Photo Credit: EMPSi Photo Credit: US Fish and Wildlife Service

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 1 TABLE OF CONTENTS
2 Chapter Page
3
4 CHAPTER 1. INTRODUCTION AND GUIDE ...................................................................................... 1-1
5 1.1 Scoping Period Process Summary .....................................................................1-1
6 1.2 Nature of Comments Received.........................................................................1-1
7 1.3 The Comment Analysis Process ........................................................................1-2
8 1.4 Definition of Terms..........................................................................................1-2
9 1.5 Methodology ..................................................................................................1-3
10 1.6 Guide to this Document ..................................................................................1-3
11 CHAPTER 2. CORRESPONDENCE SUMMARY .................................................................................. 2-1
12 CHAPTER 3. SCOPING PERIOD COMMENT SUMMARY .................................................................... 3-1
13 3.1 Preliminary Alternative A: No Action ................................................................3-1
14 3.2 Preliminary Alternative B: Expedited Reduction to No Livestock .........................3-2
15 3.3 Preliminary Alternative C: Phased Reduction to No Livestock .............................3-3
16 3.4 New Alternative Proposed ...............................................................................3-3
17 3.5 ISSUES - Cultural Resource Issues .....................................................................3-5
18 3.6 ISSUES: Park Management...............................................................................3-6
19 3.7 ISSUES: Visitor Use or Experience .....................................................................3-7
20 3.8 ISSUES: Livestock, Horses .................................................................................3-8
21 3.9 ISSUES: Livestock, Cattle ................................................................................3-11
22 3.10 Purpose and Need: Planning Process and Policy ..............................................3-11
23 3.11 Purpose and Need: Park Purpose and Significance .......................................... 3-12
24 3.12 Purpose and Need: NEPA and CEQ ................................................................3-18
25 3.13 Purpose and Need: Interpretation of Park Policies, Regulations, Laws .............. 3-19
26 3.14 ISSUES: Socioeconomics ................................................................................3-23
27 3.15 ISSUES: Vegetation ........................................................................................3-25
28 3.16 ISSUES: Public Health and Safety ....................................................................3-26
29 3.17 ISSUES: Wildlife/Special Status Species ...........................................................3-27
30 3.18 ISSUES: Water Resources ...............................................................................3-29

31 TABLES Page
32
33 Table 2-1 Comment Distribution by Code ............................................................................... 2-1
34 Table 2-2 Correspondence by Organization Type ..................................................................... 2-2
35 Table 2-3 Organizations Represented in Correspondences ....................................................... 2-2
36 Table 2-4 Correspondence Distribution by Correspondence Type ............................................. 2-4
37

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1 ACRONYMS AND ABBREVIATIONS Full Phrase

2 BLM Bureau of Land Management

3 EA Environmental Assessment

4 NEPA National Environmental Policy Act

5 NPS National Park Service

6 PEPC Planning, Environment, and Public Comment

7 PZP Porcine Zona Pellucida (contraceptive)
8 the Park Theodore Roosevelt National Park

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Chapter 1.
Introduction and Guide
The United States Department of the Interior, National Park Service (NPS) is proposing to
develop a livestock plan for Theodore Roosevelt National Park (the Park). This report documents
the results of the scoping period in support of the National Environmental Policy Act (NEPA)
document. Public scoping initiates the NEPA process and the identification of issues to address
in the NEPA document, in this case an environmental assessment (EA). All stages of public
involvement are a vital part of the NEPA process. Preceding public scoping, the NPS initiated the
collaborative public involvement process through a civic engagement period from March 16 to
April 18, 2022. Future public involvement will include a public review of the EA and collaboration
with federal, state, and local governments and interested Tribes

1.1 SCOPING PERIOD PROCESS SUMMARY

On December 12, 2022, the NPS published a scoping newsletter and initiated the start of a 50-day
public comment period. The newsletter included a description of the project background, the
project’s purpose and goals, and preliminary alternatives. On January 12, 2023, the NPS held a
virtual scoping meeting to present information on the proposed project and answer questions
posed by the public. The NPS invited members of the public to submit comments on this
newsletter electronically through the NPS Planning, Environment, and Public Comment (PEPC)
website.

1.2 NATURE OF COMMENTS RECEIVED

The NPS received 19,012 pieces of correspondence during the scoping comment period. Of the
19,012 correspondences, 5,138 correspondence letters were unique, and 13,874 were part of four
separate form-letter campaigns. 1 The topics that received the majority of the comments related
to the management of horses within the Park, while fewer comments related to the management
of cattle and bison.

1
Form-letter campaigns use a standardized correspondence letter that is generally initiated by
nongovernment advocacy groups. Form letters are those with identical or nearly identical text. For the
purposes of this report, a master form letter was identified by NPS analysts and reviewed for any substantive
comments. Correspondences identical to the master form letter were not analyzed.

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 1. Introduction and Guide (The Comment Analysis Process)

1.3 THE COMMENT ANALYSIS PROCESS

Comment analysis is a process used to compile and combine similar public comments into a
format that can be used by decision-makers and the NEPA team. The comment analysis assists
the team in organizing, clarifying, and addressing technical information regarding the livestock
plan. It also aids in identifying the topics and issues to be evaluated and considered in the EA.

The comment analysis process includes five main components:

• Developing a coding structure

• Employing a comment database for comment management
• Reading and coding public comments
• Interpreting and analyzing the comments to identify issues and themes
• Preparing a scoping comment report summary

The NPS developed a coding structure to help sort comments into logical groups by topics and
issues. The coding structure was derived from an analysis of the range of topics discussed during
internal NPS review, past planning documents, and the comments themselves. The structure was
designed to capture all comment content rather than to restrict or exclude any ideas.

The NPS used its PEPC database to manage the comments. The database stores the full text of all
correspondence and allows each comment to be coded by topic and issue. Some outputs from the
database include tallies of the total number of correspondence and comments received, sorting
and reporting of comments by a particular topic or issue, and demographic information regarding
the sources of the comments.

The analysis of the public comments involved assigning codes to statements made by the public
in their submitted letters. The NPS read and analyzed all comments, including those of a technical
nature; those expressing opinions, feelings, and preferences of one element or one potential
alternative over another; and comments of a personal or philosophical nature.

Although the analysis process attempts to capture the full range of public concerns, this content
analysis report is just one part of the process of gathering internal and external input. Comments
from people who chose to respond do not necessarily represent the sentiments of the entire
public. Furthermore, this was not a vote-counting process, and the emphasis was on the
comment’s content rather than the number of times a comment was received. This report is
intended to be a summary of the comments received rather than a statistical analysis.

1.4 DEFINITION OF TERMS

Primary terms used in this document are defined below.

Correspondence: A correspondence is the entire document received from a commenter. It can

be in the form of a letter or fax, written comment form, or a comment submitted online using the
NPS PEPC website. Each piece of correspondence is assigned a unique identification number in
the PEPC system.

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 1. Introduction and Guide (Definition of Terms)

Comment: A comment is a portion of the text within a correspondence that addresses a single
subject. It could include an expression of support or opposition to the use of a potential
management tool with rationale, or additional data regarding an existing condition.

Code: A code is the grouping centered on a common subject. The NPS developed the codes
during the scoping process and uses the codes to track major subjects throughout the EA process.

Concern: A concern is a written summary of all comments received under a particular code. Some
codes were further separated into several concern statements to provide a better focus on the
content of the comments.

1.5 METHODOLOGY
During the public scoping process, 5,138 unique correspondence pieces were received from the
PEPC website directly, or they were entered into the PEPC database for analysis. Submissions that
were duplicative or greater than 95 percent identical were analyzed as one unique submission.
The NPS read each correspondence and identified specific comments within each
correspondence. A total of 7,331 comments were derived from the correspondences received.
Only comments that were received as part of the official comment period from December 12,
2022 to January 31, 2023 were included as part of this analysis.

The NPS gave each comment a code to identify the comment’s general content and to group
similar comments together. Twenty-one codes were used to categorize the comments received.
An example of a code developed for this project is Preliminary Alternative A: No Action. This code
relates to any comments received regarding the no-action alternative. In some cases, the same
comment may have overlapping issues within the same statement; in this case, a single comment
may be categorized under more than one code, reflecting the fact that the comment may contain
more than one issue or idea. All comments were read and considered, and relevant comments will
be used to help refine the proposed alternatives, which will ultimately be analyzed in the EA.

Under each code, the NPS grouped comments by similar themes, and those groups were
summarized with a concern statement. For example, one concern statement identified—
”Removing livestock is needed to protect natural resources in the Park.”—captured several
comments. Following each concern statement are one or more representative quotes, which are
comments taken from the correspondences to illustrate the issue, concern, or idea expressed by
the comments grouped under that concern statement.

1.6 GUIDE TO THIS DOCUMENT

This remainder of this report is organized as follows:

Chapter 2, Content Analysis Report: This is the basic report produced from the PEPC database
that provides information on the numbers and types of comments received, organized by code.
The report’s first section provides a summary of the number of comments that were coded under
each topic. The second section provides general demographic information, such as the states
where commenters live, and the number of letters received from different categories of
organizations.

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 1. Introduction and Guide (Guide to this Document)

Chapter 3, Scoping Period Comment Summary: This report summarizes the substantive
comments received during the scoping process. These comments are organized by codes and
further organized into concern statements. Below each concern statement are representative
quotes, which have been taken directly from the text of the public’s comments; they have not been
edited. Spelling and grammar errors were not corrected. Representative quotes further clarify the
concern statements.

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Chapter 2.
Correspondence Summary
The following tables show the distribution of correspondences by how they were coded.

