March 16 th, Objection Reviewing Officer, Regional Forester Nora Rasure Intermountain Region USFS th Street Ogden, UT 84401

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1 March 16 th, 2015 Objection Reviewing Officer, Regional Forester Nora Rasure Intermountain Region USFS th Street Ogden, UT Sent by to: Cc: Objections to the Record of Decision (ROD) and Final Supplemental Environmental Impact Statement (FSEIS) for the Long-Term Special Use Authorization for Wyoming Game and Fish Commission to Use National Forest System Lands for their Winter Elk Management Activities at Alkali Creek Feedground Dear Regional Forester Rasure, On behalf of the Greater Yellowstone Coalition (GYC), the Jackson Hole Conservation Alliance (the Alliance) and our members from Wyoming and nationwide, we appreciate the opportunity to participate in the objection process for the ROD and FSEIS for the Long-Term Special Use Authorization for Wyoming Game and Fish Commission to Use National Forest System Lands for their Winter Elk Management Activities at Alkali Creek Feedground. GYC has over 48,000 supporters and constituents who support our mission of protecting the lands, waters and wildlife of the Greater Yellowstone Ecosystem (GYE), now and for future generations. GYC was founded in 1983 on a simple premise: An ecosystem will remain healthy and wild only if it is kept whole and we advocate for the idea that ecosystem level sustainability and science should guide the management of the region s public and private lands. GYC works to ensure that a thoughtful and holistic approach is taken to managing the wildlife resources in harmony with people and modern development. We work to shape a future where wildlife populations maintain their full diversity and vitality, where ecological processes function on public lands with minimal intervention, where exceptional recreational opportunities abound for

2 visitors and residents alike, and where communities can enjoy a healthy and diversified economy. The Jackson Hole Conservation Alliance has 2,000 supporters and works to protect the wildlife, wild places, and community character of Jackson Hole by empowering the community to live in balance with nature. Through a structure of integrating focused issue advocacy campaigns, intentional base building, leadership development, targeted education efforts, and accountability work, we strive to advance an agenda that will create a better future for people and wildlife. We lead and engage in issue advocacy campaigns regarding wildlife management, appropriate use of our public lands, transportation, and community planning. The Alliance works to ensure that our agency managers have the autonomy and resources to make decisions based on facts and data, free from political interference. History behind GYC s and the Alliance s involvement in Alkali Creek SEIS decision GYC and the Alliance both submitted comments in 2008 on the Bridger-Teton National Forest s (BTNF) Draft Environmental Impact Statement (DEIS) analyzing the Wyoming Game and Fish Commission s (WGFC) use of National Forest lands for various winter elk management programs and activities. These activities by the State of Wyoming have in the past occurred at the Fish Creek, Dog Creek, Muddy Creek, Fall Creek, Alkali Creek, and Upper Green River elk feedgrounds. Our organizations were signed onto an August 14, 2007 letter to the BTNF, with concerns raised during scoping for temporary use authorizations analyzing four elk feedgrounds and sent comments on September 17, 2007 on the DEIS for the consideration of issuing 20-year permits for the potential continuation of the same elk feedgrounds at issue here and related activities. These comments were submitted to then Forest Supervisor Kniffy Hamilton. Following that process our organizations operated individually on the scoping and draft SEIS comments. GYC submitted scoping comments on May 18, 2012 addressed to then Supervisor Jacque Buchanan. Finally, GYC submitted comments on the Draft SEIS on June 3, Together our organizations have over a decade of advocacy on elk feedgrounds in Wyoming that has spanned the process resulting in this FEIS. This advocacy has extended through the tenure of three forest Supervisor s along with many interim Supervisors and Regional Foresters. Likewise, this advocacy has endured through many individual employees of our two organizations, including Scott Groene, Lloyd Dorsey, Franz Camenzind, Tom Darin, Louise Lasley, Cory Hatch and today Chris Colligan, Wildlife Program Coordinator for GYC and Siva Sundaresan, Conservation Director for the Alliance. Collectively, these individuals have invested significant time in organizing our membership to be involved in the public process and have indivdually met with BTNF staff to raise our concerns with great frequency. We have a long history of advocating for better management of elk feedgrounds on the BTNF, including reducing artificial concentrations of elk and the phase out of supplemental feeding. We have routinely advocated for the need for changes in the management of elk feedgrounds and the threats of disease transmission to Wyoming s elk population. These comments represent our connection between prior specific written comments on this project and the content of the

