January 2023 Comment Letters

Here are some of the comment letters that have been shared with us by individuals and organizations during the public comment period for the Theodore Roosevelt National Park wild horses that ended 1/31/2023. Please send us yours! Email it to us at info@chwha.org

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I moved here from Cleveland Ohio, lived in Dickinson for 11 yrs. and fell in love with Medora. My husband and I loved going on daytrips to drive through Theodore Roosevelt National Park, and would go as often as we could. One of the main attractions of the park are the horses. To be able to see them running wild and free is just something extraordinary that you don’t always get to experience. I fell in love with them immediately and started following the family bands online. To have that history and knowledge is awesome. My husband and I even love Medora so much we got married there. All of my family traveled mainly from Ohio to attend. It was the first time they’d ever seen anything like it before, and guess what their favorite part was… the wild horses. They still talk about it and say they’d love to come visit the park again. Since moving to Bismarck we haven’t been able to make it to the park as much. I know that if the horses are taken from the park, it won’t be as much of a priority to make the trip. I would be extremely saddened, almost devastated if the horses are removed. I also know that I am not the only one. Everyone I know says the highlight of going to the park is the horses, not the scenery, buffalo, prairie dogs etc… the HORSES. There is no way the park would survive without them. Park attendance WILL decrease, then what is the fate of the town of Medora? Without tourists the town will not survive. I do not want to see that happen so please keep the horses in the park, how its been for yrs and yrs so people (like me) can enjoy them. Thanks, Jessica L

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I would also like the wild horses to stay at TRNP the bison and elk are no big deal seeing how you can see them for FREE at White Horse Hill south of Devils Lake,ND now the horses on the other hand is a different story we make several trips to TRNP a year just for the horses last year we seen something that was the best experience we could have ever had there. There were at least 30 horses all running in fact ran across the road in front of us what a beautiful site to see my wife was so excited . So let me put it this way if the horses are removed from TRNP WE WILL NOT GO BACK TO TRNP plain and simple and there are alot of people that think the same way!!!!!!

Thank you

Lonnie S

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ONCERNING THE WILD HORSES OF TEDDY ROOSEVELT NATIONAL PARK:

#1  TRNP needs a PERMANENT Wild Horse Management Plan (also known as a Feral Horse Management Plan from the Park’s own 2014 Foundation Document).

#2  Officially classify these horses as wild horses and/or feral horses as stated in the TRNP 1984 General Management Plan.  These horse have historical and cultural significance and should absolutely not be called livestock.

#3  The genetic viability of this herd definitely needs to be taken into consideration with 150-200 adult horses needed.  Even the Bureau of Land Management supports these numbers in their Wild Horse and Burro handbook.

#4   Implement a successful birth control program but make sure that science and genetics are guiding the use of birth control on ANY horse in this herd.  (Successful birth control has been done on the Pryor Mountain Wild Horses, the McCullough Peaks Wild Horses, and the Assateague Island Wild Horses.)


#5   Removal of any herd member should be based on science, genetics, and family structures of the herd.  No horse should be removed if it will impact the genetic health of the entire herd.  A herd should at least have a balance of age groups.  (Always just removing the young horses leaves an older herd slowly dying off.)

A well-designed and implemented management plan will go a long way to ensuring the TRNP HERD STAYS IN THE PARK for decades to come.

Lynn B
Ray, ND  

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Hello. I would like to comment on behalf of the TRNP herd of wild horses. These horses should not be considered "livestock". They are a vital part of the park that must be preserved. There needs to be a wild horse management plan developed for them similar to what manages other wild horse herds. Proper birth control within the herd should be managed so that there is proper genetic diversity. Number of horses should be managed so that there is decreased inbreeding. There have been many studies and documentation done on these topics, as you are aware. The wild horse herd in TRNP attracts a HUGE amount of visitors to the local communities. If the horses are removed, the majority of businesses and the local economy will suffer. This includes income for TRNP itself! I currently live in Pennsylvania. I first visited the wild horses in the summer of 2019. That’s when I fell in love… with the horses… with the land… with Medora… with North Dakota! I am finally able to visit again this summer and I am bringing my husband and two small children. I am eager to share the wild horses and TRNP with them! I was devastated to hear of your plans to remove the horses from the park. I can’t bear the thought of my family not being able to experience what I did when I visited in 2019. PLEASE do not remove the horses from the park. There is ALWAYS another way… a BETTER way! Thank you for your time. Kristi Hoffman

