Yellowstone Bison Translocation Team
Montana Department of Fish, Wildlife, and Parks
1420 E. 6th Ave.
Helena, MT   59601
E-mail:  QFBison@mt.gov

January 7, 2010

Subject:  Comments on Wild Yellowstone Bison Translocation Draft Environmental Analysis, Phase IV Quarantine Feasibility Study

Dear Montana Fish, Wildlife, and Parks Yellowstone Bison Translocation Team,

Thank you for the opportunity to comment on Montana Fish, Wildlife, and Park’s “Draft Environmental Assessment on the Translocation of Quarantined Yellowstone Bison.”

I would like to go on record as strongly opposed to the Quarantine Feasibility Study.  Much better solutions are available.  We need to fully protect the entire Yellowstone bison herd and encourage its growth.  We need to create wild Yellowstone bison migratory corridors throughout tribal lands, U.S. Forest Service lands, U.S. Bureau of Land Management lands, state land, wildlife refuges, national parks, roadless wildlands, and wilderness area.

We need to map out all potential bison habitat on public lands.  We need to identify all potential winter and summer range on public lands around Yellowstone National Park, with a special emphasis on designating and protecting spring calving grounds.

We need to reduce potential for wild bison to get diseases from domestic livestock.  Where any overlaps or potential conflicts might occur, we need to remove domestic livestock from our public lands, to ensure that public wildlife get the habitat they need and deserve.  On private lands in the Greater Yellowstone Ecosystem, we need stringent cattle-based brucellosis-risk management programs that will keep our Montana cattle herds completely brucellosis free.

Yellowstone’s bison are genetically and behaviorally unique – the ONLY herd with continuously wild ancestry from the days when millions of wild bison migrated freely across the Great Plains.  After the government-sponsored holocaust of these bison and the Indigenous Peoples that depended upon them, only 23 wild bison survived, taking refuge in Yellowstone’s remote Pelican Valley.  Yellowstone’s priceless endangered and tattered remnant herd is all that remains of 50 million wild bison!  This herd, pushed to the brink of extinction, is America’s only remaining wild migrating bison.

Wild Yellowstone bison have naturally migrated to the public lands now contained within National Forests and other public lands for millennia.  However, instead of being allowed access to their own habitat on our own public lands, this magnificent and imperiled species has been subjected to mindless slaughter by Montana Department of Livestock cowboys.

Thankfully, the Gallatin National Forest is currently mandated by its Forest Plan to “provide habitat for viable populations of all indigenous wildlife species.” We all need to work closely with the Gallatin National Forest to make sure it lives up to its Forest Plan.  The Gallatin National Forest needs to do everything it can possibly do to encourage wild Yellowstone bison to naturally migrate to public lands adjacent to Yellowstone National Park.

We need to utilize the Gallatin National Forest’s mandate to“provide habitat for viable populations of all indigenous wildlife species” as a model for all National Forests and other public lands within the Greater Yellowstone Ecosystem.  Every other National Forest within the Greater Yellowstone Ecosystem needs to incorporate similar language into their Forest Plans and their resultant administrative actions.

Public lands must be managed for public wildlife.

America’s public lands legacy deserves vibrantly healthy migrating herds of wild bison within the Greater Yellowstone Ecosystem.  National Park Service, U.S. Forest Service, U.S. Bureau of Land Management, the States of Montana, Idaho, and Wyoming, and all other public land managers need to take administrative actions necessary to enlarge the wild Yellowstone bison herd, to promote the natural migration of Yellowstone bison, and to provide the publicly-owned habitat so essential for the prosperity of these magnificent wild animals, the very symbols used to portray the American West and the U.S. National Park Service itself.

These solutions worked perfectly for tens of thousands of years.  If we are wise enough to return to them, the genetic strength and population of the Yellowstone bison herd (both now under relentless assault by the Montana Department of Livestock) will again become tenable.  Yellowstone bison have naturally migrated to these public lands for millennia.  The restoration of wild bison within the Greater Yellowstone Ecosystem will become a success story heralded worldwide, perhaps rivaling the proud creation of Yellowstone National Park, the world’s first national park.

You, as our Montana Department of Fish, Wildlife, and Parks, need to work closely with the National Park Service and the U.S. Forest Service and other agencies to provide for migration of Yellowstone bison into all National Forests and other public lands around Yellowstone National Park.  Yellowstone bison are just like elk.  They need access to these public lands.

You, as the Montana Department of Fish, Wildlife, and Parks, need to closely coordinate with the U.S. Forest Service, U.S. Bureau of Land Management, and other agencies to cancel grazing of diseased domestic livestock on public lands in the Greater Yellowstone Ecosystem, to facilitate the return of public wildlife such as the Yellowstone bison to full abundance.

You, as the Montana Department of Fish, Wildlife, and Parks, need to strip the Montana Department of Livestock of any and all authority to regulate or manage in any way the wild Yellowstone bison.  We all understand that the wild, migrating Yellowstone bison are not domestic livestock!  The disgraceful, disrespectful, and outdated policies of slaughter and gross mismanagement by Montana Department of Livestock cowboys completely ignorant of genetic diversity and strength, healthy ecosystems, biological integrity, and biodiversity are over!

Again:  Our public lands must be managed for public wildlife, such as the wild Yellowstone bison.  Our public lands’ legacy is NOT well served by converting our priceless National Forests into mere commercial cattle feed lots or taxpayer-subsidized mono-culture tree farms.

Let the Yellowstone bison flourish!

Below are some of my specific concerns with your Draft Environmental Assessment:

1.  You have not provided adequate time for meaningful public input. With release of this  Environmental Assessment to the public at 11:00 a.m. MST on December 15, 2009, the public has been given only 28 days to comment, most of it during the Holiday season.  This is unacceptable.  The short public comment period for this Draft Environmental Analysis, timed to exactly coincide with everyone’s vacations, hardly allows meaningful opportunities for the public to thoroughly digest the disseminated information, ask appropriate questions, and contribute helpful comments.  Thus, I hereby formally request that you extend the official public comment period by AT LEAST 90 days.

2.  The Montana Department of Fish, Wildlife, and Parks (MFWP) has disseminated misinformation to the public, disguised as fact.  MFWP issued a news release on December 15, 2009, announcing the release of its Environmental Assessment to translocate quarantined Yellowstone bison.  In the release, MFWP states, “Many Yellowstone bison are infected with brucellosis.”  Reputable wildlife biologists and those who closely follow this issue know full well that this statement is NOT true!  While some estimate that 50 percent of Yellowstone bison have been exposed to brucella abortus, the actual rate of infection is far less.  MFWP news releases need to state the fact that “Few Yellowstone bison are infected with brucellosis.”  MFWP statements must reflect scientific and biologic reality, rather than Montana Department of Livestock bullshit.

3.  All public agencies involved in this mess to date have failed to properly plan for the eventual return of quarantined Yellowstone bison to public and tribal lands.  Officially, the Montana Department of Fish, Wildlife, and Parks says “The aim of the project is to determine the feasibility of capturing, raising and breeding bison calves from Yellowstone National Park that are free of brucellosis exposure for the establishment of new wild herds.”  Yet, on the ground, MFWP and U.S. Department of Agriculture’s Animal and Plant Health Inspection Service wasted more than FIVE YEARS, ignoring their publicly stated goal to determine suitable habitat on public or tribal lands.  They dropped the ball!  They didn’t coordinate with the appropriate state, federal and tribal governments!  MFWP and USDA’s APHIS utterly failed to honor their promise to the public to develop a plan that would ensure the goals of the Quarantine Feasibility Study be met.  They have done little to nothing to ensure that public Yellowstone bison will be returned to public and/or tribal lands.  Those who sanctioned this inaction need to be removed from their positions.  Immediately.  Since they are NOT doing their jobs, they should NOT be paid!    MFWP and USDA’s APHIS need to hire competent professionals that will actually do their jobs, honor their word, and prepare proper alternatives that benefit and encourage the wild Yellowstone bison population.