3 objection. Appended to these comments on the FEIS we have included our past history of comments on the issues that we raise within these objections. Through these organizational and lands manager iterations, we have consistently sought a better outcome in this final decision. Our organizations envision and work toward a GYE which supports a healthy and thriving elk population with intact migrations between their native summer and winter ranges. The general practice of confining elk to feedgrounds is not in line with that vision. However, we also recognize the constraints that drive state and federal mangers to seek this unnatural management action. We offer these objections below, along with suggested remedies, as initial steps on a path toward thoughtfully reducing and ultimately eliminating this artificial practice. We raise the below objections that are consistent with our previous advocacy and are making a cognizant effort to offer remedies to improve the conditions of the final authorized use. Our comments raised concerns under the National Environmental Policy Act (NEPA) 1, Endangered Species Act (ESA) 2 and National Forest Management Act (NFMA) 3. Our goal was to offer modifications to the permit that would improve the decision from both a legal perspective, and more importantly from a practical standpoint, allowing the Forest the oversight to transition away from permitting the use in the future. We believe that by addressing our objections the BTNF can take positive steps toward improving conditions at Alkali Creek and reduce some of the negative effects of elk feeding. We are offering a set of specific remedies that can be applied in the required design features and monitoring section within the ROD that act as terms and conditions of permitting Alkali feedground and the impacts it has on our public lands and wildlife. Summary of Objections Below is the summary of the objections we are raising. 1. Feedgrounds impacts on Gray Wolves were inadequately considered in the Record of Decision (ROD). 2. BTNF arbitrarily relies upon Chronic Wasting Disease (CWD) plan that is outdated. 3. Soil compaction and disturbance impacts and risks of disease transmission are not adequately addressed. 4. BTNF did not adequately consider available forage in the ROD. Feedgrounds impacts on Gray Wolves were inadequately considered in the SEIS We disagree with the Forest s determination that there will be minimal impacts to gray wolves when the WGFC explicitly details their interests in using lethal removal of wolves on elk feedgrounds, and specifically Alkali feedground, to minimize conflicts. In addition, we believe that the Forest has not 1 National Environmental Policy Act (Public Law ) 2 Endangered Species Act (Public Law ) 3 National Forest Management Act (Public Law )

4 adequately considered the impact of lethal wolf control, following science that shows wolves role in modifying CWD transmission in elk herds. We support maintainance of healthy, viable populations of large carnivores that are allowed to play their ecological role in the largely intact landscape that makes up the analysis area for the permitted actions at the Alkali feedground and the beneficial cumulative effects of carnivores in the Gros Ventre watershed. Our concern is that without adding design features that restrict WGFC policies for the proposed management of wolves on elk feedgrounds, these ecological processes would be harmed. Our organizations have raised substantive comments with concerns about the impact of elk feedgrounds on wolf management. The permitted action is directly related to Wyoming Game and Fish Commission s wolf management plan for gray wolves that has been dismissed by Federal Courts for deficiencies resulting in relisting under the ESA. 4 In our 2008 comments on the DEIS we stated The WGFC has drafted regulations that would allow wildlife managers to kill (wolves) for elk conflicts on State feedgrounds (DEIS:81). It is clear that the presiding sentiment of the WGFD is that wolves are considered a problem on and around elk feedgrounds and some wolves have already been killed because of it. The DEIS states that since all alternative(s) assume the continued use of feedgrounds as a winter elk management program by the state, the risk of this (lethal take of wolves) would not vary by alternative. In the 2012 revision of the Final Gray Wolf Management Plan, these problems continued to persist. We raised these comments again in 2013 (page 56 of Appendix 8). The Wyoming Game and Fish Department has direction per their Final Gray Wolf Management Plan ( NAL pdf Page(s): 32-39) and Wyoming State Statutes to lethally control wolves for the interactions that occur at winter elk feedgrounds. Further, WGFD specifically cites Alkali feedground as a location that there will be anticipated conflicts with wolves causing elk damage to stored hay or cattle feedlines and brucellosis transmission to livestock, as well as elk crowding, brucellosis, (and) hay supply issues (WGFD 2011, page 37). These conflicts would allow the WGFD, per their management plan, to lethally remove wolves through agency control efforts which may be precipitated through contract with Wildlife Services, involving helicopter gunning or other means. We have continued to raise the important role wolves may play in reducing transmission of diseases such as CWD. From our 2008 comments we stated, wolves play an important role in elk ecology as well as a natural buffer to disease, crowding, over-browsing, and other negative impacts of elk feedgrounds. By reducing prey numbers, dispersing these animals on the landscape, and removing sick animals, wolves may reduce the transmission and prevalence of 4 Defenders of Wildlife et al v. Salazar et al, Case No. 1:12-cv-01833