Table 2-1
Comment Distribution by Code
Number of
Code Description
Comments1
Support Complete Livestock Removal 45
Oppose Complete Livestock Removal 2867
Preliminary Alternative A: No Action 64
Preliminary Alternative B: Expedited Reduction to No Livestock 15
Preliminary Alternative C: Phased Reduction to No Livestock 11
New Alternative Proposed 329
Issues: Cultural resources 163
Issues: Park management 429
Issues: Visitor use or experience 498
Issues: Livestock, Horses 1167
Issues: Livestock, Cattle 48
Purpose and Need: Planning Process and Policy 28
Purpose and Need: Park Purpose and Significance 439
Purpose and Need: NEPA and CEQ 1 202
Purpose and Need: Interpretation of Park Policies, Regulations, Laws 48
References: General Comments 349
Issues: Socioeconomics 367
Issues: Vegetation 113
Issues: Wildlife/Special Status Species 139
Issues: Public Health and Safety 3
Issues: Water Resources 7
Total 7,331
1Note: Each correspondence may have multiple substantive comments. As a result, the total number of
correspondences may be different from the actual comment totals.

1
Council on Environmental Quality

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 2. Correspondence Summary

Table 2-2
Correspondence by Organization Type
Number of
Organization Type
Correspondences
Federal government 1
State government 5
Nongovernmental 79
Unaffiliated individual1 18,927
Total 19,012
1Several unaffiliated individuals identified
nongovernment organizations with which they are
associated. These organizations are listed in Table 2-3.

Table 2-3
Organizations Represented in Correspondences
Organization Name Organization Type
Advocates for Wild Equine Nongovernmental
Advocates for Wild Horses Nongovernmental
American Wild Horse Campaign Nongovernmental
Animal Law LLM Candidate at Lewis and Clark Law School Nongovernmental
Animal Welfare Institute Nongovernmental
Animal Wellness Action Nongovernmental
AtlasVet Nongovernmental
AWI Nongovernmental
Blue Ribbon Stables, LLC Nongovernmental
Bureau of Reclamation & Environmental Protection Agency Federal
Carlotta’s Housing and Mentoring Service Nongovernmental
Cause 4 Paws Nongovernmental
Cedar Hill Farm Nongovernmental
Center for Global Studies Nongovernmental
Chasing Horses Wild Horse Advocates Nongovernmental
ComDel Inc. Nongovernmental
Coyote Canyon Caballos d Anza Nongovernmental
Dakota Grown Photos Nongovernmental
Dickinson CVB Nongovernmental
Dukart Ranch LLLP Nongovernmental
Eyefrogs Photography Nongovernmental
Fleursteppe Nongovernmental
GardaWorld Nongovernmental
GDCD Nongovernmental
Giangrego Nongovernmental
Grand River Ranch Nongovernmental
Grazing Land Solutions LLC Nongovernmental
Horse Medicine Productions Nongovernmental
Humane Society of the Heartland Nongovernmental
In Defense of Animals Nongovernmental

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 2. Correspondence Summary

Organization Name Organization Type

Legacy Farm and Stables Nongovernmental
Let Them Live Free Nongovernmental
Lewis and Clark trail museum Nongovernmental
Long X Visitor Center/Pioneer Museum of McKenzie County Nongovernmental
Love Wild Horses, Inc. Nongovernmental
Magic Photo Art Nongovernmental
Marian’s Dream and United Spay Alliance Nongovernmental
Medora Chamber of Commerce Nongovernmental
National Mustang Association, Colorado Nongovernmental
Newell Media Nongovernmental
Nokota Preserve, Chester Springs PA Nongovernmental
North Dakota Badlands Horse Nongovernmental
North Dakota Department of Commerce State
North Dakota Equine Assn Nongovernmental
North Dakota Senate, Kathy Hogan State
North Dakota Senate, Sean Cleary State
North Dakota Senate, Tim Mathern State
North Dakota Travel Alliance Partnership Nongovernmental
N-X Ranch Nongovernmental
Oregon Wild Horse Organization Nongovernmental
People for the Ethical Treatment of Animals (PETA) Nongovernmental
Physicians Committee for Responsible Medicine Nongovernmental
Rafter R Ranch, LLC Nongovernmental
Return to Freedom; Humane Society of the United States;
Humane Society Legislative Fund Nongovernmental
Salmonberry Tribal Associates Nongovernmental
Saveourwildhorses.net Nongovernmental
Sharing With The Hearts Of Wheezer Nongovernmental
Sierra Club Member Nongovernmental
South Dakota State University Nongovernmental
State of North Dakota, Governor State
Studio Cornelia Nongovernmental
Sundance Square Home Owners Associate (HOA) Nongovernmental
Swan Farm Akhal-Tekes Nongovernmental
Taku Skan Skan Wasakliyapi: Global Institute for Traditional
Sciences (GIFTS) Nongovernmental
The Buffalo Gap Gift Shop Nongovernmental
The Cloud Foundation Nongovernmental
The Homes for Horses Coalition Nongovernmental
The Walsh County Record Nongovernmental
Theodore Roosevelt Inaugural Site Nongovernmental
Theodore Roosevelt Medora Foundation Nongovernmental
This Old Horse (a.k.a. Wishbone Ranch) Nongovernmental
Tori Gagne Photography Nongovernmental
Travlin the 2 Trax Nongovernmental

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 2. Correspondence Summary

Organization Name Organization Type

University of Idaho Nongovernmental
University of Oklahoma Nongovernmental
Western Watersheds Project Nongovernmental
Wild Equids of New Mexico Nongovernmental
Wild Heart Sanctuary Nongovernmental
Wild Horse and Burro Fund Nongovernmental
Wild Horse Education Nongovernmental
Wild Lands, Wild Horses Nongovernmental
Wind Horse Dancer, Inc. Nongovernmental
Wood Creek Apartments Nongovernmental
World Wildlife Fund Nongovernmental
Wyoming Mustang Institute Nongovernmental

Table 2-4
Correspondence Distribution by Correspondence Type
Number of
Correspondence Type
Correspondences*
Web form** 18,849
Letter 163
Total 19,012
*Some entities sent correspondence in multiple formats (in
other words, one commenter sent the same letter multiple
ways); this table does not include duplicate letters.
**Filled out form on the PEPC database

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Chapter 3.
Scoping Period Comment Summary
3.1 PRELIMINARY ALTERNATIVE A: NO ACTION
CONCERN STATEMENT: Alternative A is preferable because it would maintain the horse
herd, which is one of the outstanding features that attract visitors to the Park.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The wild horses are a wonderful asset to this beautiful, natural place.
We love seeing them, knowing their families and watching the dynamics. The only reason we
visit TRNP is to see the horses in their natural environment. A true piece of old west history.
We can see buffalo and cattle all over but not wild horse herds. I don’t understand the desire
to completely remove these pieces of walking history. “A” is the best option. Keep the
population in check yes, but don’t remove them. I honestly think it would be harmful to park
tourism if you did.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The horses in the park are a living piece of history. Once that is gone,
you cannot get it back. They become a story of things gone by, like so many other things
mankind has failed to protect and preserve. I strongly believe that the presence of the horses
in the park should be preserved for future generations. Wherever there are wild horses in the
world, they are unique to their territory and history. If the park removes the horses, that is
gone forever. Everything passed down through generations of horses will cease to exist. I
understand the need to control their numbers for the benefit of the land, the horses, and the
other animals in the park, but to remove them completely would be a tragedy. With the
options presented, I am sure that anyone who is familiar with the horses in Theodore
Roosevelt National Park would advocate for Alternative A - No Action Alternative: Continued
herd management under the 1978 EA and 1970 management plan.

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 3. Scoping Period Comment Summary (Preliminary Alternative A: No Action)

CONCERN STATEMENT: The smaller horse population objective under Alternative A does
not allow for genetic diversity and viability.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Plan A is best of your poor options. You need closer to current
numbers for herd dynamics and family groups. Attempting to corral small numbers will make
this park no more than a roadside zoo.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: I propose that Alternative A is the only choice here and that the
number may need to be higher than 50 or 60 to ensure genetic diversity.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Alternative A Oppositions and Preferred Proposal: The current

management of the horses by the 1978 EA is outdated. The horse population objective of 35-
60 does not allow for genetic diversity and viability. This analysis is concluded by Dr. Gus
Cothran, Director of the Equine Blood Typing Research Laboratory at the University of
Kentucky. Based on his DNA analysis, Dr. Cothran believes that the minimum wild horse and
burro herd size is 150-200 animals.

• Preferred proposal: The minimum herd size should be 150 to 200 horses; to maintain
herd genetic diversity and viability.

1 3.2 PRELIMINARY ALTERNATIVE B: EXPEDITED REDUCTION TO NO LIVESTOCK

2 CONCERN STATEMENT: Alternative B is preferable because domestic livestock are resource-
3 intensive, nonnative species that often outcompete native plant and animal species.

4 Representative Quote(s):
5 Organization: Retired Organization Type: Unaffiliated Individual

6 Representative Quote: I strongly support, applaud, and urge NPS to adopt and fully
7 implement Action Alternative B to expedite the reduction of herds to no livestock. I believe
8 that this is the most reasonable and necessary alternative.

9 Domestic livestock are not native to this park’s natural ecological systems and they compete
10 for limited forage with native wildlife species that rely on that same forage and are already
11 under stress from drought and other causes.

12 Organization: Not Specified Organization Type: Unaffiliated Individual

13 Representative Quote: As such, we absolutely support and encourage you to select Action
14 Alternative B, the expedited reduction of horse and cattle herds to zero livestock. By removing
15 the demanding foraging needs of these nonnative herds from the landscape, the plant species

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 3. Scoping Period Comment Summary (Preliminary Alternative B: Expedited Reduction to
No Livestock)

1 would recover and thrive in a way they do not at this time; and the native species of plant and
2 animal within the park would be more fully preserved and sustained.

3 CONCERN STATEMENT: Expedited reduction is problematic because the Park is considered

4 home to these animals, and it is wrong to remove animals from their home.

5 Representative Quote(s):
6 Organization: Not Specified Organization Type: Unaffiliated Individual

7 Representative Quote: The park is their home, whether they belong there or not, they should
8 in my view be allowed to stay put where they know. With that being said, I believe the first
9 alternative of decreasing the herd from 186 to about 35-60 would be the better option overall.

