THANK YOU to everyone who participated in our last online silent auction of the year! It was a HUGE SUCCESS!!! Congrats to all of the winners and THANK YOU to everyone who donated items!
We had a last-minute meeting come up last night and are heading out the door for another one this morning! We will have details soon! For now, just know that it is all very exciting!
If items you won in the auction require shipping, we will be sending invoices later today. All items in the auction will be shipped this week!
If you missed the auction, there are still several ways that you can help support our critical advocacy work listed on our website: https://chwha.org/support-chwha/
Our silent auction is coming to an end! This is our LAST silent auction for this year, and we have so many amazing items that were donated to us! Thank you to everyone who donated items for our auction!
AND THANK YOU to all of you bidding on these amazing items!!!
Have you checked out the GREAT items in our online silent auction? If you have, have you checked your bid lately?
Each item in the auction has a starting bid. Bids must be increased in $1 increments.
The auction ends TODAY (December 3rd) at 8 pm MST.
“Popcorn Bidding” is enabled for ALL bids! What does that mean? If someone submits a bid within the last 10 minutes of the auction, the bidding for that item automatically extends for an additional 10 minutes.
Good luck and Happy Bidding!
100% of the money raised in this auction goes to help us with our critical advocacy work. This campaign will go into our Giving Hearts Day matching fund. We need to raise at least $3,000 by January. We have set a matching fund goal of $10,000. Can you help us?
Why do we have such an enthusiastic goal?
Our advocacy work does not come without a cost. We have website fees, subscription fees for things like zoom and every action, we have our billboard and printed materials that we pass out. We also have legal fees both from this last comment period and for future legal costs we are anticipating when the Park comes back with their decision in the spring. We are trying to be proactive, especially when it comes to raising money for our future legal fees.
Our silent auction is a GREAT way to help us! There are also several ways you can donate to us listed on website: https://chwha.org/support-chwha/
Chasing Horses Wild Horse Advocates is a 501(c )3 organization, so any donation you make is 100% tax deductible!
This week was full of unexpected twists and turns in a week that blew by way too fast! We can’t wait to share what’s been brewing this week with you soon!
We also have been continuing to talk to our North Dakota State Legislators this week. These talks have been very insightful, and we are hopeful that there is more that can be done on a state level for them to continue to advocate with us as we continue to Fight for the Spirit of the Badlands!
Stay tuned!
The last two months have been a whirlwind! We are in the process of cleaning up and adding some organization to our website. That includes adding your comment letters! Please email us your comment letter if you would like us to add it to our website. If you have thoughts or ideas on what you would like to see on our website, please let us know! You can email us at info@chwha.org
Our silent auction is coming to an end!
Have you checked out the GREAT items in our online silent auction? If you have, have you checked your bid lately?
Each item in the auction has a starting bid. Bids must be increased in $1 increments.
The auction ends TOMORROW (December 3rd) at 8 pm MST.
“Popcorn Bidding” is enabled for ALL bids! What does that mean? If someone submits a bid within the last 10 minutes of the auction, the bidding for that item automatically extends for an additional 10 minutes.
100% of the money raised in this auction goes to help us with our critical advocacy work. This campaign will go into our Giving Hearts Day matching fund. We need to raise at least $3,000 by January. We have set a matching fund goal of $10,000. Can you help us?
Why do we have such an enthusiastic goal?
Our advocacy work does not come without a cost. We have website fees, subscription fees for things like zoom and every action, we have our billboard and printed materials that we pass out. We also have legal fees both from this last comment period and for future legal costs we are anticipating when the Park comes back with their decision in the spring. We are trying to be proactive, especially when it comes to raising money for our anticipated future legal fees!
Chasing Horses Wild Horse Advocates is a 501(c )3 organization, so any donation you make is 100% tax deductible! We have said before and many of you have asked, the ONLY organization offering any financial support to us as we continue this fight is American Wild Horse Campaign (AWHC). They have done this with their own separate billboard in Dickinson and also by signing onto our comment letter with us and agreeing to pay part of the legal fees associated with that. They have also been consulting with us for years and offering us advice and sharing their insights with us. If you have specific questions this or anything we are doing here at CHWHA, please don’t hesitate to ask us in a PM or an email. We aim to be as transparent as possible!
THANK YOU! To everyone who took the time to make a donation to us yesterday on Giving Tuesday! We are keeping this campaign open through the remainder of this week! You can find ways that you can donate listed on our website: https://chwha.org/support-chwha/
Chasing Horses Wild Horse Advocates believes that saving these wild horses will come down to a combination of three different ways to actively advocate:
1 – The State of North Dakota creating legislation to save these wild horses
2 – Federal Protection for the wild horses of Theodore Roosevelt National Park
3 – Legal action.
Chasing Horses Wild Horse Advocates is continuing to work on all three of these as we continue our Fight for the Spirit of the Badlands!
Our advocacy also includes raising awareness about the current plight of these amazing wild horses. This includes our billboard on I-94, brochures, stickers, postcards and other handouts, as well as advertising on social media and in print ads and YouTube videos.
We are continuing to talk to our ND State legislators on ways that we can be proactive. Our legislators do not come back into session until 2025, BUT there are things we can and are doing now to be proactive with the state of North Dakota help our beloved wild horses. We are also communicating with Governor Burgum’s office and the ND State Historic Preservation Office.
We are continuing to work with Senator Hoeven’s office. Senator Hoeven is one of our biggest allies in our fight to save these horses!
We are working with the law firm of Eubanks and Associates and will continue to receive guidance from them on what legal recourse we may have as the Park moves forward in this NEPA process. We have also had a couple of different organizations let us know that they would be willing to sign on with us if this goes to litigation!
We are grateful for all of the help and support from everyone listed above and each and every one of you.
While we wait for the Park to come back and let us know what they decided their next steps are in this process, CHWHA will be fighting hard to let people know that this fight is far from over and keeping these amazing wild horses in everyone’s mind! You can help by continuing to share our social media posts and blogs.
We will continue to engage with the media and keep them informed of any news regarding the wild horses of TRNP. We have had several new members of the media contact us this week – so watch for more on that coming soon!
Please email us (info@chwha.org) or send us a PM if there is someone you would like us to reach out to for a future Horse Talk or if YOU would be interested in talking with us!
As always, if you have thoughts or suggestions, please feel free to PM us or email us at info@chwha.org. We do have a voting board but as we always say, ultimately Chasing Horses Wild Horse Advocates belongs to all of you.
Thank you again for your continued support! We appreciate each one of you!
Giving Tuesday is a movement to create an international day of giving at the beginning of the Christmas and holiday season. We hope that today you will take a moment to support our critical advocacy work as we continue Fighting for the Spirit of the Badlands!
The public comment period ended last Friday, but as we keep saying, this fight is FAR from over. We have spent the last few days talking to our ND State Legislators about ways that we can be proactive as they continue to advocate WITH us to keep the 200 wild horses in Theodore Roosevelt National Park wild and free!
There are several ways that you can help us!
You can make a donation by visiting our website:https://chwha.org/support-chwha/ or clicking on one of the buttons at the bottom of this email. You can also donate through any of our social media posts.
We also are growing quite the collection on our YouTube channel that can be shared to help educate people on the plight of wild horses everywhere! Have you seen our Giving Tuesday video? https://youtu.be/Fr0Y8kb8020
If you are like us, after these last two months of literally unraveling the Draft EA that Theodore Roosevelt National Park released in September of this year, you feel A LOT like Boomer right now!
There have been a few questions floating around that we wanted to answer today:
What happens now?
Does the Park read ALL of the letters that were sent?
Yes – the Park is ABSOLUTELY responsible for EVERY word and EVERY page that was sent to them.
Case in point:
In the Park’s December 2022 scoping letter -The Park stated this as their purpose statement: “Park Purpose Statement: Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, native wildlife, and wilderness qualities—the landscape that inspired Roosevelt and still inspires visitors today.”
That was a quote from the Park’s Foundation document that reads:
“Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, wildlife, and wilderness qualities of the North Dakota Badlands—the landscape that inspired Roosevelt and still inspires visitors today.”
Did you notice the word “native” quietly being slid into the scoping notice? Our lawyers did!
This is from our CHWHA January 2023 comment letter:
“Interestingly, the Park’s Scoping Notice also includes a subtle reimagination of the Park’s overall purpose statement, as promulgated in its 2014 Foundation Document. Whereas the Foundation Document defines the Park’s purpose statement as paying tribute to Theodore Roosevelt by “preserving and protecting the scenery, wildlife, and wilderness qualities of the North Dakota Badlands—the landscape that inspired Roosevelt and still inspires visitors today,” the Scoping Notice, adds for the first time ever, the word “native” to that statement: Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, native wildlife, and wilderness qualities— the landscape that inspired Roosevelt and still inspires visitors today. Scoping Notice at 2 (emphases added). Despite the far-reaching implications of this change (well beyond wild horse management), the Park’s Scoping Notice fails to notify the public of the sudden change to its “Purpose Statement,” and does not invite the public to comment thereon. See id.”
The result? The Park “fixed” this statement when they came back with the Draft EA.
The Park is legally responsible for the information that ALL of us sent them. If there is a “controversy”, like the example above, they have to correct that – which they did in this example.
Yes, we feel that Chasing Horses Wild Horse Advocates and many of you in your own comment letters – gave the Park A LOT of “controversy” this time around too! You can read our CHWHA/AWHC comment letter here: https://chwha.org/november-2023-comment-letters/
What happens now?
The Park will read through all of the comments they received. As Superintendent Richman stated in a newscast on Friday:“a comment analysis report will be made from the feedback.”
The Park has been good at giving us those reports. They will let us know how many people commented, including how many total comments and how many “unique” comments were received. They will also let us know how many addressed different issues and how many agreed with the alternatives they offered. You can view past reports on the Park’s planning website: https://parkplanning.nps.gov/documentsList.cfm?projectID=105110
The Park has stated that they will be back with the next step in the spring. Superintendent Richman also stated that the decision will be made by the regional and national NPS offices.
To that we want to add…
Superintendent Richman did NOT initiate this process. This was in the works long before she came to Theodore Roosevelt National Park. We know this from the FOIA records obtained by AWHC and by the fact that the Park announced her position as superintendent at the Park on March 23, 2023 stating that she would start in May of 2023. The Park released their plans to start this management planning process on March 16, 2023.
Superintendent Richman was sent here to do a job, and a big part of that is this “Livestock Plan”. That being said, Superintendent Richman’s total lack of public engagement and robotic responses are NOT winning her any brownie points with the general public, the state of North Dakota or even the town of Medora.
We also know from our conversations with our state legislators and Senator Hoeven’s office that NPS National Director Sams seemed open to the concerns that were raised in meetings they had. We know that ND Governor Burgum has personally met with Director Sams on several occasions. We also know from the Associated Press article released last week along with personal conversations with Jack Dura and Governor Burgum’s office last week that Theodore Roosevelt National Park and the Governor’s office are communicating. Burgum’s office told us last week:
“Our office has offered to the park to find ways to keep the horses in the national park and all possibilities are still on the table. We do not have any formal proposals or specific details to share at this time.
We will let you know if things progress further where greater details would be available.”
As for this NEPA process…
The Park will either come back with a Finding Of No Significant Impact (FONSI) OR they will let us know that they will be moving forward with an Environmental Impact Statement (EIS). The Environmental Assessment part of this process was to determine IF their proposed action – total elimination of this herd – would have an impact on the environment. That “environment” includes the scientific/ecological environment as well as the historical and cultural, and economic environments that we raised in our comment letter. The only thing that was completed on Friday was the last public comment period on the Environmental Assessment. Our lawyers took the time to make sure all of the “i’s” were dotted and the “T’s” were crossed. We believe that we have given enough documentation to the Park for them to see that they need to move forward with an EIS. We will know in the spring what course the Park takes. Their actions in the spring will prompt talks with our legal team to see if there is anything CHWHA needs to do moving forward.
Lastly, many of you have also sent us PM’s, emails or made comments letting us know that you expressed your concerns to TRNP staff when you called or visited the Park.
I cannot express this enough:
WE LOVE THEODORE ROOSEVELT NATIONAL PARK!
There is nothing that our organization or any of us individually would not do for the Park if they needed ANYTHING!
We have been saying this for years – what we disagree with is the Park’s management of the wild horses entrusted in their care.
These current decisions are NOT being made by the person answering the phone. They are NOT being made by the people manning the desk at the park or the Park rangers patrolling the park. THOSE are NOT the people who need to hear your opinions. I would venture to guess that many of them share your sentiments and have heard exactly what you said to them countless times for almost 2 years now.
How do I know this?
I chose this picture of Boomer for another reason.
That photo was taken last week while we were in the Park. The band just hiked up for the day and Boomer and Blue Angel both laid down and took a nap. Blue Angel got up after a short time and then Boomer seemed to trade with her and take a nap himself.
As we were there photographing the horses, a Park Ranger pulled up behind our vehicle. As I made my way back to our vehicle, he greeted me and asked:
“Were you just out there by that white horse?”
“Boomer?” I asked.
“Oh, you do know them! Good! I saw him lying down and was trying to get his attention. Is he ok?” he asked.
I explained what I did at the start of this, and he was relieved. He wanted to make sure he was ok because he was laying still for so long.
This comment period that ended on Friday was your chance to say what you needed to say to the people who needed to hear it. The people who work for the Park in the visitor center and gift shops more than likely are NOT the people who will be reading your comment letter or making final decisions.
Will our comments make a difference?
If you took the time to send in a comment letter, there is a chance that your words will reach the right people. If you didn’t exercise your rights during this time, then no, your voice will not be heard.
We get one chance to save these horses. CHWHA is continuing to fight from every angle. We are in contact with our state legislators, Governor Burgum and Senator Hoeven’s offices. We will talk more about what is happening there this week.
For now, keep talking about these historically amazing wild horses that call Theodore Roosevelt National Park home. People will mistakenly think this is over since the public comment period ended. Nothing could be further from the truth! We are at the beginning of a very long Fight for the Spirit of the Badlands and we need everyone’s help to save this herd.
We hope this answers your questions. Please do not hesitate to send us any other questions you may have. Educated advocates make educated statements and comments! You can email us any time at info@chwha.org.
We will also offer (again) to any other organizations that want to work with us on some critical things while we wait for the Park to come back in the spring to simply contact us. There is A LOT of work that needs to be done! These horses need ALL of us and we only get one chance to save them!
We have also been working on updating our website. We have added some of the comment letters we have received and are working on adding others. You can email us your comment letter if you would like us to share it on our website.
Thank you for your support and have a GREAT Sunday!
P.S. Don’t forget to check out our silent auction! There are so many WONDERFUL items that were donated to us! You can help support Chasing Horses Wild Horse Advocates advocacy work AND find some GREAT items for yourself AND/OR those special people on your holiday shopping list! You can view all of the items and place your bids here: https://chwha.betterworld.org/auctions/chwha-giving-hearts-day-silent-a
A friend shared this quote from Theodore Roosevelt with me the other day. It is one of my favorites and one I have referred back to many times throughout this process we are in.
“It is not the critic who counts; not the man who points out how the strong man stumbles, or where the doer of deeds could have done them better. The credit belongs to the man who is actually in the arena, whose face is marred by dust and sweat and blood; who strives valiantly; who errs, who comes short again and again, because there is no effort without error and shortcoming; but who does actually strive to do the deeds; who knows great enthusiasms, the great devotions; who spends himself in a worthy cause; who at the best knows in the end the triumph of high achievement, and who at the worst, if he fails, at least fails while daring greatly, so that his place shall never be with those cold and timid souls who neither know victory nor defeat.” ~ Theodore Roosevelt
We did it!
We successfully made it through the comment period for the Theodore Roosevelt National Park Draft EA!
Hopefully everyone submitted their comments!
What happens now?
The Park will review all of the comments received. Some of you have asked if they actually read ALL of the comments. They are responsible for every WORD that each of us sent to the Park. That is why getting your comment into the administrative record was so important! That is also why Chasing Horses Wild Horse Advocates chose to have our lawyers write our letter. EVERY LETTER AND EVERY WORD matters!
The Park should be back in a few months with a report on how many people comment like they have in the past. I am eager to see how many comments they received this time!
We added our CHWHA/AWHC comment letter to our website. You can read it here: https://chwha.org/save-the-trnp-wild-horses/ We will also work on getting comment letters added to the website from this public comment period. If you want us to share your letter, please email it to us at info@chwha.org.
Yesterday I took the CHHWA/AWHC comment letter to the Medora, ND post office where it was sent certified mail. I also mailed our CHWHA form comment letter with signatures from just under 4,000 of you ~ also certified mail, so that also becomes part of the administrative record for this comment period!
Someone asked me if I was nervous about the Friday deadline and what it meant.
I CANNOT stress this enough – Friday was nothing more than a deadline to get comments in. This is just the start of what we expect will be a very long fight for the freedom of the wild horses that call Theodore Roosevelt National Park home! We hope that each and every one of you will be with us for the long haul as we continue to Fight for the Spriit of the Badlands!
We definitely “Dared Greatly” these last few months!
With your help and support Chasing Horses Wild Horse Advocates accomplished A LOT during these last two months!
CHWHA sent in a formal request to Superintendent Angie Richman requesting an extension to the current comment period.
CHWHA demanded that TRNP make all documents cited in their Draft EA available to the public. Those documents were uploaded a week after the Draft EA was released.
CHWHA had our lawyers at Eubanks and Associates, PLLC create our comment letter for this public comment period. This expense to CHWHA is $1100 (so far). American Wild Horse Campaign signed onto our letter and is helping with the additional expense.
CHWHA held several Horse Talks where a variety of experts talked to us and answered your questions regarding different aspects of the Draft EA. All of these talks are available for you to view on our YouTube channel: https://www.youtube.com/channel/UCeyTpwa2Y1yUsTaJ4TU-eNw We will continue to host our Horse Talks! Watch for updates and also let us know if there is someone you want us to reach out to for a future Horse Talk!
Our friends at National Geographic created short, impactful videos for us to help raise awareness about the current plight of the TRNP wild horses. These videos are available to view on our YouTube channel as well: https://www.youtube.com/channel/UCeyTpwa2Y1yUsTaJ4TU-eNw
CHWHA spent approximately $4,000 in advertising during the last month to help get the word out for people to comment during this public comment period. Ads appeared on social media and in print and online ads through The Dickinson Press and Forum Communications
CHWHA connected with our ND State Legislators and introduced the North Dakota Wild Horse Preservation Act and requested that it be voted on during their special session in October. It was one of 7 requests that moved forward to the committee. It did not move forward during this special session, but CHWHA will continue to bring this to the attention of our state law makers as opportunities arise!
CHWHA has been working with Senator John Hoven’s office. Senator Hoeven is committed to making sure that a genetically viable herd of horses remains IN Theodore Roosevelt National Park!
CHWHA remains in contact with ND Governor Doug Burgum’s office. His office received a copy of CHWHA/AWHC’s comment letter. His office has told us that they continue to keep all offers on the table for TRNP to allow for a genetically viable herd of horses to remain in the Park.
CHWHA has engaged approximately 400,000 people every week through our social media pages!
CHWHA’s billboard is STILL up on I-94! This comes at a cost of $975 per month to us!
CHWHA continued to keep the horses in the news through constant communication with our media contacts.
CHWHA sent a petition with supporting documentation to the State Historic Preservation Office (SHPO) with just over 3700 signatures requesting that the SHPO find that the wild horses of Theodore Roosevelt National Park are historically and culturally significant.
CHWHA participated in Halloween events in Medora and surrounding communities to help raise awareness about the current plight of the TRNP wild horses.
CHWHA has created flyers, brochures, stickers, and other print media that can be used by our followers to help spread the word about the TRNP wild horses. Send us an email at info@chwha.org if you would like any of these items!
CHWHA put out new blogs just about every day to help educate our followers on this process and the TRNP Draft EA. Our website traffic was up over 500% during the last 2 months!
CHWHA participated in a number of podcasts to help raise awareness with different audiences about the current plight of the wild horses in TRNP.
CHWHA created talking points and a sample comment letter for our followers to use to create impactful and substantive comment letters to the Park.
CHWHA will be participating in Christmas events in Medora and surrounding communities as we continue to raise awareness and let people know that the Fight for the Spirit of the Badlands is far from over!
We are NOT just SAYING we are doing so much to fight for the wild horses of Theodore Roosevelt National Park – with your help we are actually DOING so much! With your help, Chasing Horses Wild Horse Advocates has continued to Fight for the Spirit of the Badlands from EVERY ANGLE! That fight is far from over! We will continue to fight with the same intensity even now that this public comment period is over!
Former ND Governor Ed Shafer told us to keep the pressure on and to not let up! We promised him, and all of you, that we would! THAT is a promise we intend to keep!
We have incurred some hefty expenses over the last 2 months as we continued to do everything we could to raise awareness that our beloved TRNP wild horses need EVERYONE’s help! We hope that you will help us with these costs by making a tax-deductible donation to Chasing Horses Wild Horse Advocates. Please remember, aside from American Wild Horse Campaign, NO other organization is helping us with these costs. If someone is raising money or asking for donations for the TRNP horses, please do not be afraid to ask them how their money is helping the horses!
It has been a long couple of months for sure! With your help, we think that CHWHA and our followers stepped into the arena and gave it everything we had to give!
There is A LOT more work to do to save this historic wild horse herd. Please take a moment to catch your breath! We have some NEWCalls to Action brewing! Stay tuned for details!
We cannot thank you enough for your support! Have a wonderful weekend!
Good morning! We hope everyone had a wonderful Thanksgiving!
Have you sent in your comment letter to Theodore Roosevelt National Park yet?
If you have procrastinated, or maybe you JUST found out about the plight of the wild horses that call the Park home – TODAY is the LAST day to submit your comments on the Draft Environmental Assessment (EA)!
When you have them postmarked by TODAY (11/24/2023) and mail them to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
Chasing Horses Wild Horse Advocates made it easy for you! We have a sample comment letter that you can sign onto AND use to write personalize to write your own comment letter to the Park: https://secure.everyaction.com/9pae2T4Ud0SItoaoX10DmA2
THIS is the last day that comments will be accepted on the Draft EA. Please make sure you exercise your right to weigh in on the future management of the wild horses that call Theodore Roosevelt National Park home.
The “fate” of these horses will not be decided today.TODAY is all about getting your comments in.
