The comment period has passed for letting the U.S. Forest Service know what you think of its Draft Environmental Assessment (DEA) of the proposed gravel mining operation near the Elkhorn Ranch. I’ve written several articles about this issue. But none of my articles is as eloquent and thoughtful as the one I am going to share with you today. It was written by Jan Swenson of Bismarck, who represents the several hundred members of the Badlands Conservation Alliance (BCA). I’ve written about BCA and its work on behalf of wild places in North Dakota before. If you love the Bad Lands, as I do, and if you care about protecting wild places in the face of the most massive intrusion on North Dakota’s landscape in our history, but you’re not yet a member of this organization, I urge you to go to their website and find out how to join. The battle to save western North Dakota is not yet lost, and Jan and her BCA troops are leading the effort to protect North Dakota’s best places. I hope you’ll join them. Here’s Jan’s letter to Ron Jablonski, the chief ranger at Dickinson’s Forest Service office:
Dear Mr. Jablonski:
It is the position of the Badlands Conservation Alliance that the Forest Service missed the integral issue at stake in development of the Draft Environmental Assessment (DEA) for a proposed gravel pit at the Elkhorn Ranchlands.
Badlands Conservation Alliance actively participated in the circuitous public process that resulted in the US Forest Service acquisition of the Eberts Ranch from its inception as a proposed Elkhorn Preserve under the management of the National Park Service. Our intent was and is to maintain the highest degree of protection for the 218-acre Elkhorn Ranch Unit of Theodore Roosevelt National Park, retaining the values young Roosevelt found there while safe-guarding the physical birthplace of his conservation ethic.
Any discussion of proposed actions on the Elkhorn Ranchlands should harken back to a conversation held over pizza in the community of Medora in 2000. Ranchers Ken and Norma Eberts carried a vision to then Park Superintendent Noel Poe for what is now the Elkhorn Ranchlands. That meeting pivoted on expanded protection for the Elkhorn Ranch Unit of Theodore Roosevelt National Park and the legacy of Theodore Roosevelt – in North Dakota, for the nation, and into the wider world.
It is only by the work of many and diverse supporters over more years than we care to remember that the dream survived and grew, culminating in the 2007 acquisition by the US Forest Service. All proposed actions should honor the memory of that original meeting. The Forest Service is by circumstance the caretaker of the work and dreams of many.
The US Congress in 1947 authorized the creation of Theodore Roosevelt National Memorial Park only after pointed inclusion of the Elkhorn Ranch Unit itself. The Elkhorn Ranch Unit is the site that inspired and won the establishment of Theodore Roosevelt National Park, and it is the impetus for the very existence of the Forest Service-managed Elkhorn Ranchlands today.
The Primary Issues of Soundscape, Tourism and Visuals as identified in the Draft Environmental Assessment make a dry attempt to speak to and analyze what a gravel pit would mean to the Park and to the Elkhorn Ranchlands. However, the question at hand cannot be defined by simple measurement and mitigation strategy. The core of this decision process runs much deeper.
When 26th President Theodore Roosevelt signed the Antiquities Act of 1906 into law on June 8th of that year, he, of course, could not have known how such executive authority might play out in protecting the national significance of a National Memorial Park designated in his honor. The current outcry for securing the future of the Elkhorn Ranch lies in social values not easily expressed in terms of tourism. These values, tied up in national identity and American ethos, are the primary issue.
The DEA must be revised to take into account the announcement of efforts by Theodore Roosevelt admirers across the nation to gain National Monument status for these lands. Equally significant is the announcement on June 6, 2012 of the inclusion of the Elkhorn on the National Trust for Historic Preservation’s 2012 List of America’s 11 Most Endangered Historic Places.
The Forest Service decision on the proposed project will move the Elkhorn to greater or to lesser risk. Acquisition was not merely an opportunity for the Forest Service; it is a responsibility and a trust.
Mr. Roger Lothspeich purchased the surface minerals addressed in this DEA well after finalization of Forest Service purchase of the former Eberts Ranch. His transaction was speculative at best, and he made it clear from the onset that he was pitting financial gain against recognized public interest.
Badlands Conservation Alliance recognizes the Forest Service has a legal responsibility to satisfy the mineral ownership of the applicant. However, the Forest Service also has a public obligation in the NEPA process to examine a range of reasonable alternatives. This DEA offers only two alternatives, one of which is likely illegal, and the other demonstratively contentious. This failure to meet NEPA requirements must be remedied, and should include an alternative allowing for mineral exchange.
As stated in our comment letter of October 11, 2011, BCA considers it the Forest Service’s duty to satisfy all alternatives to mining prior to approval of any proposed operating plan, and to uphold the Forest Service concept of “The Greatest Good.” Recent efforts have come to bear on this proposed gravel mine that would alter how the public’s and the applicant’s interest might best be served.
We insist that the Forest Service continue to pursue a solution for a resourceful public/private interface which would satisfy the relevancy of Roosevelt’s words in 1916: “Our duty to the whole, including the unborn generations, bids us restrain an unprincipled present-day minority from wasting the heritage of these unborn generations.”
If the Forest Service struggles with this decision, let Roosevelt guide you.
Thank you for the opportunity to comment.
Respectfully,
Jan Swenson, Executive Director
Badlands Conservation Alliance
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