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To the Theodore Roosevelt National Park Superintendent & all whom it concerns,wild horses and burros are protected as a special status species under law.   In response to your information expressed during your TRNP Livestock Plan, I would like to make comment and have included current scientific data to review to reevaluate TRNP decision to NOT remove the horses from TRNP. Facts: T. Roosevelt saw in his first historic visit in 1883, when the frontier was fast disappearing, native horses thriving on the land. Understanding the script presented of the “mission “ of the park is to follow guidelines assumed to be Teddy’s vision when establishing the park for Native Wildlife Conservation System, in which your assumptions excluded the horse.  Although, I suspect, since the horses were present prior to 1947 when the park system was first established would logically include the horse.  Please refer to the documents to confirm the horse is Native and part of the wildlife Roosevelt saw.   I find government Agencies disregard for relevant scientific information disturbing.  An important quote from Dr. Ross MacPhee, “…Native Horses played a central role in America’s history and culture, and helped shape the Great Plains and the lifestyle of the Native Americans.”  Even though TRNP is not required by “law” to protect the wild horses, I hope having read the current scientific evidence included, makes it an obvious decision to REEVALUATE  and realize the horses as part of North America’s native wildlife that is protected under the laws of the National Park. The TRNP can be the champion in upholding the wild horse’s rightful existence in North America by honoring the freedom of and helping maintain the herd that presently resides within the park’s borders, while other Federal Agencies continue to round them up to extinction. Thank you for your time and willingness to look at the information provided that documents the rights of the wild horses to remain wild & free.Please reference the two attached articles which provide scientific evidence that horses are native to North America. Article One, Equine Nativeness, was written by Dr. Ross MacPhee, a mammalogist, paleontologist, anthropologist, and a Senior Curator in residence at The American Museum of Natural History. Article Two, Horses in the Americas before Columbus? Exploring some hard evidence, provides additional evidence using carbon data, DNA, and Native American stories and cave art.  There are additional resources including documentaries from Native Americans speaking on behalf of the “Horse Nation”, as well as various presentations containing additional data that supports the horses staying wild under current law. Please allow the Horses in TRNP to remain protected thus representative of the historical value of the Frontier that Teddy was so moved by in protecting the land and all that roamed within.Thank you.Wild Blessings. ARTICLE ONEHighlander Wildlife By Dr. Ross MacPhee October 2022Equine Nativeness It is often asserted that wild horses are an invasive species in this country and should be treated as such, that is, eliminated. This assessment of the biological status of horses, which is identical to and as outmoded as that of the Bureau of Land Management, is simply incorrect, as it is based on a disturbingly shallow appreciation of the relevant scientific facts. Let’s start with the concept of “invasive species.” Calling a species “invasive” implies a lot of things, mostly bad. It means that the species in question evolved somewhere else, has no natural role to play in its newly adopted ecosystem, and is or can be a danger to native species by outcompeting them or causing other problems. A native species is by contrast a belonger, a citizen, a legitimate member of a larger fauna with a right to be here by virtue of origin, and therefore with a right to some level of protection or at least recognition. There is no single definition of nativeness, but there is general agreement among biologists that, at a minimum, place and status should go together. That means that lineages that evolved in a particular place, or have occupied it for a very long time are native to it. A couple of examples of familiar species that I believe nearly everyone would regard as part of the native North American fauna. The ancestry of our buffalo, Bison bison, is Asian. Some 180,000 years ago, ancestral bison populations began to cross the Bering landbridge, which joined Alaska to Siberia during the ice ages. No one, I think, would regard the fact that our buffalo’s predecessors evolved elsewhere should disqualify it from being counted as native. In fact, it’s quite the opposite: the buffalo is now the national mammal of the USA, a status it acquired by an act of Congress in 2016. Or consider the history of the moose, that iconic ungulate of northern North America. According to the fossil record, it was a very late immigrant from Asia, having arrived in North America only after the end of the last ice age. Should this make a difference to its status as a native North American mammal? No, but think about why the moose gets a pass and the horse doesn’t. Equus caballus is the only valid horse species living on the planet today. It is the surviving member the caballines, a specific lineage of horses that arose about 5 million years ago-in North America. That same landbridge that let the bison in also let the caballines out, enabling them to spread through- out Europe, North Africa, and the steppes of Asia where they were eventually domesticated about 6000 years ago. Ancient DNA evidence shows that some horse populations re-crossed the landbridge, coming back to North America and interbreeding with the stay-at-homes. Crossings and re-crossings were possible until the final disruption of the landbridge between 15,000 and 10,000 years ago. So what finally happened to the horses living in North America, and should that affect their status? Along with many other large mammals that used to live here, horse populations collapsed around 11,000- 12,000 years ago. These losses are known as