5 wildlife diseases such as chronic wasting disease and brucellosis (Smith 2005,) Recent research has modeled how the presence of wolves may be considered an effective measure for controlling CWD. The analysis in the ROD fails to address the implications of lethal control of wolves proposed by state of Wyoming in response to interactions between wolves and elk at Alkali feedground or even state that those actions would first need to undergo a thorough NEPA review or Biological Opinion from the USFWS before they would be allowed on National Forest lands. The ROD states My decision is in compliance with the Endangered Species Act (Public Law ). A Biological Assessment (BA) was prepared and is incorporated into the Wildlife Report as part of the analysis of the alternatives. In 2013, my staff informally consulted with the U.S. Fish and Wildlife Service (USFWS) with regards to effects on three federally listed species. Findings of may affect, not likely to adversely affect were made for Canada lynx, Designated Critical Habitat for Canada lynx, and grizzly bear. As of September 2014, the experimental, non- essential status of gray wolves in Wyoming on National Forests was re-instated. This statement raises the question on if the BTNF sought Section 7 consultation with the USFWS after wolves were relisted and if the potential for lethal removal was considered as part of the permitted action? This seems in stark contrast to the level of detail the BTNF went into citing the benefits of wolves and other large carnivores in reducing disease transmission. The Forest staff deserves recognition for the thoughtful analysis that was completed on CWD in Appendix 7. Some excerpts from that summary include: What is known is that presence of wolves influences elk behavior, and some generalizations can be made about the impact that those changes in behavior might have on disease transmission; Research on free ranging elk without wolf pressure has shown that elk in larger groups tend to have higher rates of contact and that contact lasts longer; It has been shown that deer killed by mountain lions have a higher CWD prevalence than non-killed deer, suggesting that lions select for CWD affected deer. It stands to reason that mountain lions would similarly select for affected elk and that an elk clinically affected by CWD would be targeted by wolves. This review of literature on CWD and thoughtful decision making process on the implications between carnivores and elk doesn t appear to be reflected in the ROD. Additionally, the WGFC has expressed concerns about the harrassment and harvest of scavengers on elk feedgrounds as cited in the FSEIS on page 189. In that BMAP update the WGFC added a best management practice of No harassment/harvest of scavengers on feedgrounds. The plan goes on to state that through research conducted by the Department it is suggested that reduction of elk densities on feedgrounds, time spent on feedlines (e.g., altered feeding patterns), and protection of scavengers on and adjacent to feedgrounds could reduce intraspecific transmission of brucellosis. Forest officials seem to agree as the FSEIS states (page 85) that Predators may also select for prey that are infected by diseases that render prey more vulnerable.