Once today passes, the Park will look over the comment letters and be back in the spring and let us know what they decided: will they present us with a FONSI (Finding Of No Significant Impact) or will they move forward with an Environmental Impact Statement (EIS).
At that time, and depending on what they decide, our lawyers will let us know if we have any legal recourse and we will talk about our next steps.
We have said it many times before, and we will say it again, we are at the start of what will more than likely be a very long fight for the freedom of these horses.
Today is just one step in our process.
There are also a lot of other things we are also working on to help these horses. We will share more of that next week.
For today, PLEASE make sure you get those comments uploaded to the Park’s planning website or postmarked TODAY and mailed to them.
Just under 200 wild horses are depending on you to speak up for them!
The article may also find its way to your local newspaper – if it does, be sure to send a letter to the editor to keep the TRNP wild horses in the news!
“What greater thing is there for human souls than to feel that they are joined for life – to be with each other in silent unspeakable memories.” – George Eliot
I cannot tell you how many silent unspeakable memories the wild horses of Theodore Roosevelt National Park have given me! On a day when we celebrate our families and our blessings, for me personally, that includes these amazing wild horses. I believe this is true for many of you too! This can be true if you have spent countless hours in the Park with them, or if you know them through the many social media outlets that share photos and stories about these amazing wild horses.
These horses live in a national park that was set aside to preserve nature and pay tribute to Theodore Roosevelt and his time in the Badlands of North Dakota. Without a doubt, the ancestors of the horses we have come to know and love were a part of that history.
The photo attached to this post is part of Stallion Nicols’ family. They are a young group of horses mainly made up of 2–4-year-olds who are learning to navigate life with each other and a first-time band stallion who is 9 years old. These lucky girls are not only sisters, but they were blessed to have the opportunity to learn how to be the great mares they are becoming by watching their incredible mothers: Mares Teepee, Goblin, and Indian Paint Brush.
The dynamics have been amazing to watch. Even better, now these young ladies that we have had the opportunity to watch grow, are having their own babies. Now they get to be the teachers and we get to watch their babies learn and grow.
And hopefully, our children and grandchildren get to come to Theodore Roosevelt National Park and see Nicols and his family or their offspring and be reminded of the rich equine history that runs through the Badlands of Southwestern North Dakota.
Today, your human family may be counting on you to cook the turkey, or bring desert, maybe they simply want you to show up and spend the day with them. Your family at Theodore Roosevelt National Park is also counting on you to show up for them too!
Can you take a few minutes before the hustle and bustle of the day to send a comment into Theodore Roosevelt National Park?
Or….
Maybe later when everyone is in a food coma, you might have a moment for a quick comment asking the Park to allow the wild horses of Theodore Roosevelt National Park to remain in the only home they have ever known.
If you have already sent in your comment letter to Theodore Roosevelt National Park, we are thankful for you! More than that, 200 wild horses that call the Park home are grateful that you took the time to speak up on their behalf.
If you have NOT sent your comment letter in yet, please take a moment to comment on the Draft Environmental Assessment that Theodore Roosevelt National Park released in September.
Even better – ask your family and friends to make a simple comment on behalf of the 200 horses that call the Park home.
The freedom of 200 wild horses is what is at stake. They don’t have a voice that can be heard or understood by the humans trying to eliminate them from the only home they have ever known. They need you to speak up for them.
We all have our “favorite” family members that we look forward to seeing on the holidays. Who is your favorite family member in Theodore Roosevelt National Park?
Or maybe your favorite, like mine, crossed the rainbow bridge.
Can you take a moment to fight for the legacy that Mystery, Red Face, Copper, Strawberry, Cocoa, Singlefoot, Satellite, Silver, Chubby, Blaze, Sweetheart, Wind Canyon, Cheyenne, Thunder, and so many others have left behind either through personal memories and/or their offspring that still call the Park home?
Your comment letter can be as simple or as long as you want it to be! Chasing Horses Wild Horse Advocates created a form letter for you to use to submit your comments. We also have over 3800 people who have signed this comment letter. You can find our template and sign onto our letter here: https://secure.everyaction.com/9pae2T4Ud0SItoaoX10DmA2
Have your letter postmarked BY November 24, 2023, and mailed to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
CHWHA will be mailing the comment letter that everyone has signed onto FRIDAY so it is postmarked ON November 24, 2023!
Saturday will be TOO LATE for you to weigh in on the future management of this historical herd of wild horses!
Please, take one moment today to speak up for our family of wild horses that call Thedore Roosevelt National Park home.
Also please note: Friday marks the end of this part of our fight. This is just the beginning of what we expect to be a very long battle for the freedom of these iconic wild horses.
Once you get your comments in, please be sure to check back here after you rest up this weekend! We have some things brewing and will no doubt have some new Calls to Action for you in the coming weeks!
Happy Thanksgiving to you and yours! Have a wonderful and safe holiday!
Thank you for your support!
P.S. We uploaded our Chasing Horses Wild Horse Advocates comment letter to our website yesterday. You can view it and other supporting documents to help you create your comment letter here: https://chwha.org/save-the-trnp-wild-horses/
Thank you for taking a moment to check back in with us as we are on the eve of the Thanksgiving holiday!
Have you sent your comment letter to Theodore Roosevelt National Park yet?
CHWHA has spent the last two months explaining the Draft EA and giving you talking points to use in your comment letter. It is time to put ALL of that to use and speak up for the wild horses of Theodore Roosevelt National Park!
Our comment letter will be uploaded to the Park’s website AND since the Park’s website does NOT allow for attachments, our letter will both be emailed to Superintendent Richman AND mailed to her on Friday.
We think you will be as impressed with our comment letter as we are! Our lawyers did a GREAT job making sure that all of our concerns were addressed and that every necessary document (INCLUDING NPS 2022H!) is submitted into the administrative record!
We will be billed for our part of this letter. We do hope that you will help us offset those costs by making a tax-deductible donation to Chasing Horses Wild Horse Advocates. American Wild Horse Campaign is helping us with this expense, but we do have our share from before they signed on with us. This letter is worth every penny! If you agree, you can make a donation to CHWHA here: https://chwha.org/support-chwha/
Please feel free to share your comment letters with us! We will be collecting them again and adding them to our website! You can email it to us at info@chwha.org
Thank you for your support and have a GREAT night!
Tomorrow is Thanksgiving. In light of that, I wanted to let each and every one of you know how truly thankful I am to have all of you fighting with us for the Spirit of the Badlands!
I have said this before and feel that it is worth saying again.
First, our nonprofit organization was born because so many people came to us wanting to change the constant culling of 4-month-old to 3-year-old horses twice a year, every year and to put a stop to what ended up being 11 years of experimentation on our mares with GonaCon.
When we took the leap and created Chasing Horses Wild Horse Advocates. Our nonprofit lawyer ingrained in us that nonprofit organizations belong to the community they serve.
I say that because Chasing Horses Wild Horse Advocates (CHWHA) does not belong to me, or our board. It belongs to each and every one of you. Every single one of you are an important part of what makes CHWHA work. Likewise, the successes that we have had in this fight come from the hard work of all of us that belong to this community.
I reiterate this whenever anyone thanks “ME” for what I am doing. I ALWAYS turn that “me” statement into a “WE” because Chasing Horses Wild Horse Advocates is nothing without all of you.
I am sharing this with you today because WE only have a few days left to get people to send in their comments to Theodore Roosevelt National Park.
WE have done A LOT of work since September 25th – heck, we have done A LOT of work since March of 2022!
Now it is time to make sure that everyone possible is weighing in on the future management of the wild horses that call Theodore Roosevelt National Park home in our LAST public comment period for this Draft EA process.
So first, have you sent in your comment letter? Have you had your family, friends and coworkers send in their comment letters? Remember, your comment ONLY counts when you submit it through the Park’s planning website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035 or when you have it postmarked by November 24, 2023, and mail it to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
Second, WE received a very nice complement yesterday.
Never in my life would I believe that I would be able to reach out and easily talk to people like Dr. Castle McLaughlin, Frank Kuntz, Jen Britton, Ross MacPhee, Craig Downer, Eric Molvar, Scott Beckstead, Sandy Sharkey, Suzanne Roy, Kerry Ferguson along with so many others, including an amazing man named Steve Martens who lives in Fargo, ND.
I have talked about Steve before. Steve is fighting hard for history to be preserved. For Steve, that history includes the wild horses in Theodore Roosevelt National Park.
Steve has been emailing me quite often. I feel like we are pen pals! I truly hope we get to meet in person some day!
Steve is also fighting hard for a proper Section 106 Review process for the TRNP wild horses that is happening with the North Dakota State Historic Preservation Office (SHPO). CHWHA also submitted a petition and documentation. We also talked about this in an earlier blog post: https://chwha.org/2023/10/16/historical-preservation-petition/
Yesterday, Steve sent his comment letter to me to share if I chose. His comment letter is written very eloquently as he pleads with the Park, as we all are, for the preservation of this herd.
Steve’s comment letter was attached to an incredible email that brought me to tears ~ in a good way!
I want to share that with all of you. Again, the email was written to ME but the message is for the WE that makes up Chasing Horses Wild Horse Advocates (that is ALL of you 😉 )
Please enjoy this letter and honestly, pat yourselves on the back. We have accomplished some pretty incredible things in the last (almost) 2 years!
We have A LOT more work to do and I sincerely hope that all of you will stay in this fight for the long haul. These horses need ALL of us!
Steve’s email is copied and pasted in its entirety below. I have also attached his comment letter for you to read after his email.
Thank you for your support and have a wonderful day.
P.S. Don’t forget to send in your comment letter to the Park!
No need to reply until the heat of battle is settled a bit. I just wanted to get this copy of my NPS/TRNP comment letter onto your desktop. Maybe you can re-visit it after the Friday deadline. I put my paper copy in the mail to Medora today.
Feel free to share any of my comment letter material with anyone you think may find it helpful. As soon as I hit “Send” to you I will send digital copies of my comment letter to Bill Peterson and Lisa Steckler at SHPO/SHSND, and to Patrick Springer who has developed such remarkable understanding of the issues that he can share with Forum readers.
After our Zoom conference last evening I reworked some of my comments in light of SHPO’s eventual need for “significant heritage landscape” information from NPS they can act on. Knowing how well Bill Peterson does his job and understands preservation law, I was reminded that he will be getting mostly useless “boiled down” information from NPS. I’m hopeful SHPO will seek out informed perspectives from many other sources. In my experience SHPO takes public comment seriously, unlike NPS who treat it as a perfunctory task to check off.
Last night’s conversations about humanities, social and behavioral science perspectives on landscape meaning struck me as the main thing SHPO will need to know that is not provided by NPS. Getting NPS to acknowledge those perspectives is like finding hen’s teeth when they would just rather fly a helicopter in and kill off the horses. Kind of a SWAT team approach to landscape management.
Again, I’m mindful of how incredibly busy you are just now, but I have to reaffirm what Castle said last night, about how truly helpful, constructive, and effective you are as the best advocate those horses could ever have! You bring unbelievable energy and hopefulness to this trying process. All your comments and focusing questions help the rest of us with bringing our disparate thoughts together.
Being greeted daily by photos of the horses in each of your messages invariably lifts my spirit by reminding me what we are fighting for. The expert, informed judgment of brilliant, insightful people like Castle McLaughlin, Jenn Britton and others spark constructive ideas for others of us.
Chris, you and your support group are the most effective, energetic, positive and hopeful, life-affirming advocates for heritage I’ve met in my 50-years of experience learning from North Dakota people and landscapes. Your comments and ideas are always so constructive and appropriate to our purpose. It’s an honor and privilege to be involved in this important work.
Please get a bit of much-deserved rest after the current battle. My wife and I are scrambling to find someplace we can squeeze out a small contribution from our meager resources.
Peace and once again THANKS for being the right person at the right time.
Our talk with Castle was uploaded to our YouTube channel last night. You can view it here: https://youtu.be/bTrtNh9cJOY
We have also uploaded a new series of short videos that you can share to help raise awareness that THIS FRIDAY – NOVEMEBER 24, 2023, is the LAST day that the public can comment on the TRNP Draft Environmental Assessment. We have some short and some long videos. Links to these are also great to add to comments! You can view them all on our YouTube channel: https://www.youtube.com/channel/UCeyTpwa2Y1yUsTaJ4TU-eNw
I just got done reviewing the CHWHA/AWHC comment letter that our lawyers drafted for us. I sent my comments back to them and as soon as it is approved by everyone, we will share it with you. As I said in the Horse Talk last night, I personally wrote our first comment letter and then our lawyers polished it. CHWHA did make the decision to have our lawyers write our comment letter this time because at this moment, it seems clear where this is going. We want to make sure that our I’s are dotted and our T’s are crossed. I can say that our legal team did that in spades!
Something we have danced around but have not fully discussed in our blogs is the “No Action Alternative”. Our lawyers discuss this in our comment letter, and I want to share this with you – especially in light of the Poe documents that we shared yesterday.
The “No Action Alternative” goes back to the 1978 Environmental Assessment. If you look at the Poe documents, you see that in 1995-1998 there was “no single document” being used to manage the horses. Also, if you look at the Park’s horse portal (https://www.nps.gov/thro/learn/nature/horse-management-documents.htm ) you will see a 1984 Resource Management Plan (RMP). This plan was also updated in 1994 and is listed as NPS 1994 on the Park’s planning website (https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132153). Neither of those documents refer to the 1978 EA for the management of the horses.
Soooooo
This begs the question, if they were NOT looking at the 1978 EA in 1984, 1994, 1995, 1996, 1998 or ever for that matter, WHY are we looking at it in 2023?
More than that….
A “No Action Alternative” means just what it says – no action will happen. Think in terms of “What happens if we do nothing? “
Immediately removing 150 horses does not seem like a “no action alternative”, does it?
It actually seems like the opposite – some ACTION will be taken.
All of that coupled with the fact that the Park has NEVER maintained the horses at the 35-60 horses that was set in 1978 call into question if we were actually given a “No Action Alternative”.
The answer: NO WE WERE NOT!
Now for the legal terminology from our current comment letter:
“Any alternatives analysis undertaken pursuant to NEPA must include a “no action alternative,” which NPS’s implementing regulations define as either: (1) “‘no change’ from a current management direction or level of management intensity (e.g., if no ground-disturbance is currently underway, no action means no ground-disturbance)”; or, (2) “‘no project’ in cases where a new project is proposed for implementation.” 43 C.F.R. § 46.30. The Park must ensure that the Draft EA’s No-Action Alternative is “consistent with one of the[se] definitions.” Id. “
AND
“Consequently, the Draft EA fails to include a true no-action alternative, in violation of the Park’s NEPA regulations, id. §§ 46.30, 46.310, and agency-wide guidance, see NEPA Handbook at 55 (“Except in limited circumstances (when there are no unresolved conflicts with respect to alternative uses of available resources), you must also describe and analyze the no-action alternative when preparing an EA.””
THIS is why we are working with Eubanks and Associates PLLC. We think you will be equally impressed with our comment letter. We will be releasing it once everyone has signed off on it ~ within the next few days.
We get ONE chance to save these horses. CHWHA wants to make sure that we have the BEST chance to exhaust every last resource to save this herd.
Our lawyers, our educational materials, the extensive advertising we have done, things like Zoom subscriptions, website fees, paper, ink, postage, ALL cost our non-profit organization money. We have and always will be transparent with where your donations are going. We also challenge you to ask us and ANYONE raising money to help the TRNP wild horses WHAT they are doing with your donation. As we have said before, the ONLY organization currently helping CHWHA financially is American Wild Horse Campaign. They have agreed to sign onto our comment letter and will be helping with the fees associated with that.
I will leave this blog with you today with two requests:
When you have your comment letter postmarked by November 24th and mailed to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
#2 – PLEASE consider making a donation to help us continue this critical advocacy work. As a 501(c)3 organization, we rely on your donations to help us do what is necessary to help save this herd. There are several ways you can donate listed on our website: https://chwha.org/support-chwha/. Your donation to CHWHA is 100% tax deductible!
Thank you to everyone who has already sent in your comment letter. Remember, if there are points that you didn’t make that you wish you did, please send in another comment. Think of it this way, FRIDAY is your LAST chance to comment on the Draft EA and what YOU want to see in the future management of these amazing wild horses. Make sure your voice is heard. These are OUR horses that are living wild and free in OUR national park. We ABSOLUTELY have the right to demand that our voices are being heard!
Lastly, please DO NOT think that this is all over on Friday. As we always say, we are fighting this from EVERY angle – and we already are working on some Calls to Action for you NEXT WEEK to help save this herd!
This will be a busy week for sure but we have some new information to share with you.
Please remember, A LOT is happening this week and we have A LOT brewing to share with you in the coming weeks BUT the #1 thing that EVERYONE has to do is send their comment into Theodore Roosevelt National Park. Please remember, the ONLY way that your comment counts is when you submit your comment on the Park’s planning website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035
Or when you have it postmarked by November 24th and mail it to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
Those of you who have been with us for this fight since March of 2022, hasn’t this been such a CRAZY ride? We have come A LONG way since March of 2022 and we still have so much work to do to save these horses.
Thankfully, we have some pretty incredible people fighting WITH us for these horses. Hands down one of the most incredible people I have had the pleasure to meet on this journey is Dr. Castle McLaughlin.
No one has documented the wild horses of Theodore Roosevelt National Park in the detail that Dr. McLaughlin did. Her report is in the library section of our website (https://chwha.org/library/) and also a useful tool to help you write the historical aspect of your comment letter to the Park: https://chwha.org/save-the-trnp-wild-horses/.
Dr. McLaughlin also had the opportunity to talk to people who are no longer with us AND she had access to ALL of Theodore Roosevelt National Park’s records for her research into the history of the horses.
Even more incredible, as Dr. McLaughlin went on to help Frank and Leo Kuntz found the Nokota Horse Conservancy and went on to be curator at Harvard’s Peabody museum, she has been working with us in our Fight for the Spirit of the Badlands.
Everyone gets to talk to Dr. McLaughlin TONIGHT – we will be hosting her for our NEW Horse Talk. Please make sure you register for this talk: https://secure.everyaction.com/g7a0vfnvjE6GIyKovr3BUA2. It will be a casual talk and Dr. McLaughlin will do her best to answer your questions.
We think what we are about to share will definitely conjure up some questions from all of you!
As we said, Dr. McLaughlin had access to ALL of Theodore Roosevelt National Park’s records as she did her research. She was also invited back after her report was published. We will let her talk about all that tonight!
As Dr. McLaughlin is working on her own comment letter, she has been digging back into her records from the Park and shared a few of them with us.
We ALL know who Superintendent Angie Richman is. But today we want to introduce you to Superintendent Noel (Nole) Poe.
Noel (Nole) Poe became Superintendent of Theodore Roosevelt National Park in 1995. We believe that he was superintendent for about 10-15 years. He may have been the longest running superintendent of TRNP.
In September of 1998, Superintendent Poe writes:
“During 1997, the park staff made the following decisions for the management of the feral horse herd. The last two years we have sought funding for developing an ungulate management plan that encompasses the three major wildlife species: bison, elk and horses. To date our efforts have not been successful. We will continue to pursue private and public funding.”
Did you get all that in that power packed paragraph?
In 1997 decisions were made about the management of the horses.
He WANTED a management plan but could not get the funding
The park has three major WILDLIFE species: Bison, Elk AND HORSES
He goes on to explain that Dr. Gus Cothran analyzed blood samples that were taken in during the roundups in 1991 and 1994. Poe states:
“After reviewing Dr. Cothran’s report and the current Ungulate Carrying Capacity Model, park management made as decision in 1997 to increase the population range of feral horses to vary from approximately 70 to 140 animals.”
WOW! A management decision was made in 1997 to INCREASE the herd to 70-140 horses!
In March of 1997 Poe and his staff created a “Discussion Document” on Feral (Wild) Horse Management for TRNP – YES! Poe referred to the horses as “wild”!
In 1996 Poe states:
“Current Management Actions: A management plan was approved in 1970, when the decision was made to manage the horses because of their historical ties to the Theodore Roosevelt Ranching scene. Since that time the horses have been managed under this plan with modifications made through the Resource Management Plan, memos and letters.”
Hmmmmm….
If there was no talk about the 1978 plan in 1996, why are we talking about it in 2023?
Ready for this…
CONCERNS WITH CURRENT MANAGEMENT PROGRAM:
#1 – THERE IS NOT ONE DOCUMENT THAT PROVIDES SPECIFIC DIRECTION FOR THE WILD HORSE PROGRAM.
Hmmmm again – in 1996 there was NOT ONE DOCUMENT that the Park used to manage wild horses? But in 2023 we can only get them to refer to a 1978 document?
And then there is also this…
“While refinements need to be made to the written wild horse management program, the park is essentially happy with the current management of the horses SINCE THIS PROGRAM MEETS THE GENERAL PUBLIC’S DESIRES and has cost effective practices.”
WOW!
We could go on and on all morning. Instead, please read these documents for yourself.
We hope this helps enlighten you with some past management practices with regards to the wild horses of Theodore Roosevelt National Park. This clearly shows what CAN be done, IF the Park decided to listen to the “general public’s desires” and manage the horses – with some consultation with someone like – I DON’T KNOW – Dr. Gus Cothran – who has also weighed in on the current situation regarding the wild horses of Theodore Roosevelt National Park: https://www.kxnet.com/news/state-news/cutting-the-herd-size-at-theodore-roosevelt-national-park-could-be-bad/
More than anything, please, take advantage of the opportunity to talk to someone like Dr. Castle McLaughlin and hear what she has to say about her work, Noel Poe and the current situation regarding the wild horses of Theodore Roosevelt National Park. Remember, these events are FREE, but we do ask that you register in advance: https://secure.everyaction.com/g7a0vfnvjE6GIyKovr3BUA2
Oh, and yes, these documents will be included in the Chasing Horses Wild Horse Advocates & American Wild Horse Campaign joint comment letter. These documents will become part of the administrative record for this comment period.
Today we have a new document to share with you. I would not say that it was “earth shattering” but we feel that it is important because this document came from Theodore Roosevelt National Park themselves! It shows the history of the wild horses, including captures, removals, deaths, and more – from 1947-1997!
FIFTY years of wild horse history – FROM THE PARK!
And no, the Park did NOT give us this information!
Dr. Castle McLaughlin, who we are having a NEW Horse Talk with TOMORROW (11/20/2023)– had access to all of the Park’s files when she did her research on the history of these amazing horses AND she had access again after!
