|Subject: Public Comment Period for National Bison Range Complex Environmental Assessment (EA) to be extended to 9/18|
|From: "Susan Reneau" <firstname.lastname@example.org>|
|Date: 8/26/2014 10:05 AM|
|To: "'Will Meeks'" <Will_Meeks@fws.gov>, "'Jim Kurth'" <email@example.com>, <Dan_Ashe@fws.gov>, "'Cynthia Martinez'" <Cynthia_Martinez@fws.gov>, "'Matt Hogan'" <firstname.lastname@example.org>, "'Noreen Walsh'" <email@example.com>|
|CC: "'Jeff King'" <firstname.lastname@example.org>, "'Mike Blenden'" <email@example.com>, "'King, Laura'" <firstname.lastname@example.org>|
You as top leaders in the U.S. Fish and Wildlife Service are obligated to enforce all federal laws in protection and enhancement of the National Wildlife Refuge System and this proposal of a third AFA by the CSKT thumbs its nose at many levels of federal laws you as employees of the taxpayers of America are obligated to enforce.
I remind the media and citizens interested in this tragic case that the National Bison Range Complex is not a state or local park or a nice little piece of property to be turned over to anyone wishing to take it over. It is a NATIONAL wildlife refuge that belongs to ALL Americans, not just one special interest group. What happens at the National Wildlife Refuge Complex will impact ALL national wildlife refuges and all federal land systems if the third AFA is allowed to be put into place as a precedence for the management and funding of all federal land systems. That's why the tragic case at the National Bison Range Complex has a national implication.
As I have said before, it is an absolute outrage that the Confederated Salish and Kootenai Tribes (CSKT) sovereign government has had complete and unprecedented access to ALL aspects of the financial, personnel, and task aspects of the National Bison Range Complex “ a NATIONAL wildlife refuge “ for the past four years with exclusion by the press and general public, especially the public that cares the most about the National Wildlife Refuge System. The general public and press has only six weeks now to formulate comments without the access to documents that the CSKT has had for the last four years.
do not fault the CSKT. You as the administrators and some political appointees
of the U.S. Fish and Wildlife Service and the U.S. Dept. of Interior have
allowed the CSKT to do this. The CSKT is only doing what they are allowed
to do by YOU.
You have abdicated your duties to uphold ALL federal laws by allowing a special interest group and sovereign government not beholden to ANY taxpayer or ANY federal workers to take over a NATIONAL wildlife refuge, which is what this third AFA does.
I further remind all of you that TWICE the CSKT has been removed from the National Bison Range Complex for the previous two Annual Funding Agreements and you need to examine why that happened because it goes to the heart of the problems associated with such an intrusive and illegal Annual Funding Agreement that violates many levels of federal law and insults many levels of federal workers that are dedicated to the betterment of the entire National Wildlife Refuge System, but especially the National Bison Range Complex.
I call your attention to very courageous refuge managers that wrote a letter in 2004 detailing why any AFA is intrusive and disruptive to the entire National Wildlife Refuge System. What they predicted in 2004 came true for the first and second AFAs at the National Bison Range Complex. The process forced upon qualified USFWS federal employees at the NBRC has also impacted employment practices and management throughout the system as well as negatively impacting the career opportunities of many USFWS federal workers on many employment levels.
I will certainly submit my comments about the third AFA at the NBRC by Sept. 18 and I encourage all my conservation heroes to submit comments about the impact of this third AFA to the entire National Wildlife Refuge System, but I am utterly disgusted that federal laws on the books since 1903 have been ignored by modern U.S. Fish and Wildlife Service and U.S. Dept. of Interior officials. I remind you, in case you forget, that when the National Wildlife Refuge System was first established by an Act of Congress and signed into law by then-President Theodore Roosevelt in the early 1900s for all Americans and visitors to America to enjoy. The Indian Self Determination and Education Act did not exist and this act was voted by Congress and signed into law to enhance, not destroy, the National Wildlife Refuge System.
entire proposal, written by the CSKT, for the third Annual Funding Agreement
at the National Bison Range Complex violates hiring practices required in
the Civil Service Act where qualified federal workers from around the country
can apply for any position within the National Wildlife Refuge System and
be graded based upon their experience, education, and knowledge - not by the
sovereign government they support. Furthermore, the National Wildlife Refuge
Act and the Range Management Act were written to protect the overall operation
of the National Wildlife Refuge System from special interest groups, individuals,
sovereign governments, local and state governments and any other organization
or individual since the national refuges within the National Wildlife Refuge
System are NATIONAL and within a SYSTEM.
You as the well-paid federal government officials in charge of enforcing ALL federal laws that pertain to the National Wildlife Refuge System are not allowed to pick and choose which federal laws you will follow and which you will ignore. As I have said many times before, the Indian Self Determination and Education Act was not created to destroy the inner workings of the National Wildlife Refuge System or allow inherently federal positions and tasks to be given away to sovereign governments, private contractors, individuals outside the Civil Service System or other organizations. I would object to my own husband, a certified wildlife biologist, to receive a position at the National Bison Range Complex because he is not with the Civil Service System.
The Indian Self Determination and Education Act was created to give opportunities to Native Americans to become involved in certain and limited aspects of the National Wildlife Refuge System since their ancestors were a part of our nation long before our nation was a nation. You are ignoring all other federal laws to allow one special interest group, namely a sovereign government, to dominate the operations of a NATIONAL wildlife refuge, namely the National Wildlife Refuge Complex, and to turn your backs on competent federal workers, including CSKT members and relatives at the NBRC that are federal workers, that deserve to do their jobs as part of the National Wildlife Refuge System.
I again express dismay that the CSKT has been given by you, not the CSKT, four years of complete access and federal workers throughout the process, including CSKT members stationed at the National Bison Range Complex, have been insulted and ignored throughout the process that excludes the experts from the USFWS that know the most about the management and financial balance at the National Bison Range Complex. Furthermore, those federal workers care about the National Wildlife Refuge System as a whole.
In the spirit of Theodore Roosevelt, Ding Darling, Horace Albright, Aldo Leopold, Madison Grant, George Bird Grinnell and the men of the late 1800s and early 1900s that established the National Wildlife Refuge System, National Park System, National Forest System and all federal land systems plus state game and fish agencies, I say, the wildlife and its habitat cannot speak so I must and I will and YOU as the employees of the taxpayers of America are obligated to do the same.
Susan Campbell Reneau
Author and editor of 22 books on wildlife, wildlife conservation and western historyHunter and mother of three human hunters and two Labrador retriever hunters719-661-4037
I have been in contact with you regarding the public comment period for the NBR EA over the past couple of weeks. Yesterday (8/25) the Regional Director decided to extend the comment period to 9/18 and the Federal Register extension notification is being routed for signature currently. Once all surnames have been obtained it will post in the Federal Register making it official.
U.S. Fish and Wildlife Service, Region 6
ARD-NWRS and PFW