4.  Under section 2.5.3 in the Draft Environmental Analysis, there is an alternative for placing Yellowstone bison in Wildlife Management Areas.  This alternative makes sense.  It actually supports the publicly stated goals of the quarantine project.  Placing wild Yellowstone bison in Wildlife Management Areas has considerable support from the public.  As MFWP is Montana’s state wildlife agency, it is much more suitable for Yellowstone bison to be placed in a Wildlife Management Areas, than tossing them to Montana Department of Livestock cowboys for unconscionable slaughtering.  Wildlife Management Areas may help the quarantined Yellowstone bison regain their wild integrity, lost to their unfortunate imprisonment, being treated as though they were domestic livestock, and being routinely harassed during quarantine.

5.  If cattle are present on any Wildlife Management Areas that are suitable for wild Yellowstone bison, the domestic livestock must be removed.  The Wildlife Management Areas must be actually managed for wildlife!  Placing quarantined Yellowstone bison on Wildlife Management Areas follows the stated goals of the Quarantine Feasibility Study.  Therefore, MFWP must identify many potential Wildlife Management Areas and prepare environmental analyses for these proposed sites.  MFWP must work closely with all other state and federal agencies and to secure funds, equipment, and personnel for the purpose of placing Yellowstone bison on these Wildlife Management Areas to be managed by MFWP.

6.  The Montana Department of Fish, Wildlife, and Parks (MFWP) has hundreds of thousands of acres of public land where wild Yellowstone bison can be relocated.  Right now!  Yet, MFWP has failed to adequately assess potential public lands’ bison habitat and disseminate the necessary  information to the pubic.  The Robb/Ledford Wildlife Management Area, for example, is suitable public habitat that is currently available.  “The primary goal of Montana’s Wildlife Management Areas is to maintain vital wildlife habitat for the protection of species and the enjoyment of the public,” claims MFWP.  “MFWP’s Wildlife Management Areas are managed with wildlife and wildlife habitat conservation as the foremost concern,” the agency’s Web site continues.  “Wildlife Management Areas protect important wildlife habitat that might otherwise disappear from the Montana landscape.”  (http://fwp.mt.gov/habitat/wma.html )

7.  The Montana Department of Fish, Wildlife, and Parks can better achieve its goals of conserving soils, protecting watersheds, and restoring indigenous plant and wildlife diversity within these Wildlife Management Areas by utilizing wild bison, instead of perpetuating the destruction caused by domestic livestock ill-suited for the arid West.  Thus, I hereby respectfully request that MFWP prepare proposals to reintroduce Yellowstone bison on Wildlife Management Areas and submit those proposals to the public to give us the opportunity to review and comment upon them.

8.  The U.S. Department of Interior is the agency responsible for restoring the wild Yellowstone bison to public and tribal lands.  This agency is the largest public land owner in the United States.  Given that the U.S. Department of Interior has developed a “Bison Conservation Initiative,” they should immediately be made full partner in planning and assisting with placement of quarantined Yellowstone bison on public and tribal lands.

9.  The Gros Ventre and Assiniboine Tribes of the Fort Belknap Indian Reservation have submitted proposals for locating the quarantined Yellowstone bison “on tribal and public lands in a manner that promotes cultural enhancement, spiritual revitalization, and ecological restoration.”  These tribes have been working in earnest to bring bison back home for many years now.  The appropriate state and federal agencies need to quit equivocating and fully support these tribes!  The tribes want to establish a permanent herd from Yellowstone bison on 22,000 acres.  It is the hope of many that wild bison will ultimately occupy even more of the Fort Belknap reservation’s 675,000 acres.  What possible rationalization is there for the State of Montana and the U.S. government to deny the tribes this life-giving opportunity?  How can the State of Montana and the U.S. government possibly deny that the stated goals of the Quarantine Feasibility Study are to return Yellowstone bison to public and tribal lands?  It is now time to support the tribes!

10.  Privatizing the public’s wildlife resources and the Yellowstone bison entirely abrogates the goals of the Quarantine Feasibility Study.  Transferring wild Yellowstone bison to Ted Turner effectively removes our public wildlife from the public trust.  Any alternatives that undermine the stated intents and goals of the Quarantine Feasibility Study need to be discarded without a further thought.

11.  The USDA’s Animal and Plant Health Inspection Service, MFWP’s partner agency in the Quarantine Feasibility Study, has stated publicly their opposition to privatizing our public wildlife, by converting these wild Yellowstone bison into a commercial commodity.  A U.S. Department of Agriculture veterinarian has criticized this privatization, saying it goes against the original intent of the Yellowstone bison relocation program launched in 2005, according to the November 11, 2009, Bozeman Daily Chronicle.

12.  The Montana Department of Fish, Wildlife, and Parks (MFWP) has not outlined any plans or entertained any public discussions for the eventual release from Ted Turner Enterprises, Inc. to public and/or tribal locations after the five years of quarantine following translocation.  Again, the stated purpose of the Quarantine Feasibility Study was to use these Yellowstone bison to help repopulate public and tribal bison herds, and to restore bison to public and tribal lands.  Any alternative that allows Ted Turner Enterprises, Inc., or any other private entity, to claim possession of our publicly owned wild Yellowstone bison does NOT meet the stated goals of the project and, therefore, MUST be eliminated!

13.  Any alternatives that allow Ted Turner Enterprises, Inc., or any other private entity to TEMPORARILY hold any of the public’s Yellowstone bison must incorporate irrevocable commitments that the ultimate placement of these original quarantined Yellowstone bison and all of their offspring will be onto public and/or tribal lands.  Specific time limits must be enacted to expedite removal of our public wildlife from private hands and to restore public wildlife to the public or tribal commons.

14.  No alternative should be considered that allows Ted Turner to keep ANY of the quarantined Yellowstone bison’s offspring born during ANY temporary placement on Turner’s private properties, as this would directly undermine the intent of the Quarantine Feasibility Study.  Allowing Ted Turner to “increase genetic diversity” of his own private Castle Rock bison herd solely benefits a private commercial business at the considerable expense successfully repopulating  public and/or tribal herds.  How can we make this any more clear?  Wild Yellowstone bison are PUBLIC wildlife, NOT Ted Turner’s private domestic livestock!

15.  The preferred alternative to translocate captured wild Yellowstone bison to the private lands of Ted Turner Enterprises, Inc., is ridiculous, because it effectively removes public wildlife from the public trust, and removes the potential for Yellowstone bison to be returned to tribal lands, both of which are the stated goals of the Quarantine Feasibility Study.  See Yellowstone National Park Permit #YELL-2007-SCI-5506 (See page 3 of 4).

16.  Proposing the translocation of wild Yellowstone bison out of the public trust to Ted Turner or any other private landowner demonstrates a dismal failure to fully evaluate and meet the stated goals of the Quarantine Feasibility Study, which are to:  “determine the feasibility of capturing, raising and breeding bison calves from Yellowstone National Park that are free of brucellosis exposure for the establishment of new wild herds,” (MFWP Press Release 12/15/09).

17.  ALL Yellowstone bison and progeny MUST be reintroduced into public and/or tribal herds as part of the Montana Department of Fish, Wildlife, and Parks’ policy of “direct management” after the five-year quarantine period following translocation

18.  Need we say it one more time?  NO wild Yellowstone bison or progeny should be permanently turned over to Ted Turner!  This privatization of public wildlife would result in the loss of wild Yellowstone bison genetics that could otherwise be used to repopulate public and/or tribal herds.  Exploiting these Yellowstone bison or any of their offspring for private commercial gain is against the stated goals of the Quarantine Feasibility Study.  Therefore, any alternative involving transferring of ownership of the public’s wild Yellowstone bison offspring to private bison ranches must be eliminated!  Please refer to Yellowstone National Park Permit #YELL-2007-SCI-5506 (page 3 of 4).

19.  Alternative C, 2.3, in the Draft Environmental Analysis calls for placing 14 wild Yellowstone bison in Wyoming’s Guernsey State Park for five years with NO planning for long-term placement.  This temporary placement of Yellowstone bison in a state park would confine these wild, migratory beasts into too small of an area.  In other words: A ZOO!  Zoos do NOT protect the inherent wild traits that define American bison as wildlife.

