*From The Fund for Animals:*

**

*Yellowstone's Snowmobile Plan--A Death Sentence for Bison! Letters

Needed by Monday to Protest Government's Snow Job!*



The National Park Service's (NPS) interim plan to manage winter

recreational activities in Yellowstone and Grand Teton National Parks

and the John D. Rockefeller, Jr., Memorial Parkway will placate

snowmobilers while inviting thousands of bison to wander near and over

park boundaries where most will die at the hands of the State of Montana

and the NPS. There is a solution to this crisis that has been staring

the NPS in the face for nearly a decade--stop packing or grooming the

snow on the road surface to facilitate snowmobile access into

Yellowstone restoring natural conditions and control to the size,

distribution, and movements of the Yellowstone bison population.



Bison and other wildlife use the hard-packed, snow-covered road surface

as energy-efficient travel corridors resulting in artificial and

unnatural impacts to bison population dynamics and distribution,

movement, and habitat use patterns. While restoring natural

conditions--a mandate of federal law--may not save every bison, it will

save many and would begin to repair the artificiality inherent in the

Yellowstone ecosystem from nearly 40 years of road grooming in violation

of federal law.



Since 1996, The Fund for Animals has demanded, in court and elsewhere,

that the NPS comply with the law, protect the bison, and protect the

park by prohibiting road grooming. Though The Fund has won nearly every

legal skirmish, the NPS continues to ignore court rulings, disregard the

law, and allows over 180 miles of road surface to be groomed each year

in Yellowstone to the detriment of thousands of bison. This is no way to

treat America's first and foremost national park or America's last great

bison or buffalo population.



The government new, interim plan--a plan scheduled to be in place for

the next three winters--explicitly rejects any consideration of

terminating road grooming practices in a portion or the entirety of

Yellowstone despite a court's finding that the NPS had violated federal

law by failing to subject its road grooming practices to a full

environmental impact analysis. Indeed, the NPS has illegally allowed

road grooming to continue since the early 1970s with no valid effort to

disclose or evaluate the environmental impacts of this activity.

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While The Fund will keep fighting in and outside of court to protect

Yellowstone and your bison, we need your help right now to tell the NPS

its ongoing effort to ignore the road grooming issue and to delay the

implementation of a ban on road grooming is not acceptable. The NPS is

accepting comments on its 2004 draft winter use plan and environmental

assessment until midnight, September 20, 2004.



Comments can be submitted by mail to:

Temporary Winter Use Plans EA

Yellowstone National Park

P.O. Box 168

Yellowstone National Park, WY 82190

or via the internet at http://home.nwindenv.com/YNP_Comments4/



A sample letter is included below for your convenience or, preferably,

prepare your own letter telling the NPS to prohibit all road grooming to

protect Yellowstone bison until, at a minimum, it carefully evaluates

the impact of road grooming and has absolute scientific evidence that

groomed roads do not adversely impact bison, other wildlife, or

Yellowstone itself. Please ask your friends, co-workers, colleagues,

relatives, and acquaintances to do the same.

************************************************** *****************

Temporary Winter Use Plans EA

Yellowstone National Park

P.O. Box 168

Yellowstone National Park, WY 82190



To Whom it May Concern:



The draft Environmental Assessment on Temporary Winter Use Plans for

Yellowstone and Grand Teton National Parks and the John D. Rockefeller,

Jr., Memorial Parkway is blatantly in violation of federal law as the

National Park Service (NPS) has failed, yet again, to consider the

environmental impacts of road grooming. For over eight years the NPS has

avoiding engaging in any substantive analysis of the impacts of road

grooming and/or making any final decision about grooming constantly

claiming that more study is needed as thousands of bison have been

slaughtered--their death facilitated by their use of the groomed road

system. It is time for the studying of bison use of packed roads to

stop, for road packing practices to be terminated, and for the

restoration of natural conditions and natural regulation--as mandated by

federal law and NPS policies--to again govern management of Yellowstone

and its wildlife inhabitants.



The NPS knows that bison use the groomed roads. It knows that this use

has unnaturally altered bison population dynamics and movement,

distribution, and habitat use patterns leading to an artificially

elevated number of bison in the park, adverse impacts on park

ecosystems, and hundreds of bison being killed each winter by state and

federal agents. It also knows that groomed roads impact a variety of

other wildlife species and that terminating road grooming would be of

enormous benefit the ecological health and vitality of

Yellowstone--America's first and foremost national park. Instead of

taking action to stop and reverse these impacts by banning road grooming

in those areas where it is causing these problems, the NPS continues to

use the delay tactic of claiming that more study is needed before

impacts can be ascertained and actions can be justified. The most

compelling scientific data--that data collected primarily by Dr. Mary

Meagher, the world's foremost authority on Yellowstone bison ecology,

during her over 35 year career at Yellowstone--demonstrates that the

impacts are real, that the impacts represent an impairment to bison and

other park resources, and that the impacts or impairment must be

prohibited. Instead of conceding these facts, the NPS continues to hide

behind more recent, short-term, and highly flawed studies orchestrated

by a scientist with a clear conflict-of-interest in this issue

suggesting that the impact of bison use of groomed roads is non-existent

or minimal. Even if such studies were valid, NPS policies and federal

law require the NPS, when making a management decision, to err on the

side of the bison and prohibit road grooming instead of continuing to

groom over 180 miles of trails each winter in Yellowstone.



Indeed, despite a federal law that requires the NPS to evaluate the

environmental impacts of its activities before allowing the activities

to proceed, the NPS has illegally authorized road grooming in

Yellowstone for nearly 40 years without ever engaging in a valid impact

analysis. To make matters worse, a federal district court ruled in

December of 2003 that the NPS had indeed failed to evaluate the impacts

of road packing as required by federal law--a decision that the NPS

continues to ignore. To comply with the law, the NPS must terminate road

packing immediately and, until and unless the government can prove that

road packing does not adversely impact bison, other wildlife, or

Yellowstone's ecology.



The NPS is flat wrong in its contention that it must both protect and

preserve national park wildlife and allow for public use of our parks.

The clear and primary duty of the NPS--as many courts have held--is to

protect the wildlife and other resources of a national park. Allowing

human use is a secondary duty and can only be authorized if the human

use will not adversely impact or impair park resources and/or wildlife.

While I do not oppose non-motorized recreation in Yellowstone or

automobile access on plowed roads, snowmobiling--given its own set of

significant environmental impacts--and snowcoach use since both require

groomed trails, must be prohibited.



The NPS's failure to evaluate the environmental impacts of road packing

on bison and other wildlife in the draft environmental assessment

renders the document, regardless of its other flaws, invalid and

illegal. For nearly 35 years the NPS has been required by law to

evaluate the impacts of road packing yet, for 35 years, it has avoided

preparing such an analysis. Now, even though a federal court has held

that the NPS has failed to subject road grooming to environmental impact

analysis, the NPS continues to delay the legally required analysis of

this issue. Therefore, the NPS has a single decision to make--terminate

road packing activities pending, at a minimum, a comprehensive review of

the impacts of that practice or continue to violate federal law.



Thank you in advance for considering my comments.



Sincerely,