the “Pleistocene megafaunal extinctions,” in reference to the size of some but not all of the roughly 50 mammal species that disappeared around that time. Along with the horses went the mammoths, mastodons, giant ground sloths, sabertooth cats and many others; no other event in recent geological history has been as important in shaping our current fauna. True, there are a lot of years between now and 6 millennia ago. Our research is still in its early stages, and we are looking for localities that might fill the gap and tell us how long horses persisted in North America, Indigenous peoples already have an answer: horses never disappeared. Several groups are investigating this possibility, with Native American help, and we may shortly have an answer. But would an even more recent date for horse persistence make any difference to the debate about the presence of wild horses in the West, which is largely about control of the land? From my standpoint, the thing that is so hard to understand is why there is a controversy about wild horses in the first place. Horses made this But in the last few years our understanding of nation. Apart from steam, there was no other this extinction event has been turned upside energy source that could be used to do all the down, thanks again to ancient DNA. It used to be things that horses did for us until the internal thought that overhunting by humans was combustion engine replaced them in the early responsible, directly or indirectly, for most of 20th century. these losses. The emerging consensus nowadays is that the losses were largely driven by dramatic climate change after the end of the last ice age. It also used to be thought that all of the large mammals I just mentioned had died out within a very short interval, perhaps in the course of only a few hundred years. But thanks to research conducted by my group, there is good molecular evidence that horses survived at least in northern North America for thousands of years after the time of the big losses at least up to about 5700 years ago. Some erroneously state that horses were gone by the time that humans arrived in North America. When precisely humans arrived in the new World is a contentious issue in archeology, but a minimum date would be on the order to 20-30,000 years ago, according to well authenticated dating records from Yukon, New Mexico, and southern Chile. If horses survived until 5,700 years ago, there was enormous overlap with people. It means that endemic horses inhabited this continent during the current era, inhabiting the same ecosystems that we have (in various states of degradation) today. Now they lack an important economic role and are seen, at least by some, as an impediment to progress, to be cast aside as no longer useful. The National Bison Legacy Act, which symbolically raised the bison to the level of the bald eagle, reads that it “played a central role in America’s history and culture and helped shape the Great Plains and the lifestyle of Native Americans.” What is true of the bison is equally true of horses. Both are ice age survivors, both are native, and both deserve our respect and protection. ARTICLE TWOMustang MegMarch 3, 2021NOTE: Horses in the Americas Before Columbus? – Exploring some hard evidence As many of us may be aware, currently the common belief is that the horse became “extinct” in N. America during the Ice Age while others crossed the Bering ice bridge to Europe and Asia… However, there’s more to equine history- through archeological evidence, there are those who claim that horses actually remained, as depicted on cave dwelling walls as petroglyphs and pictographs that had nothing to do with the Spanish explorers, as these archeological areas pre-date their arrival to the North American continent.In addition, when we look at paleontological records and examine how extensive the polar ice cap was south, we find that there were areas in the southern portion of North America less effected by the ice shelf, as shown in this illustration: https://www.facebook.com/photo.php?fbid=312045106948201&set=p.312045106948201&type=3I find Native American history fascinating… especially when horses are part of that history. There are ancient cave and rock images (pictograph and petroglyph) of both riderless horses, and horses with riders on cave/rock art some of which are dated to the late Pueblo II through the ‘Pueblo III periods, AD 1050-1300 (Hayes 1964:88), as well as the Utes which span 1,000 years, from the Christian era. Further, this article by Steven Jones explores more about horses on this continent prior to overseas explorers (mm) : Were there Horses in the Americas before Columbus? by Steven E. Jones  S&J Scientific Co., Provo, UT, 84606, USA This letter is in response to a request from Wayne May for information regarding my research on early horses (Equus) in the Americas, before the arrival of Columbus. This interim material is shared in order to encourage a wider community to join in the task of gathering further evidence regarding pre- Columbian horses in the Americas, including a request for photos of pictographs, petroglyphs and engravings which may represent pre-Columbian horses. About twelve years ago, I began a project to seek horse bones from sites in North America and Mesoamerica for the purpose of radiocarbon dating. In this research, I was joined by Prof.Wade Miller of the BYU Department of Geology, archaeologists Joaquin Arroyo-Cabrales and Shelby Saberon, and Patricia M. Fazio of the Buffalo Bill Historical Center. My special thanks to FARMS and ISPART who funded much of the project in years past. We secured horse bones for dating, some directly from the field. Then state-of-the-art radiocarbon dating was performed at Stafford Laboratories in Colorado, the University of California at Riverside, or Beta Analytic in Miami, Florida, employing Accelerator Mass Spectrometer (AMS) dating methods. The reliability of the AMS method of radiocarbon dating of bones is delineated in: Radiocarbon, Volume 34, Number 3, pp. 279-291. The goal was to provide radiocarbon dates for samples that appeared from depth or other