20.  Alternative C, 2.3, in the Draft Environmental Analysis calls for retaining 30 wild Yellowstone bison in quarantine facilities and slaughtering 40 of the wild Yellowstone bison.  This proposed slaughter makes a farce of the stated goals of Quarantine Feasibility Study.  Please refer to Yellowstone National Park Permit #YELL-2007-SCI-5506 (page 3 of 4).  Again, NO more wild Yellowstone bison can be slaughtered!  NO alternatives that provide for slaughtering any wild Yellowstone bison should receive ANY consideration.  How many times do we have to say this?  We’ve been saying it for more than 20 years now!

21.  ANY slaughter of any wild Yellowstone bison does NOT meet the stated goals of Quarantine Feasibility Study and, therefore, must be entirely eliminated as options.  All alternatives prepared by the Montana Department of Fish, Wildlife, and Parks (MFWP) must recognize the need to manage Yellowstone bison as an imperiled wildlife species, not as diseased domestic livestock.

22.  Yellowstone National Park’s wild bison temporarily transferred to quarantine must NEVER be exploited for commercial or revenue-generating purposes.  Again, please refer to Yellowstone National Park Permit #YELL-2007-SCI-5506 (page 3 of 4).

23.  According to the Scientific Research and Collecting Permit issued by Yellowstone National Park to USDA’s APHIS and the Montana Department of Fish, Wildlife, and Parks; quarantined bison captured from Yellowstone “may be used for scientific or education purposes only, and shall be dedicated to public benefit and be accessible to the public in accordance with National Park Service policies and procedures.”  ALL alternatives proposed by MFWP or any other agencies must comply with this mandate.  If an alternative does not comply with this mandate, it should not be considered.

24.  Additionally, the Scientific Research and Collecting Permit issued by Yellowstone National Park to USDA’s APHIS and the Montana Department of Fish, Wildlife, and Parks unequivocally states that Yellowstone bison removed to quarantine “may not be used for commercial or revenue-generating purposes unless the permittee has entered into a Cooperative Research and Development Agreement or other approved benefit-sharing agreement with the National Park Service.  The sale of collected research specimens or other unauthorized transfers to third parties is prohibited.”  Again:  ALL future alternatives proposed by MFWP or any other agencies must comply with this mandate.  If an alternative does not comply with this mandate, it can no longer be considered.

25.  The Scientific Research and Collecting Permit issued by Yellowstone National Park to USDA’s APHIS and Montana Department of Fish, Wildlife, and Parks also states that Yellowstone bison in quarantine are still considered “Federal property.”  The National Park Service must be contacted prior to any quarantined Yellowstone bison being.  The permit specifically states:  “They shall not be destroyed or discarded, without prior National Park Service authorization.”  ALL alternatives proposed by MFWP or any other agencies must comply with this mandate.

26.  ALL alternatives proposed by the Montana Department of Fish, Wildlife, and Parks or any other agencies must fully acknowledge the authority of Yellowstone National Park and the U.S. Department of Interior to intervene and prevent the slaughter of ANY more wild, migrating Yellowstone bison, whether these bison are contained within a quarantine process or left unmolested in the wild.

27.  Yellowstone National Park’s permit prevents bison from being used for commercial benefit.  The U.S. Department of Interior’s National Park Service and Yellowstone National Park have unimpeachable jurisdiction over all bison and their offspring remaining in quarantine.  Therefore, it is within the National Park Service’s responsibilities to intercede and prevent any commercialization of bison.  ALL alternatives proposed by the Montana Department of Fish, Wildlife, and Parks or any other agencies must fully acknowledge this fact.

28.  The USDA’s APHIS, U.S. Forest Service, U.S. Bureau of Land Management, Montana Department of Fish, Wildlife, and Parks, or Montana Department of Livestock cannot be allowed to slaughter ANY more wild Yellowstone bison.  An alternative must be prepared to immediately strip the Montana Department of Livestock of any and all authority to harass, slaughter, intimidate, or otherwise attempt to control wild Yellowstone bison.  In this alternative, other state and federal agencies must commit themselves to the migration of wild Yellowstone bison onto National Forest lands.  As the National Forests of the Greater Yellowstone Ecosystem reach their capacity, bison from these public lands can continue replenishing tribal efforts to reestablish wild migrating bison on their reservations and adjacent public lands.

29.  The Quarantine Feasibility Study fails completely to meet goals set by the Montana Department of Fish, Wildlife, and Parks.  State and federal agencies have thus far wasted millions of tax dollars in their misguided attempts to destroy the biological integrity of the last remaining wild migrating bison herd in the world!  Due to the absence of competent long-range planning and lack of public information or discussion regarding MFWP’s eventual “direct management” (an ominous term repeatedly used by MFWP, but NEVER actually defined) over quarantined Yellowstone bison and their offspring, ALL alternatives presented to date are therefore incomplete.

30.  We need to start anew, with scientifically-backed alternatives that place quarantined wild Yellowstone bison back onto public and/or tribal lands.  We need alternatives where the state and federal actually support the preparation of tribal lands for receiving and maintaining quarantined wild Yellowstone bison.

31.  As repopulating tribal herds are stated goals and priorities in the Quarantine Feasibility Study,  all agencies involved need to commit themselves to an alternative that placed wild Yellowstone bison in existing tribal herds or reintroducing bison to tribal lands.  Once placed, the agencies need to ensure that all bison are allowed to migrate to the fullest extent possible throughout reservations and adjoining public lands.

32.  Alternative B, 2.2, the “No Action” alternative in the Draft Environmental Analysis, calls for slaughtering 58 wild bison for “research.”  This alternative is disgusting!  It effectively negates five full years of scientific research.  It fails to meet the stated goals of the Quarantine Feasibility Study.  Alternative B, 2.2 must therefore be eliminated from being considered a legitimate option.

33.  With the Montana Department of Fish, Wildlife, and Parks’ and the USDA’s APHIS’s failure to plan for and secure tribal and/or public habitat for these Yellowstone bison, as is the stated goal of the Quarantine Feasibility Study, further quarantine of wild Yellowstone bison captured for the purpose of study must immediately be halted.

34.  Any and all slaughter of the wild migrating Yellowstone bison must cease immediately.  Slaughter is absolutely unnecessary, as there are millions of acres immediately available on state, tribal, U.S. Department of Interior, and U.S. Forest Service lands, where wild Yellowstone bison must be allowed to migrate.  Please refer to Yellowstone National Park Permit #YELL-2007-SCI-5506 (page 3 of 4).

35.  As the Quarantine Feasibility Study has proven to be a complete failure, I am strongly opposed to it in its present form.  The Montana Department of Fish, Wildlife, and Parks (MFWP)  and the USDA’s APHIS have demonstrated extreme ignorance concerning how the quarantine process, in all of its aspects, adversely affects the behaviors of imprisoned wild Yellowstone bison.

36.  The Montana Department of Fish, Wildlife, and Parks (MFWP) and the USDA’s APHIS have failed to properly plan to ensure that the stated goals of returning Yellowstone bison to public and tribal lands would be met.  MFWP and the USDA’s APHIS have had years with which to evaluate suitable public and tribal lands, and to work with state, federal and tribal governments to ensure that the objectives of the Quarantine Feasibility Study would be satisfied.  As the agencies have thus far failed to achieve any results, they need to go back to the drawing board, hopefully with new, competent staff.  In these new efforts, MFWP and the USDA’s APHIS must acknowledge that there have NO benefits from harassing, capturing, imprisoning, and quarantining this severely-imperiled keystone native wildlife species.

37.  The Montana Department of Fish, Wildlife, and Parks (MFWP) needs to immediately release the Yellowstone bison currently being held in the quarantine facility back to the wild – to suitable tribal or public lands habitat.   See Yellowstone National Park Permit #YELL-2007-SCI-5506 (See page 3 of 4).

38.  The many management failures of the Montana Department of Fish, Wildlife, and Parks of the USDA’s APHIS, described above, must be quantified, documented, and fully disclosed to the public, news media, federal, state, and tribal agencies, and Congress.  This could best be done in an entirely new and comprehensive Environmental Impact Statement that addresses all of the concerns raised herein.

39. The Montana Department of Fish, Wildlife, and Parks must prepare Environmental Impact Statements that map out all potential bison habitat, including winter, spring, and summer range, designated calving areas, and migratory corridors.