10 3.3 PRELIMINARY ALTERNATIVE C: PHASED REDUCTION TO NO LIVESTOCK

11 CONCERN STATEMENT: Alternative C is preferable not only because it would protect natural
12 resources and decrease the spread of disease and invasive plant and animal species, but also
13 because phased reduction over time seems to be the most humane option.

14 Representative Quote(s):
15 Organization: Not Specified Organization Type: Unaffiliated Individual

16 Representative Quote: After reviewing Livestock Plan, I am supportive of Alternative C.

17 (Phased Reduction of Hers to No Livestock)

18 This proposal gives adequate amount of time to parties interested in receiving the livestock.
19 Additionally this proposal enables horses to phase out over time as the remaining herd will no
20 longer be able to reproduce.

21 3.4 NEW ALTERNATIVE PROPOSED

22 CONCERN STATEMENT: The NPS should maintain the current horse population in the Park
23 by balancing the bison herd size and fully removing cattle.

24 Representative Quote(s):
25 Organization: Not Specified Organization Type: Unaffiliated Individual

26 Representative Quote: Therefore I write to urge you to cancel the planned roundups of the
27 herd living in Theodore Roosevelt Park. Horses there are an intrical [integral] part of the
28 ecosystem, in addition to continuously embodying the Spirit of America and the freedom to
29 pursue a life of happiness America stands for. They represent America for the world, which
30 continues to associate them with our beautiful country.

31 Those animals are essential for the land. Grazing cattle on a range terminally does away with
32 its grass. As cows pull the roots of the grasses they eat, horses do not. Horse cut the grass with
33 their teeth, leaving intact the root system.

34 This all has extreme consequence on the ecosystem as once the grasses are pulled, the land no
35 longer hosts all the tiny creatures living on that grass. From the tiniest rodents to insects, all

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 3. Scoping Period Comment Summary (New Alternative Proposed)

1 vacate when the grass and wild herbs no longer are there. This creates a cascading effect that
2 trickles into the whole ecosystem, as those tiny creatures serve as food for bigger ones, (small
3 mammals) who no longer can live on the land without them. Eventually it affects the large
4 mammals and the predators who maintain the balance in their population. Pretty soon the
5 earth becomes barren as nothing lives on it anymore.

6 Organization: Not Specified Organization Type: Unaffiliated Individual

7 Representative Quote: Initially, The Park definition of livestock is: "Livestock at the park
8 include any species of animal that has been selectively bred by humans for domestic and
9 agricultural purposes, including, but not limited to, cattle, sheep, horses, burros, mules, goats,
10 and swine. According to best available science, Wild horses should not be included in this
11 definition.

12 Secondly, the value of wild horses as "an integral part of the natural system of the public lands"
13 and cannot be measured. The awe they inspire, the beauty they share, is more important than
14 anything monetary. They should be allowed to be free so that we and future generations can
15 enjoy them, but that won't happen unless the special places where they exist are unimpaired
16 and protected.

17 Current best science recommends the following:

18 Wild horses permitted to thrive in the Park. They are native to North America and belong
19 here. They coevolved with North American ecosystems. They contribute to ecosystem
20 balance providing ecosystem services just by living on the land.

21 Other native North American species are struggling to survive including gray wolves and
22 mountain lions and they too, should be allowed to thrive. They regulate their own populations
23 and do not need human "management". They should not be targets of bullets, traps, snares,
24 myths or outright lies. Keystone species and apex predators, such as wolves and mountain
25 lions, play vital roles in ecosystem balance, in part by modifying ungulate behavior to reduce
26 overgrazing as documented in Yellowstone National Park. These species need connectivity,
27 larger populations and wider distribution in order to survive.

28 Cattle are NOT native to North America and are extremely detrimental to the ecosystem.
29 Cattle do not belong in the Park.

30 Organization: Not Specified Organization Type: Unaffiliated Individual

31 Representative Quote: These horses have been surviving side by side with the wildlife for
32 hundreds of years without a problem. The problem is being caused by the cattle and sheep
33 allowed to graze in our national parks. There should be specific areas for cattle and sheep to
34 graze and not on lands such as national parks or public lands designated for wild horses and
35 other wildlife. Horses are not livestock. The true livestock such as cattle and sheep are the
36 ones causing the problems and they need to be removed and no longer allowed to graze in our
37 national parks. The wild horses are native to this country as proven scientifically in many
38 different ways and they need to be left alone and not touched. Wild horses will self-regulate if

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 3. Scoping Period Comment Summary (New Alternative Proposed)

1 there's not enough food they don't need man's interference. Please leave these wild horses
2 alone.

3.5 ISSUES - CULTURAL RESOURCE ISSUES

CONCERN STATEMENT: The plan should consider horses as an integral part of the cultural
heritage of the Badlands.

Representative Quote(s):
Organization: North Dakota Badlands Horse Organization Type: Nongovernmental

Representative Quote: Cultural Landscape: The impact of removing the horses diminishes
the Park's Foundation Statement. The Foundation Statement , from 2014, states, "Horses
were an important part of the cultural landscape when Theodore Roosevelt lived in the area
and are a very popular visitor attraction today" (a). Ranchers, including Teddy Roosevelt
himself, and the Marquis used horses daily in their cattle operations. The Indigenous people
sawhorses as their relatives (b). Horses display spiritual connection that continues in today's
world. Removing the herd would impact the Heritage and Cultural values Theodore
Roosevelt National Park vows to maintain. Listen to the words of Teddy Roosevelt "Leave it
as it is. You can't improve on it. What you can do is keep it for your children, your children's
children and for all who came after you". The horses were on the land first and they should
remain there for future generations.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Horses have meaning and cultural value and have earned a
permanent place in TRNP: The naturalized horse herds in TRNP reveal powerful lessons
about biodiversity, human culture, and adaptation to a difficult environment. The genetic
legacy of the horses embodies their trade among MHA and Lakota tribal communities, 1881
confiscation from Sitting Bull's surrender at Fort Buford, building of cross-mixed horse herds
by gentlemen ranchers like deMores and Theodore Roosevelt, acquisition of herds by large
ranching interests in 1896. Horses that were too hard to catch were released into the Badlands
to graze and reproduce, where they continued genetic cross-mixing with domestic ranch
stock.

They were selectively harvested by working cowboys to work cattle and for rodeo stock. And
to rebuild the U.S. Army's cavalry herds following World War I. Their physical makeup
reflects biodiversity and environmental adaptation to ranchland grazing in the Little Missouri
Badlands through the Dust Bowl depression-era, and 70-years of experiential tourism in the
National Park. Over six generations, the horses have remained critically valuable spiritually
and commercially to at least four diverse cultural groups. They are the legacy of unfettered
freedom on the northern Plains.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Summarily, the horses may reasonably be regarded as a cultural

heritage resource that merits careful management and preservation under public policy.

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 3. Scoping Period Comment Summary (ISSUES - Cultural Resource Issues)

Recent scientific findings about equine genetics, and verifiable cultural understandings of
Lakota and MHA nations have not yet received full consideration. Tacit or inadvertent
destruction of such an asset would be a tragic loss to our national heritage, and a blight on
public perception of the National Park Service.

3.6 ISSUES: PARK MANAGEMENT

CONCERN STATEMENT: Current park management practices, including roundups and the
GSA 3 adoption program, are inhumane. They subject horses to unnecessary stress, often leading
to mortality, and leave them susceptible to being sold for slaughter.

Representative Quote(s):
Organization: AtlasVet Organization Type: Unaffiliated Individual

Representative Quote: My primary concern is the inhumane nature of rounding up all of

these animals, endangering their safety and exposing them to unnecessary stress. This can
cause avoidable morbidity and mortality of the horses as well as breaking up family units.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: It is also understood that these wild horses are to be Rounded up.
Such actions are known to subject wild horses to unnecessary stresses and injuries and break
apart family bands. We also know that wild horses which are rounded up, are not properly
cared for, and often languish in confined enclosures, and are even sold to be butchered. I
cannot condone such mistreatment of our natural resources.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: First of all, the current helicopter round ups of the wild horses is a
tortuous and cruel practice, leading to the extreme trauma and even death of a number of
horses each time, especially those most vulnerable members of the population, including the
very young, older and pregnant horses. In each of the three alternatives, the horses, once
removed, are to be offered for sale to the public. What is not here stated, but has been found
to be true though eyewitness and video accounts, is that these animals are then often re-sold
to representatives of slaughterhouses, usually in Canada or Mexico, where they are butchered
for pet or even human consumption.

CONCERN STATEMENT: The plan should consider other management options that have
shown to be successful in other wild horse herds, such as using volunteers to administer birth
control and employing the cooperation of private and public entities.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Round-up and removal is an irresponsible waste of taxpayers’ money

as well. In Douglas County, Nevada, where I live, our wild horses have been responsibly

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managed by volunteer advocates - zero cost to taxpayers. They managed population by PZP
darting which in 2022 resulted in only 2 foals born. When forced by BLM, they were able to
assist in reducing our herd by careful selection that ensured preservation of a healthy variety
of genetics and did not result in injured horses or orphaned foals as is common with helicopter
round-ups. Even if volunteers did not come forward to manage the horses with PZP,
employing BLM staff to administer the birth control is still much cheaper for the American
taxpayer.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: There are several places where wild herds are successfully managed,
such as the Chincoteague region of North Carolina and the Salt Cree Region of Arizona. Both
are maintained by the cooperation of private and public entities. What steps have you or have
you not considered to establish a maintenance and control plan to preserve the legacy of the
wild horses before seeking their elimination? Let’s see what the rallying community can do to
support the cause of keeping the horses present.