Please note: The number of horses listed on this document has always been controversial. The Park didn’t even know they had horses fenced into the Park until they were told by a local rancher. If you have ever been to the Park, we think you will agree that there are MANY places the horses could have been without being seen!
If you are finishing up your comment letter, we would suggest holding off until after you see what Dr. McLaughlin has to say tomorrow. We are sure she will give you some GREAT food for thought to add to your comment letter!
For today, enjoy these 3 pages of wild horse history (yes, note on this document from the Park – they were referred to as “wild horses” in 1997!) and we will see you tomorrow for our Horse Talk with Dr. Castle McLaughlin!
I want to thank each and every one of you no matter how long you have been on this journey with us. The wild horses of Theodore Roosevelt National Park are quite amazing, aren’t they?
We are in serious danger of losing this historic herd of wild horses.
There are just a few days left to get your comments in. I know we have talked a lot about substantive, impactful comments. This was never meant to make you feel like you had to do a lot of research for your comment letter. It is meant to make you think about what you want to say to the Park beyond, “I will never return to the Park if the horses are removed.” We think we have given you A LOT to add to your comment letter.
There are Horse Talks we have had with some pretty incredible people – including one with Jen Britton that we had tonight that was amazing! We are in the process of getting that video uploaded to our YouTube channel. We will share the link when it is uploaded. You can also subscribe to our YouTube channel so you get notified when any new videos are uploaded: https://www.youtube.com/channel/UCeyTpwa2Y1yUsTaJ4TU-eNw
The historical aspect of this argument is really significant. Dr. McLaughlin will no doubt have some amazing ways that will help you drive that point home in your comment letter!
Many of you are sending us your comment letter to read and give our opinion on. We truly appreciate all of you sending in comment letters to the Park. We also appreciate you sharing them with us. Please understand that we cannot possibility take the time to read everyone’s comment letter and provide feedback. Our lawyers just gave us our draft comment letter (31 pages!) that we have to read through and discuss with them. We also have some new documents we will be sharing and some new information this week in our blogs. Our time is extremely limited with the comment period ending this FRIDAY. Thank you for understanding.
That being said….
Your comment letter should say whatever it is that you feel the Park needs to hear about the future management of the wild horses that call Theodore Roosevelt National Park home. We created a template for you to use with key points: https://secure.everyaction.com/9pae2T4Ud0SItoaoX10DmA2. You are welcome to use those points to create a letter that is unique for you and your thoughts on the future management of these horses.
There is no right or wrong way to write your comment letter. There ARE ways to make them more impactful, and we have shared ways for you to do that through our blogs over these last 2 months.
Educated advocates write meaningful, impactful, and substantive comments.
ALL OF YOU ARE EDUCATED ADVOCATES!
We have faith in you! We know you are now well versed and educated in this process and the TRNP Draft EA. You have asked amazing questions and we have done our best to get you the best people to help give you the best answers.
Take a breath.
You got this!
If you want to share your comment letter for us to share on our website, please email them to us at info@chwha.org. We will create a page for the November 2023 comment letters.
We have some NEW stuff to share with you tomorrow – so be sure to check back. We think you will REALLY enjoy this!
Have a great night and thank you again for your support!
We wanted to share an update/story from Theodore Roosevelt National Park with you.
A few weeks ago, the Park had a bison round-up. For a full week, they used helicopters to gently round up the bison. Their target was to capture 400 bison. Captured bison are usually given to tribes, zoos or sold for meat.
While the helicopters are flying, the horses, who remember helicopter round ups, begin running too. This is interesting to note because they have not used helicopters to round up horses for 10 years. Still, the older ones remember and teach the younger ones to run at the sound.
It is also important to note that if the Park is successful in their attempts to eliminate this herd of horses, they have stated that they will go back to weeklong helicopter round ups on the horses. Also, horses who do not sell “after multiple attempts” will be euthanized.
Back to our story…
Weeklong helicopter round ups for the bison caused quite a ruckus in the horse world.
We were in the Park the other day and noticed several changes. Time will tell if these stick or if the bands will make their way back to what they were before the bison round up.
Perdita has proven to be quite an interesting mare!
She gave birth to her first baby, Mare Anisak, in April of 2019, when Perdita herself was only 2 years old. She was alone and did all she could to protect her baby as then bachelor stallions Gunner and Flash fought over who was going to start their first band with Perdita and her new baby.
After weeks of battling, Gunner finally won. Perdita has (MOSTLY) been with him ever since.
It is obvious that Perdita enjoyed their band when it was just their small little family.
Gunner, on the other hand, maybe with the male “bigger is better” mentality, had other ideas for the future of the band. Gunner has held the largest band with a number of 20!
Over the last couple of years, as the band has grown, Perdita seems to occasionally take a sabbatical away from the rest of the band. She never goes alone; she always takes her kids with her.
We will say that Perdita ALWAYS manages to find her way back to Gunner!
This week we found Perdita with her son, 2021 Colt Ace, and her daughter, 2020 Mare Birch along with Birch’s daughter, Filly Aspen, all together. 2021 Colt Beau was also “with” the group.
Since none of us were there to witness the changes, it is hard to tell what is currently happening.
The five could have simply been separated from the band during the bison round up. Gunner could have made attempts to kick Beau and Ace out of the band. Perdita could just be taking another sabbatical.
Fun fact:
Beau and Perdita are both siblings. They were both born to Mare Pretty Girl and the late Stallion Red Face is the presumed sire of both.
The horses definitely keep things interesting, that is for sure!
There are other changes that have happened over the last month as well. We will begin to talk about those here in the coming weeks. The sun sets at 4 pm now, and colder weather keeps teetering back and forth. We are trying to use the time we have to get answers on where everyone is.
As always…stay tuned!
I share this story today because this is what we do. So many people share photos and stories of what they experience when they see these amazing horses. And before you know it, everyone is in LOVE with their favorites. Or maybe you are like me, and they are ALL your favorites!
Each one of these horses is unique in their own way. They each have their own story and their own personalities. They all have their families, like Perdita, that they very obviously love and work hard to protect.
Each one of these horses is in danger of losing their freedom in the ONLY home they have ever known – the rugged badlands of North Dakota.
We have just one week left for everyone to get their comments into the Park. Have you sent yours yet?
Please note: we are NOT collecting comments. The ONLY way that your comment counts is if you submit your comment through the Park’s planning website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035 or have it postmarked by November 24th and mailed to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
Chasing Horses Wild Horse Advocates has a wealth of information to help you make an educated, impactful and substantive comment on our website: https://chwha.org/save-the-trnp-wild-horses/
For those of you who don’t like to copy and paste, you can sign onto our comment letter: https://secure.everyaction.com/9pae2T4Ud0SItoaoX10DmA2. We will mail it to the Park with all of your signatures attached and make sure it is postmarked by the November 24th deadline.
Just under 200 wild horses are counting on you to be their voice! Please make sure you take a moment to comment FOR THE HORSES!
Thank you for your support and have a GREAT weekend!
I wanted to start by saying THANK YOU to all of you who took the time to send me a birthday message or donated to CHWHA yesterday! THANK YOU!! THANK YOU!!! THANK YOU!!!
We have just about a week left for everyone to get their comments into the Park. THAT is the #1 thing that everyone should be focused on!
Have you sent your comment letter to Theodore Roosevelt National Park yet? Just under 200 wild horses that call the Park home depend on you to be their voice!
If you have already sent in your comment, as our friend Barbara at ECI says “There is always someone to your left and your right!” Have you asked your spouse, parents, siblings, friends, neighbors, and co-workers?
We hope that over the last 2 months we have helped you have a better understanding of the NEPA process and the contents of the Theodore Roosevelt National Park Draft EA. We have shared resources with you as well as helpful tips to guide you so that you could write your own comment letter. Then we even shared a sample comment letter that you can easily make into your own unique comment. We have the letter available to view and also for you to sign onto our website: https://secure.everyaction.com/9pae2T4Ud0SItoaoX10DmA2.
We have updated our Save the TRNP wild horses page. This page has all the information you need to make a substantive comment, all in one place!
We have been advertising in our local newspaper and online through Forum Communications. We have also been running ads on social media. Have you seen them?
Our billboard is also still standing tall on I-94!
We continue to share new videos created to help raise awareness about the wild horses that call Theodore Roosevelt National Park home. You can find them on our YouTube channel. Please share these videos. They are proving to be a GREAT way to help spread the word!
We have held some amazing Horse Talks to help educate our followers! They are all available to view on our YouTube channel as well!
We will also be hosting a NEW Horse Talk with Dr. Castle McLaughlin this MONDAY (11/20/2023)! We will have details shortly on what time and how to sign up!
You can view our last Horse Talk with Dr. McLaughlin on our YouTube channel:
Our comment letter is done and being reviewed by our legal team. Once they have approved it, copies will be sent to us and American Wild Horse Campaign to look over. Once we all sign off on it, we will send our comments BOTH electronically and through the mail. We will share the finished copy with all of you once it is approved by everyone.
We are not just saying “we are doing a lot to save these horses” we have always and continue to let you know every step of the way what we are doing and how you can help! Thank you for helping add strength to our voice!
The other thing you can do to help us is to help support our critical advocacy work. Lawyers, ads, promotional materials, subscriptions, website fees and general office supplies all cost us money as we continue to Fight for the Spirit of the Badlands. Every little bit helps! There are several ways you can donate to us listed on our website: https://chwha.org/support-chwha/
Can you make a donation of any size to help us cover our expenses this month? We have $1100 in legal bills, we have spent over $2,000 in advertising and want to continue to advertise through 11/24, we have our billboard fees of $975 and all of that is in addition to website and subscription fees.
We have had requests for a form letter that can be sent to the Park for the current Livestock Plan that includes the future management of the wild horses that call Theodore Roosevelt National Park home.
We have spent a great deal of time through our blogs explaining this process and how you can make your own SUBSTANTIVE comment to the Park. We also know that this can be quite an intimidating process, so we made it easy for you!
We have created a form letter that we know includes any supporting documentation that the Park already has. That means that you can simply customize this letter, copy and paste it onto the Park’s website and whalla! You just made a public comment to help the wild horses of Theodore Roosevelt National Park!
If cutting and pasting isn’t your thing, you can simply sign onto our comment letter. We will print this letter along with all of the signatures we collect and have it postmarked on November 24, 2023.
Yes! You CAN also do both!
Yes! You CAN do both even if you already submitted your own comment to the Park or plan to send your own letter!
We cannot stress enough that we hope that you will take this letter and customize it to make it your own unique comment letter.
Remember, the important thing is that we are trying to build a consensus.
” 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).
This letter checks off all of the boxes on what we think needs to be said to the Park. Again, you are free to customize this letter in whatever way you choose so that it incorporates what is important to YOU for the future management of the wild horses that call Theodore Roosevelt National Park home.
How is your comment letter coming along? Please continue to send us your questions about your comment letter to info@chwha.org. Also, if you have already sent in your comment letter and would like us to share it on our website, we will make a page for the comment letters shared with us during this round of comments.
THAT is the BEST way that you can help the wild horses of Theodore Roosevelt National Park right now.
We know that Theodore Roosevelt National Park listed a series of National Park Service polices that justify their need to remove the wild horses from Theodore Roosevelt National Park. We know that there are also polices that allow horses to stay on National Park Service lands because there is not a concerted effort to remove the 1,000 wild horses from ALL National Parks – just the 200 at Theodore Roosevelt National Park.
The Park also stated in their Draft EA:
1.2.2 Relationship to Existing Laws and Policies
There is no legislation directing the NPS to maintain horses or cattle in the Park, and horses on NPS units do not fall under the jurisdiction of the Wild Free-Roaming Horses and Burros Act, which only applies to horses on lands managed by the US Forest Service and the Bureau of Land Management.
That seems to be a shift from what they told us at the Civic Engagement Meeting in January of this year when they were emphasizing all of the policy violations as a result of allowing the horses to stay in the Park.
For the purpose of this blog, I wanted to share some of the laws/policies/regulations that Chasing Horses Wild Horse Advocates cited in our last comment letter for the comment period that ended in January 2023. The purpose of this is to show you that there are also laws that work in our favor. These are also things that you can cite in your comment letter.
Thank you for your support and have a great week!
NPS, and the National Park System as a whole, were established by Congress in 1916 through the Organic Act. See 54 U.S.C. §§ 100101-104909. Unlike other federal land management statutes that require a balance between conservation and extractive uses, the Organic Act focuses exclusively on the preservation of the nation’s park lands and the resources found therein. Cf. 43 U.S.C §§ 1701(a), 1702(c) (the Federal Land Policy and Management Act’s multiple-use mandate). Often referred to as NPS’s “non-impairment mandate,” Section 1 of the Organic Act provides that NPS: [S]hall promote and regulate the use of the National Park System by means and measures that conform to the fundamental purpose of the System units, which purpose is to conserve the scenery, natural and historic objects, and wild life in the System units and to provide for the enjoyment of the scenery, natural and historic objects, and wild life in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.
In recognition of the Organic Act’s strict focus on preservation, NPS’s regulations implementing the Organic Act broadly prohibit the removal of any wildlife, dead or alive, from the boundaries of a National Park. See 36 C.F.R. § 2.1; see also id. § 2.2 (NPS regulations concerning wildlife, which include a prohibition against “taking” and/or intentionally “disturbing” wildlife found within a park unit). NPS regulations define “wildlife” to mean “any member of the animal kingdom and includes a part, product, egg or offspring thereof, or the dead body or part thereof, except fish.” Id. § 1.4 (emphasis added).1 The TRNP, specifically, includes wild horses in its definition of “wildlife” for purposes of its prohibition against “Disturbing Wildlife” in the Park. See TRNP, Superintendent’s Compendium of Designations, Closures, Permit Requirements and Other Restrictions Imposed Under Discretionary Authority (Aug. 23, 2022) (“Except for inadvertent or casual encounters with wildlife in areas where traffic is required or essential, willfully approaching, remaining, viewing, or engaging in any activity within 25 yards to bison, elk, and feral horses or closer to any other wildlife including nesting birds, or within any distance that disturbs, displaces, or otherwise interferes with the free unimpeded movement of wildlife, or creates or contributes to a potentially hazardous condition or situation.” (emphasis added)) [hereinafter “Superintendent’s Compendium”].
As outlined above, and consistent with the Organic Act’s nearly singular focus on preservation of National Park resources, NPS’s regulations protect from take “any” animal within the boundaries of a NPS-system unit—regardless of whether those animals are native or not. 36 C.F.R. §§ 1.4, 2.1, 2.2. The only exception to that regulatory scheme relevant here is the Park’s carve-out for animals that have been properly “designated” as “livestock” under 36 C.F.R. § 2.60. Hence, if the Park’s wild horses are not “livestock,” they must be considered and managed as “wildlife” under the Park’s controlling regulations. Cf. Wild Horse EA at 1 (“Since the horses cannot be classified as a native wildlife species, they are managed as a livestock display . . . .”).
40 C.F.R. § 1508.27(b)(4) – This factor requires the preparation of an EIS whenever “the effects on the quality of the human environment are likely to be highly controversial” (emphasis added). As the Park is well-aware, its management of wild horses has been a controversial subject throughout the Park’s existence. Indeed, the Park itself has acknowledged that the management of these animals generates a significant amount of “controversy” due to its cost. See, e.g., McLaughlin Report at 174. Indeed, the Park’s past attempts at eliminating the herd have only been stopped in response to “public outcry.” Id. at 120; see also Wild Horse EA at 2 (“[D]ue to the strong local pressure and unfavorable publicity against the proposal, the decision was made to maintain a maximum 40-horse herd.”); Concurrent Res. No. 4014, 68th Leg. Assemb. (N.D. 2023) (“A concurrent resolution urging the Secretary of the Interior and the Director of the National Park Service to modify its proposed livestock management plan, and to continue to allow for interpretative, cultural, and historical 17 purposes a herd of longhorn steers in the North Unit of the Theodore Roosevelt National Park and the presence of a wild horse herd in the South Unit of the Theodore Roosevelt National Park.”).7 Furthermore, experts with relevant expertise in the management of wild horses, including Milton Frei and Gus Cothran, as well as experts regarding these specific wild horses, including CHWHA and the American Wild Horse Campaign, have taken issue with the Park’s management regime and disputed the scope and extent of the effect of the Park’s proposal on these wild horses, on the cultural and historic value they provide to the Park, on Park users who derive significant benefits from observing these horses, and on local tourism driving by Park users with strong ties to these horses. Thus, unless the Park is able to “resolve [this] serious criticism,” it must prepare an EIS for the LMP. See Standing Rock, 985 F.3d at 1043 (“Indeed, an EIS is perhaps especially warranted where an agency explanation confronts but fails to resolve serious outside criticism, leaving a project’s effects uncertain.”); see also Nat’l Parks, 916 F.3d at 1085-86 (“The question is not whether the [agency] attempted to resolve the controversy, but whether it succeeded.” (emphases added)).
40 C.F.R. § 1508.27(b)(6) – This factor is triggered whenever “the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration.” The Park’s decision here to remake the fundamental character of the Badlands by rounding up and removing all 7 Concurrent Res. No. 4014 is awaiting a vote by the full North Dakota Legislative Assembly. 18 wild horses is nothing if not precedential. The wild horses have inhabited the Badlands since well before the Park was established and the Park has never before eradicated an entire charismatic species simply because it has been deemed insufficiently “native.” As discussed below, the Park’s decision to amend the TRNP “purpose statement” to reflect this new attitude also represents a remarkable shift in Park policy, one which inexplicably prioritizes one Park value (native inhabitants) over another (the Park’s preservation of a historic landscape). Assuming this policy shift was not arbitrarily engineered to encapsulate just wild horses, it promises significant management changes for other Park wildlife, including the California bighorn sheep, which, the Park admits, is not native to the Badlands and has been bred for inclusion in the Park. See, e.g., NPS, General Management Plan at 41 (discussing the extinction of native “Audubon bighorn sheep” and their replacements, the “California bighorn sheep,” which were initially selectively bred in Park “enclosure[s]”). In addition, the Park’s radical reinterpretation of the Organic Act and its implementing regulations to characterize non-domesticated wildlife as “livestock” sets an ominous precedent that allows other National Park System units to eradicate wild horses or other wildlife that fall within this broad new definition of livestock.
There is a lot of confusion these days about a petition that was started asking for support for North Dakota Senate Concurrent Resolution 4014 and why we are not supportive.
First, I am not joking when I say please watch this short video: https://youtu.be/OgVKvqTItto?si=lcdCz2c3sY6ukj7Y. Saturday morning cartoons used to have a hint of education to them, and I cannot explain this process any clearer than School House Rock did.
When we as citizens want something to change, how do we do that?
We contact our elected officials! We all have elected officials on a state and a federal level.
Chasing Horses Wild Horse Advocates has been reaching out to our state and federal delegates since 2018 asking for help for the wild horses of Theodore Roosevelt National Park!
An important note: The North Dakota State Legislators are ONLYin session once every 2 years for 80 days. We were extremely grateful that they were in session this year when Theodore Roosevelt National Park announced their plans to eliminate the ENTIRE herd of wild horses in December of 2022.
When the Park made their announcement, we reached out to our state and federal delegates again.
We asked our state legislators – “WHAT CAN WE DO?”
Their response was that they could draft a resolution asking the Park to allow the wild horses to stay.
After weeks of talking to numerous state legislators, the birth of SCR 4014 started. Honestly, more like the labor pains! Lol
Chasing Horses Wild Horse Advocates FULLY AND COMPLETELY supported SCR 4014! We supported it so much that we helped draft the legislation and we worked hard to find ND state legislators to sponsor the resolution during the last ND state legislative session.
We were successful in finding 6 of our North Dakota state legislators to sponsor and co-sponsor this resolution.
CHWHA also testified at every committee hearing.
In April of 2023 SCR 4014 passed UNANIMOUSLY in both the ND House and the ND Senate.
The resolution was then sent to the ND Secretary of State to sign and send to the National Park Service and our North Dakota Federal Delegates.
This resolution DID NOT require the signature of Governor Doug Burgum because it was a resolution not a bill or law.
Governor Burgum, understanding how much these horses mean to not just the people of North Dakota, but people from other states and countries, decided to do a “ceremonial signing” of SCR 4014 to stress the importance of these horses by the state of North Dakota.
Governor Doug Burgum
Governor Doug Burgum
Governor Doug Burgum
We were there. He handed us the copy of the resolution he signed after the ceremony.
Bill Signing HCR 4014 with Governor Doug Burgum
Bill Signing HCR 4014 with Governor Doug Burgum
Bill Signing HCR 4014 with Governor Doug Burgum
Then, CHWHA took copies of that signed resolution to about 250 members of congress when we lobbied them in April of 2023. This was to help raise awareness about the current plight of the wild horses in TRNP, also to help educate members of congress and ask them to support any legislation that might help our horses. At that time, the ONLY legislation we knew that might help was the Interior Department Appropriations Bill. Senator John Hoeven added language to that bill asking the National Park Service to allow the horses to stay. That legislation has also passed.
I do not think that we could support this resolution any more than we already did.
I do not think that our North Dakota state legislators could support this any more than they did. 100% of them voted for this resolution. How do you support something more than 100%?
AND remember – THE NORTH DAKOTA STATE LEGISLATORS ARE NOT IN SESSION AGAIN UNTIL 2025!!
I do not think that Governor Doug Burgum, who is now running for President, could support SCR 4014 any more than he already did.
This petition is confusing because it is asking the petition signers to let people who already overwhelmingly supported this legislation that has already passed with flying colors that we support them signing the legislation.
Remember simple civics:
We want change
We contact our legislators
They decide on how they can help us get that change
They do the thing that gets the change
And then we move on.
It is time to move on from SCR 4014. Our ND State Legislators have. Governor Doug Burgum has.
For example: and this is in no way a debate on Roe v Wade – just an example:
The Supreme Court overturned Roe v Wade.
People who agree with their decision are no longer picketing or lobbying for Roe to be overturned – BECAUSE IT WAS!
Likewise, our legislation, SCR 4014, was also passed. There is NOTHING more to do and no more support that we can get for legislation that has already passed.
The worst part of this is when we say to people “Please make sure you take a moment to send a comment to the Park” and give them the link, people say, “I did, I signed the petition.”
We cannot stress this enough:
The #1 thing that you can do to help these horses RIGHT NOW is to send your own personal, educated, SUBSTANTIVE comment to the Park.
Or by sending it in by mail to: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645.
Comments on posts, emails to anyone, and signing petitions DOES NOT replace your comment.