CONCLUSION:

The wild Yellowstone bison population is the LAST continuously wild population of American bison to occupy their native range.  The wild Yellowstone bison are the only bison remaining on Earth that retain their identity and integrity as a true wildlife species.

The ongoing mismanagement of this endangered keystone species by the Interagency Bison Management Plan and all of its components including quarantine and indiscriminate slaughter, directly jeopardizes the evolutionary potential and wild integrity of a species that is critical to the ecological health and restoration of North America’s grassland and prairie ecosystems.

By forestalling the migration of the wild Yellowstone bison throughout public lands of the Greater Yellowstone Ecosystem, our Nation is deprived of its national heritage.  Yellowstone’s bison are genetically and behaviorally unique – the only herd with continuously wild ancestry from the days when 50 million bison migrated freely across the Great Plains!

It is now time to address and correct the U.S. government-sponsored holocaust of these bison and the Indigenous Peoples that depended upon them.  The relationship between bison and First Nations cultures can no longer be disrespected or subverted throughout the government’s wholesale slaughter of wild bison.  All proposed alternatives to the Quarantine Feasibility Study and all subsequent wild Yellowstone bison management proposals must start by recognizing First Nations’ cultures that hold bison sacred as an integral part of their lives, traditions, and spirituality.

With the Yellowstone bison, we are charting the future for the world’s only wild migrating bison herd.  All agencies involved in the Interagency Bison Management Plan and its various management facets must seek the wisdom, guidance and direct participation of First Nations in order to ensure that this irreplaceable population of American bison is not placed in further jeopardy.

ALL future alternatives presented to the public must truly respect the wild Yellowstone bison by  encouraging genetic diversity, guaranteeing biological integrity, increasing migration, and establishing viable wild bison populations throughout tribal land, U.S. Forest Service land, U.S. Bureau of Land Management land, state land, wildlife refuges, national parks, and wilderness areas.  All environmental reviews and documents of all federal, state, and tribal agencies need to start with these basic assumptions.

Thank you for this opportunity to comment.  Please heed these comments.  Please enter them into any hearing record or other similar assemblage of public comments.

Please keep me thoroughly informed concerning all proposals, decisions, and management actions affecting our last free and wild migrating Yellowstone bison.

Sincerely,

Paul Richards
30 Brown’s Gulch Road
Boulder, MT   59632
Paul@PRMediaConsultants.com

Dispatches from the Wildlands™ ©2010, Paul Richards

Official Testimony

S. 1470 – The Tester Wildlands Logging Bill

January 7, 2010

Submitted To:
U. S. Senate Subcommittee on Public Lands and Forests,
U. S. Senate Committee on Energy and Natural Resources

c/o Hon. Sen. Ron Wyden, Chairman, Subcommittee on Public Lands and Forests
c/o Hon. Sen. Jeff Bingaman, Ex Officio Member, Subcommittee on Public Lands and Forests
c/o Hon. Sen. Lisa Murkowski, Ex Officio Member, Subcommittee on Public Lands and Forests
Fax:  202-224-7970
Fax:  202-224-6163

From:
Paul Richards
PR  Media Consultants®
Public Interest Media Since 1968
30 Brown’s Gulch Road
Boulder, MT   59632
www.PRMediaConsultants.com
Paul@PRMediaConsultants.com

Requests:
Please include this testimony in the “Official Hearing Record regarding S. 1470, the Tester Wildlands Logging Bill,” heard by the U.S. Senate Committee on Energy and Natural Resources’ Subcommittee on Public Lands and Forests on December 17, 2009.

Please keep me informed as to your deliberations and decisions concerning the Tester Wildlands Logging Bill.  Thank you.

Weaknesses of S. 1470, Sen. Jon Tester’s Wildlands Logging Bill

Analysis by Paul Richards, PR  Media Consultants®

Submitted January 7, 2010, to the Official Hearing Record of S. 1470,

The Tester Wildlands Logging Bill,

Heard by the U.S. Senate Committee on Energy and Natural Resources’

Subcommittee on Public Lands and Forests on December 17, 2009.

Weaknesses of S. 1470, Sen. Jon Tester’s Wildlands Logging Bill:

All of the following weaknesses of S. 1470, Sen. Jon Tester’s Wildlands Logging Bill, were covered in my July 2009 in-depth analysis posted the day that Tester announced this legislation at a Townsend, Montana, sawmill at:  www.NewWest.net.

On July 17, 2009, NewWest.Net offered Sen. Jon Tester an opportunity to rebut all of these points.  As of this writing (January 7, 2010), he is still “considering it.”

It should be noted that, on July 17, 2009, Peter Aengst of the Wilderness Society did issue statements calling this analysis and the resultant NewWest.Net investigative piece a “rant.”  Aengst refrained from addressing any specifics.

1. The public was completely shut out of the drafting of S. 1470, the Tester Wildlands Logging Bill.  The bill was drafted in an underhanded manner by a handful of insiders, sworn to secrecy.  Rather than incorporating meaningful public involvement, Tester chose the path of “fait accompli.”  This has created enormous resentment from all quarters.

DETAILS:  I, for example, am a member of the National Wildlife Federation, Trout Unlimited, and Montana Wilderness Association.  I served on the board of the Montana Wilderness Association and have received the organization’s “Brass Lantern” Award.

Years ago, when these three conservation groups and the timber industry first formed the “Beaverhead-Deerlodge Partnership,” I approached the players.  As one who had been involved at the grassroots level with the Deerlodge National Forest for over 27 years, and as an official member of the Deerlodge National Forest Technical Advisory Committee, I thought my presence might be an asset during negotiations.  I had been involved with the successful appeal and resultant “Settlement Agreement” of the Deerlodge Forest Plan, which had been heralded region-wide as a model for citizen participation.

Over a two-year period, I sent numerous e-mails and made numerous phone calls, trying to get into the negotiations or at least monitor them.  All my attempts were rebuffed, as were all attempts by many other members of the public. We, as members of the National Wildlife Federation, Trout Unlimited, and Montana Wilderness Association, were kept entirely in the dark as our organizations’ staffs compromised away our public wildlands.

I have also been a member of the Wilderness Society for 40 years.  At NO time were Wilderness Society members ever appraised as to deals, trade-offs, and The Wilderness Society’s staff actually supporting the removal of current administrative and Congressional protections for our public wildlands.

Wildlands proponents weren’t the only ones excluded.  People in favor of resource development, county officials, and state legislators were also kept in the dark.  U.S. Forest Service officials, scientists, biologists, botanists, silviculturalists, and public information specialists were purposefully excluded from participation and denied access to all drafts of the Tester Wildlands Logging Bill.

In short:  There was NO public information and NO  public discussion.  Countless interest groups and individuals were surgically removed from every major decision regarding their own public lands.

Instead being forged by well-informed public debate, reviewed by U.S. Forest Service scientists and experts, and exposed to the healing properties of disinfecting sunlight, Tester’s bill was clandestinely and sloppily cobbled together behind-the-scenes.

2.  S. 1470, the Tester Wildlands Logging Bill, violates Tester’s 2006 campaign promise “to protect all of Montana’s remaining roadless areas.”

DETAILS:  With only a week to go, polls showed State Sen. Jon Tester and State Auditor John Morrison at a dead heat in the June 2006 Democratic primary race for U.S. Senate.  Tester operative Missoula attorney Pat Smith directly contacted former state Rep. Paul Richards (me), who was running third of five candidates in the race, concerning Richards’ possible endorsement of Tester.

Richards agreed to meet twice with Tester in Helena, Montana, on Tuesday, May 30, 2006, to see if terms could be worked out for this endorsement.

As a result of these two negotiating sessions, Tester agreed to terms detailed at:  www.Richards2006.us, including the specific promise that:  “If elected, Jon Tester will work to protect all of Montana’s remaining roadless areas.”

In exchange for these mutually-agreed-upon-with-witnesses (including Tester’s wife, Shar, and Tester’s son, Shon) terms, Paul Richards agreed to withdraw from the race for U.S. Senate and publicly ask his supporters to vote for Jon Tester.  After the agreement was reached, Richards personally contacted his extensive network of environmental advocates throughout the state, detailed Tester’s commitment to “protect all of Montana’s remaining roadless areas,” and asked his supporters to vote for Tester  in the June 2006 Democratic primary election, rather than Richards.

