Buffalo Field Campaign Legislative
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Federally Protected Grizzly Bears Threatened by Bison Hazing Operations |
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April 26, 2012 BFC Letter to IBMP Agencies re: Evidence of Threatened Grizzly Bear Activity in the Hebgen Basin (PDF, 104kb)
April 29, 2012 BFC Follow-up Letter to IBMP Agencies re: Evidence of Threatened Grizzly Bear Activity in Hebgen Basin (PDF, 521kb)
April 29, 2012 BFC Evidence of Threatened Grizzly Bear Activity in Hebgen Basin (PDF, 1.8MB)
March 2012 Yellowstone National Park & Gallatin National Forest Hebgen Lake Ranger District, Public Announcements, Articles, Closures and Food Storage Orders (PDF, 3MB) |
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Buffalo Field Campaign has provided expert assistance to the nonprofit Alliance for the Wild Rockies who filed suit in federal court against the Interagency Bison Management Plan (IBMP) agencies for permitting low-altitude bison-hazing helicopter flights that harass and displace threatened grizzly bears from occupied habitat.
Filed by attorney Rebecca K. Smith, Public Interest Defense Center, the Alliance's complaint alleges violations of the:
* Endangered Species Act because the IBMP agencies failed to consult with the U.S. Fish and Wildlife Service to address the impact of helicopter hazing on threatened grizzly bears in occupied habitat;
* National Environmental Policy Act because the IBMP agencies have never addressed the effects of low-altitude helicopter hazing flights on threatened grizzly bears in an environmental impact statement;
* National Forest Management Act because helicopter hazing does not comply with grizzly bear protections set forth in the Gallatin National Forest Plan; and
* Administrative Procedure Act, because the agencies' complete failure to assess the impact of helicopter hazing on grizzly bears is arbitrary and capricious, and abuse of discretion, and otherwise not in accordance with the law.
Defendants are the U.S. Dept. of Agriculture, USDA Animal and Plant Health Inspection Service, USDA Forest Service, U.S. Dept. of the Interior, U.S. Fish & Wildlife Service, National Park Service, and Christian MacKay in his official capacity as Executive Director of the State of Montana Department of Livestock. |
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Alliance for the Wild Rockies, Complaint, May 18, 2011 (PDF, 452k)
Alliance for the Wild Rockies, Amended Complaint, July 14, 2011 (PDF, 496k)
Alliance for the Wild Rockies, Supplemental brief and administrative record January 15, 2012 (PDF, 415k)
Public Interest Defense Center, Rebecca K. Smith, Declaration to supplement administrative record, January 15, 2012 (PDF, 250k) |
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Alliance for the Wild Rockies, Index of Exhibits (PDF, 235kb)
Alliance for the Wild Rockies, Exhibit 1 (PDF, 900kb)
Alliance for the Wild Rockies, Exhibit 2 (PDF, 2MB)
Alliance for the Wild Rockies, Exhibit 3 (PDF, 111kb)
Alliance for the Wild Rockies, Exhibit 4 (PDF, 267kb)
Alliance for the Wild Rockies, Exhibit 5 (PDF, 108kb)
Alliance for the Wild Rockies, Exhibit 6 (PDF, 179kb)
Alliance for the Wild Rockies, Exhibit 7 (PDF, 56kb)
Alliance for the Wild Rockies, Exhibit 8 (PDF, 43kb)
Alliance for the Wild Rockies, Exhibit 9 (PDF, 108kb)
Alliance for the Wild Rockies, Exhibit 10 (PDF, 30kb) |
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