November 20, 2023
Angie Richman
Superintendent
Theodore Roosevelt National Park
PO Box 7
Medora, ND 58645
Subject: Comments on Theodore Roosevelt National Park Livestock Plan
Dear Superintendent Richman:
I write to you on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former National Park Service (NPS) directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.
We appreciate Theodore Roosevelt National Park’s (THRO) efforts to address concerns regarding feral livestock within the park boundaries and their impacts upon native flora and fauna and cultural resources, as well as compliance with NPS laws, regulations, and policies. We hope that our following comments are considered and lead to a plan that identifies appropriate desired future conditions and actions within the park and take into consideration the humane handling and welfare of the animals during the actions proposed.
We understand that these choices are difficult and oft times embroiled in passionate exchanges, but NPS laws, regulations, and policies are quite clear.,Realigning the park to be in compliance with these requirements and guidelines is not only important to the park, but to the National Park System as a whole. After reviewing the Environmental Assessment (EA) and participating in the public scoping sessions, the Coalition supports primarily Alternative C: Phased Reduction of Herds to No Livestock (in both units) and secondarily Alternative B: Expedited Reduction of Herds to No Livestock (in both units).
This plan is not about the ancestry of the animals, which the science currently suggests is not unique, but about aligning the park with applicable laws, regulations, and policies. We applaud the park’s effort to fulfill its management responsibilities with regard to conserving the natural and cultural resources of the park. This conservation mandate is where our comments are focused.
1. You have outlined laws, regulations, and policies well. You have only briefly touched on the THRO Enabling Legislation. It would be good to articulate in this document what that legislation does and does not state in regards to livestock in both the written legislation and the Congressional discussion creating the park.
2. In regards to your visitor surveys where the public regards “wildlife viewing” as an important activity at the park, it appears that the public may not understand that horses and cattle are NOT wildlife.
3. In addition, the EA could expand on the conditions that were present during the time of Theodore Roosevelt’s business tenure at the site. As he was in the ranching business, he reported that he handled horses and cattle as other ranchers in the region did and was the practice (i.e., rounding up free-ranging horses and cattle as the need arose). Therefore, rounding up the horses now can be looked at as also a means to meet a management need.
4. It should be well-articulated in this document that on no public lands in this nation (USFS, BLM, BIA, USFWS, NPS) are horses considered a native species and are generally referred to as exotic, non-native, and in many cases, invasive. Horses are protected on USFS and BLM lands under the Wild and Free-Roaming Horses and Burros Act of 1971; however, this Act does not apply to NPS lands.
5. Most recent analyses show that domestic horses from Spanish settlements in the American southwest had become significant in indigenous lifeways by the first half of the 17th century. Trade in horses became widespread amongst indigenous Americans before Europeans had occupied their lands and the horse became an instrument of cultural expansion through trading and raiding, as well as through exploitation of bison herds. The relationship between Native Americans and horses remains strong in many cultures. We recognize this and respect this perspective, but it does not change the science or policy implications. The most recent genetic work emphasizes that there is no direct link between North American Pleistocene horses and modern North American horses. This is a conclusion that has been vociferously objected to by some Native American scholars and advocates (c.f. https://lovewildhorses.org/native-wild-horses), who maintain that it is Western science that is mistaken and that indigenous knowledge proves there has been an unbroken relationship between humans and horses in North America. There remain stories in the oral traditions of some indigenous groups, but the horses themselves are gone.
6. This plan could address recreational equine use as well. For example, we recommend that the park require the use of weed seed-free hay while in the park and within the USFS number of prescribed days of use prior to entering the park; restrict the use of stallions for recreational riding from entering the park should gelding the males in the park herd be incorporated as the tool for reducing the herd in a phased approach; and ensure that recreational livestock use is not impacting natural or cultural resources by assessing areas open to use.
7. We recommend that NPS assess and provide information regarding current herd dynamics and projected costs of implementing proposed actions. How many males, females, and foals are there currently? What are the short- and long-term population projections, and how does the cost associated with treatment of mares or geldings factor in to the overall budget of the park?
8. Gonacon as a treatment is a repetitive procedure, not always effective, and includes repeated annual treatments, resulting in further and repeated stress on the mares. This can be costly and could go on for 20+ years. The surgical procedure is more effective but likely more costly as there are more mares and foals than stallions, we assume. Every male foal could be gelded as soon as practicable during the decision-making process and initiation of plan implementation.
9. Gelding the males was not offered or discussed as an alternative to Gonacon. Horses are a very social species, and herd dynamics are important. Gelding the males is a one-time process and the animals could still, for a period of time, engage in social herd dynamics while the phased reduction is initiated and carried out. The capture of stallions would be stressful and may be hazardous, but again, a one-time only process. Or consider a hybrid treatment of both mares and stallions.