3.7 ISSUES: VISITOR USE OR EXPERIENCE

CONCERN STATEMENT: Reducing the number of horses within the Park or removing them
altogether would degrade the visitor experience, as they are the primary reason that people visit
the Park.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Theodore Roosevelt National Park without a herd of wild horses that
can roam freely would certainly lessen the draw for myself and my family visiting in the future
and would diminish the experience for me and other visitors who want to see robust wildlife
represented when they enter the park. If another alternative besides option A is selected, I
would be extremely disappointed and would reconsider spending our summer visiting other
state and national parks where wild horses are allowed to freely roam.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The horses at TRNP are an important aspect of visitor enjoyment of
the Park. Their presence represents Theodore Roosevelt's experiences here during the open-
range ranching era. In 1970, Park policy recognized the horse as part of the historical setting.
New policies were written and enacted to manage these horses as a historic demonstration
herd.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Also, with these few numbers, how will the handicapped be able to
see these horses without the ability to hike? At the current number of 186 it is an enhanced
visitor experience since there are enough to see in several areas along the loop road; however,
at low numbers how can you continue to enhance the visitor’s experience with the horses for

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the handicapped’s enjoyment, of which they are a huge part? Thank you for considering my
questions and concerns.

3.8 ISSUES: LIVESTOCK, HORSES

CONCERN STATEMENT: The effect(s) of contraceptives on horse health and behavior is a
concern. The NPS should use PZP 4 contraceptive instead of GonaCon due to concerns
regarding short-term and long-term physiological impacts, such as site of injection injury or
sterilization.

Representative Quote(s):
Organization: None Organization Type: Unaffiliated Individual

Representative Quote: Given concerns about its potential for permanent sterilization and
injection site abscesses, eliminate the use of GonaCon for the fertility control program. When
administering any fertility control program, the NPS must consider the herd’s genetics and
bloodlines as well as the safety of mares. 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.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: I support the management plan of adoption and contraceptive

vaccines. I understand the need for herd management in this enclosed area but I’d like to see
TRNP utilize a different contraceptive such as PZP. This vaccine has been scientifically
proven and used for forty years in various wildlife including wild horses and has been
recommended by The National Academy of Sciences for use in federally protected wild
horses. PZP is currently utilized by The BLM to manage several wild horse herds with great
outcomes. A few of those herds include the wild horse populations of The McCullough Peaks
HMA since 2012, The Pryor Mountain herd in Montana, and Spring Creek Basin herd in
Colorado since 2012. These specific herds have had great results in using this vaccine which
I’m sure you are aware. This has been a humane alternative to round ups and removals. This
vaccine has a current cost of $30.00 per dose. Each mare would receive a priming dose then a
booster 2-4 weeks later than an annual booster once per year. The research and science
behind PZP has shown it’s treatment for fertility control is the best answer for managing wild
horses. It’s a proven technology that provides safe, humane, and cost-efficient alternatives.
I’m curious why this method has not been attempted with this herd

Organization: Oregon Wild Horse Organization Organization Type: Non-Governmental

Representative Quote: Any alternative that permanently removes any horse from the park is
likely to send horses into the slaughter pipeline. As addressed above these horses were given
GonaCon for years. The agencies who have studied, and put forth studies to get GonaCon
registered, as well as the EPA (see Attachment 2) itself, have not produced these studies to the
American public.

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In addition, the 2022 ASPCA poll admits that 83% of the American public is opposed to Horse
Slaughter up from 80% in 2012. This is relevant because once removed from the Park there is
no mechanism in place by which the National Park Service or DOI can disallow and/or stop
an “owner” of a wild horse (that has been converted to livestock) from being sold over the
borders to Mexico or Canada for slaughter, or subsequently from illegal live shipment
overseas, or air flight, to inhumane illegal slaughter around the globe.

The use of GonaCon for fertility control can, after more than one treatment, result in
permanent sterilization, and ingesting the flesh of these horses has not been proven safe for
either predators, pets or humans that may consume that horse meat.

CONCERN STATEMENT: The NPS should manage for the appropriate herd number to
prevent inbreeding and genetic drift.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The number of horses 35 to 60 needs to be changed to 150 horses to

ensure a genetically viable herd. This has been recommended by Dr Gus Cothran equine
geneticist for all wild horse herds in us.

If new horse blood needs to be brought into the herd introducing horses who historically are
significant to TRNP and prioritize the DAKOTA horse.

A 2018 study from Texas AND M found that the historic herd is at risk of inbreeding and
recommended introducing new mares and changing removal strategies to preserve genetics.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Management plans based on scientific studies have shown that
healthy herds should not fall below 200, also the horses have survived in the park area since it
was fenced and have not caused any adverse problems to the landscape. The history of the
park has always included these magnificent animals and to reduce their numbers so drastically
would not only upset the ecosystem but also make for a very unhealthy herd.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: To protect the GENETIC HEALTH of the herd and promote its
genetic viability, the minimum population should be 150, or more. By allowing the horses to
use additional areas of the TRNP, the herd can and should be managed at a HIGHER
MINIMUM POPULATION LEVEL

Organization: None Organization Type: Unaffiliated Individual

Representative Quote: If “new blood” needs to be brought into the herd, introduce horses
who are historically significant to TRNP and prioritize the Nokota horses. A 2018 study from
Texas A&M found that the historic herd is at risk of inbreeding (even at a number of 70-75

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horses!) and recommended introducing new mares and changing removal strategies to
preserve genetics and lineages.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Please keep a large enough herd for the necessary biodiversity, which
is more than twice the number proposed.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: For a population on the edge of extinction in the wild, the IUCN SSC
Equid Specialist Group recommends at least 500 reproductively intact, interbreeding
individuals. (Duncan, P. 1992. Zebras, Asses and Horses: An Action Plan for the Conservation
of Wild Equids. IUCN SSC, ESG). But for a thriving normal population living in nature, it
recommends 2,500 intact individual equids. The low population you have defined would not
allow these horses to fill their niche, harmonize with the ecosystem, and naturally self-stabilize
their numbers, which they do by dint of their mature social units, or “bands.”

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Theodore Roosevelt National Park needs an alternative that takes
into consideration the genetic viability of this herd. Dr. Gus Cothran has stated repeatedly
that 150-200 adult horses are needed for a genetically viable herd. On January 5, 2023, Dr.
Cothran spoke to North Dakota’s KX News (https://www.kxnet.com/news/state-
news/cutting-the-herd-size-at-theodore-roosevelt-national-park-could-be-bad/) and
reiterated this statement, this time speaking SPECIFICALLY with regards to the wild horses
of Theodore Roosevelt National Park. The Bureau of Land Management’s Wild Horse and
Burro handbook also supports the need to maintain 150-200 horses for genetic viability.

Theodore Roosevelt National Park should develop and analyze an alternative in which ONLY
reversible birth control is administered to the herd with the following conditions: (1) older
mares should only be given birth control where they have a proven genetic representation in
the herd; (2) any birth control program should be rotated to reduce the chance of permanent
sterilization; and (3) treated mares should be monitored for any health or behavior changes.
Assateague Island is successfully implementing its birth control program with PZP, with
marked reductions in population growth and better body condition scores within their herd.
As a result, that park has added two new age groups to the herd dynamics because they now
have horses living beyond the age of 25.

A similar birth control program should be implemented in this wild horse management plan.
To the extent that a successful birth control program is implemented, TRNP should stop
managing the herd by numbers only and make sure that science and genetics are guiding the
use of birth control on ANY horse in this herd.

To the extent that culling the herd is required, TRNP should develop and analyze an
alternative that makes any wild horse removals contingent on rigorous genetic monitoring;

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that is, an alternative whereby horses are removed only if their removal would not negatively
impact the genetic health of the entire herd.

3.9 ISSUES: LIVESTOCK, CATTLE

CONCERN STATEMENT: Bison could be exposed to Mycoplasma bovis from trespass cattle
that enter the Park’s boundaries or bison that escape the Park’s boundaries and introduce the
disease to the Park’s bison herd.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Another concern mentioned with the longhorns is the possibility of
them introducing Mycoplasma bovis to the bison herd. I was not familiar with this disease, so
I did a quick web search. For what it’s worth, it seems that there is both testing for and
vaccination against the disease available. Cattle from outside the park occasionally trespass
into the park and could bring the disease in, and bison trespass out of the park where they
could also contract the disease. In addition, Wyoming has documented the disease in
pronghorns and both species of deer, so it already exists in wild native animals that could act
as vectors to introduce it into the bison herd. Given all the other ways that M. bovis could
reach the herd, a few longhorns that could be tested and vaccinated before being introduced
into the park don’t seem like a very credible threat. I would be interested to know if the disease
is of concern to the park’s elk and bighorns as well.

CONCERN STATEMENT: Cattle cause harm to the environment, and grazing does not belong
on public lands.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: These cattle do irreparable harm to the habitat that many species
need to thrive. Cattle must not be allowed to graze lands that belong to the American public.
These lands must be maintained in the most pristine shape possible for this and future
generations to enjoy

3.10 PURPOSE AND NEED: PLANNING PROCESS AND POLICY

CONCERN STATEMENT: The NPS has not provided adequate evidence of the impacts of
horses on the landscape and wildlife, as well as their impact on the Park’s budget.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The National Park Service needs to share publicly and transparently
the reasons for removing the horses: What impact on the environment, other regional native
species, cost (budget) of maintaining warrant this decision as well as a clearer picture on
impact on tourism. No clear reason (supporting data) of why removal of the horses is
necessary.

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Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: In reality, the idea of rounding up the horses and neutering and selling
them is just “the easy way out.” There is no long term planning in this. I am an environmental
scientist, and prepare NEPA documents for a living, I don’t believe the science that the animals
are destroying the natural environment. I think that the animals and endangered species can
co-exist. It takes planning, the application of science, but most of an understanding that would
create a long term plan.