We have 12 days left to get your comments in.
We also want to address two other things that have come up:
We do keep saying that you can comment more than once. We also have ALWAYS recommended that you open a new blank Word document and take time to craft your letter. We have let people know who have said, “Oh, I already sent my comment, I wish I added that.” That they CAN comment again.
Just under 20,000 people commented last time. This is NOT about getting some crazy number of comments.
This is about getting as many well-crafted, SUBSTANTIVE comments to the Park by November 24th so that they become part of the Public Record.
Second, please never be afraid to ask anyone you are making a donation to where your money is going. There are several other pages and organizations that are asking for donations to help the TRNP wild horses. The only one that is helping us in any way financially is American Wild Horse Campaign.
We just received a legal bill in the amount of $1100 for consultations about the Draft EA, for our lawyer being a part of the Horse Talk to answer your questions and for the beginning of their work on our comment letter before AWHC agreed to sign on and help with the cost.
We also have $975 that will be due at the end of this month for our billboard on I-94.
We have spent over $2,000 advertising on social media, and in print in The Dickinson Press and online at Forum Communications.
All of that is in addition to website fees, zoom subscriptions, printed materials, etc.
If you want to make sure you are helping us, please see our website for ways that you can donate to help us continue to Fight for the Spirit of the Badlands: https://chwha.org/support-chwha/
Thank you for your support. We hope this blog helped answer your questions. As always, feel free to email us at http://info@chwha or PM us on social media with any additional questions.
1.(of a person, policy, or action) creating or controlling a situation by causing something to happen rather than responding to it after it has happened: “be proactive in identifying and preventing potential problems.”
We have received a lot of questions about how we got to this situation with the wild horses in Theodore Roosevelt National Park. We have also been asked why there are so many different organizations that claim to be advocates for these horses. The biggest question is always, “Why can’t all of the organizations work together to help save this herd.” Today, we received numerous emails and private messages as a result of posts on other pages. We hope that this blog post will help answer those questions.
One of the things that Chasing Horses Wild Horse Advocates (CHWHA) has tried to do is to be PROACTIVE in our advocacy for the wild horses that call Theodore Roosevelt National Park home. Members of our board have been advocating for these horses long before CHWHA was officially formed in 2021.
Early on we knew that the continued round ups of ALL of the young horses aged 4 months old to 3 years old would leave only older horses. It doesn’t take rocket science to understand that continuing to support this practice would eventually mean that this herd would die off and cease to exist. This is something that if you read Dr. Castle McLaughin’s research paper on the history of these horses, you will see that Theodore Roosevelt National Park has been trying to get rid of the horses in the park from the moment they realized they fenced them in. (You can read her report in the library section of our website: https://chwha.org/library/)
In 2009, Colorado State University (CSU) started working with the Park experimenting on our horses with GonaCon.
No one spoke up for the horses. In fact, these other organizations that worked with the National Park Service (NPS) HELPED CSU AND throughout the experiment.
Dr. Dan Baker, head of the CSU experiment, said the following in a presentation at the Free-Roaming Horse and Burro Fertility Control Workshop in 2018: (You can view in the library section of our website): https://chwha.org/library/
“I’m concerned about one particular thing you know these horse advocates are very passionate about their horses and they care about what researchers do to them are you going to have our back if things go south and you know we cause more damage than then good.”
In 2015, the Park created partnership agreements with nonprofits solely for the purpose of getting their help to remove the horses. We received copies of those “partnership agreements” through a FOIA request (Freedom of Information Act). You can read those agreements in the library section of our website: https://chwha.org/library/.
Again, no one spoke up for the horses.
We questioned how any horses would ever be left if they kept taking all the babies and leaving only older horses.
The standard response from those nonprofits groups was always “The Park knows what they are doing. We don’t question the Park.”
In an effort to be PROACTIVE:
Members of our organization started contacting our North Dakota federal delegates in 2018 asking for their help to save this herd.
Members of our organization started numerous petitions and sent them to Senator Hoeven, Congressman Armstrong, and Senator Cramer’s offices as well as to Governor Burgum’s office.
Members of our organization asked our federal delegates to help us get federal protection for these horses as early as 2018.
Members of our organization reached out to congressman from other states asking for their help to protect our horses.
We have ALWAYS talked to the press, trying hard to raise awareness for these horses. CHWHA has NEVER said “We have no comment.” to the press when they called. Yes, other groups have.
Members of our organization contacted American Wild Horse Campaign and has been working with them since 2020 as we continue to fight to save this herd. We even invited the other organizations to work with us AND AWHC – that invitation was also declined.
Members of our board have been meeting with Theodore Roosevelt National Park to discuss concerns about the management of the wild horses since 2017. Those meetings with Blake McCann and Superintendent Wendy Ross included offering solutions to issues concerning the management of the horses. Those offers included anything that would help support the Park in their management of the horses including but not limited to helping to raise money for a proper management plan, to raising money and helping with responsible birth control for the horses.
When those personal meetings were not invoking change, in 2021, we hired the law firm, Eubanks and Associates. They thoroughly reviewed our claims, and this was from our initial correspondence with them in 2021:
“First, we recommend sending a letter to NPS demanding increased transparency in its management decisions, specifically calling on the agency to identify : (1) what formal decisions the agency has made regarding the management of wild horses, including how and why wild horses are classified as “livestock” under NPS regulations; (2) what level of NEPA review accompanies its gather decisions, including how its excess-horse determinations are made; and (3) how its decision to manage the herd at an arbitrary population level is consistent with its non-impairment mandate under the Organic Act. Our firm would be more than happy to assist Chasing Horses in the preparation of that letter, including sending it on our firm’s letterhead.
Second, because NPS’s lack of transparency has presented an obstacle to public understanding of its management of wild horses, and to our firm’s evaluation of potential legal solutions, we recommend filing a FOIA request to seek more information about the agency’s management regime. Our firm would be happy to help with this process as well.”
It is not out of the ordinary for advocates to ask for this information from federal agencies. The public has a right to seek answers from a federal agency that is funded by our tax dollars! CHWHA has refused to “step in line” with the Park like other nonprofit organizations have because what was being asked was working directly against the future health and sustainability of the wild horses that call Theodore Roosevelt National Park home.
In March of 2022, the Park FINALLY initiated a much-needed wild horse management plan.
Does the timeline compute? They were being asked uncomfortable questions for the first time in YEARS! The way to escape having to answer our lawyers or a judge in a lawsuit was to FINALLY DO THEIR JOBS and create a proper wild horse management plan.
We are now BEYOND petitions. They will not help. And who would you send them to? Governor Burgum? He already knows how many people want the horses to stay. Our North Dakota state legislators? They will NOT be in session again until 2025! PLUS they ALL know how much people support the horses staying in the Park. Our North Dakota federal delegates? Again, they are on our side!
Starting a petition now, in the midst of this public comment period, is ONLY creating confusion to people. They now think that signing onto this petition means that they DO NOT have to send a comment to the Park – yes, we received several messages on this now too. Again, the ONLY way that YOUR comment gets to the Park is through their website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035 and we need EVERYONE to comment!
IF contacting any of our legislators or starting a petition would help these horses, CHWHA would have made a “Call to Action” for that in a heartbeat.
There is simply no reason to bombard people who are already on our side.
The Park is engaged in a NEPA process, and that process has to play out.
Contacting your own personal federal delegates will not help because there is NO legislation for them to talk about. There is NOT even any legislation being drafted! Federal legislation takes YEARS to get passed, which is why we started asking for it in 2018! Go back to your Saturday morning civic lesson: https://youtu.be/OgVKvqTItto?si=UGJ2MvTgaWl3SrI9
Since these horses are NOT protected under the Wild Horse & Burro Act, Federal legislation is the ONLY thing that will protect the future of this herd and stop any further removal actions from the Park.
Contacting the ND legislators, who ALL support the horses, will not help because they CANNOT do anything until 2025!!
STILL….
CHWHA TRIED!! Our ND legislators got called back for a special session last month. While our proposed legislation was one of the items introduced to the committee, our legislators decided to only work on the legislation they were called back to rework.
Meanwhile….
The other organizations stayed silent.
I also want to note that we have REPEATEDLY asked these organizations to work with us to help save these horses. They have CONTIUALLY SAID NO!
We even asked that if they refuse to work WITH us, please stop working against us!
Even that answer is a no, as you can see by the recent posts on their pages.
So now, after refusing to help us get state or federal protection for these horses in the past, and refusing to share any of our efforts to do that, they are all now throwing around our words like it was some NEW epiphany they just had.
Meanwhile….
MEMBERS OF OUR ORGANIZATION HAVE BEEN DOING ALL OF THESE THINGS SINCE 2017!!!!
The ONLY way you can help the horses now, is to make sure you send an educated, well crafted, SUBSTANTIVE comment to the Park by November 24, 2023 through their website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035 or by mailing it directly to the Park: Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645..
It is A LOT easier than it sounds and CHWHA is helping you do that through our blog posts. There is also a wealth of information, including supporting documentation for you to use all in one place on our website: https://chwha.org/save-the-trnp-wild-horses/
Your substantive comment IS important because it becomes part of the public record, and that public record will be critical as we continue to explore our legal avenues.
We are in the beginning of a VERY LONG process. The fate of these horses will NOT be decided on November 24th. The Park will be back, probably next spring, with either their final decision in this matter OR they will state that they have to perform an Environmental Impact Statement (EIS). Once we know their decision, our legal team will advise us on what they suggest our next steps should be.
And yes, we have asked the other groups to be a part of our legal fight.
How is your comment letter to Theodore Roosevelt National Park coming along?We have 2 WEEKS from TODAY to get these letters completed and sent off to the Park.Remember – just under 200 wild horses are counting on you!
We cannot tell you what to comment, but we are making some suggestions based on emails, comments and messages we have received.
We have talked about this before:
” 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).
Today, let’s talk about how comment about the Purpose & Need statement.
The Park’s Purpose and Need statement reads:
PURPOSE AND NEED
The purpose of the proposed action is to address livestock—horse and cattle herds—within the Park, under relevant laws, regulations, policies, and management priorities, including the conservation of native species and natural prairie ecosystem functions.
The proposed action is needed to:
• Address operational commitments to livestock management • Address potential impacts of livestock on the landscape and natural resources, including native wildlife, native vegetation, and water resources • Address potential impacts of livestock on cultural resources, including archeological sites and cultural landscapes • Provide resiliency for native ecosystems and species in the face of a changing climate • Align livestock management with relevant laws, regulations, and policies • Emphasize bison management in alignment with Secretarial Order 3410
This is an important part of your comment letter because THIS is what every comment goes back to.Does what you are stating in your comment support the Purpose & Need statement of the Draft Environmental Assessment (EA)?
Throughout the Draft EA, especially the last 2 pages. we see continual reference to this:
“This alternative also would not meet the project’s purpose and need..”
So, the first thing everyone should say about the Park’s Purpose & Need statement is that it is too narrowly focused.
Here is part of our January comment letter about the Purpose and Need statement:
NEPA imposes on the Park a duty “study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources.” 42 U.S.C. § 4332(2)(E). The duty applies regardless of whether the “agency is preparing an [EIS] or an [EA], and requires the agency to give full and meaningful consideration to all reasonable alternatives.” N. Idaho Cmty. Action Network v. U.S. Dep’t of Transp., 545 F.3d 1147, 1153 (9th Cir. 2008) (quoting Native Ecosystems Council v. U.S. Forest Serv., 428 F.3d 1233, 1245 (9th Cir. 2005) (emphasis added)); see also W. Watersheds Project v. Abbey, 719 F.3d 1035, 1050 (9th Cir. 2013) (same).
“The scope of an alternatives analysis,” i.e., whether a given alternative is “reasonable,” “depends on the underlying ‘purpose and need’ specified by the agency for the proposed action.” League of Wilderness Defenders-Blue Mtns. Biodiversity Project v. U.S. Forest Serv., 689 F.3d 1060, 1069 (9th Cir. 2012) (citing 40 C.F.R. § 1502.13; City of Carmel-By-The-Sea v. U.S. Dep’t of Transp., 123 F.3d 1142, 1155 (9th Cir. 1997)). Although the Park enjoys discretion in framing its purpose and need, it “may not define the objectives of its action in terms so unreasonably narrow that only one alternative from among the environmentally benign ones in the agency’s power would accomplish the goals of the agency’s action,” thereby rendering the NEPA process a “foreordained formality.” Id. (quoting Friends of Southeast’s Future v. Morrison, 153 F.3d 1059, 1066 (9th Cir. 1998); see also Union Neighbors United, Inc. v. Jewell, 831 F.3d 564, 575 (D.C. Cir. 2016).
Again, if you are not a lawyer, don’t try to be one now! lol
However, can you take those paragraphs and make them your own?
Here are some points to personalize into your own comment letter about the purpose and need statement:
·The Park’s Purpose and Need statement is too narrowly focused.
·The Park should consider an alternative that allows for a genetically viable herd of wild horses to remain within the Park.
·The Park should amend its Purpose & Need statement to include the historical and cultural significance of the wild horses.
·There have been several court cases challenging narrowly focused Purpose & Need statements that have been won in the past.
Now take those comments and make them your own.Again, PLEASE DO NOT copy and paste them into a letter.And remember, we are trying to build a consensus.The Purpose and Need statement is a big one!
Even though the Park has answered the statements above in their Draft EA (i.e. stating why they will not consider an alternative that allows for a genetically viable herd of horses to remain in the Park) you STILL need to make that part of your comment letter.
Remember:
·You CAN comment more than once.
·Your letter can be as short or as long as you want it to be.
·Your comment to the Park becomes part of the public record!
·Just under 200 wild horses are counting on YOU to be their voice!
We will only have a few more blog posts and you will be ready to send your letter!For today, work on making this part personal to your thoughts and feelings.
Please continue to send us your questions.We will continue to work to incorporate them into our blogs.
Thank you for your support and have a GREAT weekend!
As we continue on the actual writing of your comment letter, please remember NOT to copy and paste the information we share here and send it into the Park. IF you do, the Park will end up counting all of those comments as ONE comment. We are asking that you take a moment to customize the information we are giving you and make it your own original comment.
We asked that you write your heart out to the Park and let them know you feel about their proposed action, to eliminate all of the wild horses from the Park.
If you did, please set that aside for now. We hope that helped you get all of the emotions and feelings out of the way so that we can now work on your SUBSTANTIVE comment letter. We are not saying there is no place for yesterday’s homework, – we do think there will be an opportunity to pepper that in once we finish this letter.
Comment letters are being sent to Superintendent Richman so your letter should be addressed to her. Remember, be respectful.
Next, you should let her know why you are writing to her:
Dear Superintendent Richman:
Thank you for the opportunity to comment on the proposed Livestock Plan currently being reviewed that includes the wild horses of Theodore Roosevelt National Park.
Here is where you can pepper in some of yesterday’s homework:
My family has been coming to Theodore Roosevelt National Park for generations.
Or
I make a trip to Theodore Roosevelt National Park at least three times a year. I have been doing that for xx years.
Or
My grandmother brought me to Theodore Roosevelt National Park when I was 6 years old. I have visited the Park every year since for the last 55 years.
Add in that seeing the horses is always the highlight of your trip.
You get the idea…
And then add in everyone’s favorite line…
If the horses are removed from the Park, I will not be back.
Feel free to elaborate if you choose.
Then give some FACTS:
I know that as one person that may not matter, but according to the results of the Brownlee study, 89% of Park visitors feel the same way that I do. They stated that they want to continue to see horses in the Park.
Feel free to elaborate as you choose. Talk about tourism – how the loss of those 89% of people impact not only attendance for the park, but it will also negatively impact small businesses in the town of Medora and the surrounding communities as well as the entire state of North Dakota.
Does that make sense?
Do you see how adding facts to your own personal statement about not returning to the Park strengthens your letter?
I want to take this slow and give you time to work on your letter as we continue. We have 16 days left to finish this letter and it won’t even take us half of that time 😊
Remember:
You CAN comment more than once.
Your letter can be as short or as long as you want it to be.
Your comment to the Park becomes part of the public record!
Did you know that I was a Girl Scout Leader – yikes – some 30+ years ago?!
I am so happy that social media allows me to keep in touch with many of those girls who have now turned into amazing young women.
Last week I made a comment on one of their posts letting them know how proud I was of her.
She replied:
“A lot of the reasons I’m outspoken and speak up is because you taught us not to take any shit when we were younger. The Girl Scout cookie strike stays with me, and I tell people that story often. We were refusing to sell cookies unless we got more money per box, and we were going to switch to girl guides. We were in the paper you made us work and get those awards and those were the first times I felt accomplished, and I liked it.”
I guess old habits don’t change for me!
I received an email the other day from one of our followers:
“I commented last week after receiving your email urging me to do so. However, that message had NO link for any info to base my comments on, so I did my best using what was in that message & the links it led to. If I recall correctly, I did go to your website, again, no points to use in my comment, so I did my best.
If you’re asking people for donations, you need to prove you use those funds effectively. Asking people to comment on a message that gives no points or info to use in doing so wasn’t the most effective way you could’ve put those requests out.”
I took a deep breath and thought ok, maybe in my busyness I have not been clear. Maybe this person is new to our page and unaware of everything on our website.
I kept my response simple:
Hello and thank you for contacting us! We are very transparent with where donations are going including to help pay for a billboard on I-94, brochures and flyers to help raise awareness, legal fees and general office/website fees. We have spent over $2,000 advertising over the last few weeks and hope to be able to continue advertising through 11/24 when this comment period ends.
There is a wealth of information on our website, including almost daily blogs, that will help with your comment letter. We even pulled resources and talking points into one section of our website: https://chwha.org/save-the-trnp-wild-horses/
Thank you for reaching out and please let us know if you have additional questions.
I share these two stories with you because we have spent A LOT of time writing blogs over the last 43 or so days.
WHY?
Just like with my Girl Scouts, I am not here to TELL you what to do. CHWHA is here to help educate you about the current situation the wild horses of Theodore Roosevelt National Park are facing. We are here to help you navigate through this NEPA process and do our best to make sure you fully understand the best ways that you can help these horses right now.
KNOWLEDGE IS POWER!
Educated advocates make educated comments.
CHWHA is NOT out to meet a comment goal.
We are here to empower you to take a stand and use YOUR voice to speak up for these amazing wild horses.
YOUR voice + HER voice + HIS voice + MY voice = ONE LOUD voice that cannot be silenced.
We have 17 days left to make our comments. We have never asked you “Have you made your comment yet?” We have actually encouraged you to wait to make your comments so that we can share information with you on how to make a SUBSTANTIVE comment for yourself.
We have shared A LOT of information. We have explained A LOT of things. We have (hopefully) shown you reasons to have some hope.
We hope that we have helped you feel “accomplished”.
NOW
We hope that you will take ALL of that and put it into a well-crafted comment letter.
We are still here with you!
We will help you write your letter. It is going to be a lot easier now that you understand the language and process we are all embarked upon.
We have supporting documentation and helpful blog links for you to use to write your comment letter all in one place on our website: https://chwha.org/save-the-trnp-wild-horses/
One thing I will NOT do: is write your comment letter for you.
THAT you have to do for yourself.
These wild horses that call Theodore Roosevelt National Park home have to mean THAT MUCH to you that you can take the time you need to be their voice and speak up for them during this critical time.
We are still here. We are STILL helping.
NOW it is time for YOU to do the work.
As for that cookie strike…
Years have buried that memory deep for me but I smiled as I read her message and remembered. While ALL of the details escape me, I CAN tell you that we had a very large and very popular group of Girl Scout troops. We were rightfully upset that the price of Girl Scout cookies increased WITHOUT giving more money to the young girls doing all the work to sell them.
Again, the details escape me, but I can tell you that we DID NOT leave Girl Scouts.
I can also tell you that we DID NOT compromise.
I can also tell you that the choice was ALWAYS up to the girls. I agreed to stand by them no matter what that choice was and help them make their voices heard.
We plan on fighting just as hard for a genetically viable herd of wild horses to stay IN Theodore Roosevelt National Park!
We WILL NOT compromise on that.
We hope you will continue to fight with us!
As always, that choice is yours.
Thank you for your support and for allowing me to share a small personal piece of me with all of you.
We are going to start pulling all of the information that we have shared together so that you can see how easy it is to write a SUBSTANTIVE comment to Theodore Roosevelt National Park.
Remember: If you are NOT a scientist, a historian, a lawyer, etc., now is NOT the time to try to sound like one. Those people are writing their comment letters in great detail.
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).
What is the “consensus” we are trying to build?
We think everyone will agree with the following points:
The wild horses in Theodore Roosevelt National Park should NOT be considered livestock
The Purpose & Need statement is too narrowly focused
The Park needs to take a “HARD LOOK” at the economic impact of their decision
The Park needs to take a “HARD LOOK” at the historical and cultural significance of this herd
The Park needs to consider an alternative that allows for a genetically viable herd of horses to remain in the park
The Park needs to perform an Environmental Impact Statement (EIS)
I have been asked several times to make the talking points we have on our website into a document that people can copy and paste into the online comment form. I will not do that.
While I understand that people are busy and having a form that can be easily copied and pasted into the website would be a way to generate more comments, consider this:
If we create a form letter for you to send in and 1000 people send in that same letter – IT ONLY COUNTS AS ONE COMMENT!
If you have fallen in love with these horses, either because you have witnessed their amazing beauty in person or through any of the social media outlets that share their photos, it is time to give back to what they have given to all of us! Can you spare maybe 10-30 minutes to be the voice for these 200 wild horses?
As we now begin sharing samples of ways to write an impactful comment letter, I am going to ask that you PLEASE refrain from simply copying and pasting what we share here. If you copy and paste into your own word document, use the thesaurus or synonym feature in Word. Rearrange the sentences into your own voice. BE ORIGINAL. It really is not that hard to do! Remember: BE RESPECTFUL.
The very first thing I want everyone to do is write a letter to the Park letting them know exactly how you feel about their plans to eliminate the entire herd of horses from the boundaries of the park. Give it to them! Let them know how angry they have made you. Don’t forget some comments we have heard from all of you:
I will never come back to the park if the horses are removed!
I hope that when this is all over that you guys lose your jobs and people who actually care about these horses replace you!
Our tax dollars pay for this park and we should have a say in what happens in our national park!
This is government bureaucracy at its finest!
These horses are part of our nation’s history!
Stop trying to erase history!
Future generations deserve to see these amazing wild horses!
