This West Is OUR West

Comments re: Notice of Intent to prepare a Comprehensive Conservation Plan (CCP) for the National Bison Range, Moiese, Montana

U.S. Fish and Wildlife Service

Toni Griffin, Refuge Planner

National Bison Range CCP

134 Union Boulevard

Lakewood, CO 80228

February 1, 2017

Mr. Griffin,

The following comments have been prepared on the scope of planning as described under the Notice of Intent (NOI) to prepare a Comprehensive Conservation Plan (CCP) for the National Bison Range, Moiese, Montana.

It's gratifying to see the U.S. Fish and Wildlife Service (Service) finally recognize the importance of preparing a CCP for one of the most iconic wildlife refuges in the National Wildlife Refuge System. It is long, long overdue. Unfortunately, the Service is not starting out this process in a very professional manner, as the NOl is inadequate and inconsistent with Service policies on preparing CCPs. These policies were prepared as a guide to the Service so planning activities could be consistently carried out in accordance with the National Wildlife Refuge System Administration Act of 1966, as amended by the Refuge Improvement Act of 1997. They were also prepared to step down key features of the National Environmental Policy Act of 1959 so management actions being considered could be properly evaluated for impacts under full public disclosure. A questionable state of compliance has created an appearance that the Service has not taken these congressional statutes to heart or embraced the spirit of their intent. The following points will articulate these shortcomings.

First, the Service has not disclosed any important refuge issues to focus on that appear to fall within the scope of the CCP. AII national wildlife refuges have resource issues, and given the complexity of the National Bison Range and its existence for over 100 years, there could be many issues worth evaluating to see how they may be addressed while formulating alternatives. These issues of the refuge when disclosed up front by the Service, can serve as a basis for thought provoking input from the public in an effort to flush out other issues of concern and aid in the evaluation of effects tied to other problem solving alternatives.

Second, the Service should begin to identify known alternatives as part of this NOI, but it is inappropriate to label any of them as a "preferred management option" at this stage of the planning process. It is extremely pre-mature, and unacceptable under any planning process, to boldly claim a preference in management when there has been no public involvement or input from stakeholders, and there has been no evaluation of any management impacts. Selection of a preferred alternative should happen only after these actions have been acted upon, occurring much later in the process. A significant level of public participation and involvement is the hallmark of the CCP process and this is what sets it apart from other planning efforts undertaken by the Service on behalf of the Refuge System. CCPs set a very high bar, a standard other processes have never come close to matching. Within the NOI the Service argues and implies that past public input over the years for the National Bison Range justifies a current position for a preferred management option. I'm not aware of any planning process for the National Bison Range, completed by the Service from beginning to end, that can be compared to and considered an equal to a CCP effort under consideration today.  Furthermore, never have I seen any Notice of Decision as part of a record for preparing a Finding of No Significant Impact in association with an Environmental Assessment Even if some form of planning effort has been completed and finalized, it would fail to meet the public and stakeholder threshold requirements of a CCP. Any previous planning effort should be cited and rolled into the CCP process as additional information. None should be construed as an adequate substitute for any part of this CCP. Good examples of former planning efforts include Habitat Management Plans, Fire Management Plans, Visitor Services Plans, etc.

Third, and as previously stated, the Service should begin to identify known alternatives as part of this NOI. This document should briefly address a current management alternative as a baseline. It should state that a preferred management option be developed as a preferred alternative once all alternatives have been evaluated. Finally, it should briefly summarize other alternatives that properly fall within sideboards and scope of the CCP. Each alternative must still articulate how it will address purposes for establishment of the refuge and the Refuge System mission. One such alternative that appears to have been grossly overlooked is that which serves Enhancement in Management This enhancement strategy could take on current limitations within the visitor services program, or other resource management programs. In particular, given the National Bison Range's purpose for establishment of preserving the American bison, it seems appropriate to consider the refuge's role in biological diversity and ecosystem management where purity of genetic strains of bison are preserved for restoration of herds at various locations of the Great Plains. This would be part of a greater landscape conservation effort. In regards to the Annual Funding Agreement alternative, I find this to be a difficult sell given all the challenges and issues the Service has faced with its implementation over the recent past

Finally, it is noted that the Service intends on inviting the Confederated Salish and Kootenai Tribes (CSKT) to participate in the CCP process as a "cooperating agency". It is unclear how that role will unfold at this time. However, it is clear that there is a substantial historic relationship between the Service and the CSKT, and that there is much to gain by the tribes under certain alternative scenarios. This fact is all the more reason the Service must take extra precautions to remain transparent and open to all stakeholders and the public at large. It must be disclosed with certainty that the Service will remain sole and full decision making authority throughout the duration of the CCP process as required by federal statute and law.

In closing, it is my hope that the Service recognizes this opportunity as a major milestone in the crossroads for conserving the American bison. A well-laid foundation in planning can add greatly to the Service's ability to make sound decisions in cooperation with its partners, and help realize a vision for this iconic refuge which is both inspiring and shared by many. Wildlife of the National Bison Range, the American people, and in particular, our national mammal, deserves nothing less.

Please feel free to contact me if you have any questions regarding these comments.


Ralph D. Webber

Troy, Montana 59935

(406) 295-5952