News of Richards’ endorsement appeared on front pages of most Montana daily newspapers and was prominent in all other media the final week before the election.  Tester and Richards celebrated the win jointly at a June 6, 2006, election night party in Missoula, MT.

3. S. 1470, the Tester Wildlands Logging Bill, alienates Tester’s main supporters from the 2006 election.

DETAILS:  Conservationists provided the margin of victory that allowed Tester to defeat incumbent Sen. Conrad Burns in the general election of 2006.  In tacking solely towards the timber industry, moneyed corporations that never previously supported him in any fashion, Tester has abandoned his true constituency.

To date, due to interminable efforts by countless pro-logging public relations specialists, reporters and editors that know better have been forced into states of profound stupor.  As a result of this lethargy, Montana’s corporate media have largely bought into the “spin” created by timber corporations, Tester, Baucus, Wilderness Society, National Wildlife Federation, Trout Unlimited, Montana Wilderness Association, and Greater Yellowstone Coalition.

Instead of raising necessary questions concerning potential loss of our public wildlands legacy and expenditures of well over $100 million in taxpayer timber subsidies, corporate media in Montana have cast legitimate public debate aside and joined the spinmasters’ choir, making Tester’s bill the “feel good” legislation of the year!

National media, on the other hand, will likely see through the smoke and mirrors, no matter how numerous and gregarious the spinmasters, how “nice” the legislation’s sponsor, or how desperately the sawmills crave even more taxpayer subsidies.

As the actual implications of the Tester Wildlands Logging Bill become known to public lands stakeholders throughout the nation, Tester’s credibility among public lands advocates and true conservationists will suffer accordingly.  Ultimately, this will become reflected in his in-state standing.  Instead of longtime dedicated conservationist like the esteemed Senator Lee Metcalf representing the long-term interests of our public lands legacy, Montanans are now looking at a one-term flash in the pan.

4. S. 1470, the Tester Wildlands Logging Bill, “undesignates” S 393 wildlands and loots the wildlands legacy of former Senator Lee Metcalf – Montana’s greatest conservationist.

DETAILS:  Tester’s bill is a full-scale pillaging of the legacy of Montana’s greatest conservationist and my mentor, U.S. Senator Lee Metcalf.  In 1977, Sen. Metcalf, only a year before he died, worked tirelessly to pass Senate Bill 393, the Montana Wilderness Study Act.

Sen. Metcalf’s magnificent legacy protected nine roadless wildland areas, while they were studied for official designation as wilderness under the Wilderness Act of 1964, a bill which Sen. Metcalf had earlier personally shepherded through Congress, with the conscientious advocacy of Wilderness Society Executive Director Stewart Brandborg and Wilderness Society Field Director Clif Merritt, both Montana natives.

Tester’s bill removes the Sapphire Wilderness Study Area and the West Pioneers Wilderness Study Area from the Congressional protection of Sen. Metcalf’s Senate Bill 393 and opens more than two-thirds of these priceless and irretrievable roadless wildlands to logging.

Only high-elevation “rocks and ice” non-timber producing tracts would be designated wilderness.  Of the 94,000 acres of public roadless wildlands currently in the Sapphire Wilderness Study Area, only 53,000 acres would be protected from development.  Of the 151,000 acres of public roadless wildlands currently in the West Pioneers Wilderness Study Area, only 26,000 acres would be protected from development.

Tester’s bill “undesignates” the Axolotl Lakes Wilderness Study Area, Bell/Limekiln Canyons Wilderness Study Area, East Fork Blacktail Wilderness Study Area, Henneberry Ridge Wilderness Study Area, and Hidden Pasture Wilderness Study Area.  These roadless wildlands would be subjected to “logging without laws,” as Tester’s bill excludes logging them from protective provisions of the Federal Land Policy and Management Act.

5. S. 1470, the Tester Wildlands Logging Bill, pulls roadless areas out from the protection of the Clinton Roadless Rule and the Obama Roadless Initiative.

DETAILS:  Tester’s bill withdraws around one million acres of public roadless wildlands on the Beaverhead-Deerlodge National Forest from the protection of the Clinton Roadless Rule and the Obama Roadless Initiative and opens them to roading and logging.

You won’t find this in the bill.  You have to go to the maps that accompany the bill, maps to which courts will undoubtedly refer, if this misguided legislation actually passes.  The maps (located at:  http://tester.senate.gov/Legislation/upload/Proposed-Land-Designations.pdf ) are very specific in reclassifying the Beaverhead-Deerlodge National Forest’s currently protected roadless wildlands to a new category, officially designated “Timber Suitable or Open to Harvest.”

6. S. 1470, the Tester Wildlands Logging Bill, Congressionally overrides legitimate forest planning processes that involve full public information and participation.

DETAILS:  Tester’s bill circumvents National Forest planning laws, procedures, and regulations.  Currently, the U.S. Forest Service is required to honestly evaluate “site-specific impacts” of proposed logging.

Under Tester’s bill, these requirements would be supplanted by a new system of “Landscape Scale Restoration Projects” where mandated logging takes place in the total absence of well-established forest planning procedures that require state-of-the art science, public information, and public involvement.

Tester’s bill Congressionally mandates cut levels, damn the environmental and financial costs.  Instead of decisions being made at local levels by informed forest science professionals, Tester’s bill dictates a one-size-fits-all prescription that prioritizes logging above all other uses.

Under Tester’s bill, taxpayer subsidies to timber corporations are more important than anything, be it elk hunting (which would diminish as elk security is logged away by mandated timber cutting), fishing (drastically debilitated by inevitable water degradation caused by unsustainable logging), steady supplies of clean irrigation water (logging causes much faster watershed runoffs and increased sedimentation), pure community water supplies (most western Montana cities get their water from our public roadless wildlands), diminished wildlife habitat, you name it.

7. S. 1470, the Tester Wildlands Logging Bill, promotes “logging without laws.”

DETAILS:  By mandating timber cuts be placed above all other concerns, Tester’s bill could statutorily exempt timber cutting from the Clean Water Act, Endangered Species Act, National Environmental Policy Act (which Tester’s bill mistakenly calls the “National Environmental Protection Act”), Wilderness Act, National Forest Management Act, and the Federal Land Policy and Management Act.  This is a point of contention.  Tester claims environmental laws will be adhered to.  To the uninitiated, that sounds just great!  However, the initiated know full well that when Congress mandates timber cutting quotas, federal courts have consistently held that the Congressional mandate to cut down the public’s trees trumps federal environmental and land use laws.

We’ve been through all this before.  For over 20 years, politicians have claimed environmental laws would be followed, at the same time that they have imposed mandatory cutting quotas on public lands.  While Tester’s public relations have lulled gullible “conservationists” into believing we can get the cut out and follow environmental laws, the courts consistently rule that the mandated cuts are paramount and that environmental laws don’t have to be respected.

The legal track record is available to anyone that can Google.  The court precedents have already been established:  If you have a conflict in law, “the specific overrides the general.”  That is, Congressionally-mandated cutting quotas preempt such laws as the Clean Water Act, Endangered Species Act, Wilderness Act, National Environmental Policy Act, National Forest Management Act, and the Federal Land Policy and Management Act.

Thus, despite proclamations to the contrary from Tester’s “conservation” collaborationists, if the Tester bill’s forced cutting quotas are approved by Congress, environmental laws would likely fall helplessly by the wayside.

8. S. 1470, the Tester Wildlands Logging Bill, mandates a cut of 7,000 acres a year for 10 years on a forest that sustainably produces, according to Beaverhead-Deerlodge National Forest officials, only between 500 and 2800 acres a year.

DETAILS:  As a lifelong resident of the area and as a long-time member of the U.S. Forest Service’s Technical Advisory Committee, I know full well that the Beaverhead-Deerlodge National Forest is not productive timberland.  Much of the forest is east of the Continental Divide, receives little precipitation, and has an extremely short growing season, due to its high altitude.  Due to these limiting factors, it costs the public at least $1,400 per acre to log in the Beaverhead-Deerlodge National Forest.