CONCERN STATEMENT: The plan to remove domestic livestock from the Park is unnecessary
because NPS policy allows for the balancing of native and nonnative species.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The wild horses in the park certainly are representative of Teddy
Roosevelt that used his horses daily in his cattle operation. There’s many photos of Teddy
Roosevelt on horseback taken in the park.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: For preliminary alternatives B and C, the EA would need to describe
the reasoning whereby complete elimination of the wild horses and longhorns is necessary
and some balance with native wildlife and other natural resources could not be achieved via
active management. NPS policy allows for this balancing. The alternatives would need to
discuss an analysis of resource condition data, past and present trends in resource condition
and applicable scientific literature. For alternative A, a thorough review of the same data,
coupled with analysis of past management actions would be needed. All alternatives
necessarily must thoroughly discuss implications of emerging Mycoplasma bovis risk to bison
and potential mitigation, as they relate to longhorn management.

3.11 PURPOSE AND NEED: PARK PURPOSE AND SIGNIFICANCE

CONCERN STATEMENT: Because horses were a part of Theodore Roosevelt’s experience
during his time in and around what is now the Park, managing wild horses is part of the Park’s
purpose and significance. Theodore Roosevelt would have seen reproductive horses and cattle
at large, and they ultimately led to his awe and appreciation for the natural world and
subsequent creation of the NPS. Horses should also be protected because they are part of the
area’s culture and historic landscape, which should be protected under the Federal Land Policy
and Management Act and the Organic Act.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Wild Horses may not be native to this area but they have been here
longer than we have been a state. I would urge that these wild horses be allowed to remain
within the Park so visitors to North Dakota can continue to enjoy the site of wild horses. These

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fine animals cannot be seen any other place in North Dakota and it would be a shame to
deprive our citizens the joy of seeing them in the wild.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: For many people, myself included, the wild horses are Theodore
Roosevelt National Park. They are an integral part of what makes the park, the park. They are
part of North Dakota’s culture, traditions and history. These horses serve as ambassadors for
North Dakota, representing the ruggedness and heartiness of its people. Theodore Roosevelt
himself was a rancher and had an immense love of horses. They are a symbol of the man for
whom the park is named.

They were made part of the park when the park was established and fenced them in, therefore
they should remain a part of it. The horses have adapted over decades to not just surviving,
but thriving, in this environment. To remove them would be cruel.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The Park Purpose Statement fails to document the requirement to
protect Cultural and Archeological resources.

The legal, Enabling Legislation should be included in this Scoping Document to help us
understand what the park is to manage and protect.

Are there other Cultural Resources in the park that are being managed or protected?

The horses and cattle should be considered a Cultural Resource and managed as such.

THRO is not a pristine natural site, like Yellowstone and should not be managed as such.

Organization: Long X Visitor Center/Pioneer Museum of McKenzie County Organization

Type: Unaffiliated Individual

Representative Quote: Since the TRNP memorializes Theodore Roosevelt, the cattle and
horses are very representative of his time spent in North Dakota and should be part of the
park protection and that memorialization of TR himself. I believe this would also fall within
the “cultural” resource management responsibility of this park as well as the responsibility to
the communities of Watford City, Medora and western North Dakota. These specific animals
are culturally a large part of Theodore Roosevelts life, the reason of him locating to the area
as well as why many of those that live here today.

Organization: Individual - Family Organization Type: Unaffiliated Individual

Representative Quote: The wild horses in the Theodore Roosevelt National Park are an
important and integral part of the region’s history and culture. The herd was present prior to
the establishment of the park, and as such needs to be preserved. The animals are a part of the
park’s attraction to the public, therefore adding to its value

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Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Furthermore, 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 et seq. Unlike
other federal land management statutes (e.g., the Federal Land Policy and Management Act,
43 U.S.C §§ 1701(a), 1702(c)) 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
specific resources found therein. In relevant part, the Organic Act provides that NPS:

“Shall 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.”

Organization: Chasing Horses Wild Horse Advocates Organization Type: Unaffiliated

Individual

Representative Quote: The Park’s Purpose and Need Statement Must Embody Explicit
Consideration of Wild Horses’ Historical Significance Within the Park

As stated in its Scoping Notice, the Park’s “Purpose and Need” for the LMP and concomitant
NEPA analysis “is to address livestock, horses and cattle herds, within the Park, under relevant
laws, regulations, policies, and park management priorities including the conservation of
native species and natural prairie ecosystem functions.” Scoping Notice at 2. The Park also
lists five discrete objectives, including addressing impacts on Park resources and bringing
“livestock management into compliance with relevant laws, regulations, and policies.” See id.

Although the Park states that an LMP is also “needed to . . . [a]ddress operational
commitments to livestock management,” id., it does not make explicit the need to address the
herd’s historical significance within the Badlands landscape, which the Park is meant to
preserve as a tribute to Theodore Roosevelt and the “profound effect” it had on him. See, e.g.,
Foundation Document at 3; see also id. at 11 (listing “Theodore Roosevelt’s experiences in
the Little Missouri Badlands” as the first “interpretative theme” of the Park). As discussed
above and in CHWHA’s March 21, 2022 letter, wild horses are, indeed, an indelible symbol of
the rugged character of the Badlands and demonstrably played a role in “Theodore
Roosevelt’s experiences in the Little Missouri Badlands.” Id. at 11, 10 (acknowledging that
wild horses “were an important part of the cultural landscape when Theodore Roosevelt lived
in the area”). Thus, regardless of the Park’s classification of wild horses, the LMP’s impact on
their historical significance and the Park’s historic interpretation of the Badlands must be
made a part of the “purpose and need” for the herd’s future management. The Park should
amend its NEPA analysis accordingly, in order to avoid artificially narrowing the scope of
alternatives analyzed by the Park--which is demarcated by the purpose and need for the
action.

Organization: Not Specified Organization Type: Unaffiliated Individual

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Representative Quote: The modern public experience of the National Park is far more than
the experience of native flora and fauna. There is a historical preservation aspect to the Park
when visited. The historical connection to Theodore Roosevelt himself through the ever-
present references to Roosevelt within the Park Headquarters and throughout the area are
overwhelming. Although the park makes these misalignment claims, the Park Purpose
Statement leads to the conclusion that Roosevelt was inspired by the entire area including the
horses that roamed wild in his days here. His adoration for the equine is no secret.
Maintaining a historical herd of the horses in the Park is an enduring tribute to his heritage.

Organization: American Wild Horse Campaign Organization Type: Unaffiliated Individual

Representative Quote: The Park Purpose Statement similarly undercuts the alleged
justification for the NPS’s arbitrary decision to eliminate the wild horses. Specifically, the Park
Purpose Statement provides that the 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.” Id. Without question, wild horses are
integral to the scenery, native wildlife, and wilderness qualities of the Park - the landscape that
inspired Roosevelt and still inspires visitors today. This is readily and unequivocally
acknowledged in the 1978 EA and attributed to Teddy Roosevelt himself through a quotation
about the wild horses from Ranch Life and Hunting Trail. 1978 EA at 6. See also the NPS
“Horse Background and History” webpage (https://www.nps.gov/thro/learn/nature/horse-
history.htm). It is not clear why the agency now feels entitled to dismiss the stated purpose of
the Park and similarly ignore the perspective of its namesake.

Organization: American Wild Horse Campaign Organization Type: Unaffiliated Individual

Representative Quote: In addition, the horses at the Park have immense historical
significance based on their unique ancestry. As noted in The History and Status of the Wild
Horses of Theodore Roosevelt National Park, the horses in the Park are descendants of two
closely related stocks representing an original Badlands horse, with historical lineages that
trace all the way back to the horses surrendered by Sitting Bull in the late 1800s. Castle
McLaughlin, The History and Status of the Wild Horses of Theodore Roosevelt National Park
(Dec. 1989), available here: https://chwha.org/wp-content/uploads/2021/08/Castles-
report.pdf (hereafter “Castle”) at 244 and 70 and See
https://www.nps.gov/libi/learn/historyculture/sitting-bull.htm (with the NPS describing the
historical significance of Sitting Bull).

A recent study identified how unique and historic the mitochondrial lineage of the Theodore
Roosevelt wild horses truly is. See Ovchinnikov IV, Dahms T, Herauf B, McCann B, Juras R,
Castaneda C, et al. (2018) Genetic diversity and origin of the feral horses in Theodore
Roosevelt National Park. PLoS ONE 13(8): e0200795. available here:
https://doi.org/10.1371/journal.pone.0200795. Compliance with the Organic Act’s mandate
“to conserve the scenery, natural and historic objects, and wildlife in the System units”
requires that the agency examine this issue in great detail, regardless of its arbitrary intention
to eliminate this unique population of horses.

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Given this unique historical and cultural significance, the Organic Act requires that the agency
develop a plan to conserve, not eliminate, the wild horses in the Park. In developing a
conservation plan, the agency must examine current information regarding the genetic
viability of wild horse populations. The National Academy of Sciences (NAS) found in its 2013
report Using Science to Improve the BLM Wild Horse and Burro Program: A Way Forward
(available here: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3796106.pdf
(Hereafter “NAS Report”)) that a larger population of wild horses is necessary to maintain the
appropriate effective population size to maintain genetic diversity and that keeping
populations artificially low causes wild horse populations to increase at higher rates. NAS
Report at 161-16 and 81. In fact, part 4.4.6.3 of Bureau of Land Management (BLM) Wild
Horses and Burros Management Handbook (2010) provides that a population size of about
150-200 wild horses is recommended to maintain an acceptable level of genetic diversity.
(internal citation omitted). BLM, Wild Horses and Burros Management Handbook (2010),
available here:
https://www.blm.gov/sites/blm.gov/files/uploads/Media_Library_BLM_Policy_H-4700-
1.pdf at 22.

Therefore, absent showing a negative effect on other wildlife, there is no justification for
considering reducing the number of wild horses under the Organic Act, and in fact the agency
is obligated to plan maintenance of the population at a level that will ensure viability and
ultimately conservation. This is especially true given the characterization of the current
population limit for wild horses as “somewhat arbitrary” and an “arbitrary and administrative
decision” in the 1978 EA, which was further determined without any of the relevant
information included in the NSA Report. 1978 EA at 6 and 19.