STOP destroying EVERYTHING!
These horses are a tourist attraction for the state!
LEAVE THEM ALONE!
STOP THE MADNESS!!
What a criminal act!
THE HORSES WERE HERE FIRST!!
THIS IS BULLSHIT! (and whatever other swear words you want to insert)
You get the idea.
Write from your heart.
Write from your anger.
Write from that place that feels so much disappointment in the Park’s decision.
That is your “homework” for today. Write your letter, from your heart, with all the feelings attached. Without science. Without historical facts. Put pen to paper (or fingers to keyboard) and let your heart and even your anger fill the page.
DO NOT send this into the Park – yet! We have some more work to do on your personal comment letter. We STILL have 17 days left to perfect your letter! If you feel a need to share your letter somewhere right now, feel free to email it to us at info@chwha.org.
Bring that letter back here tomorrow. Just like your comment letter to the Park, you might come back with just one line written on your paper. You might have a paragraph, a page or maybe even 10 pages! Let whatever comes out come out! There is no “right” or “wrong” way to do this.
We will see you back here tomorrow!
On another note…
Our advertising is working! We are now engaging over 250,000 people (that is an increase of over 146%!!) per week on our social media pages and our website traffic is up 115%!!!
Can you help us keep these ads running? Any donation helps! There are several ways you can donate listed on our website: https://chwha.org/support-chwha/
Second, we have several 1 page FACT sheets that we have been passing out to local businesses and posting around Medora & Dickinson to help raise awareness about this comment period. Can you help us spread the word? Simply send us an email and let us know how many of each you would like and we will get them off in the mail to you! You can view our print materials here: https://chwha.org/join-the-fight/
Third – don’t forget we are holding another silent auction on November 24th! Do you have some items you can donate to help our silent auction be a success? You can upload your items on our website: https://chwha.betterworld.org/donate-an-item or send us an email at info@chwha.org and let us know what you can donate.
Remember: any donations you make to Chasing Horses Wild Horse Advocates is 100% tax deductible!
Our friend Jen Britton will be joining us on November 18th at 4 pm MST for a NEW Horse Talk!
Jen’s topic will be:
Making the Case for Protecting Wild Horses: A Social Sciences Perspective
From Jen:
Emerging research in paleontology has been helping wild horse advocates better understand the evolutionary history of horses in North America—this science has been a critical resource in our advocacy toolkit. Although the social science and humanities research defending the presence of wild horses in US public lands is thinner, it also offers powerful ways to advance wild horse advocacy. Along with my husband, Christian Hunold, who is an environmental political theorist, I have been working on building the scholarly foundations of wild horse social science. I will share some of the knowledge we have established in our research, as well as some of the arguments for protecting wild horses from fields like human-animal studies, compassionate conservation, and feminist science studies. I will also offer a comparison of how wild horses are managed in different national park properties like Assateague Island National Seashore and the Ozark National Scenic Riverways.
A little about Jen:
Jen Britton lives in Philadelphia, Pennsylvania, and is a nature, wildlife, and wild horse photographer who visits and documents wild and free-roaming horses and burros around the US. She has an MS in Science, Technology & Society (STS) and is Drexel University’s Executive Director for Sustainable Development Strategy, a role in which she leads Drexel’s institutional climate action planning and sustainability initiatives and strategies. As part of a research team with Christian Hunold, Professor of Politics at Drexel, she has published research about wild horses in the journals Humanimalia, Animal Studies Journal, Borderlands, and Society and Animals. As a volunteer for Assateague Island Alliance, she created the first educational field guide for park visitors about the island’s wild ponies. Jen also works on research and analysis in the higher education community engagement and anchor mission spaces, publishing on institutional strategies and practices in Metropolitan Universities journal.
We have just 18 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.
First, unlike any other national park, Theodore Roosevelt National Park was named for President Theodore Roosevelt. More than that, this park exists to honor Theodore Roosevelt’s legacy.
For starters, the Park wants to tell us that legacy is now ONLY Theodore Roosevelt’s CONSERVATION legacy NOT his ranching legacy. Even though it seems obvious, it is worth noting in your comment letter that it is well known that Theodore Roosevelt would NOT have had a conservation legacy without his ranching experiences in the Badlands of North Dakota.
We know without a doubt that Theodore Roosevelt’s time in North Dakota included wild horses.
Dr. Castle McLaughlin’s report (which you can download to read on our website) is filled with valuable information showing the historical and cultural significance of wild horses in Southwestern North Dakota. Instead of quoting her here, we are working on setting up a NEW Horse Talk with her so she can share her insights and answer your questions. You can also watch our last Horse Talk that we had with Dr. McLaughlin. The video can be watched on our YouTube channel here: https://youtu.be/0RA8SlJ3oro
We know that the horses also have cultural significance. Earlier this year, The MHA Nation unanimously passed their own resolution that was sent to Theodore Roosevelt National Park. In that resolution, they stated:
“The MHA Nation is held holds horses in high esteem as horses are significant to the MHA people and have played a major role in MHA history, tradition and culture.”
We also know that for as much as the Park is telling us that the horses will first be offered to local Native American Tribes and that they are consulting with the Tribes, in January of this year the United Tribes of North Dakota sent a letter to Superintendent Richman letting her know that they stood with Governor Burgum and the State of North Dakota and asked that they allow the wild horses to remain IN Theodore Roosevelt National Park. Their letter stated:
“United Tribes has reviewed the letter to you from Governor Doug Burgum dates January 30, 2023, and now hereby submits this letter to provide their general support for the continued preservation of wild horses and longhorns in TRNP as proposed by the Governor.”
Most importantly, Theodore Roosevelt National Park ALSO knows that these horses have historical significance. They have always referred to these horses as a historical demonstration herd and their 1984 Natural Resources Management Plan and Environmental Assessment, stated that the TRNP herd was a
“historical demonstration” herd requiring “management as a natural resource, to control population size and to protect the grassland resource.”
More recently, Melissa Thompson completed her graduate paper, Genetic Breed Association And Contraceptive Response GWAS Of The Feral Horses (Equus Caballus) Of Theodore Roosevelt National Park. As a graduate student at the University of North Dakota, it is worth noting that Blake McCann, currently Director, Resource Management and Science at Theodore Roosevelt National Park, was part of the “Faculty Advisory Committee under whom the work has been done and is hereby approved.”
In her report Thompson states:
“The feral horses are maintained as a “living history demonstration”, representing the free-roaming livestock that Theodore Roosevelt documented during his residency (Harmon, 1986).”
Our next series of blog posts will take away some of the anxiety over making a SUBSTANTIVE comment and give you some ideas on how to write your own impactful comment to the Park. It’s easier than you think!
Please note: The link above is the ONLY way that your voice counts in this current comment period. Comment letters must be sent to through the link above or by mailing it to the Park. Comments on our posts, blogs or other social media posts, including the Park’s Facebook page DO NOT get counted into the administrative record.
We have several tips and documentation for you on our website to help you make a SUBSTANTIVE comment.
We will also be sharing more tips this week.
We need your help to spread the word and get as many people as possible to comment!
A few easy ways you can help:
Share our social media posts! We have also created several graphics that are available on our Facebook page that can be easily shared to help raise awareness for this public comment period. We have also added some of them to our website for you to download and use: https://chwha.org/join-the-fight/
Help us pass out our FACT sheets! These can be put out ANYWHERE – it doesn’t have to be in North Dakoka! If you would like some of our handouts, please email us at info@chwha.org
Please help us with our advertising expenses! We have spent over $2,000 advertising on social media, our local newspaper and online ads over the last couple of weeks! We have 19 days left and need your help to continue this push! Our website traffic is up 90% over the last 7 days and most of that is due to our advertising! We are also engaging just under 200,000 people on social media!!! Please help us keep this momentum going! Any amount will help! There are several ways you can donate: https://chwha.org/support-chwha/
This week is getting busier every day! We will be speaking at a local Kiwanis meeting and also have a Giving Hearts Day meeting! We are working on some NEW Horse Talks and will have details soon! We also did a wonderful podcast last week and should have that link for you soon too!
If you missed our Horse Talk yesterday with wildlife ecologist Craig Downer, the technology gods were good to us this time! We just uploaded the video to our YouTube channel. You can view our talk with Craig here: https://youtu.be/43_EXeJ2pV8
A little about Craig Downer:
Craig has defended wild horses/burros against attacks for over 40 years and observed many of the West’s colorful herds. He has studied the endangered mountain tapir and is president of the Andean Tapir Fund, also dedicated to saving wild horses/burros (www.andeantapirfund.com). A member of the IUCN Species Survival Commission and board member of The Cloud Foundation, he enjoys nature photography and musical composition, lives in Nevada, and is proud companion of mustangs Lightning, a palomino stallion, and Princess Diane, his curly mare, both of whom he knew in the wilds of NW Nevada before they were captured by BLM in 2010. He is a professional wildlife ecologist and has authored scientific and popular articles and books.
Many of you have asked about Craigs books and published papers. We will include them at the end of this blog.
Thank you for joining us again, Craig! We appreciate your support in our fight for the wild horses of Theodore Roosevelt National Park and for your lifelong advocacy for wild horses everywhere.
The book can also be ordered directly from Craig for a personalized copy and he also includes other material and also offers his musical piano CD, 45 minutes, w/ 13 medleys entitled Wild Horse Rhapsody. You can email Craig at ccdowner@aol.com for info on how to get your personalized copy of his book.
Here are some of the major articles and publications that will help everyone understand in greater depth and be more effective in this very important cause to restore the naturally living horses and burros and their habitats at long-term-viable levels:
“Everyone shows up in different ways of course, but this is no time to be complacent or hopeless.” ~ Dosse Via
That quote came across my path yesterday and it seemed quite fitting.
It is a frustrating time for wild horse advocates. The BLM is notorious for their plans to eradicate wild horses on the western landscape. Bait & Trap will begin soon for the McCullough Peaks wild horses, despite overwhelming public outcry. The Forest Service has shown that they are no better, last month over 200 wild horses were rounded up in the Devil’s Garden herd. And, in our own battle, we have the “stewards of the land” at the National Park Service (NPS), specifically, Theodore Roosevelt National Park, planning to erase just under 200 wild horses from the landscape.
It is no secret that the Department of the Interior, who oversees the BLM & NPS, strategically plan the release of their environmental assessments as well as their roundups. While we are all busy fighting our own individual battles, we don’t get to pay as much attention as we would like to all of the wild horse herds out there that are constantly under attack.
It would be easy to just throw our arms up in the air and say, “The heck with it all!”
THAT is exactly what government bureaucracy aims at doing. Wearing us down, making us tired, making us feel hopeless – until we finally give up.
Giving up is not an option. The lives and living history of wild horses everywhere is at stake. We need to preserve these majestic beings who were so crucial to shaping America. They deserve so much better than what they have been given.
How do we change things?
Persistence. We don’t give up and we don’t give in. We don’t compromise at the expense of the well-being of these horses.
Just under 20,000 people commented in the last public comment period for the TRNP wild horses. We know from the Park’s report that ONLY 45 of those 20,000 supported the Park’s plans to eliminate every last one of the horses within the boundaries of the park.
As a branch of the federal government, that operates with our tax dollars, in the USA where we have a government OF the People, BY the people and FOR the people, – how can Theodore Roosevelt National Park honestly come back with the Draft Environmental Assessment that they gave us on September 25, 2023??
They are counting on all of us to read it and throw our hands in the air and say “Well, they proved why they HAVE to get rid of the horses.” They counted on their ability to “connect the dots” for us.
I believe we are smarter than Theodore Roosevelt National Park gave us credit for! We have disproved much of their Draft EA and poked holes in their “facts”.
This weekend, we will finish up our historical & cultural blogs and then we will start giving you examples of ways that you can make an impactful comment to the Park.
In the meantime – what are you doing to help save this herd?
Please, talk about these horses to everyone you know and encourage them to comment!
Share our YouTube videos! Our friends at National Geographic just sent us a new one. It is available in wide-screen and mobile version. These have proven to be impactful in getting the public’s attention! It’s as easy as a simple share!
Sign our petition for the State Historic Preservation Office! We have just over 3,000 signatures! Thank you! We are getting our info together to mail to them with all of your names – make sure you we have yours! We will keep the petition open through Sunday (11/5/2023) and mail it off Monday morning!
Share our graphics! We have several on our Facebook page that give a clear and simple message asking people to comment to Theodore Roosevelt National Park to help save these horses!
Last week we shared ways that Chasing Horses Wild Horse Advocates is working to save these horses. Please read that blog post and continue to give us your suggestions on what we can do to help raise awareness.
Chasing Horses Wild Horse Advocates is working hard to save these horses. We are advertising on social media and in our local newspapers. We also have a TON of materials that we are passing out and posting in the local community to help raise awareness! Please consider making a donation to help us cover these costs!
No matter what it is you are doing – with what you have, from where you are, PLEASE don’t stop now! We have until November 24, 2023, to get as many SUBSTANTIVE comments into the Park as possible! There are STILL a lot of people who do not know that the freedom of these horses is being threatened!
PLEASE REMEMBER: Your comments ONLY count when you go to the Park’s planning website to make the comment! Comments made on social media posts, even the ones for Theodore Roosevelt National Park DO NOT go into the administrative record! Make sure you speak up for these horses! Here is the link to submit your comments: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035
You CAN comment more than once!
Thank you for your support and have a GREAT weekend!
P.S. – Don’t forget to join us tonight as we host a NEW Horse Talk with wildlife ecologist Craig Downer! This event is FREE, but we do ask that you register in advance! https://secure.everyaction.com/9BWTjmZjN0ech4amUJ6I3A2
We are getting a lot of positive feedback from yesterday’s blog. We are glad it helped! We have more to say on the historical/cultural aspects so please check back! We will also be giving some samples of ways you can easily incorporate the information we are sharing into your own letter.
We have also been asking that the public send “letters to the editor” to their local newspaper. Understand, this is a NATIONAL PARK, so don’t feel like you HAVE to live in North Dakota to send one. You can send one to your own local newspaper and/or to the newspapers in North Dakota.
Letters to the editor are a way to get your message to the public. If enough letters to the editor are published, it DOES get the attention of our state and federal lawmakers. THAT is part of how we got the State of North Dakota to draft and pass Senate Concurrent Resolution SCR 4014 earlier this year. Our ND legislators told us that when they continued to see letters to the editor daily about the TRNP horses, they knew they had to do something.
Can you imagine what would happen if enough newspapers in other states started publishing letters to the editor about our TRNP wild horses? It could possibly help get the attention of other members of congress!
No matter what – it doesn’t hurt and really takes just a few minutes to do!
What should you write? I am including a few letters to the editor that have recently been published in our North Dakota newspapers.
Before I share a few, I want to address a topic that comes up a lot. Paywalls. The Fargo Forum does an amazing job at covering the plight of the wild horses in Theodore Roosevelt National Park. Patrick Springer at the Forum especially does an incredible job. His articles are usually behind a paywall. I believe the cost is 99 cents for 3 months. Yes, it is a pain, and we understand if you are on a fixed budget and cannot afford that. But if you can, subscribing to read the articles in any newspaper – and sharing those articles so hopefully more people read them – is a GREAT way to let the newspaper know that wild horse stories matter to the public.
Here is my letter to the editor that was printed recently in the Fargo Forum:
Letter: What will the National Park Service’s actions cost us?
Christine Kman, founder of Chasing Horses Wild Horse Advocates, urges readers to express their support for keeping wild horses at the Theodore Roosevelt National Park.
Opinion by Christine Kman
October 29, 2023 at 2:39 PM
Theodore Roosevelt National Park held their “virtual” civic engagement meeting Jan. 12, 2023. The park selected questions to answer, as they consciously grazed over questions that they did not want to answer, as they spoke out of the other side of their mouths about their commitment to remain “transparent” with the public.
Not only is the park currently on course to remove all of the wild horses from the boundaries of the park, the weeklong helicopter roundups along with the euthaization of horses that do not sell will come at the expense of the taxpayers.
We asked Supt. Richman the following questions that were blatantly ignored by the park during the civic engagement meeting:
When the park plans to eliminate 150-200 horses during week long helicopter round-ups, what is that cost and where will that money come from? Is this something that will come out of the budget of the National Park Service or will the Bureau of Land Management be footing that bill like they did with the GonaCon experiment? What is the proposed budget for the removal of the horses? We are sure you have prepared a budget that was proposed to cover things like the cost of week-long helicopter roundups, veterinarian bills, and all of the aftercare associated with rounding up the horses. While you are asking the public to weigh in on the alternatives you have presented, it would seem that knowing what that budget is, that will obviously be paid for with our tax dollars, would be important to making an educated comment on the Draft EA.
If, in fact, you will say that there is no proposed budget, aside from the obvious comment that there needs to be a determination before any such actions take place, can you tell us what the cost was to round up the 400 bison recently? Maybe that will help us get an idea of the overall cost.
Also, I noticed on the BLM sites for comments, there is a way for the public to see how many comments have been submitted. Is there a way for the park’s planning site to give the public updated information on the number of comments that have been submitted for the TRNP Livestock Plan?
Lastly, the Draft EA states that if after “several” attempts to sell the horses on GSA Auctions that the horses would be euthanized. Can you define “several” and that timeline for selling the horses, please? For example, will the horses be listed for a day, a week a month, etc. before they are relisted and/or euthanized? Also, what agency will be responsible for the actual euthanization of the horses and the costs associated with that? The NPS, BLM or is this new and alarming direction coming from the Department of Interior directly?
It would seem like all of this should have been discussed in the Draft EA.
Thank you for your consideration. I appreciate your commitment to being transparent with the public.
As you have probably assumed, in their standard “transparent” fashion, Superintendent Richman refuses to answer these questions. Instead, I was directed to make them part of my comment letter. To be clear, this is our last public comment period during this process, so when will these questions be answered for the public to comment on before the proposed action they want to take is initiated?
The answer: It won’t. None of our valid questions will be answered because the park has shown us time and time again that it is above having to answer to anyone, let alone the taxpaying public.
Aside from the public losing part of our culture and history that just under 20,000 people spoke up against during the last public comment period, isn’t it nice to know that our tax dollars will pay for the very action we all oppose?
Christine Kman is founder of Chasing Horses Wild Horse Advocates.
I will admit, that was a longer letter than some letters to the editor will allow. I sent the same letter to the Bismarck Tribune and had to cut 400 words!
Here are a couple other letters to the editor some of our followers shared. If you have a letter to the editor that gets printed, please share the link with us!
Letter: The wild horses draw visitors to our state
“Almost 90% of visitors rate the quality of their visit based on wildlife viewing, including wild horses. I am one of those people. My visit quality is always based on seeing wild horses. Period,” writes Michelle Jennison of Fargo.
I urge the National Park Service to stop trying to remove the only herd of wild horses in North Dakota from Theodore Roosevelt National Park (TRNP).
The recently published Livestock Plan Environmental Assessment (EA) manipulated statistics to support the NPS removal of the wild horses. If the NPS is willing to publicly falsify documentation about the Brownlee et al. (2020) study, it makes me question how much of the rest of the EA is accurate.
The EA states, “While no comprehensive visitor use survey has been conducted specific to horses in the Park, 49 percent of visitors interviewed for the Brownlee et al. (2020) study supported maintaining horse herds in the South Unit.” This is simply not true. The Brownlee et al. (2020) reports 89.13% of visitors interviewed want the horses to remain in the park and only 4.38% of park visitors want the horses removed.
From the NPS Reference Documents, please see: “Brownlee et al 2020.pdf” which shows 49.16% strongly support, 33.92% support, and 6.05% somewhat support “Maintain the herd of horses in the S. Unit of park.”
The Brownlee report also states, “Because almost 90% of visitors reported participating in wildlife viewing and indicate that this experience was important to the quality of their visit, continue direct and indirect management of park wildlife and associated habitats.” It also states, “The National Park Service’s (NPS) enabling legislation (the Organic Act of 1916) mandates park managers protect and maintain the natural and scientific values of the park and to provide for public enjoyment, education, and inspiration (NPS, 2016). This protection-visitor use dual mandate is applicable to all NPS units, including Theodore Roosevelt National Park. Theodore Roosevelt National Park (THRO) features natural, cultural, and recreational resources that invite a diverse population of visitors.” The horses are a cultural resource and should stay in the park.
With the above information, I cannot understand why the NPS would want to remove the wild horse herd from the NPS. Almost 90% of visitors rate the quality of their visit based on wildlife viewing, including wild horses. I am one of those people. My visit quality is always based on seeing wild horses. Period. The elk and deer are great to see when they make a rare appearance. The prairie dogs annoy me. The buffalo are nice to see, but my sole reason to visit the park is see how many wild horses I can find.
The TRNP wild horses have lived their entire lives wild and free in the park since the park boundary fence was put up in the early 1950s. They are not livestock. Livestock, by definition, are any population of animals kept by humans for a useful commercial purpose. That does not describe the wild horses in the South Unit at all. Humans do not “keep” these horses as they thrive without intervention, including during harsh North Dakota winters. No one feeds them. No one waters them. No one gives them shelter. Please stop calling them livestock. They are wild horses or feral horses. The park gift shop even sells a postcard with a photo of wild horses and calls them feral horses on the back of it.
The wild horse herd in TRNP is an important historical resource to the state, with reference to rancher and park namesake President Theodore Roosevelt. The wild horse herd is a tourism draw. Many people, including myself, travel to TRNP several times a year just to see the wild horse herd. The horses have an economic impact to the local economy as they draw visitors. I personally visit and spend my vacation money locally in the saltwater taffy shop and Boots every time I visit, at least twice annually from Fargo. Every few years I take in the musical and pitchfork fondue, too. I often camp, but sometimes stay in a cabin or hotel, too. If the wild horses are removed from TRNP, I will absolutely vacation elsewhere in protest of this terrible NPS decision. I am not alone.
The ND Senate unanimously passed Concurrent Resolution No. 4014 to help save the herd because the majority of residents want the wild horses to remain in the park. It states, “A concurrent resolution urging the Secretary of the Interior and the Director of the National Park Service to modify its proposed livestock management plan, to recognize the benefits of livestock grazing, and to continue to allow for interpretative, cultural, and historical purposes a herd of longhorn steers in the North Unit of the Theodore Roosevelt National Park and the presence of a wild horse herd in the South Unit of the Theodore Roosevelt National Park.”