Tester claims the mandated cut will come from the Beaverhead-Deerlodge National Forest’s suitable timber base and that inventoried roadless areas are not threatened.  But, Tester is ignoring reality.  In recent years, logging professionals with the Beaverhead-Deerlodge National Forest have established the Forest’s sustainable yearly harvest at 500 acres.  The most they’ve cut, even during the years of the housing boom, is 2,800 acres a year.

Can Tester mandate a cut of 70,000 acres (7,000 acres a year for 10 years) on a forest that is not productive timberland, without entering and developing undeveloped (roadless) lands?  For a clue, review the maps located at:  http://tester.senate.gov/Legislation/upload/Proposed-Land-Designations.pdf and note that, under the Tester bill, the Beaverhead-Deerlodge National Forest’s inventoried roadless wildlands are officially re-designated as “Timber Suitable or Open to Harvest.”

9. S. 1470, the Tester Wildlands Logging Bill, mandates a cut of 30,000 acres of grizzly bear habitat on the Kootenai National Forest, causing distress and disturbance that some biologists say will force the dwindling Yaak grizzly bears into insecure habitat and ultimately extinction.

DETAILS:  Wildlife consultant Brian Peck reports, “I have worked for 15 years to try and save the imperiled 30-40 grizzlies in the Cabinet-Yaak Ecosystem in a landscape where the “Cores” are too small, the “Buffers” are over-logged and roaded, and the “Linkages” are non-existent.

Tester’s bill mandates the cutting of 3,000 acres per year for ten years on the Kootenai National Forest, a forest that already looks like a moonscape in many areas from decades of U.S. Forest Service abuse. How is another 30,000 acres of logging not going to be the last nail in these bear’s coffin?”

10. S. 1470, the Tester Wildlands Logging Bill, could have a severe adverse impact upon rare, threatened, and endangered species.

DETAILS:  Since the Tester bill Congressionally-mandates timber cuts, curtails forest planning, and severely restricts the U.S. Forest Service from accurately assessing logging’s impacts; environmental protections provided by the Clean Water Act, Endangered Species Act, National Environmental Policy Act (mistakenly called the “National Environmental Protection Act” by Tester’s bill), National Forest Management Act, Federal Land Policy and Management Act, and Wilderness Act will likely be preempted.

If this scenario plays out, the public will never know the full extent to which secluded, rare, threatened, and endangered species will be adversely impacted, particularly in the Kootenai National Forest and the Beaverhead-Deerlodge National Forest.

By forcing unsustainable industrial-scale logging upon our public lands, Tester’s bill would irrevocably harm essential habitat of species that characterize the wild nature of the northern Rockies, such as the gray wolf, bull trout, cutthroat trout (Montana’s official state fish), otter, mountain goat, mountain sheep, elk, arctic grayling, northern goshawk, boreal owl, pileated woodpecker, ferruginous hawk, Montana vole, sage thrasher, wild bison, peregrine falcon, bald eagle, pine marten, fisher, lynx, wolverine, and grizzly bear (Montana’s official state animal).

11. S. 1470, the Tester Wildlands Logging Bill, ignores the scientific need to protect different elevation habitats and their dependent species.

DETAILS:  Conservation biologists have long understood the need to protect different elevation habitats and their dependent species, with core areas, buffer zones, and connecting biological corridors, or linkages.

More recently, scientists have documented that forest habitats are changing radically, due to global climate change.  The species depending on our National Forests for survival are increasingly stressed by climate change and are increasingly in need of broader migration opportunities.

The “conservation” collaborationists (Wilderness Society, National Wildlife Federation, Trout Unlimited, Montana Wilderness Association, and Greater Yellowstone Coalition) publicly boast that, by supporting Tester’s bill, they are “creating” new wilderness areas.

These areas fail to pass scientific muster.  A handful of nonproductive, high-altitude, limited-habitat “rocks and ice” wilderness areas, allocated to human recreational enjoyment does nothing for the vast majority of forest species.  Unconnected islands of  “rocks and ice” provide no biological integrity and no potential for sustaining biodiversity.

12. S. 1470, the Tester Wildlands Logging Bill, costs over $100 million for taxpayer-subsidized timber sales and lavish new sawmill power plants.

DETAILS:  It costs the public at least $1,400 per acre to log in the Beaverhead-Deerlodge National Forest.  Mandating logging of 7,000 acres will cost the public $9,800,000 a year.  Mandating this level of cutting for 10 years, as Tester proposes, will cost taxpayers at least $98 million dollars.

In fact, the cost of these timber industry subsidies will be considerably higher, as the above economic figures date from the housing boom, three-to-four years ago.  Now, that we are in economic depression, there is no housing construction and hardly anyone is buying timber.

In today’s depressed market for timber, the “hard money” subsidies for loggers that the Tester bill mandates will likely reach into the hundreds of millions of dollars over the next 10 years.

In addition to these taxpayer subsidies, Tester wants additional untold millions in taxpayer subsidies to build costly on-site power plants for the timber corporations promoting his bill.  The taxpayer-financed power plants will only serve the timber corporations, not the communities of western Montana.

It is more corporate pork, plain and simple.

Tester’s power plants also make absolutely no sense.  Trucking biomass to large, centralized power plants is grossly inefficient, when compared to utilizing numerous small-scale portable decentralized facilities.

It is far more practical to truck numerous inexpensive portable generators to the biomass, than to truck the biomass increasingly long distances to expensive and instantaneously obsolete centralized power facilities at sawmills.

13.  S. 1470, the Tester Wildlands Logging Bill, negligently ignores the fact that there is no current demand for timber.

DETAILS:  Since there is no demand for sawmills’ lumber, Tester’s bill defies basic common sense.  The legislation is blatantly undisguised in its privatization of public resources and its forcing the public assumption of lumber mills’ private debt.

A mere four corporations:  Pyramid Mountain Lumber (Seeley Lake), Roseburg Lumber (Missoula), RY Timber (Townsend and Livingston), and Sun Mountain Lumber (Deerlodge) will receive well over $100 million courtesy of the kind Senator, with taxpayers picking up the tab in tax dollars spent, watersheds degraded, habitat lost, and public wildlands destroyed.

14. S. 1470, the Tester Wildlands Logging Bill, mandates timber cutting, while leaving ensuing forest restoration optional.

DETAILS:  This is the elephant in the living room.  If Tester’s bill passes, by Congressional mandate, public wildlands will be roaded and their trees cut down.  Then, after the trees are long gone, there will be no forest restoration.

Tester’s bill contains absolutely NO restoration mandates.

National Forests are littered with giant messes of logging restoration left unfunded and undone.  It’s the U.S. Forest Service’s dirtiest secret:  After the public’s trees are cut down and the logs hauled out, somehow, the agency just never seems to be able to find the money to honor its once-so-earnest promises of restoration.

There isn’t a national forest in the country that has actually delivered on its past commitments to restore public lands and watersheds wounded by logging.  When it comes to budget priorities, post-logging forest reclamation and restoration has always been the U.S. Forest Service’s neglected and unwanted step-child.

Maintaining a brave posture in the face of this undeniable track record, Tester claims that revenues from mandated logging will pay for forest restoration projects.  But, inconvenient truth again rears its ugly head:  In lodgepole pine-dominant forests, there simply won’t be any revenues!  At taxpayer-subsidies of $1,400 for every acre logged, just how will Tester’s restoration funds be magically generated?

This giant Ponzi scheme will likely be the undoing of the Tester Wildlands Logging Bill.

15. “Conservation” collaborationists supporting S. 1470, the Tester Wildlands Logging Bill, have all received massive funding from the Pew Charitable Trusts, which works to “confine wilderness legislation to rocks-and-ice regions by co-opting gullible or calculating people in the wilderness movement.”

DETAILS:  The Pew Charitable Trusts are an independent nonprofit organization–the sole beneficiary of seven individual charitable funds, with assets of $5.2 billion at the end of June 2008, established by two sons and two daughters of Sun Oil Company founder, Joseph N. Pew, and his wife, Mary Anderson Pew.

Pew works to “confine wilderness legislation to rocks-and-ice regions by co-opting gullible or calculating people in the wilderness movement,” according to former Montana Wilderness Association President Elaine Snyder and former MWA Board Member Ross Titus.

“Organizations that have gained access to Pew money are expected to show short-term gains in wilderness protection regardless of the cost to other public resources and political efforts,” according to Snyder and Titus.