Organization: Not Specified Organization Type: Non-Governmental

Representative Quote: 1.the National Park Service Organic Act, Implementing Regulations,
and Management Policies 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.0 §§ 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.

54 U.S.C. § 100101(a).

In 1947, Congress established the TRNP “to honor the memory of Theodore Roosevelt.”
TRNP, Foundation Document: Theodore Roosevelt National Park at 3 (April 2014),

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hops://bit.ly/3sPRgkK [hereinafter Foundation Document]; see also 16 U.S.C. §§ 241-247

(TRNP enabling legislation). To that end, the TRNP “preserves a landscape--the North
Dakota Badlands (also referred to as the Little Missouri River Badlands)--that had a profound
effect on Theodore Roosevelt.” Foundation Document at 3 (emphasis added). The Park’s
Foundation Document--which provides “basic guidance for planning and management
decisions” in the TRNP, id. at 2--defines “the specific reason(s) for establishment of the
TRNP as follows:

[TRNP] 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.

Id. at 6. According to the Foundation Document, “[t]he purpose statement for Theodore
Roosevelt National Park was drafted through a careful analysis of its enabling legislation and
the legislative history that influenced its development.” Id. As such, this “purpose statement
lays the foundation for understanding what is most important about this park.” Id.

Organization: Oregon Wild Horse Organization Organization Type: Non-Governmental

Representative Quote: As stated above the natural objects and wildlife that were there and
which were supposed to be part of this park to honor what Theodore Roosevelt saw and
found to be healing were in part the wild horses. While he called them feral, that legal
determination that stands today and which courts have ruled making them wildlife, had not
yet occurred. However, removing the horses removes a very large part of the landscape, the
scenery that he found there. When the NPS fought to keep this herd off the list of federally
protected herds it was with the understanding that they would be managed as a “historic
demonstration herd.” Doing this now, removing this entire herd makes what the public felt
was a promise to protect these horses as a special herd seem so disingenuous. This damages
the enjoyment of so many members of the public that own these lands, and these horses, and
will impair these natural resources (wild horses) leaving future generations of Americans void
of the chance to see this historic herd that has so many special meanings to so many groups of
people.

The American taxpayers who come and visit the park relate these horses to Theodore
Roosevelt, and often to the very creation of wild spaces. Some who know the Indigenous
history, and many members of tribes relate them to the Sitting Bull war horses. Taking these
horses away leaves a space where many of us will not want to be, there will be a void, a sadness,
a sense of loss of what once was. A loss of history that cannot be replaced. These horses are
unique and the experts you had as historians told you that.

The NPS used 2 different persons as historians. One was Robert M Utley, who worked for the
National Park Service for 25 years in various capacities, including being the Chief Historian
from 1964-1972. And the second was Dr. Castle McLaughlin, Associate Curator of North
American Ethnography at Peabody Museum of Archaeology and Ethnology. Both of these
people we believe filled the “cultural resources expert: position. However, in this decision to

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label the horses as livestock and ignore their cultural significance that evidence shows links
them to Chief Sitting Bull, the NPS goes against the research. If the NPS has employed, or
contracted with another professional who fills this expert position that needs to be explained
in the EA.

CONCERN STATEMENT: The NPS should not manage livestock in the Park because
recognizing Theodore Roosevelt’s leadership in conservation policy does not require managing
for livestock.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: It is fine to recognize Roosevelt’s role as hunter and rancher, but the
park itself should not be dedicated to these purposes. Commemorating his role does not
require hunting or the maintenance of livestock on these grounds.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Roosevelt himself, would most likely have preferred leaving these
lands in pristine condition. During his own life, he was torn between the urge to consume and
preserve wildlife resources. He expressed concern about killing one of the last remaining
bison in the area and did so in part because he could not help himself and because he reasoned
that others would, even if he did not. There is no need to repeat the Tragedy of the Commons
in this case. There is no greater need to maintain horses in Roosevelt N.P. than in Yosemite,
or Sequoia National Parks where they also once served the very industries that these parks
were established to prevent.

Organization: Retired Organization Type: Unaffiliated Individual

Representative Quote: This national park should be the strong exception to this appalling
pattern of destructive livestock management by these other federal land managing agencies.
This national park should expedite the removal of all non-native livestock to allow degraded
areas to heal and to demonstrate the ecological benefits of removing livestock.

3.12 PURPOSE AND NEED: NEPA AND CEQ

CONCERN STATEMENT: An environmental impact statement should be prepared due to the
controversial nature of the project for the following reasons:

• There are disputes as to the size, nature, or effect of the proposed actions.

• There is scientific controversy surrounding horse herds.

• There are social and economic effects of the proposed actions.

• There is the potential for significant impacts.

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Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Finally, due to the controversial nature of the LMP and the myriad of
legal, environmental, economic, and social issues it raises, an Environmental Impact
Statement is required.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Before moving ahead with its planning document, the NPS must
complete an Environmental Impact Statement (EIS). An EIS is unquestionably required given
the scope of the management plan, its profound impact on the quality of the human and
natural environment and the Park’s historic legacy. In addition, the Biden Administration has
implemented new policies to elevate and support the inclusion of traditional knowledge in
federal decision-making. Because these are considered Lakota, Nokota and Dakota horses,
the protections discussed above must be incorporated in the planning and reflected in the EIS.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: An Environmental Impact Statement (EIS) is required and should

consider and analyze the following alternatives:

• Change the designation of the Theodore Roosevelt horses from “livestock” to

“wildlife.” The NPS has given no reason for the “livestock” designation.
• To ensure a genetically viable herd, set a MINIMUM herd size of 150 horses as
recommended by not only Dr. Gus Cothran, geneticist and profession emeritus at the
Texas A&M School of Veterinary Medicine, but ALSO as acknowledged in the Bureau
of Land Management’s Wild Horse and Burro Handbook.
• Eliminate the use of GonaCon for the fertility control program due to serious concerns
about its potential for permanent sterilization and injection site abscesses.

3.13 PURPOSE AND NEED: INTERPRETATION OF PARK POLICIES, REGULATIONS, LAWS

CONCERN STATEMENT: Wild horses should be recognized as native wildlife, not livestock,
for the following reasons:

• Horses do not meet the definition of livestock because they are not domesticated animals
raised in an agricultural setting for economic profit.

• The NPS has never provided water, feed, or shelter to the horses, as it does for the
longhorn cattle.

• Classifying horses as livestock deprives them of certain important protections afforded to

wildlife.

• The NPS has classified the wild horses at Assateague Island National Seashore as wildlife;
the NPS should explain why it classifies the same resource differently.

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Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The Chincoteague horses are considered feral, even though their
history is largely unknown, much like the horses of TRNP. There is no definitive
documentation that the TRNP horses are direct descendants of ranch horses. Even if that
were the case, they are not livestock or domestic now. Labeling them as domestic livestock
just seems wrong. One could hardly go out and saddle one to round up cattle. And the United
States does not consider horses for meat. Is there any solid proof that horses did not exist here
before Roosevelt showed up?

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Equine species inhabited North America 2-4 million years ago and
may have even originated here, emigrating over a land bridge to Asia and Europe. That would
make them very much native to North America before going extinct on this continent
approximately 7000-10,000 years ago.

The modern horse was REINTRODUCED to North America by the Spanish approximately
500 years ago - long before the United States became an official country or the National Park
Service came to be. There is no genetic or paleontological evidence to support the contention
that modern horses in North America are a different species or that they are non-native.

Organization: Not Specified Organization Type: Non-Governmental

Representative Quote: The Park’s past concessions that “feral horses” are, in fact, “wildlife”
comports with how wild horses are managed in the limited few other NPS units where wild
horses are found. For instance, at the Assateague Island National Seashore, NPS maintains a
herd of 80-100 wild horses across 48,700 acres. NPS, Environmental Assessment of
Alternatives for Managing the Feral Horses of Assateague Island National Seashore at 7 , 28
(2008). Like the TRNP, the Assateague herd pre-dates that park’s establishment and
comprises descendants of domestic stock. Id. at 5, 62. Unlike the TRNP, however, the “feral
horse population [at Assateague] is managed, in general, as a wildlife resource.” Id. at 7
(emphasis added); see also NPS, Feral Horses, https :fib t.ly/.3Jabi ij (last visited Jan. 24, 2023)
(explaining that wild horses in the Cumberland Island National Seashore are considered by
NPS to be “non-native” wildlife). This, of course, flatly undermines the TRNP’s assertion that
horses must be “managed as a livestock display” because they “cannot be classified as a native
wildlife species” under the agency’s regulations. See Wild Horse EA at 1.

In sum, the TRNP wild horse herd cannot be reasonably classified as “livestock” under the
plain language of the NPS’s own implementing regulations. As a result, they must be
considered “wildlife” and managed accordingly. Such classification comports with the plain
meaning of the Park’s regulations, the historical understanding of wild horses in the Badlands,
the Park’s disparate treatment of similarly classified cattle, and other NPS units that manage
wild horses. To the extent the Park insists on managing its wild horses as “livestock,” it must

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thoroughly explain in any forthcoming NEPA document the rationale for its classification and
why these countervailing considerations do not apply or have been ignored by the agency.

Organization: Not Specified Organization Type: Non-Governmental

Representative Quote: To be sure, the TRNP horses are likely descendants of domesticated
animals, see id. at viii; however, the Park itself has long referred to the modern population as
“feral”--a term that, by definition, means these horses are no longer “domesticated” and,
therefore, no longer livestock. Compare Feral, Webster’s New Collegiate Dictionary (7th ed.
1967) (defining “feral” as: (1) “of, relating to, or suggestive of a wild beast”; and (2) “not
domesticated or cultivated” (emphasis added)), with 43 C.F.R. § 4100.0-5 (BLM regulations
defining “livestock” as “species of domestic livestock - cattle, sheep, horses, burros, and
goats” (emphasis added)); see also Wild Horse EA at 1 (characterizing the TRNP herd as
“feral”); Foundation Document at 36 (same). Accordingly, the Cumberland Island National
Seashore, TRNP’s sister park in the National Park System, has explained that a “feral horse”
is “an animal that was once domesticated, but has reverted to a wild state and adjusted to
surviving in a natural environment without help or support of any kind from humans.” NPS,
Feral Horses, https://bit.ly/3Jabiii (last visited Jan. 24, 2023).