Gov. Doug Burgum released a statement in favor of keeping the wild horses in TRNP, “We continue to urge the National Park Service to maintain a herd of wild horses in Theodore Roosevelt National Park, just as wild horses roamed those lands during Roosevelt’s transformative years in the Badlands, when President Truman signed the bill creating the park in 1947 and when it received official national park status in 1978,” Burgum said. “These horses are a hugely popular tourist attraction, embodying the untamed spirit of the Badlands while also reminding us of the deep ties to Roosevelt’s ranching and conservation legacy. As we’ve expressed repeatedly to the NPS and Director Sams, the state remains ready and willing to collaborate with the Park Service to keep wild horses in the park in a manner and number that supports genetic diversity and protects the park for visitors now and long into the future.”
Please leave the only herd of wild horses in ND in TRNP. Listen to the ND people; we want our wild horse herd to remain in TRNP. I grew up in ND; this is my home. I started visiting the park with my family when I was a toddler, and I am now 49. I go to the park at least twice a year and have for almost my entire life. If the NPS removes the wild horse herd from my state’s only National Park, I will never visit it again. TRNP is a gem of a National Park and offers something almost all others do not: wild horses. Do not kill ND tourism!
Michelle Jennison lives in Fargo.
Letter: We must find a way to keep wild horses in Theodore Roosevelt National Park
Idon’t even know where to start. I have been told by people not to emotional, not to get angry, and stay calm. When you put it all on paper, how can you not get angry, emotional and very sad! Some people are try to take away a very magnificent part of our North Dakota history! Our beautiful, wild, and free horses! They have earned their place in our history here. People come all over to see them, like the majestic stallion watching over his mares and foals. Running across the tops of the bluffs and down into the valley below. Friends were here in August, they went to Medora for day and took some beautiful photos of the horses, none of the prairie dogs! When we were talking later, she said, “hope it’s not the last time we see them.” They are hoping to come back next summer with Grandkids to see the horses and Medora.
I hope and pray they will still be in the beautiful TRNP. We have to find the way to keep them safe and free.
Thank you for space.
Trish Hulm, Bismarck
As you can see, your letter can be any length and cover any aspect of why we are fighting so hard to keep these horses IN the only home they have ever known.
“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: https://secure.everyaction.com/Af1717oXqU2wTrcB0Yz6jw2. 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.
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.”
Interesting…
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.”
THE GOAL OF LIVING HISTORY
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.’””
AND
““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.”
AND
“With plans and periodic culls, administrators treated the horses the same as buffalo and elk.”
WOW!!
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.
I had a GREAT chat this morning for a NEW podcast. We will share that link as soon as it is made available to us!
We are also thankful to our friends at Chasing Horses – They donated over $1,000 in local advertising credit for us so that the following ads can run in the The Dickinson Press over the next 4 weeks to encourage people to get their comments in!
Our social media ads are up and running! They are getting AMAZING responses! Please consider making a donation to help us cover these advertising costs. We have 25 days left to reach as many people as possible and get them to comment! You can make a TAX FREE donation to CHWHA here: https://chwha.org/support-chwha/
We are working on the blog for the Historic aspect of the comment period. This will likely be at least 2 posts! We have some new to us information that has been shared that we want to look over that we think will help with your comments.
Comments are due to the Park by November 24, 2023. We have plenty of time, so please make sure that you are putting together some well thought out and FACTUAL & SUBSTANTIVE comments. Please look at our blog posts for tips. We also have documents you can use as supporting documentation listed on our website: https://chwha.org/save-the-trnp-wild-horses/
A special THANK YOU to the angel who apparently took some of our flyers from the Trunk or Treat in Medora last week and is putting them up around Dickinson! We appreciate you helping to spread the word! If you would like some of our NEW FACT sheets, brochures or stickers, please send us an email at info@chwha.org letting us know what you want and how many: https://chwha.org/join-the-fight/
Our Facebook engagement is up almost 500% and our Instagram engagement is up almost 200%!! Can you tell?!
Welcome to all our new followers!
Just a few reminders:
The wild horses in Theodore Roosevelt National Park are managed by the National Park Service (NPS) NOT The Bureau of Land Management (BLM). BOTH agencies DO fall under the jurisdiction of the Department of the Interior (DOI) and the current actions of the Park do resemble the BLM playbook.
Theodore Roosevelt National Park is fenced. There are no concerns for cattle or other livestock taking the place of the horses if they are removed.
People have asked about supporting materials to reference in their comment letter. We have those on our website in the Save the TRNP Wild Horse’s section: https://chwha.org/save-the-trnp-wild-horses/ This section is filled with reference documents used throughout the wild horse advocacy world during NPS and BLM comment periods. PLEASE utilize these documents and share them! The documents the Park has on their planning website – MIGHT help – like the Brownlee report, but most of those documents were used to support the Park’s arguments on why the horses should be removed from the park so we do not recommend looking there for your supporting documentation.
Our last comment letter is also on our website. Any documents cited in that letter have also been sent to the Park. If you reference those documents, you DO NOT have to send the Park a hard copy of the reference material. IF you have a NEW document, you do have to send that to them. Documents the Park listed on their planning site DO NOT have to be mailed to them. We know they have them! If you are unsure, feel free to email us at info@chwha.org.
To our long-time followers: no matter how long you have been in this fight with us, at some point, the management actions of Theodore Roosevelt National Park were (and may continue to be) shocking to you. Remember that as we welcome new followers to our page. They may just be learning about what is happening to our horses and we are happy to have them joining us in this fight. We have REPEATEDLY stated that there are still too many people who do not know what is happening in OUR national park. Please feel free to help us answer their questions with understanding and compassion.
There will always be people who disagree with us. That is fine. Yesterday at the Trunk or Treat in Medora, a woman wanted to argue with me about the benefits of continued removals of the horses from the Park – so she can own one herself. And surgical sterilization of “lower grade” mares as an added management practice. While I DID ask her if it would be ok if we permanently sterilized “lower grade” humans as well – my husband quickly reminded me that we were REALLY there for the kids. Remember why you are here. If someone gets to be too much, please send us a PM or an email at info@chwha.org and we will give them a warning before we ban them from the page. These people are entitled to their opinions – we just will NOT tolerate someone who is just here to argue and belittle our followers.
Many of you are sharing comments that say things like “I will not return to Theodore Roosevelt National park if the horses are removed.”
That ALONE is NOT a SUBSTANTIVE comment. The Park does NOT care if I never go to the Park again. The Park does NOT care if 20,000 people say they won’t go to the Park again.
Consider saying SOMETHING like this instead – again in your own words please:
“Me and my family will NOT return to Theodore Roosevelt National Park if the horses are removed. They are the only reason we go to the Park. We can see bison in other places, like Yellowstone and Custer State Park. We are not the only ones who feel this way. A 2020 study released by Brownlee CLEARLY shows that 89% of visitors to your park agree with us as the report shows that most visitors want the presence of wild horses to remain in the South Unit. Moreover, out of 22 different topics brought to the attention of visitors, the wild horses received the most positive responses from visitors on what was important to them to experience while they visited the South Unit.”
THAT gave your simple comment some SUBSTANCE – some backbone – SOME FACTS!
You not only expressed that you disagree with their decision to eliminate the horses, you let them know that 89% of the people in a study they vetted, ALSO want the horses to stay! You also DO NOT have to send them the Brownlee study – they have it and we know that because it is on their website. You do NOT have to sound like a scientist or lawyer to make an IMPACTFUL and MEANINGFUL comment – you simply have to give them FACTS that they can use as they move forward in this process.
Now, IF 20 of you copy and paste that paragraph EXACTLY as it is above – THAT will count as ONE comment. Please use those facts stated there, just put it into your own words to be respectful of other people who are commenting and to help make EVERYONE’s comment count!
We have discussed the Purpose and Need statement as well as the “livestock” classification in other blog posts. Please feel free to look through past blogs as well as other people’s comment letters from the last comment period, for ideas on how to make your comment count.
We have also talked to some pretty awesome people in our Horse Talks. Those are available on our YouTube channel and can be helpful to you when you are writing your comment letter. We are working on a couple more to help and our talk from Friday will be posted later today or tomorrow.
Please continue to send us your questions either through social media PM’s or by email at info@chwha.org.
We will be back tomorrow to talk about the historical and cultural significance of these horses and where you can get the reference materials you need for that argument.
REMEMBER: your comment can be as short or as long as you like! AND YES! You can comment more than once. We do suggest that you start a word document of some sort and have a place where you can add to your comments as other topics come up that you want to personally tell the Park. Then, once you have everything together, send it in as one document.
Just a reminder, if you are interested in any of our educational or promotional materials, please email us at info@chwha.org. We will be sending out materials tomorrow, to those of you who let us know last week.
Welcome again to all of our new followers and THANK YOU to everyone old and new for being in this fight with us. Just under 200 horses are depending on us to be their voice! We appreciate each one of you!
Hello and Happy FRIDAY to everyone! Is it just me or did this week also fly by?
I was thinking recently after different conversations with people how there are always things going on behind the scenes that we are not always aware of. Then I was thinking that there is A LOT going on at Chasing Horses Wild Horse Advocates (CHWHA) that maybe all of you are not aware of. I thought today would be a good day to invoke a brainstorming session with all of you.
I have said this before and it is worth repeating, as we were setting up our non-profit, our non-profit lawyers instilled in us that non-profit organizations belong to the communities they serve. We strive to be transparent with all of you and listen to your thoughts, ideas and concerns.
Now that the legislative process is over and we have an answer to our extension to this comment period, I have spent the better part of today working on ways to spread the word about these horses and the comment period.
Here are some things we are already doing. We also welcome your thoughts and suggestions.
Our billboard is STILL up. This comes at a cost to CHWHA of $975 per month. American Wild Horse Campaign has a separate billboard up in Dickinson to help raise awareness.
We are in regular contact with our legal team, and they are hard at work on our comment letter. We are happy to announce that American Wild Horse Campaign will be submitting their comment letter jointly with Chasing Horses Wild Horse Advocates. They have also agreed to pay the legal expenses for this comment letter. We are thankful to them for continuing to fight with us!
Today we created several of these graphics. They will post on our Facebook page at least twice a day through November 24, 2023:
Some of these graphics have also be sent to our Dickinson Area Chamber of Commerce. They will send them out in their weekly emails every Tuesday from now through 11/21/2023 to reach over 1,000 businesses/organizations and people in our local community.
We are getting the cost to run these as ads in the Dickinson Press for the next 4 weeks.
Facebook and Instagram ads were created with these graphics. A new ad will run every week through 11/24/2023.
We started our video ads this week. We created an ad with the wide screen version that is running on Facebook and Instagram. We also took the mobile version and created a “reel” that we boosted. As more videos are released to us, we will create additional ads.
The results so far are great – AND it has ONLY been 3 days!!:
We ordered 5,000 stickers to pass out over the next week and also to send to followers who have requested them.
We will pick up our FACT sheets today from our local printer. These will be passed out over the next week, mailed to our followers who requested them and will be on hand at stores in Medora.
TOMORROW – 10/28/2023 – we will be at the Rough Rider Hotel in Medora for their 1st ever Trunk or Treat! We will be passing out candy, stickers and flyers to help raise awareness about the TRNP wild horses!
TUESDAY – 10/31/2023 – we will join over 70 businesses in Dickinson for their annual “Trunk or Treat”. They are expecting about 3,000 kids and their parents to come through. We will have candy, stickers and flyers to pass out.
We will pass out our FACT sheet out to businesses in Medora and Dickinson. The Chasing Horses store has been a hub for information on this process. All of our promotional materials are also available to be picked up there as well for anyone interested (please message us ahead of time to make sure we are there and that we have what you want).
We are in the process of updating our brochure.
We will be advertising in local horse expos programs this fall/winter.
We remain in communication with the local press to help keep the horses in the news.
We are utilizing our membership with the North Dakota Newspaper Assn. which allows us to send out press releases to every newspaper in North Dakota once a month.
We continue to host our Horse Talks and participate in Zoom events/podcasts with other advocates to help spread the word! We are hosting one tonight – have you registered? We will also have information soon about a NEW Horse Talk with Craig Downer!
We are sharing this with you today to #1 – let you know where your donations are going and #2 – to honestly brainstorm with all of you on what else we could do to help raise awareness about these historic wild horses? We have been engaging over 100,000 people through all of our social media channels and website over the last couple of months. That means there should be over 100,000 different ideas brewing in your heads! If you come up with anything, please let us know! You can share your thoughts as a comment on our blog, on our social media posts or email us at info@chwha.org.
All of this advertising and different membership fees also come at a cost. We wanted to let you know where your donations to CHWHA are going and we also hope that you will continue to support our efforts! There are several ways that you can donate listed on our website: https://chwha.org/support-chwha/. As a 501(c)3 organization, your donations are 100% tax free!
I want to take a quick break from our substantive comments.
I am continually amazed by the people who continue to cross my path as we continue to Fight for the Spirit of the Badlands. There are so many people who have come in and out of my life since all of this started in March of 2022 that I don’t always get to talk about them because time and the focus gets so critical.
Last week, I was talking to former ND Governor Ed Shafer. When I told him how hard this fight gets sometimes, he told me to call him anytime I need a “pick me up”.
How crazy is that?
The truth is, I have a great list of people who seem to say the right thing at just the right time when even I didn’t know I needed to hear it the most.
At the very top of that list is always my husband, Gary. He is the quiet one behind the scenes, always doing something to help raise awareness about these horses. Our truck has literally become a moving billboard of sorts! Last week, when all of the legislative stuff was happening, he kept reminding me that I had to keep going “even if this doesn’t turn out the way you want it to” – he knows that I like to get my way and how hard I will fight for what is right. “I know, I know, I know.” I reassured him. And when we didn’t get the votes, he was the first one to call me to make sure I was ok. The other day we had a conversation where he let me know that he believed these horses came first, above even him, in my life. I am glad we had that conversation because truly he is and always will be #1 in my life.
I have to mention my mom, who usually knows before I do when all this gets to be too much for me and does one of her “mom things” to help.
I have also had the pleasure of meeting and talking to Dr. Castle McLaughlin. This amazing woman emails me just about every week and we talk on the phone as our schedules allow. It can be as simple as how great the last zoom was, a random thought or idea that came into her head, an argument to a thought I shared in a blog or just some encouraging words, like part of this email from her the other day in response to my “Defeated” blog: “I am always encouraged by your posts, and in my mind you have become such a model for effective activism. Truly Chris you are incredibly committed, resourceful and skilled at this and regardless of what happens here you can use these gifts to make the world a better place.”
Yes, I cried lol
Here is the woman, who we cannot thank enough for recording the history that would be gone otherwise, telling ME how I encourage her.
People like her and my dear friend, Frank Kuntz, who also called me this week to tell me that he admired me, really move me. These are people I have come to really look up to for all of their work in preserving the history that is so important to the Badlands of North Dakota. They remind me that I am doing the right things with a level of integrity that is very important to me.
During the last public comment period, a man named Steve Martens and his wife Joanna contacted me. They shared their comment letter with me, and it was honestly one of the best comment letters I read. You can read it on our website: https://chwha.org/january-2023-comment-letters/
My hands down favorite part of that letter is this:
“At a minimum, if the horses are unwisely removed from TRNP, NPS alternative management plans should provide for mitigation of the harm from extermination of the herds. Please understand; this is not meant to be sarcastic, although it is plainly critical. Minimally, the mitigation of harm should include producing a permanent exhibit and video recording commemorating the rich multicultural tradition of free-roaming horse herds on the Northern Plains. As a way of educating future generations about the tragic effects of bureaucratic management by the National Park Service in the brief period 1978-2023, a permanent bronze plaque could be installed overlooking Cedar Valley, or another setting in which we have observed horses, informing future generations of the consequences of irresponsible neglect of a living heritage resource.
The plaque might read, “Had you stood in this spot anytime from 1880 to 2020 you could have experienced the iconic free roaming herds of naturalized horses that were the product of Native American and Euro-American ranchers and cowboys. In your experience of Theodore Roosevelt National Park, consider the reasons and rationale for why this experience no longer exists. Then, the visitor should travel to the reservation lands of the MHA Nation near Mandaree and Twin Buttes, or the habitat of free-roaming Nokota horses near Linton, ND to experience the equine heritage that no longer exists here (within the park).”
I hope you are nodding your head in agreement with those very fine-tuned words of wisdom shared in those two paragraphs. They defined very well the plight of not just these horses, but the rich history of a very important period in time for the entire US and of course, the town of Medora that is nestled in the Badlands of North Dakota.
Steve Martens and I correspond regularly through email. This amazing man and his wife are now added to the list of people who just randomly send me messages that really hit me in just the way I needed in that moment. They are always wonderfully encouraging and I always look forward to seeing what they have to share.
Steve wrote to me again today. He shared an article wrote back in 2014. He said, “This was my attempt to summarize cultural heritage significance of the park, based on what I learned about the Neuens family who had lived in that Little Missouri Badlands landscape from about 1885 onward.”
This story is important as a record of the birth of what we now know as Theodore Roosevelt National Park.
His email today was a reminder that we are literallyFighting for the Spirit of the Badlands. That spirit includes the history that made this park what it is as much as the horses that we are fighting for today. We are fighting for the preservation of the past. We are fighting to make sure this history is available for future generations to SEE with their own eyes, not through accounts of what once was able to be experienced within the boundaries of one of the best National Park’s in the US.
So today, instead of listening to me ramble on about how to write your comment letter, I hope that you will take some time to read the two articles I have attached here. Both are also available in the Library section of our website.
The first: Badlands and Broomtails: The Cultural History of Wild Horses in Western North Dakota by Dr. Castle McLaughlin
The second: The Designed Landscaped of the North Dakota Badlands: Weldon and Marjorie Gratton, Faithful Stewards and Genuine Collaborators by Steve Martens.
These two articles will give you more information than I ever can on the historical & cultural significance of our fight. You might even find a thing or two to add to your comment letter.
Tomorrow we will be hosting a new Zoom with me, Chris Kman, to answer your questions on this process. Please remember to register in advance to get the zoom link: https://secure.everyaction.com/smU9KC-nNkyPAevZYGFDEA2
I’ll be back this weekend with some new tips on substantive comments with Section 106 and the historical and cultural significance up next.
While you wait for that, I hope that you will take the time to read these two articles and I will spend some time letting my husband know that wild horses could never drag me away from him 😉
Enjoy your day! We will pop in if something comes up on social media! I hear there will be something good in tomorrow’s Fargo Forum! Please make sure that you like and follow us for those updates: Facebook: https://www.facebook.com/ChasingHorsesWHA Instagram @chasinghorseswha
Thank you also to each and everyone of you who stand with us in this fight. My voice alone does not make the same sound as ALL of our voices together. THANK YOU all for giving this lone voice some strength!
Are you ready to pull up your sleeves and continue working on your comment letter? We have a NEW topic for you today.
Just a few reminders before we begin:
Our comments this time can be the same as they were last time. We DO NOT have to offer NEW information to make a SUBSTANTIVE comment.
IF you are NOT well versed in the topic, don’t state things you don’t understand. That being said, don’t be afraid to look up words or ask questions so that you CAN understand. Knowledge is power 😉
REMEMBER:
Comments should highlight (with evidence, studies, or personal anecdotes where possible) why impacts will be significant to resources such as:
Economic impacts to local governments, businesses, and residents Wildlife and wildlife habitat Historic and cultural resources Ecologically critical areas
We also want to remind everyone that we DO have talking points along with documents you can read for yourself to help support your own comment letter to the Park on our website: https://chwha.org/save-the-trnp-wild-horses/
We are giving suggestions in these posts. Please do not copy our words verbatim and send them in as your own. Find a way to say the same thing in your own words. That helps give power to your words as an individual comment, so it will not be seen as a form letter.
Our next topic on what to add to your comment letter is challenging the narrow focus of the Purpose & Need Statement in your comment letter.
I want to start by sharing a small but significant change in the language the Park used in their scooping notice in December of 2022 and what we were given in this Draft EA. I am showing you this to hopefully show you the impact of even the smallest arguments and SUBSTANTIVE comments can make.
This is from our comment letter in January of this year:
“The Park promulgated its Foundation Document in 2014, and it “provides a focus for park planning activities and establishes a baseline from which planning documents are developed.” Foundation Document at 2. This includes the Park’s “Purpose Statement,” which “identifies the specific reason(s) for establishment of a particular park” and “aids park managers” in “protecting resources and values that are integral to park purpose and identity.” Id. at 2, 6. According the Foundation Document, the TRNP purpose statement “was drafted through a careful analysis of its enabling legislation and the legislative history that influenced its development.” The TRNP’s purpose statement, as written in the 2014 Foundation Document, provides that:
Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, wildlife, and wilderness qualities of the North Dakota Badlands—the landscape that inspired Roosevelt and still inspires visitors today.
In the Park’s recent Scoping Notice, the Park suddenly adds the word “native” to the TRNP purpose statement—without notifying the public about the change. The purpose statement that appears in the Scoping Notice reads:
Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, native wildlife, and wilderness qualities of the North Dakota Badlands—the landscape that inspired Roosevelt and still inspires visitors today.”
Our lawyers made the argument that the Park COULD NOT change their purpose statement that was delivered to the public in their Foundation Document without notifying the public of that change.
In the Draft EA that was released in September, the Park went back to the purpose statement as it is ACTUALLY written in the Foundation document:
“As described by the Park’s purpose statement, “Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, wildlife, and wilderness qualities of the North Dakota Badlands – the landscape that inspired Roosevelt and still inspires visitors today.”
We hope this helps you see the power of our comments. This is a small but significant change that was brought about by our comment letter. THIS is also why we have lawyers!
Moving on to the Park’s Purpose and Need statement and your SUBSTANTIVE comment on this topic:
NEPA requires that range of feasible alternatives is determined by the purpose and need for the action.
A few notes:
Courts have cautioned agencies against defining the project purpose too narrowly.
The purpose and need statement is a key factor in determining the range of alternatives considered.
The term “all reasonable alternatives” implies that every reasonable alternative must be rigorously evaluated, no matter how many reasonable alternatives exist.
United States Code (USC) Section 139 requires lead agencies to provide an opportunity for involvement for agencies and the public in defining the purpose and need and determining the range of alternatives.
Chasing Horses Wild Horse Advocates made the argument in the last comment period and will make the argument again that Theodore Roosevelt National Park’s Purpose and Need statement is too narrowly focused.
