Theodore Roosevelt National Park (TRNP) released their Draft Environmental Assessment (EA) in September of this year.  The current comment period ends on November 24, 2023.  The Park announced their “Proposed Action” last December: TOTAL elimination of the herd of just under 200 horses that have called the Park home since the Park's inception.  The Draft Environmental Assessment supports their proposed action. 

The ONLY alternative of the three that the public has been given that allows for ANY horses to stay within the boundaries of the Park is the current 1978 Environmental Assessment. This alternative limits the herd size to an unsustainable 35-60 wild horses.  This alternative would require the removal of about 150 horses.  It is also important to note that the Park has never been able to maintain the horses within that number in the past 45 years. 

We need your help to save this historic wild horse herd! 

Please sign onto our public comment letter to Theodore Roosevelt National Park.  We suggest that you copy and paste the following letter onto the Park's Planning website: https://parkplanning.nps.gov/document.cfm?parkID=167&projectID=105110&documentID=132035 or have it postmarked by November 24^th by USPS and mail to:  Superintendent, Theodore Roosevelt National Park, P.O. Box 7, Medora, ND 58645. and you can also sign onto our letter below. We strongly suggest personalizing this letter to make your public comment unique.  This letter, with all of your signatures, will be mailed on November 24^th to ensure it is postmarked by the comment deadline.  

Superintendent Richman:

Thank you for allowing the public to comment on Theodore Roosevelt National Park's (TRNP) Draft Environmental Assessment (EA) for the proposed Livestock Plan for the wild horses that call the Park home. 

This plan has proven to be controversial and raises historical, cultural, environmental, economic, social and legal issues.  I am sure you are aware that 40 C.F.R. § 1508.27(b)(4) requires the preparation of an Environmental Impact Statement (EIS) whenever “the effects on the quality of the human environment are likely to be highly controversial”. 

An EIS, NOT a FONSI (Finding of No Significant Impact) is required. 

The EIS must begin by addressing the Park's narrowly focused Purpose and Need Statement. In similar contexts, reviewing courts have found that the agency “failed to consider an adequate range of alternatives” where its NEPA analysis “considered only a no action alternative along with two virtually identical alternatives.” Muckleshoot Indian Tribe v. U.S. Forest Serv., 177 F.3d 800, 812-13 (9th Cir. 1999) (per curiam).  To help alleviate this, the following points should be analyzed in the EIS:

• The designation of the “livestock” given to the TRNP wild horses needs to be changed.  The Park has never explained why they're designated as livestock.  These horses do not fit the state or federal definitions of livestock; therefore, they are wild horses. 
• The Park must analyze an alternative that allows for a genetically viable herd of at least 150 reproductive horses to remain within the boundaries of the Park. 
• TRNP's wild horses have unique genetics that must be preserved.  Melissa Thompson's 2022 study is the latest report to show that the wild horses of Theodore Roosevelt National Park are a uniquely genetic herd of horses. 
• The Park's own Brownlee study shows that 89% of visitors polled support the ongoing presence of wild horses in Theodore Roosevelt National Park.  The study supports the concerns of local business owners in Medora who know that the removal of these horses would have a negative impact on their business.
• The Park should consider an alternative that takes the historical and cultural significance of these horses into consideration.  The United Tribes of North Dakota have requested the preservation of the wild horses that call Theodore Roosevelt National Park home.  
• The use of GonaCon has created concerns about possible permanent sterilization and injection site abscesses.  TRNP should eliminate the use of GonaCon for their fertility control program. Instead of GonaCon, the NPS should implement a fertility control program using PZP that has been proven to be reversible and safe for the mare. Any fertility control program that the Park embarks upon should take into consideration the herd's genetics and bloodlines as well as the safety of mares.  
• Instead of selling captured horses via the General Services Administration Online Auctions website, the NPS must develop an adoption program that vets potential buyers, follows up with buyers and helps prohibit the sale of horses for slaughter.

Theodore Roosevelt National Park should also take advantage of the offers from the State of North Dakota, non-profit organizations and other individuals and businesses who have offered to help the Park maintain a genetically viable herd of wild horses within the boundaries of the Park. 

Thank you for your consideration. 

Sincerely,