The Montana Wilderness Association has received tens of thousands of dollars of Pew money.  The National Wildlife Federation, Trout Unlimited, and the Wilderness Society have each received many millions of dollars from the Pew Charitable Trusts.  National Wildlife Federation staffers are even housed at Pew’s Washington, D.C. headquarters.

Pew tipped its hand concerning the Tester Wildlands Logging Bill with a preemptive Thursday, July 9, 2009, e-mail “Alert” entitled “Sen. Tester Leads on Wilderness” from Mike Matz, executive director of the Pew-funded “Campaign for America’s Wilderness” (formerly known as the “Pew Wilderness Center”).  “We need to THANK Senator Tester for showing positive leadership to protect the best of Montana’s pristine national forests,” Matz wrote.

“His bill would add the first new wilderness in Montana in more than a quarter of a century,” Matz continued. “Sen. Tester needs to hear that Montanans want to protect their special places as wilderness, for Montana families, clean water and wildlife.  Please

take a moment to call Senator Tester today and make a difference for Montana’s wilderness.  Dial the nearest local office now and tell them you appreciate Sen. Tester’s leadership on wilderness,” Matz concluded.  Matz then listed the telephone number for each of Tester’s eight Montana field offices.

Matz was asking well-intentioned wilderness advocates, who don’t know the funding sources of the “Campaign for America’s Wilderness,” to praise Tester for a wildlands logging bill that Tester refused to allow the public to see!

On the same afternoon, the Wilderness Society, sent out its own “Wild Alert,” under the name of Kathy Kilmer.  “Montana’s Sen. Jon Tester is considering legislation that would give Montana its first new wilderness designations in decades,” Kilmer wrote.  “Sen. Tester needs to hear that Montanans want to protect their special places as wilderness, for Montana families, clean water and wildlife.  Please call Sen. Tester and thank him for showing positive leadership to protect the best of Montana’s pristine national forests,” Kilmer concluded.  The Wilderness Society used the exact same non-alphabetical listing of Tester’s eight Montana field offices as Matz.

Besides the eeriness of identical non-alphabetical listings and the same language (“Sen. Tester needs to hear that Montanans want to protect their special places as wilderness, for Montana families, clean water and wildlife.”), the incredible thing about the preemptive Pew-funded e-mail campaigns of July 9, 2009, was that no one anywhere had actually seen the Tester Wildlands Logging Bill, other than the timber industry and its collaborationists!  Yet, we grassroots wildlands supporters were supposed to sign a blank check, call Tester, and thank him for drafting a public lands bill in secret!

When I first reported on the Pew-orchestrated campaign, Peter Aengst of the Wilderness Society wrote the following to Jared White of the Wilderness Society:  “Can you check with Kathy Kilmer and see if it is possible to remove certain unsupportive people from our Wild Alert lists?  Like Paul Richards (see his direct quoting of our alert).”

How dramatically have millions of Pew dollars caused the Wilderness Society to stray from its original mission, once pursued so faithfully by such courageous stalwarts as Robert Sterling Yard, Benton MacKaye, Robert and George Marshall, Aldo Leopold, Howard Zahniser, Stewart Brandborg, and Clif Merritt?

How could today’s Pew-funded Wilderness Society take me, a member of 40-years-standing, OFF of its mailing lists for being pro-wildlands and pro-wilderness?

How could today’s Pew-funded Wilderness Society exclude the public from public land decisions; support throwing away untold millions of dollars of pork for taxpayer-subsidized timber sales and lavish new sawmill power plants; exempting public wildlands from federal laws and the protection of a new earnest President; “undesignating” the legacy of Montana’s greatest conservationist; and destroying an irretrievable portion of Montana’s priceless roadless wildlands heritage?

16. S. 1470, the Tester Wildlands Logging Bill, fragments the Northern Rockies Ecosystem, the ONLY functioning ecosystem in the lower 49 states where all native species still reside.

DETAILS:  Northern Rockies wildlands are the only place in the lower 49 states where all native species and wildlife remain!

These are our public wildlands, belonging to all Americans.

The Tester Wildlands Logging Bill strips away the protection of these public wildlands currently provided by the Clinton Roadless Rule, the Obama Roadless Initiative, and Sen. Lee Metcalf’s incredibly farsighted Senate Bill 393.

By fragmenting the Northern Rockies Ecosystem, the Tester Wildlands Logging Bill is a direct assault on the scientific principles of biodiversity and biological integrity for which so many dedicated citizens have worked so hard for the last quarter century.      If Tester’s bill passes:  Secluded, rare, threatened, and endangered species will be adversely impacted, particularly in the Kootenai National Forest and the Beaverhead-Deerlodge National Forest.

By forcing unsustainable industrial-scale logging upon our public lands, Tester’s bill would irrevocably harm essential habitat of species that characterize the wild nature of the northern Rockies, such as the gray wolf, otter, mountain goat, mountain sheep, pika, elk, northern goshawk, boreal owl, pileated woodpecker, ferruginous hawk, sage grouse, Montana vole, sage thrasher, wild bison, peregrine falcon, bald eagle, pine marten, fisher, lynx, wolverine, arctic grayling, bull trout, cutthroat trout (Montana’s official state fish), and grizzly bear (Montana’s official state animal).

The “wilderness” areas in the Tester bill are fragmented and unconnected islands of largely “rocks and ice,” with no biological integrity and no potential for sustaining biodiversity.

These minimal “wilderness” designations in Tester’s bill fail entirely to protect different elevation habitats and their dependent species with core areas, buffer zones, and connecting biological corridors.

The Tester Wildlands Logging Bill promotes numerous abuses and violations that are clearly incompatible with the 1964 Wilderness Act, including motorized access into and through “wilderness,” low-level military overflights of “wilderness,” military aircraft landings in “wilderness,” possible “wilderness” logging, and other intrusions that violate the intrinsic principles of Wilderness.

As Montana State Rep. Francis Bardanouve used to say:  “This is a BAD bill”:

As my dear friend and companion, the late Rep. Francis Bardanouve, the dean of the Montana Legislature, sometimes proclaimed, when I served with him in the Montana House of Representatives, “This is a BAD bill!”

Francis did not say this very often.  But, in the rare times he did say it, legislators listened.  They knew Francis did his homework.  They knew Francis always researched exhaustively and deliberated studiously, before arriving at his opinion.  As a result, Francis’s peers listened carefully and consistently heeded Francis’s warning that “This is a BAD bill.”  They voted the bad bill down.

For all the reasons outlined above and for many other reasons raised by other groups, officials, and citizens:  S. 1470, Sen. Jon Tester’s Wildlands Logging Bill, is a BAD bill.  It needs to die a quick death.

There is a well-researched alternative to S. 1470, the Tester Wildlands Logging Bill.

Thankfully, there is a sound, well-researched, and well-written alternative to Sen. Tester’s Wildlands Logging Bill that complies with existing Federal environmental and forest management laws.

Twenty-four years ago, after talking with our region’s leading scientists and conservationists, I wrote the first draft of what was-to-become the Northern Rockies Ecosystem Protection Act (NREPA).

To preserve the biological integrity of the Northern Rockies Ecosystem, the LAST remaining functioning ecosystem in the lower 49 states where all native species still reside, NREPA designates as wilderness nearly 7 million acres of public roadless wildlands in Montana, 9.5 million acres in Idaho, 5 million acres in Wyoming, 750,000 acres in eastern Oregon, and 500,000 acres in eastern Washington.  Included in this total are over 3 million acres of backcountry wilderness in Yellowstone, Glacier and Grand Teton National Parks.

Detailed Comparison:  HR 980, the Northern Rockies Ecosystem Protection Act (the House bill) to S. 1470, the Tester Wildlands Logging Bill (the Senate bill).

To assist you as you fulfill your role as elected stewards of our priceless and irretrievable public wildlands legacy, I offer you the following comparison between HR 980, the Northern Rockies Ecosystem Protection Act (the House bill) and S. 1470, the Tester Wildlands Logging Bill (the Senate bill):

1. By officially designating our remaining public roadless wildlands as wilderness, HR 980, the Northern Rockies Ecosystem Protection Act (NREPA), provides the strongest protection that the federal government can confer on public wildlands and dependent species.  Instead of protecting different elevation habitats and their dependent species, S. 1470, the Tester Wildlands Logging Bill, would only set aside meager high-altitude “rocks and ice,” with no biological integrity and no potential for sustaining biodiversity.