From our last comment letter:
“NEPA imposes on the Park a duty “study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources.” 42 U.S.C. § 4332(2)(E). The duty applies regardless of whether the “agency is preparing an [EIS] or an [EA], and requires the agency to give full and meaningful consideration to all reasonable alternatives.” N. Idaho Cmty. Action Network v. U.S. Dep’t of Transp., 545 F.3d 1147, 1153 (9th Cir. 2008) (quoting Native Ecosystems Council v. U.S. Forest Serv., 428 F.3d 1233, 1245 (9th Cir. 2005) (emphasis added)); see also W. Watersheds Project v. Abbey, 719 F.3d 1035, 1050 (9th Cir. 2013) (same).”
That paragraph states the U.S.C. (United States Code) and also cites court cases that have weighed in on this topic.
The Park’s Purpose and Need Statement does not take the historical and cultural significance of these horses into consideration.
Our lawyers went on to state a way to rectify this narrowly focused Purpose & Need:
“To rectify that oversight, the Park should consider managing a genetically diverse wild horse herd representative of the phenotypes that would have been “part of the cultural landscape when Theodore Roosevelt lived in the area.” Foundation Document at 10. As the Park is well aware, such an alternative has been proposed previously; in 1984, the Park acknowledged the possibility “of maintaining a historic badlands horse herd, with the animals being direct 20 descendants of the horses which were found here when the park was founded.” See NPS, Natural Resources Management Plan and Environmental Assessment at 46-47 (1984); see also McLaughlin Report at 173 (same).”
Again, our entire comment letter from January of 2023 is available to read on our website. We also expect to have our comment letter completed in the next couple of weeks and will share it as soon as it has been approved and sent in.
The Purpose and Need statement is important to challenge because this is where the Park is telling us WHAT they are proposing and WHY. We have given you a few points above to help you challenge this in your own comment letter.
Remember, if you aren’t a lawyer, don’t talk like one 😉 BUT DO put those examples into your own words to personalize your own comment letter to make it unique and impactful.
We will be back tomorrow with more! Remember you are always welcome to email us with your questions: info@chwha.org
If you remember, we sent the following email to Superintendent Richman on October, 23, 2023:
Superintendent Richman ~
Hello! I have been asked the following questions several times by our followers and did ask these questions at the Civic Engagement meeting, but they seem to have not made the cut for questions that were answered that night.
When the Park plans to eliminate 150-200 horses during week long helicopter round-ups, what is that cost and where will that money come from? Is this something that will come out of the budget of the NPS or will the BLM be footing that bill like they did with the GonaCon experiment? What is the proposed budget for the removal of the horses? We are sure you have prepared a budget that was proposed to cover things like the cost of week-long helicopter roundups, veterinarian bills, and all of the aftercare associated with rounding up the horses. While you are asking the public to weigh in on the alternatives you have presented, it would seem that knowing what that budget is, that will obviously be paid for with our tax dollars, would be important to making an educated comment on the Draft EA.
If, in fact, you will say that there is no proposed budget, aside from the obvious comment that there needs to be a determination before any such actions take place, can you tell us what the cost was to round up the 400 bison last week? Maybe that will help us get an idea of the overall cost.
Also, I noticed on the BLM sites for comments, there is a way for the public to see how many comments have been submitted. Is there a way for the Park’s planning site to give the public updated information on the number of comments that have been submitted for the TRNP Livestock Plan?
Lastly, the Draft EA states that if after “several” attempts to sell the horses on GSA Auctions that the horses would be euthanized. Can you define “several” and that timeline for selling the horses please? i.e, will the horses be listed for a day, a week a month, etc. before they are relisted and/or euthanized? Also, what agency will be responsible for the actual euthanization of the horses and the costs associated with that? i.e., the NPS, BLM or is this new and alarming direction coming from the DOI directly?
It would seem like all of this should have been discussed in the Draft EA.
Thank you for your consideration. I appreciate your commitment to being transparent with the public.
Thank you for reaching out. I appreciate your continued engagement in the Livestock Plan Environmental Assessment (EA) process. Formal comment on the Livestock Plan EA is only accepted through the project website: https://parkplanning.nps.gov/LP or hardcopy by U.S. mail. Please submit your questions about the content or specific concerns about the Livestock Plan EA on the project website or by mail. The Livestock Plan EA public comment period is now open through November 24, 2023.
Angie Richman Superintendent Theodore Roosevelt National Park Medora, ND 58645
Our response:
Superintendent Richman ~
Thank you for taking the time to respond to my email. We will definitely raise these questions in our comment letter and I will also take the time to submit them through the horse portal and encourage our followers to do the same.
More importantly, the answers to those questions would be helpful for the public to make educated comments to the Park on this Livestock Plan process. Especially since this is our last opportunity for public comment during this process.
For clarification purposes, does your response mean that the NPS views last week’s bison roundup within the scope of the LP EA?
You heard the lady: “We have continued to respond to all communication pertaining to horse and cattle management through the online communication portal. Our hope is to maintain transparency, information consistency, and equitability among the public and park stakeholders”
Are you ready to pull up your sleeves and start writing your comment letter?
I want to say that our comments this time can be the same as they were last time. We DO NOT have to offer NEW information to make a SUBSTANTIVE comment. IF you feel that the Park has answered your last comment letter to your satisfaction, then move on. IF you feel they have NOT given a satisfactory answer, then ABSOLUTELY restate your comment.
IF you are NOT well versed in the topic, don’t state things you don’t understand. One of our followers is a historian. They are working on their comment letter mostly filled with historical FACTS. They have 9 pages so far and they are still working on it! We won’t cover that much in our comment letter, because we don’t have the knowledge they do. That being said, don’t be afraid to look up words or ask questions so that you CAN understand. Knowledge is power 😉
REMEMBER:
Comments should highlight (with evidence, studies, or personal anecdotes where possible) why impacts will be significant to resources such as:
Economic impacts to local governments, businesses, and residents Wildlife and wildlife habitat Historic and cultural resources Ecologically critical areas
We also want to remind everyone that we DO have talking points along with documents you can read for yourself to help support your own comment letter to the Park on our website:https://chwha.org/save-the-trnp-wild-horses/
We are giving suggestions in these posts. Please do not copy our words verbatim and send them in as your own. Find a way to say the same thing in your own words. That helps give power to your words as an individual comment, so it will not be seen as a form letter.
We are going to start at the beginning of the Draft EA:
The classification of the wild horses of Theodore Roosevelt National Park as “livestock”.
First, for people who have been following this herd of horses, you know that the Park USED TO refer to these horses as “a historical demonstration herd” or “feral” and the horses USED TO be included in the Park’s definition of “wildlife”. Actually, if you read Superintendent Richman’s Superintendent’s Compendium (labeled NPS 2011a on the Park’s planning website) In May of 2023, the horses were referred to as “wildlife”:
“Disturbing Wildlife: All wildlife in the park is wild and potentially dangerous. Except for inadvertent or casual encounters with wildlife in areas where traffic is required or essential, willfully approaching, remaining, viewing, or engaging in any activity within 25 yards to bison, elk, and feral horses or closer to any other wildlife including nesting birds, or within any distance that disturbs, displaces, or otherwise interferes with the free unimpeded movement of wildlife, or creates or contributes to a potentially hazardous condition or situation, is prohibited.”
Insert any of those quotes about how it is easy to remember the truth and harder to keep up with the lies.
Chasing Horses Wild Horse Advocates has been asking for YEARS about the classification of the horses in the Park – LONG before this “Livestock Plan” even started. The Park cannot simply change the classification of these horses without input from the public. We have been asking for YEARS for that documentation and since the Park has not given it to us in our FOIA (Freedom of Information Act) requests, we are left to assume that is because the document does NOT exist.
Sooooo
As easily as they changed the classification of the horses to “livestock” they can easily change it back.
Here is part of what our lawyers wrote in our last comment letter about this topic. I chose this because I think you will all enjoy how our lawyers called them out on their inconsistencies. There is A LOT more to our 68 page comment letter – you can view it all on our website:
“The Park’s Ad Hoc Definition of “Livestock” Does Not Carry the Force of Law; the Agency Must Explain Its Rationale
Evidently, the Park recognized that the inconsistency between its use of “livestock” and the plain meaning of that term is problematic for its end-goal of eliminating wild horses from the TRNP. So, the Park decided to invent its own definition and post it to its website.
In any case, the Park has not explained how it ascertained this novel definition of “livestock.” Nor has it explained how this newly minted definition applies to wild horses since neither the Park nor anyone else “selectively breed[s]” these animals for any reason, let alone domestic or agricultural purposes—at least not anymore; 5 to the contrary, one of the Park’s primary contentions is that wild horses are breeding too quickly on their own and there has been no assertion from the Park that it is selecting specific horses for domestic or agricultural purposes. E.g., Wild Horse EA at 4. The Park has also failed to explain why its definition does not apply to the Park’s bighorn sheep, bison, or elk herds. As the Park has recognized in the past, all three have, at some point, “been selectively bred by humans” for inclusion in the Park.
If the Park insists on applying its blatantly outcome-determinative definition to wild horses, it must explain in any forthcoming NEPA document how that definition was derived, how it applies to wild horses, and why the Park is choosing to treat similarly situated animals differently. Anything less is textbook arbitrary and capricious action under the Administrative Procedure Act (“APA”), 5 U.S.C. § 706(2).”
Since we are not all lawyers…here are some other supporting documents you can use for your argument against the horses being classified as “livestock”:
According to 29 CFR § 780.328, the federal definition of “livestock”: The term “livestock” includes cattle, sheep, horses, goats, and other domestic animals ordinarily raised or used on the farm.
29 CFR § 780.120 further clarifies: The meaning of the term “livestock” as used in section 3(f) is confined to the ordinary use of the word and includes only domestic animals ordinarily raised or used on farms. That Congress did not use this term in its generic sense is supported by the specific enumeration of activities, such as the raising of fur-bearing animals, which would be included in the generic meaning of the word. The term includes the following animals, among others: Cattle (both dairy and beef cattle), sheep, swine, horses, mules, donkeys, and goats.
Our friend Theresa at Oregon Wild Horse Organization explains: “It makes it clear that wild animals may be raised on a farm, but not be “livestock” just because they are. Therefore, when the courts ruled that wild horses living in the wild are no less wild than grizzly bears -Mountain States V Hodel – 799 F.2d 1423 (10th Cir. 1986) and again in WHOA v NMLB support that these horses that the NPS called wild in previous documents cannot now just be changed and placed under the legal designation of livestock because they say so. They deemed them wild until this year when they decided to get rid of them.”
Under North Dakota Century Code Title 11. Counties § 11-33-02.1, The state of North Dakota defines “livestock” as: “Livestock” includes beef cattle, dairy cattle, sheep, swine, poultry, horses, bison, elk, fur animals raised for their pelts, and any other animals that are raised, fed, or produced as a part of farming or ranching activities.
Wildlife means any member of the animal kingdom and includes a part, product, egg or offspring thereof, or the dead body or part thereof, except fish.
36 C.F.R. § 2.60 (a)(3) discusses livestock use and agriculture: As designated, when conducted as a necessary and integral part of a recreational activity or required in order to maintain a historic scene.can be read here: https://www.ecfr.gov/current/title-36/chapter-I/part-2/section-2.60
The wild horses of Theodore Roosevelt National Park do NOT fit any definition of “livestock” – NOT by the federal government, the State of North Dakota or even a regular dictionary definition.
As our lawyers stated, the Park has not properly let us know how they came to the conclusion that the horses were livestock.
This was NOT answered in the Draft EA. We DO know it was discussed in the secret meeting the Park held in October of 2022 as NPS 2022h states.
I received an email last night from a follower. She was feeling pretty defeated and honestly, I completely understand. I have many days like that.
I want to start by saying, I don’t believe there is a manual for “Effective Wild Horse Advocacy”. Even Wild Horse Education, American Wild Horse Campaign, The Cloud Foundation, In Defense of Animals, and all of us are learning as we go. What works today MIGHT work again tomorrow, then again, maybe it won’t!
I think that all of us believe in our heart of hearts that somewhere within the walls of the Department of the Interior (or whatever government office) that they are still part of a government that is “OF the people, BY the people and FOR the people.”
Most days it doesn’t seem like that, does it?
Someone else emailed me yesterday concerned because another page said that the “fate” of these horses will be decided on November 24, 2023.
NOTHING could be further from the truth!
The TRUTH is the Park is engaged in a NEPA process. The LAST public comment period for this particular part of the process ends on November 24, 2023.
THAT is ALL that ends on November 24th!
I have said this before, and I will say it again – we are ONLY in the beginning of what looks like will be a very long fight for the freedom of these horses.
For example…
On November 24th, this public comment period ends. The Park then reviews the comments and either comes back with a FONSI (Finding of No Significant Impact) OR they do a more in-depth analysis of their proposed action and move on to perform an Environmental Impact Statement (EIS). OR They come back with a FONSI and our lawyers advise us to fight for an EIS. OR our lawyers advise us that it is time to file a lawsuit against the park for whatever reasons they give us. OR about a million different scenarios that I have running through my mind happen.
We keep fighting.
The “fate” of these horses is decided when we STOP FIGHTING. And THAT is what the Park is counting on.
Wearing us down.
Dividing us.
Making us tired.
Having us feel like nothing we say matters.
OUR VOICES DO MATTER!
The Code of Federal Regulations tells us that!
What is the Code of Federal Regulations?
The Code of Federal Regulations (CFR) annual edition is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.
“[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).
What the heck does all that mean?
From our lawyers: “My take away is 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).”
THAT is why a SUBSTANTIVE comment matters.
THAT is why simply sending in a comment simply saying you won’t go back to the Park does NOT help these horses.
THIS IS NOT AND NEVER HAS BEEN about the NUMBER of comments that the Park receives. It is about the number of SUBSTANTIVE comments that the Park receives.
This is NOT a time for short and sweet comments, it is not a time for matter-of-fact comments. Senator Hoeven went to bat for us and asked NPS Director Sams for a 30-day extension to this comment period. In his request he said:
“Given the significant interest in maintaining wild horses at the park, members of the public should have ample opportunity to fully review the draft EA and provide MEANINGFUL input on any proposed changes to the management plan.” ~ Senator John Hoven 10/18/2023
AND
“A 30-day extension of the comment period is necessary to ensure members of the public are able to contribute to a well-informed decision related to the future management of wild horses at the park.” ~ Senator John Hoeven 10/18/2023
We have some AMAZING people advocating with us for these horses. Let’s not toss their hard work aside by minimizing our comments.
We get ONE chance to save these horses. We are in the thick of it for sure. Take your moments away when you need to – but please, for the just under 200 horses that call Theodore Roosevelt National Park home, make sure you come back to the fight.
They need you.
We ALL need you.
For those of you interested in creating meaningful, well informed, educated comments on the future of the wild horses in Theodore Roosevelt National Park, please check back here later as we continue discussing how to make your comment count.
I want to end by saying, I in NO WAY think I have all the answers. This has been an extremely hard learning curve for me. Insert the words of Stevie Nicks that echo in my head: “My mind won’t rest and I don’t sleep…not even in my dreams.” There is A LOT to all of this and THAT is an extreme understatement. Believe me, I have my people I turn to too in those moments when I feel completely defeated. And when I don’t understand, I don’t make things up, I phone a friend (and sometimes a couple) until I find someone who can explain it to me in terms I can understand.
And yes, some days I just want to crawl back in bed and ask for a day “off” from all this. Some days I am angry, mad, upset. And yes, some days I cry. Like when I was looking through the videos I sent to my friend at National Geographic.
These horses need every single one of us. Every single one of us together creates a loud voice that can’t be silenced.
Don’t worry about the lies and deceit coming out of the Park. I like to believe that the truth always finds a way to come out. A friend of mine always says “God doesn’t like ugly!”
We sent the following email to Superintendent Richman. We asked these questions during the last Civic Engagement meeting but they were not answered that night. We will let you know when she responds.
Superintendent Richman ~
Hello! I have been asked the following questions several times by our followers and did ask these questions at the Civic Engagement meeting, but they seem to have not made the cut for questions that were answered that night.
When the Park plans to eliminate 150-200 horses during week long helicopter round-ups, what is that cost and where will that money come from? Is this something that will come out of the budget of the NPS or will the BLM be footing that bill like they did with the GonaCon experiment? What is the proposed budget for the removal of the horses? We are sure you have prepared a budget that was proposed to cover things like the cost of week-long helicopter roundups, veterinarian bills, and all of the aftercare associated with rounding up the horses. While you are asking the public to weigh in on the alternatives you have presented, it would seem that knowing what that budget is, that will obviously be paid for with our tax dollars, would be important to making an educated comment on the Draft EA.
If, in fact, you will say that there is no proposed budget, aside from the obvious comment that there needs to be a determination before any such actions take place, can you tell us what the cost was to round up the 400 bison last week? Maybe that will help us get an idea of the overall cost.
Also, I noticed on the BLM sites for comments, there is a way for the public to see how many comments have been submitted. Is there a way for the Park’s planning site to give the public updated information on the number of comments that have been submitted for the TRNP Livestock Plan?
Lastly, the Draft EA states that if after “several” attempts to sell the horses on GSA Auctions that the horses would be euthanized. Can you define “several” and that timeline for selling the horses please? i.e, will the horses be listed for a day, a week a month, etc. before they are relisted and/or euthanized? Also, what agency will be responsible for the actual euthanization of the horses and the costs associated with that? i.e., the NPS, BLM or is this new and alarming direction coming from the DOI directly?
It would seem like all of this should have been discussed in the Draft EA.
Thank you for your consideration. I appreciate your commitment to being transparent with the public.
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!
Why?
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!
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.”
AND
Excerpts from the NEPA Handbook 6.9.2.1
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.
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
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!
I have been wanting to share this photo of Stallion Arrowhead all week. Today seems like a good day.
This picture was taken in the spring on a very foggy and rainy morning.
When I look at this picture, I am reminded of the journey that Chasing Horses Wild Horse Advocates has been on as we continue pushing forward with all of you to do what we can to save this iconic herd of wild horses.
Do you remember December 12, 2022? The Park made their formal announcement to us that their “preferred alternative” was to eliminate this entire herd of horses!
I will admit, at that moment, I felt completely defeated and helpless.
I believe I quoted “Inch by inch, it’s a sinch” at that time.
One step, one action at a time.
This week, I spent most of my time reaching out to our North Dakota State Legislators and working on the North Dakota Wild Horse Preservation Act. It was a long week.
This quote made its way across my path this week and it seems fitting here:
“If you really want to do something, you’ll find a way. If you don’t, you’ll find an excuse.”
― Jim Rohn
We worked hard this week to get the attention of the North Dakota State Legislators – and it worked! The North Dakota State Wild Horse Preservation Act was brought to the table as our legislators discussed yesterday which bills to bring forward into this special session.
First, out of somewhere between 30-40 bills/resolutions that were brought forward, only 7 made it to the table for the 17 committee members to vote on. The North Dakota State Wild Horse Preservation Act was one of them!
Our legislators heard you! Their email boxes were flooded in a 24-hour period from all of you BEGGING them to help save our TRNP wild horses.
In the end, only one of the seven bills made it into this special session, and it was not ours.
Representative Josh Boschee did an amazing job not only getting this into the mix at the last moment but also speaking to the importance of the issue of the wild horses to the committee. He called me last night on his way home to make sure I heard the news. He also encouraged me to reach out if something else comes along that the State of North Dakota can help with. He also said that he noticed more of his own constituents in West Fargo (400 miles from TRNP) contacted him this time compared to last December when all of this started. He said, “You have really gained some traction and support.”
All of you should be proud of what we have accomplished together! This one didn’t go our way. BUT it would have been criminal on our part to not try.
Since December, Chasing Horses Wild Horse Advocates, along with our followers have realized some AMAZING things. Here is a small list of some of our accomplishments:
Chasing Horses Wild Horse Advocates worked hard from the moment the Park made their announcement to bring attention to the plight of the wild horses of Theodore Roosevelt National Park! CHWHA NOT ONLY got the attention of our North Dakota State Legislators who UNANIMOUSLY passed SCR 4014 but also:
Governor Doug Burgum who sent in his own comment letter to the Park offering ““the State of North Dakota stands ready to collaborate with the National Park Service, whether with resources or management expertise, to ensure that the herd of wild horses can be maintained in a manner and size that supports genetic diversity and protects the park for visitors today and for generations to come.“
By spreading the word about these horses with all of you, Theodore Roosevelt National Park’s public comment period that ended January 31, 2023, the Park received 19,012 comments. Of the comments received only 45 of those comments supported the Park’s plans to eliminate the horses.
On February 3, 2023, the United Tribes of North Dakota sent a letter to Theodore Roosevelt National Park urging them to continue the preservation of the wild horses within the Park’s boundaries.
CHWHA began working with the MHA Nation and Whereas on April 13, 2023, the MHA Nation sent a resolution to Theodore Roosevelt National Park stating that the MHA Nation holds horses in high esteem as horses are significant to the MHA people and have played a major role in MHA history, tradition and culture; and The MHA Nation recognizes the wild horses running free in the park require genetic diversity and responsible herd management policies and techniques to maintain for the health of the herd. The Tribal Business Council voted unanimously to support the continued free running of the horse herd in Theodore Roosevelt National Park pursuant to a management policy that includes proper genetic diversity and efficient herd management policies and techniques.
On April 17, 2023 North Dakota Senate Concurrent Resolution SCR 4014 was formally filed with the North Dakota Secretary of State after the resolution which asked Theodore Roosevelt National Park to allow the wild horses to stay within the Park passed both the North Dakota House and Senate unanimously.
On July 11, 2023, the City of Medora requested in their own resolution to Theodore Roosevelt National Park that the Park keep the horses. Their resolution stated that the horses of Theodore Roosevelt National Park bring tourism to the state and the City of Historic Medora and elimination of the herd poses economic concerns for the business community and negatively impacts preservation and appreciation of our state and communities’ history.
CHWHA has been in regular communication with North Dakota Senator John Hoeven’s office. The Senator, who serves on the Senate Appropriations Committee, included language in the Interior Department’s Appropriations Bill urging Theodore Roosevelt National Park to allow the horses to stay in the Park.
In addition to those very important and very critical milestones, Chasing Horses Wild Horse Advocates has:
Worked hard to maintain a relationship with other advocacy groups like American Wild Horse Campaign, The Cloud Foundation, Save Our Wild Horses, Oregon Wild Horse Organization, and Equine Collaborative International, just to name a few.