10. Phased reduction and ensuring no new infusion of new horses for genetics or other purposes will eventually achieve the desired future conditions for the park (livestock reduction and eventual elimination and resources restoration and preservation). That being said, it will be a long process as horses can be a fairly long-lived species (20-30 years generally), but it is critical to ensure no future breeding or new foals as soon as possible in order to achieve goals which would reduce and eventually eliminate the livestock in the park – bringing the park into alignment with NPS law and policy, in a safe and humane manner.
11. The impacts from the horses to both natural and cultural resources could have been provided in detail to make the argument for reducing horse and cattle impacts. If there are inventory and monitoring data, especially on at-risk flora and fauna or other native species of concern, it could be better articulated in this document. It is currently not compelling.
12. In addition, laying out post herd reduction and elimination restoration plans and efforts is critical. What are the priorities for restoration of habitat and species? What are the monitoring protocols to achieve the desired condition? What does success look like for the park?
13. “While not specifically documented, horses at the Park may contribute to impacts on archeological resources similar to those described above for native species where such resources overlap with horse use or areas in which ground-based horse management activities occur.” (EA p. 29) Statements such as this are confusing. Data or links to reports could be provided in order to make a compelling argument regarding horse and cattle impacts. This is critical information to assess restoration post livestock removal.
14. Should the management decision for livestock population objectives within the park boundaries be zero, to meet that objective we suggest the NPS consider removing all horses from the park over a span of years through the following strategies as a hybrid alternative with phased reduction efforts:
a. Affiliated or non-affiliated tribes could be provided with the first opportunity to receive horses.
b. Horses could be transferred to other authorized entities or sold through a GSA auction.
c. Consider Mesa Verde National Park’ equine adoption program as a potential model or tool.
d. Work with the local community to find community or state or local lands outside the park where the horses could draw interested tourists and others and perhaps the community could benefit from an economic standpoint.
15. Last but not least, it is unclear in the EA to what extent NPS has coordinated the NEPA process with Section 106 consultation requirements under the National Historic Preservation Act (NHPA). EA Section 3.2.2 indicates that “[the] Section 106 and NEPA processes are separate” but there is little, if any, description in the EA about what information or feedback NPS may have received during the 106 consultation process. However, as described in the NPS NEPA Handbook 2015, Section 4.14: “The CEQ and DOI 77 2015 NPS NEPA Handbook regulations direct that NEPA reviews should be integrated with analyses used to meet such other requirements (1502.25(a); 46.430(b))… [Note that for NHPA Section 106 you must complete consultation prior to signing a [NEPA] decision document. If you do not do so, there is a risk that once consultation is complete, you will be unable to implement a selected action and that additional, supplemental NEPA review would be required prior to implementing an action.” (Emphasis added to underlined sections.) Given the controversy surrounding the proposed reduction or removal from the park of feral horses and cattle, which the EA identifies as “ethnographic resources,” it would be prudent for NPS to more clearly coordinate the NEPA and NHPA processes to ensure that the EA fully considers and addresses impacts to cultural resources, including horses and cattle. Perhaps NPS has already done so, but it is not adequately described in the EA? In any case, we strongly recommend that NPS add an appendix to the EA that summarizes the 106 consultation process. Such an appendix might include a list of historic properties, correspondence between NPS and consulting parties, a map of the Area of Potential effect (APE), and a description of agreed upon mitigation measures, if any.
As the park proceeds with finalizing and implementing the livestock management plan, we re-emphasize that it is important for the park to achieve and maintain desired resource conditions that are consistent with the purposes for which the area was established. Once the plan is implemented, it will be important for the park to conduct periodic monitoring to track success and public acceptance as management actions are implemented in the future. We also encourage the park to consider adaptive management strategies as new data are made available and lessons are learned as to approaches that work best in different situations. Over time, the park may wish to consider a combination of strategies.
At a Park Service-wide level, there is unlikely to be a “one size fits all” management approach to feral horses and livestock within the National Park System. It is recognized that this can be a highly-charged issue, particularly with the local community as horses are well-loved. It needs to be articulated that it is critical that park managers comply with not only their park’s enabling legislation, but also with relevant laws, policies, and scientific information pertaining to the issue. The NEPA process was authorized and designed to examine the scientific data and to ensure public input. It is the Superintendent’s responsibility to review authorized options and best available information in the decision-making process. It would shameful if this issue were to become so politicized that the results of the public NEPA process are overridden.
In closing, we appreciate the opportunity to comment on this important planning process.
Sincerely,
Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks
cc:
Bert Frost, Regional Director, Regions 3-5, National Park Service
Ray Sauvajot, Associate Director for Natural Resource Stewardship and Science, NPS
The Honorable John Hoeven, United States Senator for the State of North Dakota
The Honorable Kevin Cramer, United State Senator for the State of North Dakota
The Honorable Kelly Armstrong, U.S. Representative for the State of North Dakota
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