considerations to be pre-Columbian. The time frame of interest can be expressed in terms of“ Before Present” by convention and extends from 10,000 BP (thus after the last ice age) to 500 BP (when Spaniards soon after Columbus brought horses to America). The prevailing paradigm holds that there were no horses in the Americas during this time interval; the Book of Mormon and a number of native American oral traditions hold otherwise. The samples in this study can be divided into two categories according to their origins: Mexico, and the United States. Forty-five Equus samples were obtained in Mexico. Based on AMS dating, there was one sample from the Ice Age period, and six from the post-Columbus period. Other samples had insufficient collagen in the bone to permit dating – collagen protein locks in carbon-14,permitting accurate C-14 dating. Thus, the laboratories require a certain minimum amount of collagen in order to proceed with the dating. There were no Equus samples found in this study in Mesoamerica for the time interval 14,700 BC to 1650 AD. By contrast, in North America, there are found Equus samples which do indeed appear in the time frame between the last ice age and the arrival of Columbus. The first of these was found in Pratt Cave near El Paso, Texas, by Prof. Ernest Lundelius of Texas A&M University. Prof. Lundelius responded to my inquiries and provided a horse bone from Pratt Cave which dated to BC 6020 – 5890. This date is well since the last ice age, into the time frame when all American horses should have been absent according to the prevailing paradigm. Another Equus specimen was identified by Elaine Anderson, an expert on Equus identification, at Wolf Spider cave, Colorado. It dated to AD 1260 – 1400, again clearly before Columbus. Note that horses arrived on the new-world mainland with Cortes in 1519 AD[Henry, Marguerite and Wesley Dennis. All About Horses. Random House, 1962.] Dr. Patricia Fazio of the Buffalo Bill Historical Center in Cody, Wyoming, has joined our network of researchers in this field. Dr. Fazio (private communication) alerted us to a horse bone found at Horsethief Cave in Wyoming which dates to approximately 3,124 BP, i.e., 1100 BC, using thermo luminescent methods. We attempted to have this bone re-dated using the AMS methods which are more accurate, but there proved to be insufficient collagen in the bone to permit AMS dating. The 1100 BC date (although approximate) still stands. Dr. Fazio also pointed to a publication, The Wyoming Archaeologist 38: 55-68, where results of a horse bone found in Wyoming were dated to 1426 – 1481 AD (one sigma calibrated dates) using AMS methods, well before Columbus. The authors express difficulty in explaining this early date: “These radiocarbon dates place the horse skeleton at a very early age for modern horses to have been in Wyoming.” A paper by Dr. R. Alison notes evidence for horses in Canada dating 900 and 2900 years ago; also in the period of interest: However, the compete extirpation of ancestral horse stock in Canada has yet to be completely confirmed and a bone found near Sutherland, Saskatchewan, at the Riddell archaeological site suggests some horses might have survived much later. The bone (Canadian Museum of Nature I-8581), has been tentatively dated at about 2900 years ago. Another Equus sp. Bone, found at Hemlock Park Farm, Frontenac County, Ontario, dates to about 900 years ago. Exhaustive confirmation of both bones has yet to be completed, but if they prove to be authentic, they comprise evidence that horses survived in Canada into comparatively modern times.  http://members.shaw.ca/…/Research%20Paper%20-%20R.%20Alison…Thus, there are a half dozen dated Equus samples that date in the time frame 6,000 BC to 1481 AD, well since the last ice age and all before Columbus. Note that all of these radiometrically-dated Equus remains were found in North America. In addition to this hard physical evidence, a number of researchers are looking seriously into oral histories of native Americans which point rather clearly to the existence of horses before the Spanish arrived. In particular, we note that research results have been published by Yuri Kuckinsky. For example, the Appaloosa horse appears to have been in North America before the Spanish brought European horses. In particular, the Equus samples that have been identified in North America, anomalous because they date to the “excluded” period between 6,000 BC and 1490 AD, can now be analyzed to determine whether or not the DNA corresponds to domesticated Spanish horses brought over by the Conquistadores. My prediction is that the DNA will not so correspond. In conclusion, using state-of-the-art dating methods, we along with other researchers have found radiometrically-dated evidence for the existence of horses in North America long after the last ice age and before the arrival of Columbus. These data challenge the existing paradigm. Further DNA analyses will provide additional insights. Background of Professor Steven E. Jones: Prof. Steven Jones was a full Professor of Physics at Brigham Young University where he served for over 21 years before his early retirement in 2007. He conducted doctoral research at the Stanford Linear Accelerator Center and received his Ph.D. in Physics from Vanderbilt University in 1978. He received his B.S. degree in Physics from Brigham Young University in 1973, where he held a David O. McKay Presidential Scholarship. His research interests include studies in archaeometry, fusion and solar energy. He has published papers in Nature, Scientific American and Physical Review Letters. He taught an advanced class on Archaeometry (Physics 513R) and published, “Archaeometry Applied to Olmec Iron-ore Beads,” BYU Studies 37, no. 4 (Oct. 1998), pp.128-142. The horse-bone dating project fits very well into Dr. Jones’ long-range plans for research in archaeometry. SOURCE:  For the complete report:  https://www.researchgate.net/…/303446285_Were_there_Horses_…ADDITIONAL READING:  A North American Native (ancient horse native to N America): https://www.facebook.com/…/a.10158717834…/10158836829813956/ Peggy

