2016 CPANP Letterhead Logo

May 19, 2016

Messrs. Jim Arthaud, Mike Kasian, and Joseph L. Kessel
Billings County Board of Commissioners
495 4th Street, P.O. Box 247
Medora, ND 58645

Dear Sirs:

I am writing to you on behalf of over 1,100 members of the Coalition to Protect America’s National Parks (Coalition). Our membership is composed entirely of retired, former, or current salaried employees of the National Park Service (NPS). As a group, we collectively represent more than 30,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System.

We are writing to express our concerns about the proposal by Meridian Energy Group to construct and manage an oil refinery to be located about three miles from the South Unit of Theodore Roosevelt National Park (Park). As you know, this so-called Davis Refinery would be the largest infrastructure project ever completed in Billings County. It would have a 55,000 barrel per day capacity. And it will likely lead to a much larger industrial complex that could extend along the full seven miles from Fryburg to Belfield.

Such a proposal, if implemented, would also significantly compromise the integrity of the Park, long recognized as one of the crown jewels of North Dakota, and increasingly recognized as a national destination. In so many ways, from harm to air quality, excessive use of water, and a jarring view from popular high points, Park values would be damaged forever.

It is not the intent of this letter to get into the proverbial weeds about toxic chemicals, odors, percent of viewshed impacted, and especially air quality standards required by the Federal Clean Air Act in a Class 1 designated area. We have read claims by Meridian Energy Group that this refinery will be as “green” as possible. Unfortunately, throughout our careers in parks around the country, we have often heard the same proclamations whenever commercial development is proposed near park boundaries. Sadly, it very rarely comes out that way. We will defer to others, Federal and State evaluators, and non-profit groups, with current knowledge of the legal and technical nuances, to engage with the Meridian Energy Group along the path toward various levels of review and approval/disapproval regarding pertinent compliance. Our many and painful experiences with such processes suggest that, given the very substantial threats to Park values, it will be a prolonged and costly engagement.

Rather, it is the intent of this letter to urge that all efforts be made to find another, more appropriate, location for the Davis Refinery. Our experience, past and present, strongly indicates how much value that most elected officials – Federal, State, and County – give to having a national park in their state or neighborhood. At the least, parks are increasingly recognized as sustainable economic engines in communities and the region around them. It is estimated that the three national parks in North Dakota, led by Theodore Roosevelt, currently generate over $40,000,000 dollars to the state and regional economy each year. And that number can be expected to go up as the number of visitors increases each year – the current trend.

For many, parks are of even greater importance as a source of regional and state pride. Such special areas define a place, and define the people responsible for caring for such places. Preserving park values, however, is not always simple, and never simply the duty of the National Park Service alone. We have, many times in many places, applauded loudly when states, counties, towns, and communities all over the country have stepped up in countless ways to protect parks. In recent years, and in all corners of the country, past and current NPS leaders have worked with far-sighted and courageous leaders from government and private industry toward decisions that favor park protection. Invariably, such decisions require extra creativity, extra work by many, and sometimes more a bit more investment by developers and commercial interests. We’ve learned, however, that positive solutions happen when there is a joint commitment to park stewardship by leaders who choose to have a stake in the outcome.

2016 is the year that the National Park Service celebrates 100 years since its establishment. We cannot imagine a better time for you to exercise strong and appropriate leadership to guide relocation of the proposed Davis Refinery.




Maureen Finnerty, Chair
Coalition to Protect America’s National Parks

The Honorable Jack Dalrymple, Governor, State of North Dakota
The Honorable Heidi Heitkamp, United States Senate
The Honorable John Hoeven, United States Senate
The Honorable Kevin Cramer, United States House of Representatives
Jon Jarvis, Director, National Park Service
Cam Sholly, Midwest Regional Director, National Park Service
Wendy Ross, Superintendent, Theodore Roosevelt National Park, National Park Service