And now:Ish <[EMAIL PROTECTED]> writes:

>X-Sender: [EMAIL PROTECTED]
>Date: Thu, 31 Dec 1998 11:51:47 -0700
>To: "Wild Rockies Alerts" <[EMAIL PROTECTED]>
>From: Wild Rockies InfoNet <[EMAIL PROTECTED]>
>Subject: Comments on Buffalo Capture-for-Slaughter Facility Due on Jan. 13
>Sender: <[EMAIL PROTECTED]>
>
>Action Alert: Comments on Horse Butte Buffalo Trap Due on January 13, 1999
>
>Howdy folks,
>
>Please take some time to read and respond to the request for comments on
>the Horse Butte Buffalo Trap Environmental Assessment and support
>Alternative 3: the No Action (No Capture Facility) Alternative. The EA is
>online, see the address at the bottom of this alert. And thanks to all of
>you who responded to our request for comments on the first phase of this
>misguided project. Though the Forest Service only sent out scoping notices
>to about 13 organizations, they received 502 comments, with over 300 of
>them coming via email!! Keep up the good work!
>
>As of December 30th, the Montana DOL has yet to begin construction of the
>facility, though they have put up a gate and plowed roads to the proposed
>location, and have relocated snowmobile routes. They also have asked the
>USDA for the funds to construct and operate the facility, though APHIS has
>only committed itself to providing half of the construction cost ($50,000),
>and hasn't decided on the operating expenses (appx. $500,000).
>
>This is our last opportunity to object before they start capturing and
>hauling buffalo to the slaughter house.
>
>Jim Coefield
>mailto:[EMAIL PROTECTED]
>____________________________________________
>
>On December 14, 1998, the Gallatin National Forest released the
>Environmental Assessment (EA) on the Horse Butte Buffalo Capture Facility.
>Comments on the EA are due by January 13, 1998.
>
>This is the second phase of the trap permitting process. The first phase
>was  when the Montana Department of Livestock (DOL) requested a Special Use
>Permit and that the Forest Service grant a Categorical Exclusion (CE) to
>expedite the process. CE's cannot be appealed, and are either granted in
>emergencies, or when the proposal doesn't rise to a certain level of
>significance. Obviously, issuing an EA for this proposal underscores its
>significance, and the inability of the CE to stand on its own.
>
>In an odd, and most likely illegal planning maneuver, the Gallatin NF split
>the project into these two phases. The first phase authorized construction
>of the trap at the main Horse Butte site (Alternative 1 at Site 2A) and
>granted authority to operate it until January 31, 1999. The second phase,
>which this EA would authorize, also analyzes an alternative site
>(Alternative 1, Site X) to the one authorized in the CE, and looks at
>operating the facility for the next 10 years.
>
>The Chief of the Forest Service also granted an exemption from the
>automatic stay provisions of the appeal regulations. This means that even
>though parties may appeal the EA decision, the Chief will allow the project
>to proceed during the appeal process. This leaves us with a lawsuit as our
>only remedy. What does this all mean? It's a done deal! The heck with

