Montana Natural Resource Coalition P.O. Box 468 • Lewistown, MT 59457
[email protected] Interim Steering Committee Ross Butcher, President John Fahlgren Dan Bartel Anna Morris Jolene Ehlert Fergus County Valley County State Representative Treasurer Secretary June 17, 2020 Mr. William Pendley Mark Albers Deputy Director, Policy and Programs District Manager Bureau of Land Management North Central District Office Exercising the Authority of the Director Bureau of Land Management 1849 C Street NW, MS 6156 920 Northeast Main Washington DC 20240 Lewistown, MT 59457 Mr. John Mehlhoff Tom Darrington State Director Field Manager Montana/Dakotas State Office Malta Field Office Bureau of Land Management Bureau of Land Management 5001 Southgate Drive 501 South 2nd St. East Billings, MT 59101 Malta, MT 59538 Re: Report Transmittal; Termination of APR NEPA Process for Cause Via: Electronic Submission; US Post - Certified Mail Dear Messrs Pendley, Mehlhoff and Albers: I write as President of Montana Natural Resource Coalition (MtNRC) to transmit a report entitled Repurposing of Federally-Reserved Taylor Grazing Districts For Wildlife Rewilding: A Statutory, Administrative and Legal Analysis, and to request that the Bureau of Land Management (BLM) immediately terminate the National Environmental Policy Act (NEPA) review of the American Prairie Reserve (APR) cattle-to-bison change is use application due to regulatory flaws and information deficiencies fundamental to proper administrative determinations. As detailed in the attached Repurposing report, unambiguous BLM regulations do not allow bison to legitimately be classified as domestic livestock,1 and thus access of privately owned, indigenous bison herds to commensurate BLM grazing lands associated with APR fee lands can only be granted under BLMs Special Grazing and Leases Regulations at 43 CFR § 4130.6- 4.