Because the Park’s wild horses cannot be reasonably classified as “livestock,” they fall within
the ambit of NPS’s regulatory definition of “wildlife,” and must be managed as such. See 36
C.F.R. § 1.4 (defining “wildlife” as “any member of the animal kingdom”); see also Wildlife,
Webster’s New Collegiate Dictionary (7th ed. 1967) (“wildlife” means “living things that are
neither human not domesticated,” especially “mammals, birds, and fishes hunted by man.”
(emphasis added)). As explained above, wild horses have roamed free across North Dakota’s
Badlands (and specifically, the Park area)--without human intervention--since well before the
TRNP even existed, including during Mr. Roosevelt’s time inhabiting these lands. See TRNP,
Natural Resource Condition Assessment at 10 (Feb. 2014) (“When [TRNP] was established in
1947, several hundred horses were present in the park.”); see also id. at 8 (“These feral horses
have been found in western North Dakota for decades; their existence has dated back to the
mid-19th century.”); McLaughlin Report at 48 (“The wild horses found in the Little Missouri
Badlands when [TRNP] was created in 1947 were evidently an enclave population--the last of
several feral groups that once occurred throughout the western half of the state.”).

In fact, the Park itself has classified its wild horse herd as “wildlife” on several different
occasions. For instance, in 1974, the Park announced in local newspapers its “intent to manage
this horse herd as an integral part of the wildlife inhabiting the park.” McLaughlin Report at
140 (emphases added). Then, in the Park’s 1984 General Management Plan, which remains in
effect today, “wild horses” are listed as “Wildlife” in its description of “Natural Resources”
found in the Park. See TRNP, General Management Plan at 164 (1984). More recently, in the
Superintendent’s Compendium, the Park explicitly prohibits “disturbing wildlife,” including
“feral horses,” but does not extend that same prohibition to the Park’s longhorn cattle. See
TRNP, Superintendent’s Compendium of Designations, Closures, Permit Requirements and
Other Restrictions Imposed Under Discretionary Authority (Aug. 23, 2022).

Organization: Not Specified Organization Type: Non-Governmental

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Representative Quote: The wild horses in the TRNP are plainly excluded from NPS’s
definition of “livestock” for several different reasons. First, they have never been formally
“designated” as livestock--a necessary prerequisite under NPS’s own regulations. See 36
C.F.R. § 2.60(a)(3). Indeed, the Park has never promulgated any rule, through proper notice-
and-comment rulemaking or otherwise, defining “livestock” and/or explaining how the
TRNP wild horse herd fits that definition.

Second, there is no indication that the TRNP’s herd is domesticated in any way; that is, they
do not “live and breed in a tame condition,” and have not done so since long before Mr.
Roosevelt inhabited these lands. Domestic Animal, Webster’s New Collegiate Dictionary (7th
ed. 1967). The distinction between wild horses and actual livestock is typified by the Park’s
longhorn cattle herds, which “are managed in a more controlled environment, where they can
be handled and afforded supportive care.” See TRNP, Frequently Asked Questions About
Longhorn Cattle, https://bit.ly/3R5MHgG (last visited Jan. 24, 2023). Unlike the Park’s wild
horses, the cattle herd is provided with food (hay), nutritional supplements, water, shelter,
and veterinary services. See id.; see also TRNP, Management Plan for Longhorn Cattle at 3
(Oct.12, 1970), https://bit.ly/3wtXAPM (describing seasonal management recommendations
for TRNP’s cattle, including the provision of alfalfa and the use of a “small stock tank
equipped with a butane fired heater” to prevent the herd’s water source freezing during the
winter). By contrast, the Park has never fed, sheltered, or provided veterinary or other kinds
of care to the wild horses, which are uniquely adapted to survive North Dakota’s harsh
winters. See, e.g., McLaughlin Report at 158 (describing the Park’s wild horse herds as
“historically accurate and biologically well-adapted to the badlands environment”).

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Including the wild horses in a management plan for livestock is a huge
mistake. After reviewing the Theodore Roosevelt National Park 1984 General Management
Plan that you and your staff referenced throughout the virtual public scoping meeting on
January 12, 2023, it is clear that this document not only makes no reference to the wild horses
as livestock, but also speaks of the need for a WILD HORSE MANAGEMENT PLAN.
Further, the park’s own Foundation Document dated 2014 makes no reference to the wild
horses as “livestock” but instead speaks of the need for a Feral Horse Management Plan.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Protection for the TRNP wild horses also exists under 36 CFR § 2.60
(a) (3) as stated on the NPS website: “Theodore Roosevelt National Park horses are
maintained as a demonstration herd to represent a historic scene reminiscent of Theodore
Roosevelt’s time in the Badlands of North Dakota. Livestock, including horses, is allowed on
NPS lands to present a cultural scene and are managed per 36 CFR § 2.60 (a) (3).’’NPS Website
Frequently Asked Question 8. The same protection afforded by public law to the Assateague
Island National Seashore horses and the Shackleford Banks wild horses from Cape Lookout
National Seashore, another national park with wild horses.``

Organization: Not Specified Organization Type: Non-Governmental

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Representative Quote: As a threshold matter, the Park’s characterization and management

of wild horses as “livestock” runs contrary to the plain language of the National Park Service’s
(“NPS”) binding regulations, the Park’s past practice, and the treatment of these animals by
other parks within the National Park System. In reality, wild horses are “wildlife”--and they
should be managed as such.

CONCERN STATEMENT: The horses should be managed in accordance with the Wild and
Free-Roaming Horses and Burros Act of 1971.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Please do not remove wild horses from Theodore Roosevelt National
Park. These horses are protected under the 1971 Wild Horse and Burro Act and it is shameful
that our government has allowed the inhumane captures and helicopter roundups which
injure and terrify these animals

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The wild horses and burros of Theodore Roosevelt park should be
included in the 1971 Wild Free Roaming Horses and Burros Act. They should be protected
and managed appropriately without cruelty and harm. They are part of our culture and to
round them up and remove them would be a similar action of reintroducing them once you
realize your mistake. They have been an integral part of American history. Please protect them
and all wild horses and burros in the United States.

3.14 ISSUES: SOCIOECONOMICS

CONCERN STATEMENT: The NPS should consider the tourism draw and economic benefits
to the area and local communities provided by the wild horse herd. The plan should quantify the
costs associated with reducing the herd’s size or removing the herds altogether and consider
ways to increase the economic benefits associated with the herd.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The reduction of the wild horse population will have a far reaching
affect at TRNP than what is estimated. The majority of tourists come to see the wild horse
population because there is no other place like TRNP that has wild horses. Dramatically
reducing the wild horse population will cause huge drops in tourism. To be frank, Medora
doesn’t offer a lot to tourists. The wild horses could be capitalized on.

Organization: ND Travel Alliance Partnership Organization Type: Unaffiliated Individual

Representative Quote: In 2021, more than 770,000 trips were made to Theodore Roosevelt
National Park, half of those from out of state. These visitors pumped $16 million into Billings
County, the home to Medora and the south unit. Many of these visitors were treated to the
majestic sight of the horses grazing or running around in the rugged park.

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Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Another area that demands investigation is the impact the horses of
TRNP have on the tourism industry in Medora and surrounding communities. Although the
park offers a multitude of natural wonders and wildlife that attract visitors, it has been
sounded that a vast majority of people come for the opportunity to observe the feral horses in
their dynamic backdrop of the Badlands. The fact that TRNP is one of only a few National
Parks that have feral horses adds an exclusive uniqueness, putting the small town of Medora
on the map, and trickling down to boosting the tourism industry in ways that, without horses,
would not be possible. I am eagerly awaiting the town of Medora, Dickenson, and other
communities to speak out and declare their viewpoint on the state of horses in TRNP.

Organization: In Defense of Animals Organization Type: Unaffiliated Individual

Representative Quote: The Livestock Plan as currently drafted would have a significant
impact on tourism to the park and surrounding communities. In the Scoping meeting
Maureen answered that comment by saying that protecting the scenery and wildlife was what
Teddy Roosevelt championed. As the park’s mandate for following Roosevelt’s ideals, that is
what the park follows, to keep the wildlife community and habitat intact. As noted above, the
wild horses are native wildlife in their native habitat. But, that does not address the negative
impact on tourism that removing the horses would cause. The TRNP horses are beloved by
visitors from all over the country and the world. Proof of the impact that removing the wild
horses would cause can be found in a USA Today 10 Best Readers’ Choice Awards in 2017
which found the Pryor Mountain Wild Mustang Center in Lovell Wyoming to be the Number
One Best Attraction in the state of Wyoming. Keep in mind, Wyoming is the home to
Yellowstone National Park! Tourism entities in North Dakota are already concerned about
the removal of wild horses from TRNP as they are hearing from multitudes of past and future
visitors opposed to the wild horse removals. The economic impact from the reduction in
tourism to the area will be significant to the surrounding communities of TRNP.

Organization: Oregon Wild Horse Organization Organization Type: Non-Governmental

Representative Quote: A National Park Service (NPS) report shows that 793,383 visitors to
Fort Union Trading Post National Historic Site, Knife River Indian Villages National Historic
Site, and Theodore Roosevelt National Park in 2016 spent $49.579 million in communities
near these parks. That spending supported 681 jobs in the surrounding areas. According to
the 2016 report, most park visitor spending was for lodging (31.2 percent), followed by food
and beverages (27.2 percent), gas and oil (11.7 percent), admissions and fees (10.2 percent),
and souvenirs and other expenses (9.7 percent), local transportation (7.4 percent), and
camping fees (2.5 percent).