2. Since it was co-written by our nation’s leading wildlife and aquatic biologists, HR 980, the Northern Rockies Ecosystem Protection Act (NREPA), protects the habitat essential for the survival of species that characterize the wild nature of the northern Rockies, such as the gray wolf, otter, mountain goat, mountain sheep, pika, elk, northern goshawk, boreal owl, pileated woodpecker, ferruginous hawk, sage grouse, Montana vole, sage thrasher, wild bison, peregrine falcon, bald eagle, pine marten, fisher, lynx, wolverine, arctic grayling, bull trout, cutthroat trout (Montana’s official state fish), and grizzly bear (Montana’s official state animal).  S. 1470, the Tester Wildlands Logging Bill, does not.

3. At last count, HR 980, the Northern Rockies Ecosystem Protection Act, is sponsored by 103 members of the House of Representatives.  S. 1470, the Tester Wildlands Logging Bill, has but one sponsor.

4. HR 980, the Northern Rockies Ecosystem Protection Act, is completely compatible with the 1964 Wilderness Act.  In stark contrast, S. 1470, the Tester Wildlands Logging Bill, which would endorse motorized access into and through “wilderness,” low-level military overflights of “wilderness,” military aircraft landings in “wilderness,” possible “wilderness” logging, and other intrusions that violate the intrinsic principles of Wilderness, is totally incompatible with the 1964 Wilderness Act.

5. It should come as a secret to no one that HR 980, the Northern Rockies Ecosystem Protection Act, has consistently been supported by the 1964 Wilderness Act’s leading proponents, former Wilderness Society Executive Director Stewart Brandborg, former Wilderness Society Field Director Clif Merritt, and former U.S. Forest Service Deputy Regional Forester Bill Worf, all Montana natives.  S. 1470, the Tester Wildlands Logging Bill, has no prominent supporters from the 1964 Wilderness Act era.

6. HR 980, the Northern Rockies Ecosystem Protection Act, has been subjected to careful review by the public for 24 years now.  Every section of HR 980 has been gone over with fine-tooth combs by hundreds of scientists, conservation and outdoor groups, agency officials, business leaders, Congressional staffers, and attorneys.  While HR 980, the Northern Rockies Ecosystem Protection Act, may be the best written public lands legislation since the original 1964 Wilderness Act; S. 1470, the Tester Wildlands Logging Bill, ridden with loopholes, and cleverly designed to be incomprehensible to all, was cobbled together behind-the-scenes; with NO scientific input, NO comprehensive legal review, NO Congressional review, NO agency review, and NO public involvement.

7. HR 980, the Northern Rockies Ecosystem Protection Act, is supported by over 100 grassroots groups.  S. 1470, the Tester Wildlands Logging Bill, is backed only by a handful of “collaborationist” staffers from top-heavy, out-of-touch, Pew Charitable Trusts-funded Beltway-based “Big Green” or “Gang Green” bureaucracies.

8. HR 980, the Northern Rockies Ecosystem Protection Act, will hopefully pass the House this year (2010).  S. 1470, the Tester Wildlands Logging Bill, has been deemed unsupportable by the U.S. Forest Service, due to extremely high subsidies from taxpayers, entirely unsustainable timber quotas, and severe damage it would wreck upon our environment and public lands legacy.

I offer the above information with great hope that it helps you, as you deliberate between the carefully-written and long-term vision for our public lands legacy provided by HR 980, the Northern Rockies Ecosystem Protection Act; and the loophole-ridden and nearsighted economic and environmental Hindenburg that is called S. 1470, the Tester Wildlands Logging Bill

If you have any questions, or if I can provide any further information, please do not hesitate to contact me.

In support of lasting protection for our Nation’s priceless and irretrievable public wildlands legacy,

I remain yours,

Sincerely,

Paul Richards
PR  Media Consultants®
Public Interest Media Since 1968
30 Brown’s Gulch Road
Boulder, MT   59632
www.PRMediaConsultants.com
Paul@PRMediaConsultants.com

(Note: This testimony is located at:  http://blogs.alternet.org/paulrichards/ .  For extensive in-depth analyses and commentary about the Tester Wildlands Logging Bill and for information about The Last Best Place Wildlands Campaign, a coalition of 55 conservation groups opposed to the Tester Wildlands Logging Bill, go to:  http://testerloggingbilltruths.wordpress.com/ ).

Dispatches from the Wildlands™ ©2010, Paul Richards

PAUL THOMAS RICHARDS

A journalist with more than 43 years’ experience in Western politics and resource issues, Paul Thomas Richards has served as editor or co-editor of three newspapers; newsman and editor for The Associated Press; and elections manager for The AP, UPI, ABC, CBS, CNN and NBC.

Richards founded and produced a successful radio news network; founded and hosted a political television interview program; founded and managed a news service for weekly newspapers, and authored a syndicated statewide political column.

Richards is a voluntarily-retired member of the Montana House of Representatives and a former candidate for the U.S. Senate.

Richards owns a leading consulting firm for nonprofit organizations and Indigenous Peoples, PR Media Consultants®, Public Interest Media Since 1968™, www.PRMediaConsultants.com , in the Boulder Valley, near the community of Boulder, Montana; works as a professional writer and editor; and contributes Dispatches from the Wildlands™,  located at: http://blogs.alternet.org/paulrichards/ to AlterNet.

Paul Thomas Richards, Dispatches from the Wildlands™

DISPATCHES FROM THE WILDLANDS™

Every day, more Americans realize what the Corporatocracy and its puppet media and corporate-funded nonprofit organizations tell us to believe is usually a very far cry from reality.

As a reporter with more than 43 years’ experience in Montana politics and Western resource issues, through Dispatches from the Wildlands™, I bring viewpoints and information otherwise unavailable to readers, listeners, and viewers of corporate media in Montana; the Northern Rockies Ecosystem; and the West.

The Northern Rockies Ecosystem, comprised of northwestern Wyoming, Montana, Idaho, eastern Oregon, and eastern Washington, is the LAST surviving ecosystem in the lower 49 states with all its Native species.

My Maxim as an Investigative Reporter, Journalist, and Editor:

“Obscenely overpaid corporate CEOs, CFOs, apologists, PR flacks, lobbyists, and their ilk are fleet-footed enough to dash in and steal what we let them from our national treasury; environmental commons of air, land, and water; or our Nation’s priceless public lands Legacy.

But, Democracy is a Marathon, not a sprint!  My job as a writing professional is to help farsightedness prevail against short-term greed.  I’ve been on this beat for 43 years, and I’m hoping for another 43.”

My Maxim as an Organism on a Living, Breathing Planet:

“Stupid parasites kill their hosts.  As we become smarter, or as we recognize and adhere to the inherent intelligence of Indigenous Peoples, and of our host planet; we can again coevolve with our living Mother Earth in cooperative, respectful, and reverent symbiosis.”

My Maxim as an Activist:

“Water Wears Away Stone.   This is the undisputed, irrefutable LAW of NATURE.   If you (or, “Water”) are tired from recurrently encountering “Stone”―The lies, deceit, and pile after pile after pile of steaming fresh bullshit from the same transnational corporations, thieves, banksters, con artists, promoters, lobbyists, cronies, and self-serving politicians of the Corporatocracy; simply visit Hell’s Canyon or the Grand Canyon.

“Just stand on the edges and look down.   Take all the time you need:  Hours, days, weeks, months, years, decades, centuries, millennia, or eons.

Gaze far, far down and appreciate every one of these 8,000 feet of pure Truth.  Look down upon 8,000 feet that precisely chronicle Nature’s Law:   Water Wears Away Stone! Then:  Celebrate!  We Can Do This!”

More Information about Paul Thomas Richards:

For more information about Paul Richards, go to:  www.PRMediaConsultants.com® (Business Web Site) and www.Richards2006.us (U.S. Senate Campaign Web Site).

Dispatches from the Wildlands™ ©2010, Paul Thomas Richards

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