in or affected by the proposed action.” Id. § 46.110(b).And, where the decision-maker finds “that the consensus-based alternative, if any, is not the preferred alternative, he or she must state the reasons for this determination in the environmental document.” Id. § 46.110(d).

This means that the more consensus we can build around a certain alternative, the better because NPS has a regulatory duty to seriously consider any such alternative (or, explain why it hasn’t).

Our past blogs have gone over the Purpose & Need, the Livestock Classification and over the next couple of days we are going to talk about historical and cultural significance. 

For starters, remember that this proposed action of Theodore Roosevelt National Park is subject to a Section 106 review.  That review is being done by the North Dakota State Historic Preservation Office.  We will be sending in our petition at the end of this week.  Please make sure you have signed our petition: As of this morning (10/31/2023) we have just under 3200 names on our petition!

I want to start by sharing this passage from the very beginning of the book: Presenting Presenting Nature: The Historic Landscape Design of the National Park Service, 1916-1942 by Linda Flint McClelland

“Just over fifty years ago, the Civilian Conservation Corps (CCC) ended, and with it eclipsed a grand era of park-building marked by naturalistic principles, craftsmanship, and native materials. Rooted in the American park movement of the nineteenth century, naturalistic park design flourished under the stewardship of the National Park Service in the early twentieth century. Park designers—landscape architects, architects, and engineers—forged a rich legacy of roads and trails that blended with the natural scenery, picturesque park villages, campgrounds and picnic areas, scenic overlooks, and majestic views. Many of these places have fulfilled the National Park Service’s dual mission to conserve the natural scenery and to provide for public use, enjoyment, and appreciation. They have continued to serve visitors for several generations. Park managers, public officials, and preservationists are now being called upon to recognize these places, appreciate their historic significance, and protect them as cultural resources.”

That book along with the book by the same author: Building the National Parks: Historic Landscape Design and Construction, discusses how our National Parks were carefully designed and crafted to be “designed cultural landscapes”.  

Long before I became involved in the advocacy work for these wild horses, I think that I, along with most of the taxpaying public, have an image of our National Park Service employees as stewards of the land.  We trust them to take care of our National Parks and all of the resources within their boundaries. I think that is why people are so outraged at Theodore Roosevelt National Park’s current plans to rape the history of the wild horses from the landscape of the Park.

From the same book quoted above:

“In 1937, the National Park Service began publishing an annual yearbook on park and recreation progress, which brought together articles by noted experts on a range of topics related to the federal relief work in public recreation. Over the next seven years, articles appeared on park planning, sports, park structures, landscape architecture, and park administration. In the first issue, Wirth proclaimed, “The greatest resource of any nation is its human wealth, and in the conservation of the human wealth recreation plays a major part.” He set out the three components of a nationwide park and recreation program: (1) the park and recreation system, (2) access and travel, and (3) use and direction. He wrote, “It is through properly directed use that the physical, mental, and spiritual benefits of outdoor recreation are produced with equal emphasis to achieve social adjustment of the individual in order that he may live a full, useful, and complete life.” Wirth and other park service officials saw their work as a social-humanitarian effort. They were laying the foundation of a federal and state partnership in recreation that would significantly contribute to the human wealth of the nation.”

That seems a far cry from the robotic responses we receive from Theodore Roosevelt National Park today, doesn’t it?

My historian friend Steve also brought a new document to my attention: Theodore Roosevelt National Park, North Dakota Historic Resource Study.  This study was completed in 2017 by Public Lands History Center at Colorado State University in Fort Collins, Colorado.  It was created to:

“In telling the stories of the place and linking them to broader contexts, this historic resource study aims to enrich park personnel’s understanding of the historical significance of the resources they manage, preserve, and interpret for the public.”

We suggest you read this document and add it to your list of supporting documentation.  We have added it to both the Save the TRNP wild horses section of our website and the Library section of our website.

You can also download it here:

Within this document, you will find a few gems like:

On page 110:

“The number of feral horses multiplied during the ranching and homestead eras, and by the 1940s, several hundred freely roamed southwestern North Dakota.”

On page 141:

“The park existed because of its association with Roosevelt and his Badlands open range ranching experiences in the 1880s. Protection and restoration of natural resources followed secondarily to the area’s status as a historical park.”

Pages 111, 142 & 150 & 168:

“In 1956, officials reintroduced bison, elk, California bighorn, and pronghorn into the park’s South Unit.73 These reintroduced species both restore some of the historical biological diversity of the area and represent mid-twentieth-century American sensibilities that valued such animals for aesthetic and recreational purposed. Thus the animals represent both natural and cultural resources.” (111)

“In 1951, seventy-five pronghorn from Yellowstone National Park arrived at the South Unit.” (142)

“By 1956, fencing complete, the park brought in twenty-nine bison from Fort Niobrara National Wildlife Refuge in Nebraska and released them into the South Unit. Six years later, with the herd thriving in the South Unit, managers moved more bison to the newly fenced North Unit. Bighorn sheep returned to the park in 1959.” (150)

“In contrast, rangers never had to justify elk as historic when they reintroduced them in 1985. The reason for elk re-introduction was their “role as a major herbivore in the badlands ecosystem.” Their presence when Theodore Roosevelt lived there was an ancillary consideration.” (168)

Did you get all that?
The “NON-NATIVE” horses existed in this area before Theodore Roosevelt National Park was established. BUT the “NATIVE” species: pronghorn, elk, bison and big horn sheep had to be reintroduced to the area.

Also from page 150:

“However, more than these wild species, which were mostly gone when Roosevelt came to the Badlands, domestic animals had characterized the historic period.”


AND page 150 goes on…

“With the goal of living history, park officials decided to bring longhorn cattle to the North Unit in 1966 and thereafter.”


