Elk Management Plan / EIS Comments

I have reviewed the Elk Management Plan and Environmental Impact Statement in its entirety and have weighed the options carefully. I am pleased to have identified an Alternative that I support and that I hope will be the choice the park makes in the end.

Below is a copy of the comments I submitted about Theodore Roosevelt National Park's Elk Management Plan. It should be made clear that these are my comments as a citizen, and they do not reflect the opinions of Theodore Roosevelt National Park, the National Park Service, or any of their employees, nor do my comments reflect any official position on the part of any group, agency, or other entity. Theodore Roosevelt National Park has not identified a preferred alternative, and the issue is open for debate. I think that makes it more important to comment on than most documents of this type. Anyone interested in reviewing and commenting on the Elk Management Plan can do so here. The document is open for public comment until the end of the day, 3/19/09.

My comments:

After a full review of the entire Elk EIS / Management Plan, I feel sufficiently informed and confident to identify an option that I support and that will meet Theodore Roosevelt National Park and National Park Service objectives. I support Alternative D, termed “Testing and Translocation,” for reducing and maintaining the size of Theodore Roosevelt National Park’s elk herd.

Alternative D, “Testing and Translocation,” provides the park with the means to meet its elk management goals while achieving all of the collateral goals of the wildlife management action. Additionally, it addresses my personal concerns for the public perception of the National Park Service and its methods for wildlife management. The option does not preclude continued hunting opportunities outside the park. Importantly, Alternative D will have a minimal impact on visitor experience in the park, and will be the easiest action for the park to reconcile with U.S. citizens of diverse backgrounds from all fifty states.

I prefer Alternative D because I strongly feel that it is the most ethical choice and the most beneficial for the most parties involved. Since Chronic Wasting Disease (CWD) has not been documented in the park, I am confident that some of the animals would be allowed to live elsewhere at the end of the action. If it is the underlying logic of the elk management action that some elk must die so that others may live, do not the largest number of animals live when some of the herd’s elk are translocated? Although the action’s flow chart suggests that it is a complicated course to pursue, any failure to reach the ultimate goal – the delivery of park elk to a willing recipient – would have the same net result as Alternative C, reduction by euthanasia. Why not at least try to let some of the population survive where they can be a benefit to other people, agencies, and ecosystems? Those elk selected for translocation could later be hunted, thereby achieving the goals of Alternative E, to “increase elk hunting opportunities outside the park.” Lastly, I prefer the option because the processing and testing is done off-site, where it will be out of public view and where it will have the least impact on visitor experience.

I am very uncomfortable with Alternative B and Alternative E because they are politically sensitive and do little to benefit the park’s surviving elk population. Alternative B allows the most vocal opposition to the Park’s elk management action – hunters – to find further cause for complaint. My fear is that “skilled volunteers,” as suggested by the language in the Elk Management Plan, will be a small and marginal factor in the action, causing only frustration for vast majority hunters that wish to be involved but would not be allowed to participate. It is better to preclude anything remotely resembling “hunting.” Additionally, how would the public perceive elk carcasses being dragged out and removed from the kill zones by park officials? Alternative E is inadequate for reducing and maintaining the elk herd, as scientific data in the EIS show. The elk appear to know what areas are “safe” to them and which are “unsafe,” from a hunting standpoint, and tend to avoid leaving the park.


The park must be very careful in how it would “look to increase elk hunting opportunities outside the park.” Sharing real-time locations of elk, or worse, driving them outside the park with a helicopter or other means violate the ethics of sportsmanship and reflect poorly on the National Park Service. The image of a helicopter driving elk out of the park into the sights of waiting hunters is too easily drawn as an editorial/political cartoon. In addition to the elk’s situational awareness making them difficult to maintain through hunting, hunting is a pastime of a minority of Americans with a shrinking number of participants. There are other concerns about hunting and its unintended consequences for the elk population’s health. A January 12, 2009 article in Newsweek, “It’s Survival of the Weak and Scrawny,” describes how trophy hunting has changed the laws of natural selection in animals such as elk since Theodore Roosevelt’s time: the largest bull elk are killed and the younger, less-impressive bulls do more breeding. Over time, the genetic makeup of the hunted animals changes, with the surviving generations becoming smaller, weaker, and demonstrating “frighteningly little genetic diversity,” according to the article. In increasing hunting opportunities outside the park, the overall health and genetic robustness of the herd the National Park Service was created to protect “unimpaired for the enjoyment of future generations” must be considered with an understanding that hunting tends to reduce the virility and vitality of the elk herd. By instead pursuing Alternative D, “Testing and Translocation,” the park would be a nursery for elk with the vitality and characteristics of the elk that Theodore Roosevelt hunted in the 1880s. Preserving the animals and landscape as Theodore Roosevelt experienced them is a goal of Theodore Roosevelt National Park.

Likewise, Alternative A, the “No-Action Alternative” would spell disaster within a few years. I have heard some individuals say that the elk would “move out” before they would allow themselves to deplete the forage available to them, but this is erroneous. Elk, as the EIS indicates, have site-specific habitat preferences, and would likely degrade the land if they were allowed to become overpopulated as other deer species have been known to do in the past. As Aldo Leopold recognized, in the absence of some form of population control, deer species can be very destructive to the land, leading to erosion and negative impacts on plants and other animals. Leopold wrote in his essay “Thinking Like A Mountain,” “I have seen every edible bush and seedling browsed first to anemic desuetude and then to death….In the end, the starved bones of the hoped-for deer herd, dead of its own too-much, bleach with the bones of the dead sage, or molder under the high-lined junipers.” Taking no action for any reason would be irresponsible for the elk, the plants, the soil, and the other animals that depend on those plants and the habitats they provide. Allowing overgrazing and the resulting starvation die-off would also be a shameful waste that would detract from the visitor experience. It is my expectation that Theodore Roosevelt National Park will pursue another option before it allows such a situation to occur, and I am encouraged that the Elk Management Plan strongly leans toward other options.

Alternative D, “Testing and Translocation,” is the best option for the reduction and continued management Theodore Roosevelt National Park’s elk population. Alternative D will meet park goals for reducing and managing the elk population, will minimize political opposition because hunting will remain at present or increased levels statewide, and will have the minimum impact on visitor experience in the park. It is also easier for the park to reconcile through its efforts in interpreting the management policy for the public: imagine a park ranger standing in front of a group and explaining how the park transported some of the herd elsewhere, then imagine him or her explaining why hundreds of elk are being shot from helicopters and having their carcasses hauled out of the park, or why the park is promoting hunting. There are the most good reasons to pursue Alternative D, and the fewest reasons not to pursue it.