>public process and opinion. The DOL wants the authority to construct and
>operate this facility at all costs, even illegal ones.
>
>The no action alternative (Alternative 3) is the only logical solution.
>Unfortunately, the no action alternative already has been rendered invalid
>by the CE's allowing the Forest Service to issue the Special Permit (which
>it already has done) for the construction and operation of the facility.
>
>"The No Action Alternative would constitute a decision not to issue a
>special use permit to the DOL for the installation or operation of a bison
>capture facility in the Horse Butte area." (from the EA)
>
>In other words, there isn't any possibility that the Forest Service will
>chose the no action alternative, because the permit already has been
>issued. Double speak extraordinaire.
>
>The main issues:
>
>* The trap will be placed in a location where the greatest concentrations
>of buffalo are. Buffalo will be lured into the trap by baiting with hay or
>by hazing. All animals will be tested for brucellosis. All "pregnant
>females and animals testing positive would be transported from the site for
>disposal." That means slaughter.
>
>* The preferred alternative (Alternative 1 at Site A2) would locate the
>trap within 1/2 mile of a bald eagle nesting site. The so-called reason for
>splitting the project into two parts (CE and EA) rests with the Bald Eagle
>(a threatened species) situation. Until February 1st, the project would not
>necessarily violate Bald Eagle management guidelines. After that day, the
>nest site is considered to be active, and a higher level of restrictions on
>human activity kicks in. The Gallatin NF's solution? A site specific Forest
>Plan Amendment to exempt the project from Bald Eagle guidelines and to
>exempt it from visual quality standards. Don't like restrictions? Sweep
>them under the carpet.
>
>* The Gallatin already has shown its unwillingness to enforce Bald Eagle
>closures. Last winter a DOL hazing operation violated a special closure
>around the Horse Butte nesting site by flying a helicopter through the area
>and actually landing in the area. Buffalo Nations and Cold Mountain, Cold
>Rivers have video documentation of the violation. Helicopter? What
>helicopter? I don't see no helicopter.
>
>* The Forest Service's whole logic with permitting the trap rests on the
>notion that if they allow the capture facility, then only animals that test
>positive to brucellosis or pregnant females (even if they test negative)
>will be slaughtered. They infer many times that without the trap, more
>animals will be slaughtered through indiscriminate shooting. The EA refuses
>to examine the issue of brucellosis transmission from buffalo to cattle.
>But how can you determine that there is a need for an action (slaughtering
>buffalo) without discussing the scientific data (or lack thereof) on
>transmission of brucellosis from buffalo to cows. Cows are not even present
>in the area until June, and it is an accepted scientific fact that if the
>buffalo move back into the Park 30-60 days prior to cattle being moved into
>the area, that there is no risk of transmission.

>
>* Horse Butte is a beautiful area surrounded on three sides by water.  The
>facility will be located at the neck of it.  It is traditional
>winter/nesting/birthing grounds for not only the endangered bald eagle and
>the buffalo but elk, deer, swans, pelicans and other many species.
>
>Make sure to include the following points in your comments:
>
>* Demand that the Forest Service adopt the "no action" alternative, which
>will not allow the trap to be built or operated, and to rescind the Special
>Use Permit that the CE allowed.
>
>* Splitting the DOL's Special Use Permit request into a CE and an EA
>violates NEPA by segmenting the trap project into two connected actions.
>This is illegal.
>
>* Exempting the trap from Bald Eagle protection guidelines in the Forest
>Plan (by amending the Plan) is wrong, and will not exempt the trap from
>provisions of the Endangered Species Act that protect threatened and
>endangered species.
>
>* Reducing buffalo population numbers in the ecosystem through unnatural
>processes (trapping and slaughter) impacts the grizzly bear by removing an
>essential food source (winter killed and weakened animals) in the spring.
>
>* Demand that the Forest Service adopt scientifically based "risk
>management" techniques instead of the DOL's "zero tolerance" approach to
>buffalo management. These risk management tactics are discussed more fully
>in Plan B and the Bison Alternative (independently developed alternatives
>to the EIS on Bison Management in Yellowstone and Montana that is in
>progress).
>
>* There are many other issues involved with this proposal with other
>threatened and endangered species, local residents, snowmobiling, etc. If
>you take the time to read the EA (see online address below), you'll
>discover many other things to
>comment on.
>
>Thanks!
>
>______________________
>
>Please send your comments (by Jan 13th), or requests for further
>information to:
>
>Olleke Rappe-Daniels
>USDA Forest Service R1 HQ
>200 E. Broadway
>Box 7669
>Missoula, MT 59807
>ph: 406-329-3028
>mailto:[EMAIL PROTECTED]
>
>CC: to Mike Dombeck
>Chief, Forest Service,
>Auditor's Bldg
>201 14th Street, S.W. at Independence Ave., S.W.
>Washington, DC 20024
>202-205-1661.
>mailto:[EMAIL PROTECTED]
>
>If you send your comments by email, make sure to include your name and
>address so that the Forest Service can fully analyze the range of comments,
>and where they come from.
>
>For more information, you can view the EA online at:
>http://www.fs.fed.us/r1/gallatin/bison/index.html
>
>You also can check out our web pages for more information in general about
>the buffalo situation in Yellowstone National Park:
>
>Buffalo Nations: http://www.wildrockies.org/buffalo/
>Stop the Slaughter: http://www.wildrockies.org/bison/
>Plan B: http://www.wildrockies.org/PlanB/
>
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