Worked with photography pages and groups like National Geographic to not only help spread the word on the plight of our amazing wild horses, but to help use their strengths to bring about new tools to our advocacy toolkit, like the videos we released this week: https://youtube.com/shorts/JCysrji51-w and https://youtu.be/WD1qw_9CA1U
We have the North Dakota State Historic Preservation Office requesting more information from Theodore Roosevelt National Park – more on this in a new blog post hopefully tomorrow lol
We got an extension to this comment period! Comments are NOW due by November 24, 2023!
Remained in regular contact with Senator Hoeven’s office. He is hearing the people who are reaching out to his office and is committed to helping us save this herd!
Continued to engage with our media contacts who are helping to keep the Fight for the Spirit of the Badlands in the news.
I could go on and on – but I do hope you get the picture.
We will continue to go over ways to make your best comment for these horses in our blogs. We also had a GREAT talk with Heather from Save Our Wild Horses yesterday. We will share that video when it is available. We will also have some new Horse Talks coming up soon so stay tuned!
Most importantly, give yourselves a pat on the back! You all did a great job this week! Heck! You guys have done a GREAT job for the last 10 months. Thank you for being in this fight with us for the long haul. We STILL have a LONG way to go and A LOT of work to do to save this herd.
What a day this has been!! THANK YOU to everyone who shared and participated in our urgent call to action today. I apologize but things happened so fast today, I did my best to get as much information out to as many people as possible to give this call to action the best chance at success.
First – THANK YOU to everyone who sent emails to our North Dakota State Legislators! This is something we have been working very hard on all week, so I wanted to take a moment to explain what is happening and why…
Our North Dakota State Legislators are “part time politicians” meaning – they are ONLY in session for 80 days every 2 years!
THANKFULLY they were in session this year and as you remember, earlier this year we worked with them to draft ND Senate Concurrent Resolution 4014 which asked Theodore Roosevelt National Park to allow the wild horses to STAY in the park.
The North Dakota State Legislators are not scheduled to be back in session until 2025.
BUT
The North Dakota Supreme Court struck down some important budget legislation as unconstitutional. That means that the legislators have to come back into session to take care of that budget legislation per orders by the ND Supreme Court.
Since they are coming back into session, Chasing Horses Wild Horse Advocates has been in communication with ND House Majority Leader Representative Mike Lefor. Representative Lefor has been a huge supporter of our fight to save the TRNP wild horses. We have been urging our legislators to take stronger action to protect the wild horses of Theodore Roosevelt National Park.
We had until 5 pm CST TODAY (10/19/2023) to have our North Dakota Wild Horse Preservation Act submitted to the committee who will decide TOMORROW when they meet at 10 am CST #1- IF they will allow other legislation into this special session and #2 – WHAT legislation they will allow into this special session.
At 4:30 CST, Representative Josh Boschee called to talk to me about the North Dakota Wild Horse Protection Act. He agreed to get it submitted for us TODAY by the 5 pm CST deadline and has promised that IF additional legislation is allowed, he will speak up for the North Dakota Wild Horse Preservation Act to the committee on our behalf!!!! THANK YOU REPRESENTATIVE BOSCHEE!!!!
A few notes…
Representative Boschee said that IF the North Dakota Wild Horse Preservation Act is NOT allowed into this special session, our followers should NOT be discouraged or take it personally.
The ND Legislators prefer to come into this session and just take care of what they have been mandated to come back and take care of. They do not want extra legislation introduced.
HOWEVER, since Governor Burgum has a couple of pieces of legislation he wants introduced, that is opening the door to the option for other legislation to also be introduced.
The question of what is critical and has to be heard RIGHT NOW as opposed to what can wait until the next regular session when the legislators reconvene in 2025 will be discussed IF they allow other legislation.
Our North Dakota State Legislators are aware of how important the wild horses in Theodore Roosevelt National Park are to the public and the passion that drives our advocacy. I have been told by several legislators that it is understandable that this legislation would be critical to hear right now. As we have noted, in 2025 there might not be any wild horses in TRNP for them to take action for, if they do not take action now. I personally spoke with several ND Legislators today who said they would support the North Dakota Wild Horse Preservation Act!!
Representative Boschee promised to keep me posted on how the day develops tomorrow. We will share any information as we get it with all of you.
There are A LOT of other things that happened today. We will talk about most of that tomorrow. It has been a REALLY long day for me. We continue to do what we can with what we have from where we are – without a doubt! We promise, we are NOT leaving ANY stone unturned in our fight to save these horses!
In case you missed it, our extension request WAS granted today! The NEW deadline to submit your comments is November 24, 2023. We will talk more about this in the coming days too.
Don’t forget – Heather from Save Our Wild Horses will be hosting us in a Zoom tomorrow. The event is FREE but you do have to send Heather an e-mail to register: kaya97524@yahoo.com
To be honest, yesterday was a tough day for me and it didn’t look like we would be able to get any legislation submitted for us. I was upset and discouraged. I cried for a moment and took a nap! This morning I woke up and decided it was a new day and knew that there were mountains to be moved. THANK YOU to all of you who literally helped us move mountains today! I cannot fully express how critical all of your actions today were and how much I appreciate each and every one of you!
Thank you again for your support and have a great night!
We have an URGENT call to action for everyone – this has to be done TODAY (10/19/2023) We have been working hard on this all week and now we need your help to make this happen!
Our North Dakota State Legislators are being called back into a special session next week. We have drafted legislation that we NEED them to vote on next week when they are back in session. They will be deciding TODAY what goes into the special session!
THIS IS CRITICAL BECAUSE THEY WILL NOT BE BACK IN SESSION UNTIL 2025!!!
Whereas “The National Park Service preserves unimpaired the natural and cultural resources and values of the National Park System for the enjoyment, education, and inspiration of this and future generations. The National Park Service cooperates with partners to extend the benefits of natural and cultural resource conservation and outdoor recreation throughout this country and the world.” The wild horses have been a cultural resource since 1947 and before and wild horses are a natural resource.
Whereas the Theodore Roosevelt National Park horses have been a public trust for generations and not been raised on a farm or ranch, have not been raised as a food animal, are not and have never been owned or held in private ownership. The wild horses in Theodore Roosevelt National Park therefore are not livestock pursuant to 29 CFR 780.328 and NDAC Section 48.1-09-01-01-definitions. Therefore, they are wild horses and since these horses are not covered under the 1971 Wild Horse and Burro Act, or any other federal act, they are eligible and should be protected as wild horses by the state of North Dakota as a public trust. (NMAG 94-06 https://nmonesource.com/nmos/ag/en/item/15067/index.do & AZ 2016 HB2340 AND AZ 2016 HB2340 https://legiscan.com/AZ/text/HB2340/id/1385534)
Whereas Theodore Roosevelt National Park is the #1 tourist destination in North Dakota and the wild horses are a driving force that brings visitors to our state. The Park recently released their Visitor Use and Associated Thresholds at Theodore Roosevelt National Park Research Report that was performed from 2016-2018. The report states that 89% of visitors surveyed support the ongoing presence of a wild horse herd in Theodore Roosevelt National Park. Only 4% of visitors surveyed opposed the ongoing presence of wild horses in the Park.
Whereas Theodore Roosevelt National Park is the only national park named for an individual. The Park’s 2014 Foundation Document states that the Park’s Purpose is “Theodore Roosevelt National Park memorializes Theodore Roosevelt and pays tribute to his enduring contribution to the conservation of our nation’s resources by preserving and protecting the scenery, wildlife, and wilderness qualities of the North Dakota Badlands—the landscape that inspired Roosevelt and still inspires visitors today.” We know from Theodore Roosevelt’s writings that wild horses existed in this area when he was in North Dakota: “In a great many–indeed, in most–localities there are wild horses to be found, which, although invariably of domestic descent, being either themselves runaways from some ranch or Indian outfit, or else claiming such for their sires and dams, yet are quite as wild as the antelope on whose domain they have intruded.”
Whereas on January 30, 2023, North Dakota Governor Doug Burgum held a press conference and sent a formal comment letter to Theodore Roosevelt National Park requesting that the Park allow the horses to stay. Further, Governor Burgum offered that “the State of North Dakota stands ready to collaborate with the National Park Service, whether with resources or management expertise, to ensure that the herd of wild horses can be maintained in a manner and size that supports genetic diversity and protects the park for visitors today and for generations to come.“
Whereas during Theodore Roosevelt National Park’s public comment period that ended January 31, 2023, the Park received 19,012 comments. Of the comments received only 45 of those comments supported the Park’s plans to eliminate the horses.
Whereas on February 3, 2023, the United Tribes of North Dakota sent a letter to Theodore Roosevelt National Park urging them to continue the preservation of the wild horses within the Park’s boundaries.
Whereas on April 13, 2023, the MHA Nation sent a resolution to Theodore Roosevelt National Park stating that the MHA Nation holds horses in high esteem as horses are significant to the MHA people and have played a major role in MHA history, tradition and culture; and The MHA Nation recognizes the wild horses running free in the park require genetic diversity and responsible herd management policies and techniques to maintain for the health of the herd. The Tribal Business Council voted unanimously to support the continued free running of the horse herd in Theodore Roosevelt National Park pursuant to a management policy that includes proper genetic diversity and efficient herd management policies and techniques.
Whereas on April 17, 2023 North Dakota Senate Concurrent Resolution SCR 4014 was filed with the North Dakota Secretary of State after the resolution which asked Theodore Roosevelt National Park to allow the wild horses to stay within the Park passed both the North Dakota House and Senate unanimously.
Whereas on July 11, 2023, the City of Medora requested in their own resolution to Theodore Roosevelt National Park that the Park keep the horses. Their resolution stated that the horses of Theodore Roosevelt National Park bring tourism to the state and the City of Historic Medora and elimination of the herd poses economic concerns for the business community and negatively impacts preservation and appreciation of our state and communities’ history.
This North Dakota Wild Horse Preservation Act is a temporary action to provide protection of the wild horses in Theodore Roosevelt National Park by the State of North Dakota. This temporary action will expire in April of 2025. The North Dakota State Legislature will review this action during the 2025 session and after The North Dakota Wild Horse Preservation Act has been properly vetted through committee procedures and legislative protocols, the North Dakota State Legislators will decide if continuation of this action is necessary.
Please send this email to our North Dakota State Legislators:
Thank you for helping us to get this in front of our North Dakota State Legislators! We will keep you updated on if this is accepted into this special session as soon as we hear!
Theodore Roosevelt National Park extends comment period on the Livestock Plan Environmental Assessment
MEDORA, N.D. – The National Park Service is extending the comment period on the Environmental Assessment on the Theodore Roosevelt National Park Livestock Plan through November 24, 2023.
Please submit comments online through the Planning, Environment, and Public Comment (PEPC) website at https://parkplanning.nps.gov/LP. The comment period will be open for an additional 30-days and all comments must be submitted by November 24, 2023. Comments may also be mailed to the following address and be post-marked by November 24, 2023.
Just 7 days left to get your comments into Theodore Roosevelt National Park. Superintendent Richman STILL has not responded to our extension request. So much for all of the caring about the public and the agency transparency she promised at the civic engagement meeting. We will update you when and if she answers our request.
Chasing Horses Wild Horse Advocates does have talking points as well as documents that you can use to state your case on our website: https://chwha.org/save-the-trnp-wild-horses/ We have a few more documents we will be uploading soon.
Please don’t forget to share our NEW videos! They do a great job highlighting the wild horses of Theodore Roosevelt National Park and sharing their plight. We added a full screen version today: https://youtu.be/WxPRhMGBRLc and there is also the version that is best viewed on your phone or mobile device: https://youtube.com/shorts/FZ4jsb–Ilo. Thank you to our friend Dickon at National Geographic for helping us with these! Watch for more videos to be released soon!
We are pushing hard from a new angle to try to save these horses. We will discuss this more in the coming days, but know that meetings and seemingly endless phone calls have been demanding our time.
We DO have a NEW zoom meeting coming this FRIDAY (10/20) with our friend Heather from Save Our Wild Horses. The event is FREE but Heather does ask that you email her to get the zoom link: kaya97524@yahoo.com
We also have the zoom meeting we did with our lawyer Matt from Eubanks and Associates on our YouTube channel. You can view it here: https://youtu.be/QERohSyjpnY
Both zoom meetings had a variety of great questions that were asked!
You can also always send us an email at info@chwha.org or private message us through any of our social media channels with your questions.
Please make sure you sign our petition asking the North Dakota State Historic Preservation Office to declare the wild horses of Theodore Roosevelt National Park historically and culturally significant. You can sign the petition here: https://secure.everyaction.com/Af1717oXqU2wTrcB0Yz6jw2 – THANK YOU to the over 1500 people who have signed this petition so far!
I am constantly amazed at the people we have met over these last 10 months (or so) since Theodore Roosevelt National Park announced their plans to eliminate the ENTIRE herd of horses from the boundaries of the Park. Not only have we been honored to meet these people, we have been humbled by their willingness to do whatever they can to help us as they advocate with us for these amazing wild horses.
We talked about some friends earlier and we are happy to share with you some help coming from some friends we have made that work at National Geographic!
They have taken some of our videos and photos and put them into the first in a series of videos they will be putting together for us to help raise awareness about the current plight of the wild horses in Theodore Roosevelt National Park. We are hoping you will help us share these videos as we release them to help raise awareness for our beloved herd of horses in TRNP! Chasing Horses Wild Horse Advocates will also be using these videos to create ads on social media to help raise awareness and encourage people to comment.
We are currently 8 days away from the end of the comment period for the wild horses in Theodore Roosevelt National Park. Superintendent Richman will be back in the office tomorrow (10/18) so hopefully she will make an announcement on IF the Park will be granting our extension request.
Meanwhile…
We wanted to take a moment to say thank you to friends who have been instrumental in helping us in a variety of ways over these last few weeks:
THANK YOU to our followers who emailed us yesterday and helped us understand the Section 106 Review process! Your insights on this aspect of our advocacy helped more than you know!
THANK YOU also to the 315 of you who have already signed our petition that we will be sending to the North Dakota State Historic Preservation Office. Public comments ARE considered during their process. THIS is how we get the wild horses of Theodore Roosevelt National Park classified as “historical” and/or “culturally significant” WITHOUT interference from the Park! THANK YOU also to all of those groups/organizations and pages who understand how important this is to the fate of the wild horses of Theodore Roosevelt National Park and have shared our message!
We also want to say THANK YOU to our friends at Oregon Wild Horse Organization (OWHO)! They have been working diligently on their comment letter to Theodore Roosevelt National Park and found that there are STILL7 documents that Theodore Roosevelt National Park cited in their Draft EA that they have NOT released to the public! That’s right – 8 days before the comment period is scheduled to end, we STILL have 7 documents that we cannot properly view. OWHO sent this email to Superintendent Richman yesterday:
Hello Angie Richman,
I am preparing a public comment on the TRNP Livestock Plan EA. There are some references cited that I cannot access. Some are in the links you provide but only give us an abstract which I am sure you understand do not provide the specific details of the studies or projects that allow us to understand how the author/researcher got to the conclusions, or made statements utilized in the EA to support the narrative you have expressed.
We would like the documents we list at the bottom of this email. And due to the extensive pagination to be read and evaluated we would like a time extension of at least 30 days to provide a full substantive public comment.
Thank you and I look forward to your timely response to this request.
TJ Barbour
Berger, J. 1985, Interspecific Interactions and Dominance among Wild Great Basin Ungulates, Journal of Mammalogy, Volume 66, Issue 3, 9 August 1985, Pages 571–573. Internet website: https://doi.org/10.2307/1380939.
Irby, L. R., J. E. Norland, J. A. Westfall Jr., and M. A. Sullivan. 2002. “Evaluation of a forage allocation model for Theodore Roosevelt National Park.” Journal of Environmental Management 64(2):153–169.
Jabro, J. D, W. M. Iversen, R. G. Evans, B. L. Allen, and W. B. Stevens. 2014. Repeated Freeze-Thaw Cycle Effects on Soil Compaction in a Clay Loam in Northeastern Montana. Soil Science Society of America Journal, Volume 78, Issue 3, pages 737-744, June 10, 2014.
Lesica, P. 2020. “Feral horses are associated with a decline in a rare semi-arid grassland plant.” Journal of Arid Environments 179. 104180. 10.1016/j.jaridenv.2020.104180.
Lopinot, N. and J. Ray. 2007. Trampling Experiments in the Search for the Earliest Americans. American Antiquity, 72(4), 771-782. doi:10.2307/25470445.
2022h. Communication between Angie Richman, Blake McCann, Maureen McGee-Ballinger, and Bret Morton, Theodore Roosevelt National Park with Holly Prohaska Amy Cordle and Andy Spellmeyer, EMPSi. October 11–13, 2022. Medora, North Dakota
Stoneburner, A., and J. Spaak. 2023. Rangeland Health Assessment of Theodore Roosevelt National Park. Nature Resource Report NPS/THRO/NRR – 2023/XXXX. National Park Service. Fort Collins, CO (In press, not yet final).
Todhunter, P. E. and R. DeVries. 2021. “Climate Change Assessment using Spatial Climate Datasets: Theodore Roosevelt National Park (South Unit), 1895–2019.” Climate Research 85: 91–106. Internet website: https://doi.org/10.3354/cr01672
USFWS (US Fish and Wildlife Service). 2023. IPaC – Information for Planning and Consultation. Database access. Internet website: https://ipac.ecosphere.fws.gov/location/index. IPaC from August 1st, 2023.
Must have a gov login to access.
Our friends at OWHO also shared some GREAT points with us that can be included in your own comment letter. We will share that in a NEW blog post tomorrow.
Yesterday, I had the pleasure of talking to Carol Walker! Chasing Horses Wild Horse Advocates and our discussion on the wild horses of Theodore Roosevelt National Park will be featured in her Wild Hoofbeats podcast next week! We will share the direct link when she sends it to us! Thank you again Carol! I appreciate you taking the time to chat with us and help us raise awareness about the current plight of these amazing wild horses!!
This Friday – October 20th, our friend Heather from Save Our Wild Horses, will be hosting us for a zoom! We will have a short presentation and be available to answer your questions. This event is FREE, but you do need to email Heather to get the link for the talk. You can email Heather at: kaya97524@yahoo.com
We have another podcast coming up soon too that we will share!
Chasing Horses Wild Horse Advocates has been invited to participate in a couple of community Trunk or Treat events! This will be a GREAT way to get the message out to thousands of people! We are grateful to our local community businesses in Dickinson that have donated candy to us for this event: Cashwise, Runnings & Walmart! We also ordered ANOTHER batch of stickers to hand out. Wait until you see our spooky plans for these events!
Please email us at info@chwha.org if you would like us to send you any promotional materials!
We are truly grateful for these opportunities that will help us reach a larger group of people who will hopefully join us in the Fight for the Spirit of the Badlands!
THANK YOU to all of you who help us in so many ways! There is A LOT of ground to cover, and we can’t do it all. We truly appreciate all of the help and support we get from each one of you!
Just wait until you see what some of our other friends are working on for us 😉
We will collect names through 11/3/2023 and then send the entire petition along with a letter from our organization citing pertinent documents to the North Dakota State Historic Preservation officer. You are STILL also welcome to send a snail mail letter into the office. And yes! You CAN do both!
IF you also want to send a snail mail letter, your letter can be customized in whatever way you choose, but please, use these lines specifically:
I am writing to request that the wild horses in Theodore Roosevelt National Park be considered a significant historical and cultural resource to the state of North Dakota.
Your letter should be sent to:
North Dakota State Historic Preservation Office 612 E. Boulevard Ave. Bismarck, ND 58505 Attn: Bill Peterson
In case you missed our earlier blog post, here is some information for you:
As part of FEDERAL LAW – there is a 1966 federal Historic Preservation Act law as amended requires all public agencies to cooperate with State Historic Preservation Offices in protecting historic resources by making a determination of historic significance and any potential negative effects of proposed actions.
It starts with the State Historic Preservation Officer (Bill Peterson) making a determination if the property (in this case, the National Park) is historically significant according to NPS National Register guidelines.
A lot of State Historic Preservation Office staff time is necessary to make a meaningful review, so the determination letter is usually quite short and not supported with much narrative. Something like, “of course it’s historically significant under NRHP criterion “A” for the Park’s “embodiment of broad patterns of historical events associated with the design and construction by NPS and other federal agencies (CCC, WPA) cooperating with the North Dakota State Historical Society, to establish a memorial park in the North Dakota Badlands commemorating the influence of that landscape on President Theodore Roosevelt.”
At a minimum, IF the State Historical Preservation Office finds the wild horses of Theodore Roosevelt National Park to be historically and culturally significant within the state of North Dakota, it will help strengthen our argument for a detailed Environmental Impact Statement to be performed INSTEAD OF a FONSI (Finding Of No Significant Impact) – which is what the Park wants to do!
The State Historical Preservation Office tries to formulate an informed judgment based on evidence. They DO understand how this process works, though, so important to let them know that the public is concerned.
We are asking again, PLEASE sign our petition and/or send a snail mail letter to the State Historic Preservation Office. I know – snail mail letters are a pain! But what will be a bigger pain is if the wild horses of Theodore Roosevelt National Park are removed from the boundaries of the only home they have ever known. THAT is the reality of where we are folks. Please take 5 minutes to sign our petition and send your letter! You DO NOT have to live in the state of North Dakota to have your voice heard.
Thank you for your support and PLEASE share this information far and wide. THIS is a REAL way you can help make a difference in the outcome for the wild horses that call Theodore Roosevelt National Park home.
We KNOW from NPS 2022h that the Park is concerned about Section 106 and no doubt meeting with the North Dakota State Historic Preservation Office too. Please make sure this office hears from you as well!
Thank you for your continued support and for fighting so hard with us to save this herd!
We are NINE days out from the current end of this public comment period. As I mentioned yesterday, I did email Theodore Roosevelt National Park to inquire about our extension request. I got an automatic reply from Superintendent Richman saying that she was out of the office until 10/18/2023. So, I emailed her boss, Regional Director Bert Frost to ask him. His response today was:
Ms Kman
We received your request and I believe Superintendent acknowledged that we did. As she stated, we are taking it under consideration and we will let you know either way, once a decision has been made.
Bert
So maybe when Superintendent Richman gets back on the 18th we will have an answer. Our request was sent on October 6th and we requested a response last week. Our lawyers said that requests are usually granted at the last minute. Apparently, this is a tactic used often within the Department of the Interior for apparent reasons.
The REAL purpose of this post today is to remind you that we have a ve
