U.S. Fish and Wildlife Service
Bernardo Garza, Branch of Planning and Policy
134 Union Boulevard, Suite 300
Lakewood, Colorado 80228
Dear Mr. Garza,
The following comments have been prepared on the draft Comprehensive Conservation Plan (CCP)
and associated draft Environmental Impact Statement (EIS) for the National Bison Range headquartered in Moiese, Montana.
My comment is in part come from the 16 years I worked at National Bison Range maintenance Department. With a crew off our full time and 2 seasonal. It was a full time job to keep the National Bison Range up to refuge standards. I hope Fish and Wildlife Service will not lower those standards. As noted and by admission within the CCP, the proposed establishment of the Western Montana Complex is a significant planning issue. Rational decision makers would have chosen the National Bison Range for the complex headquarters, primarily for its location and having the infrastructure in place, as well as its historical status and resources for drawing the highest number of refuge visitors. Total disregard
and adherence to the guidelines of NEPA is setting the table for another challenge in court, and as already stated the Region’s track record is dismal in winning any litigation. Complexing of the National Bison Range should have been addressed and totally analyzing in each of the alternatives, as the argument that this is a dollar saving issue is political.
Environmental consequences. This decision of super-complexing the National Bison Range Complex Lee Metcalf Refuge with the Benton Lake Refuge Complex is the pentacle of arrogance with a total disregard of disclosing impacts as directed within the spirit of the National Environmental Policy Act (NEPA).
The Bison Range has been reduced to 4.5 on site staff, less than a third of the staff it had 15 years ago and less than half assigned only 5 years ago. These Bison Range-based employees are also responsible for the management of Pablo and Ninepipe refuges a long with several waterfowl production areas. By contrast, there are 23 FTEs currently assigned to the Rocky Mountain Arsenal in Colorado, a refuge which is smaller in size then the Bison Range but with similar visitation and purposes for preserving plains bison. This disparate treatment at its best.
In its 111 years heritage the National Bison Range has never faced as much disregard for land wildlife and the public. This goes directly against the very reason it was created. This is a result of the regional office in Denver over riding sound on the ground management. It would be no wiser than to allow a banker to manage the ranch. Bankers bottom line is more important then the survival of the ranch. A fine example of poor decision making by the Regional Office. A brand new maintenance shop at the National Bison Range none operational before it had to be condemned. The $800,000 building had no on job inspector to save money. Which is not standard procedure for such an investment. The building now broken in half and has sunk 7 inches. The answer from the Denver Regional Office is to tear it down and start over at the cost of over a million dollars. This could have been avoided.
These are the very Regional Leadership that be in full charge of financing the National Bison Range under complexing. and CCP.
Complexing with out added maintenance workers to do the qualify work is no more then a shell game. The added cost of windshield time perdeum and veical wear is compounded by loss of on site time. Maybe the regional office will make the staff report to a satellite refuge on there time and dime. When a refuge staff is detailed to a different refuge there work at home refuge goes undone, And when the complex refuge sends it’s staff to help their work goes on hold. this is a very expensive shell game indeed.
I was told at more then one public meeting that complexing can change the CCP if the regional office see fit. Hard for me to understand how. Complexing can be trump. Since NEPA and EIS are required. then it should be required for complexing. The negative impacts will be to numerous wildlife resources and neighboring communities of each refuge within the Complex.
Partnership: I also want to point out that the FWS already has a very successful partnership with the CSKT, despite the absence of an AF A. Refuge employees and the Tribes natural resources department (NRD) prepared a joint grant to restore grassland habitats on the refuge. The grant, which can only be applied to federal lands within or adjacent to Tribal Reservations in nearly $1 million dollars, most of which has been given to the Tribes to implement the restoration program designed by the FWS. Tribal employees have been removing invasive Douglas Fur trees in order to restore native grasslands, critical to bison and other refuge wildlife. The NBR also has a long standing and successful partnership with the Tribes fire management program. The CSKT are responsible for initial attacks of any fire on FWS
lands within the Reservation boundary. These same individuals have assisted with prescribed burning programs, used to improve refuge habitats. It must be pointed out that these successful partnerships were negotiated at the field level with little or no interference from regional or national leadership, and attorneys on both sides.
Visitors Center: The discussion regarding the visitor center is also troubling, and seems to deliberately diminish the outstanding environmental education and interpretive programs that formally existed at the NBR. The Region’s action not to fill any vacant visitor services position’s and selectively keeping the center closed to the public during peak visitor periods in unforgivable and requires an in depth discussion. The CCP indicates a smaller visitor contract station will replace the visitor center under alternative A. Doing this will result in diminishing the environmental education opportunities and interpretive programs. This is definitely another deliberate efforts to diminish the NBR’s once
outstanding programs as well as necessary funding. This downsizing effort should be handled as a current management action under Alternative A. Also, the enhanced visitor services option to improve programs. It is confusing using the terms visitor contact station and visitor center together within this document, and clarification is needed. Here again the entire discussion regarding the visitor center and contact stations seems deliberate to reduce the NBR’s funding and true potential for maintaining or expanding visitor use. This is yet another fine example of how the Denver Regional Leadership in charge can in vision what is best suited for not only there budget but also for the ecological
preservation of the existing refuge. To move and build new is more than a waste of valuable resources. It is an unreasonable destruction of habitat. With a no square foot gain on the wildlife refuge. What good could come of that?
I hope the FWS, will use the comments they receive to the best of their abilities. With out increase qualified staffing and funding at the National Bison Range none of the alternatives will work.
I would urge the service:
l. No complexing
2. Increase maintenance staffing by three
3. A partnership with the CSKT, pay as you go, no AFA
4. Leave the visitor at Moiese and build office space as needed
5. Altemative A will do the lest amount of damage to the National Bison Range
The Fish Wildlife Service should take note. If they do not make a wise choice in regards to the National Bison Range. They will find itself in court again. They have a poor track record so far. The Regional Office seems to try everything else before doing the right thing. If they screw this chance to do the right thing this time. Maybe a different region should replace region six.
Skip Palmer
54624 Hwy 212
Charlo, MT 59824
Retired Fish and Wildlife Service
Region Six