In 2020, Medora, ND had a population of 142 people with a median age of 43.8 and a median
household income of $51,563. The economy of Medora, ND employs 75 people. The largest
industries in Medora, ND are Accommodation & Food Services (21 people),
Construction (16 people), and Other Services, Except Public Administration (14 people), and
the highest paying industries are Total ($27,396).

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3.15 ISSUES: VEGETATION

CONCERN STATEMENT: Unmanaged livestock with no natural predators may have
detrimental effects on native vegetation through overgrazing when the livestock exceed the
desired management levels.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: As recently as our last visit to the South Unit in October 2022, the
number of feral horse herds and the number of horses per herd struck us as off-balance for
this ecosystem. These nonnative herds dominated the landscape on the trails and as we drove
the scenic highway. We have concerns about horse herd impact to the forage which is
detrimental to the bison and elk populations. While we have not seen the cattle herd directly,
this too is our concern that the forage they consume is better left to native wildlife.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: The EA should also include peer review of relevant literature on the
changes in plant species richness and herbage production when livestock graze riparian as
well as upland areas vs wildlife. The rate of change in the mixed grass prairie where the Park
is located is dependent on specific sites but a change is likely to occur towards a greater
diversity of native plants and more forage produced when livestock are removed. If a change
is made in the Park’s management of livestock, the Park should conduct a study documenting
any changes in plant species over several years.

CONCERN STATEMENT: Livestock, such as horses, can have beneficial impacts on the health
of rangelands, including the overall health of vegetation populations and communities. They
also can prevent wildfire.

Representative Quote(s):
Organization: none Organization Type: Unaffiliated Individual

Representative Quote: There have been numerous studies conducted on the ecological
impacts of wild horses, and the data overwhelmingly supports their importance in maintaining
healthy ecosystems. One study, published in the journal Ecological Applications, found that
wild horses play a crucial role in shaping plant communities in grassland ecosystems (Beaver
et al.,2023). The horses’ grazing habits stimulate the growth of certain plant species and help
to prevent the overgrowth of woody plants, which can lead to the degradation of grasslands.
This dynamic interaction between plants is essential for maintaining the diversity and health
of the ecosystem.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Another, very important and timely matter is that horses may help
prevent wildfires. Given the number of wildfires the west has experienced this should at the
very least be considered. “Horses are like slow-moving fire brigades,” stated NPR host Emily

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Kwong recapped in the outlet’s radio episode on the topic. “Their natural behavior changes
the landscape in ways that prevent wildfires from getting really big in the first place.”

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Wild horses are beneficial to the environment. The manner in which
they graze (unlike the cattle for which they have been erroneously scapegoated by various
industries) does not destroy plant life - it is beneficial to plants and animals alkie, and actually
reduces the likelihood of forest fires.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Horses are also healers of nature and help restore biodiversity unlike
ruminants such as cattle, sheep, goats, and white tail deer which have multi -chamber
stomachs containing bacteria, protozoa and fungi that allows them to digest plant materials
through fermentation. In Contrast, a horse, a non-ruminant herbivore only has a small, single
compartment stomach for digestion and no significant fermentation takes place. Horses’
stomachs are also relatively small, suited for more frequent but slow intake of forage as
opposed to large meals.

By not removing the wild horses of TRNP, it would allow for the horses to properly contribute
to the park in helping reseed the land through their manure as horses don’t digest seed unlike
livestock such as cattle and sheep. Because horses also have large manure, the seed is protected
in the clumps and can regrow and reseed, by extending the grass cycle through continuous
reseeding, as grass only has an average lifespan of five years. Horses are also a great component
in preventing wildfires through cutting down excess brush which act as fuel in the event of a
wildfire.

3.16 ISSUES: PUBLIC HEALTH AND SAFETY

CONCERN STATEMENT: Interaction with horses has been shown to benefit human health
and safety.

Representative Quote(s):
Organization: Salmonberry Tribal Associates Organization Type: Unaffiliated Individual

Representative Quote: Just being around horses has been shown to benefit human mental
and emotional states.

• The PATH Intl. mission statement: “The Professional Association of Therapeutic

Horsemanship International (PATH Intl.) promotes safety and optimal outcomes in
equine-assisted activities and therapies for individuals with special needs.”
• EAGALA statement - “Horses are the perfect partner. Because horses are highly
sensitive, clients can work through their life struggles by interacting with the horses
without feeling judgment or interpretation by another person.”
• Horses born wild have a unique ability to sense emotional trauma in humans: How
Wild Born Horses are Healing Human Hearts.

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• Wild Lands Wild Horses save TRNP horses website

3.17 ISSUES: WILDLIFE/SPECIAL STATUS SPECIES

CONCERN STATEMENT: The presence of horses has been found to have beneficial impacts
on native wildlife. Other native wildlife also should be managed, including prairie dogs, which
are more of a nuisance than horses.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: If you want to control a species in the park, our suggestion would be
to control the prairie dogs. They have taken over much of the grass there. They do not chew
the grass off so that new chutes can come up for the animals to graze on. They dig
underground and destroy the roots. All that will grow around the holes is weeds and cactus.
So the dogs go on to other areas to destroy more grass.

Organization: none Organization Type: Unaffiliated Individual

Representative Quote: In addition to their positive effects on plant communities, wild horses
also provide important benefits to other wildlife species. A study published in the journal
Biological Conservation found that the presence of wild horses in the Great Basin region of
the United States was associated with increased densities of pronghorn antelope and mule
deer (Gates Ella., 2011). The authors of this study suggest that the horses may indirectly
facilitate the presence of other species by creating foraging opportunities and modifying the
landscape in ways that benefit other herbivores.

Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: If the park gets rid of them, they will be doing a huge disservice to the
park and every tourist that comes to experience the park. The wild horses as much as the
buffalo and the elk are a part of the history of this area. The praise dog population is
overpowering and more of a nuisance than anything, causing holes for animals to easily break
a leg never mind what they do to the grass. Manage that species to a reasonable level and allow
the vegetation to flourish and keep the horses.

CONCERN STATEMENT: The NPS has failed to state why wildlife, such as mule deer,
pronghorn, elk, and bison, some of which are reintroduced to the landscape, are not managed in
the same manner as horses, and why horses are not also considered wildlife since they have also
been reintroduced into the Park.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Elk and Bison have been introduced into the Theodore Roosevelt
National Park. They too, can fit your definition of livestock, just as you have designated the
wild horses. If you rid our Theodore Roosevelt National Park of wild horses, should you also

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 3. Scoping Period Comment Summary (ISSUES: Wildlife/Special Status Species)

rid the park of the bison and elk? I think you should treat them all as equals. Rid the park of
horses, follow suit with the elk and bison.

My honest opinion is the horses, bison and elk are either all wildlife or all livestock. If you
treat them differently, I think there will be a huge public outcry.

Organization: Chasing Horses Wild Horse Advocates Organization Type: Unaffiliated

Individual

Representative Quote: 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. See
TRNP, General Management Plan at 41 (1984) (describing TRNP’s efforts to combat disease
amongst the “introduced” population of California bighorn sheep through “reproductive
recruitment from the existing animals, thereby gradually developing a self-sustaining
population of bighorn”); see also TRNP, Natural Resource Condition Assessment at 9 (2014)
(“Following reintroduction, the elk population grew rapidly, exceeding the NPS-established
maximum population threshold,” leading to the “harvest [of] appropriate animals (adult cow
elk)”); id. (explaining that “[g]enetic variability is a major management goal” for the TRNP’s
selective removals of bison from the Park, “as inbreeding can cause decreased heterozygosity,
adaptive response (ability of herd to adapt to environmental changes), and population
viability”).

Organization: Oregon Wild Horse Organization Organization Type: Non-Governmental

Representative Quote: With the bighorn, the park has had to deviate slightly from its policy
of reintroducing only indigenous fauna. By the time Roosevelt arrived in the badlands in 1883,
Audubon mountain sheep (Ovis canadensis auduboni) were well on their way to being routed
from Dakota by the impinging cattle industry. None, anywhere, survived the end of
Roosevelt’s presidency. Even if bighorn sheep did not figure prominently in his writings, their
importance to a simulation of a 19th-century ecosystem, their desirability as a game animal,
and, one imagines, their nobility and beauty of movement made it incumbent upon the Park
to try to re-establish a herd. Since Audubons had gone completely extinct, California bighorn
sheep (Ovis canadensis califomiana) were chosen instead.
https://www.nps.gov/parkhistory/onlifIQ, j)Q0kQiittNiadtli9.11trn
7 Irby, Lynn R.; Norland, Jack E.; Sullivan, Mark G.; Westfall, Jr., Jerry A.; and Andersen,
Paula, “Dynamics of Green Ash Woodlands in Theodore Roosevelt National Park” (2000).
U.S. National Park Service Publications and Papers. 3.
https://digitalcommons.unledu/natIpark/3

The NPS on these points must reconsider the statement that they are going to focus on native
wildlife. This cannot be accomplished by getting rid of the horses and not bison, elk,
pronghorn, and bighorn sheep, when the only native wildlife large herbivores that existed
when the Park was created were deer and horses.

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3.18 ISSUES: WATER RESOURCES

CONCERN STATEMENT: Livestock cause significant impacts on water resources, including
the degradation of water quality, fisheries, and riparian areas, and contribute to E. coli
contamination.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: Horse populations on federal lands have exceeded nuisance levels.
With no natural predators and all human related population management tools prohibited or
curtailed, horse populations are unchecked. Horses incur a significant impact upon natural
landscapes. Horses also have a significant impact upon natural water sources and natural
vegetation. They also out compete native animals on the landscape.

CONCERN STATEMENT: During the winter months, horses help smaller animals survive by
breaking ice and exposing food and water that are otherwise inaccessible.

Representative Quote(s):
Organization: Not Specified Organization Type: Unaffiliated Individual

Representative Quote: During winter months wild equine have been proven to break the ice
in riparian areas where land meets the rivers and streams as well as ponds and lakes, to drink.
This opens the way for other wildlife also to have access to water.

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