Still more from page 150:

“Though prior to the 1950s park staff had tried to remove the feral horses that competed with native wildlife, disputes about National Park Service roundups by the mid-1960s pressured the park into allowing the horses to remain. As they would have existed in the region during Roosevelt’s time, horses seemed as appropriate as the introduced cattle.”

Seems the horses are part of the LIVING HISTORY being presented in Theodore Roosevelt National Park.

And despite the Park’s plans to try to change the scope of their focus, you will find this interesting piece on page 157:

“During a brief period in 1964 when the National Park Service categorized parks, the secretary of the interior officially labeled it a historical park. The 1973 Master Plan explicitly reaffirmed its historical mission. To be managed “as an historical area,” the park was to illuminate Roosevelt’s experience of the North Dakota Badlands between 1883 and 1898 and open-range cattle ranching. It would “interpret those geological, biological, ecological, and scenic aspects of the Badlands that helped to influence his thinking as our first ‘Conservation President.’””


““The primary resource of the park is Theodore Roosevelt’s association with the Badlands and the open-range cattle frontier of the 1880’s. The wildlife, typical of the Great Plains, includes antelope and bighorn sheep, deer, and reintroduced bison. Longhorn cattle have also been reintroduced in the North Unit, and a small herd of feral horses exists in the South Unit. Geological resources include the scenic Badlands, concentrations of petrified tree stumps, and a burning lignite vein.””

AND on page 158:

“However, with the notable exception of Elkhorn Ranch, by the late 1970s, the natural and cultural resources that Theodore Roosevelt National Memorial Park needed to tell its historical story were in place. By preserving the cultural scene commemorating Roosevelt, resource managers essentially protected the ecologic scene as well.”

Page 158 also references the park presenting a “living museum”.

Incredible, huh?!

We aren’t done yet! lol

Page 168 states:

“In a historical park, Theodore Roosevelt National Memorial Park’s animals had been the exceptions….they added historic authenticity to the re-creation of Roosevelt’s landscape. Essentially, the animals served as the park’s most prominent cultural artifacts, especially when so little else from Roosevelt’s time remained.”

AND on page 169:

“Although the park considered feral horses to be livestock and only kept them in the park for their symbolic, cultural value, the public perceived them as feral horses and a part of the natural scene.”


“With plans and periodic culls, administrators treated the horses the same as buffalo and elk.”


Still NOT done….page 170:

“Feral horses served as Theodore Roosevelt National Park’s romantic icon of wildness, much like Yellowstone’s wolves. Ironically, this invasive species, as it were, overshadowed the wildlife truly native to the Badlands and became the park’s “high profile species.”

THIS seems pretty important to our argument – from page 196:

“In the 1940s, as plans for a national park in the badlands were underway, no elk and only a small number of deer and antelope had been seen in the region since the homesteading era. But assisting with the recovery of these typical fauna, a mix of wild and domesticated species including bison, longhorn cattle, and feral horses became important features that the NPS would use in coming decades to interpret the history of the badlands.”

From page 200: (we suggest reading this whole page as it gives a brief history of horses in the area)

“Park visitors by then perceived the horses as part of the natural scene and thus they required scientific management along with the wildlife species. Despite genetic evidence to the contrary, some North Dakotans argued that the horses were a unique indigenous breed descended from Sitting Bull’s war ponies. In 1993 a state bill sought to make the “so-called Nakota horse” the honorary equine species of North Dakota. As the horses achieved this iconic status and even greater scrutiny, park management of the herd required ongoing ecological and political savvy and the animals came to represent how ideas about wildlife and wildness have changed over time.”

Theodore Roosevelt National Park, the ONLY national park named for an individual, is RICH in history because it was created to PRESERVE a period in our history.  A period that celebrated ALL that our conservation president experienced while he was in the Badlands of North Dakota.  Those experiences included wild horses. 

Remember, this document was created FOR the Park personnel:

“In telling the stories of the place and linking them to broader contexts, this historic resource study aims to enrich park personnel’s understanding of the historical significance of the resources they manage, preserve, and interpret for the public.”

Maybe they should re-read it!  They seem to be missing some key points – including from page 202:

“Today, THRO maintains an approximation of open range habitat within the interior of the park as an important historic feature that characterizes the nineteenth century landscape of the Badlands.”

Maybe that answers the “Native Prairie Ecosystem” question?

“Feral horses, on the other hand, bred readily and therefore presented park administrators and rangers with significant management challenges. Abandoned or escaped domestic stock had roamed the Badlands in the first half of the twentieth century. When the National Park Service acquired the park property, these animals came with it. At first, the park tried to eliminate them, despite the fact that Theodore Roosevelt had encountered feral horses. In 1954, a horse roundup in the South Unit reportedly removed about 100 horses, most of them branded, confirming the park’s view that these animals descended from escaped domestic stock. In 1965, rangers again tried to capture and remove all horses, but their efforts met with “very strong public disapproval.” Politically and practically, the park could not easily rid itself of what it considered invasive livestock.”

They could NOT get rid of the horses in 1965 and Chasing Horses Wild Horse Advocates is doing ALL we can to make sure that Theodore Roosevelt National Park is NEVER able to rid these culturally and historically significant wild horses from the landscape of the Park. 

Thank you again to Steve for bringing this document to our attention.

We know that this was a longer post, but we hope that you found some nuggets for your comment letter in what we shared in this blog.  We also encourage you to read the document for yourself. 

Our next blog post will continue talking about the historical and cultural significance of the wild horses that call Theodore Roosevelt National Park home. 

Please remember: Comment can ONLY be accepted on Theodore Roosevelt National Park’s planning website! When you are ready to make your comment, please make sure you submit your comment here:

Thank you for your support and have a GREAT day!

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