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What really puzzles me is the ignoring or glossing over of stated NPS policy and TRNP policy. The almost complete dismissal of historical significance and recognition of their tie to TR legacy. Most troubling is the classification of them as livestock. Which unfortunately I think is calculated to aid in desire to eliminate. Think Apr 2022 was important to those actions. Below is my 3rd comment.

I understand need to control population of the wild horses of TRNP, what I don’t understand the classification of them as livestock and preferred plan for slow removal or alternative of expedited removal based on being “livestock”. As recent as Sept 2022 in NPS stated correct classification is feral horses.

In that Sept 2022 NPS on TRNP “Horse Background and History” states: “Their presence represents Theodore Roosevelt’s experiences here during the open-range ranching era. By the late 1800s European settlement of the plains had reached the Dakotas.”. Goes on to say “In 1970, a change of park policy recognized the horse as part of the historical setting. New policies were written and enacted to manage the horses as a historic demonstration herd”. When did that policy change? Why now? According to 36 CFR 2.6, (cited in Jan 12th meeting) current policy (a) states: “The running-at-large, herding, driving across, allowing on, pasturing or grazing of livestock of any kind in a park area or the use of a park area for agricultural purposes is prohibited, except: … (3) As designated, when conducted as a necessary and integral part of a recreational activity or required in order to maintain a historic scene.”. The wild horses of TRNP do that and have since the parks inception when fenced in over 75 years ago. That I have enjoyed since a child as my grandaughter does now and I continue to.

As I stated I understand need to control population and need for updated policy. However think need to consider they are feral horses not livestock by definition and the asset they are to TRNP. The horses of TRNP are living historic and cultual representatiin of ND, history and TR legacy. Who embody the spirit of settlers, natives and Theodore Rooservelt himself, who spoke of the wild horse in ND badlands.

They have been part of the landscape of TRNP since inception of the park when fenced in. Not only historic and culturally significant but economically an asset to the the area drawing people who at TRNP can see wild horses they can see at very few national parks. I hope an economic impact study will be included in EA.

The horses of TRNP have existed with the native animals for over 75 years. I think using science and genetics a viable herd can be maintained alongside native species as they have for over 75 years. By expert opinion that is 150-200 horses. An unique experience that very few national parks have and makes TRNP distinctive. With good management practices no need to eliminate or drastically reduce the herd to point of not being viable. To continue to allow those family units of feral horses to be a living historic and cultural representation of history of ND that Theodore Roosevelt said shaped him from his experiences here. I ask you to carefully consider these points for not only me and many others who treasure and cherish seeing them but for future generations. Once their gone their gone forever, what a shame that be for the horses and their family units and the people who visit Theodore Roosevelt National Park.
Marlene M

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Please don’t eliminate the wild horse herd. There are better ways to manage them and many organizations and volunteers who would be willing to help. The wild horses are an American icon embodying freedom, toughness, ability to survive despite all obstacles and strong family bonds. We need more of this in our fractured society. The wild horses are a tourist attraction and can be utilized to promote all the great things our parks are supposed to represent. Come up with an alternative plan and find a better way.
Fredi L

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