6 With all the analysis of the benefits of wolves (and other scavengers) in disease mitigation discussed extensively in the ROD and FSEIS we are struggling to understand why the BTNF has not taken the explicit intentions of the WGFC to lethally remove wolves on elk feedgrounds into consideration. We offer the following remedy that would address our concerns and compliance with the ESA and NEPA. Remedy: A design feature would be added that specifically prohibits lethal removal of wolves, carnivores and other scavengers within analysis area of Alkali feedground as it relates to operation of the feedground management activities. BTNF arbitrarily relies upon Chronic Wasting Disease (CWD) plan that is outdated Our organizations have concerns over how the BTNF has addressed the threats of CWD in the ROD. The ROD states in condition #8 that If chronic wasting disease is detected in Wyoming west of the Continental Divide the provisions of the WGFD Chronic Wasting Disease Management Plan will be implemented and the Bridger-Teton will intensify coordination with the WGFD and surrounding federal and state land management agencies concerning disease management actions. Later the agency admits that the development of a contingency plan is still aspirational and that a plan will not be completed until July Forest Service requested that WGFD convene an interagency working group to update contingency plans for the feedground portion of the WGFD Chronic Wasting Disease Management Plan. WGFD did convene such a group and it consists of staff from WGFD, Bridger-Teton National Forest, Grand Teton National Park, and the National Elk Refuge. The results of this group effort are expected to be released in July, While we agree that it is critical for interagency coordination to occur on the threats of CWD, the approach the BTNF has taken appears to be pre-decisional to permit the activities to continue without the implementation of a plan that addresses the concerns raised by our organizations and members of the public regarding this issue. In our comments on the 2013 DSEIS, we noted that the BTNF defers to the WGFD Chronic Wasting Disease Management Plan, which violates NEPA and the Administrative Procedures Act. Unfortunately, as in the 2008 DEIS, the BTNF in this DSEIS, page 9 at 3, again defers to the WGFD CWD Management Plan to avoid having to adequately address and mitigate the effects of this deadly disease on elk herds and the environment. Our concerns remain that WGFC s CWD Plan intends to continue with winter elk feedgrounds even if CWD is discovered thereon. The WGFD is not bound by any regulations to maintain the health of federal lands other than to follow the conditions of permits issued by the USFS, and has stated clearly in its CWD Plan that even if CWD-infected elk are discovered on feedgrounds, it will continue to operate feedgrounds on those very USFS lands that may be contaminated with CWD prions. The duty to protect those USFS lands, however, lies with the USFS.

7 Our comments in 2013 stated that to defer to the WGFD CWD Action Plan and the WGFD assessment of CWD, and to the USFWS treatment of CWD, which are one and the same, and ignore the entire body of real expert reports is arbitrary, capricious, and an abuse of discretion by the BTNF of the highest order. (5 USC Sec 706(2) (2000). This concern remains despite the language contained in the ROD that assures coordination is occuring. Wyoming s CWD plan contained in the FSEIS (Appendix 3, page 243) was written in 2006 and is clearly outdated given the vast scientific research that has occurred in the last decade on CWD that BTNF staff reference in Appendix 7. However, the USFS continues to rely upon the outdated WGFD CWD Management Plan (DSEIS, Page 5). The WGFC's Chronic Wasting Disease Management Plan (2006) contains actions that will be implemented if CWD is identified in elk attending feedgrounds. The CWD plan even states that the plan will be reviewed and updated as the CWD situation in Wyoming changes and additional information becomes available. A review may be forthcoming, but there is no assurance that the efforts at local coordination on CWD issues possibly released in July of 2015 will be integrated into this plan nor that any management decisions at Alkali feedground will be changed as a result of these two plans. We have raised concerns in the past that the BTNF is deferring its responsibility under NFMA by relying on the WGFC s CWD Action Plan. Because WGFD would continue to feed on private, state, and other federal lands even if a permit is not issued for this feedground, elk will continue to congregate on WGFC feedgrounds regardless of this Forest Service decision. The potential for CWD transmission through use of feedgrounds is addressed in the State s CWD Management Plan, Appendix 3 and the USDI Bison and Elk Management Plan and Environmental Impact Statement for the National Elk Refuge and Grand Teton National Park. Because it is projected that feeding would continue regardless of the Forest Service decision proposed here, this decision does not affect or control the potential for CWD transmission. It is clear that the BTNF put significant time and consideration into how to address CWD in the FSEIS and ROD. There is much uncertainty over when CWD may arrive on Wyoming elk feedgrounds and what the impacts will be. We feel the Forest Service is required to implement the precautionary principle in how it manages this uncertainty. We offer the following remedy that will put the BTNF and its lands and wildlife resources in a better position for managing the impacts of CWD. Remedy: An additional design feature will be added to the ROD ensuring that the BTNF will not only engage in local coordination with staff from WGFD, BTNF, Grand Teton National Park, and the National Elk Refuge to update contingency plans, but also that BTNF ensure these contingency plans are reflected in the future review of the WGFC CWD Action Plan. Further that this contingency plan will ensure that feeding will cease at Alkali Creek feedground upon discovery of CWD in any ungulate species within the Jackson Elk Herd Unit.

8 Soil compaction and disturbance impacts and risks of disease transmission are not adequately addressed GYC and the Alliance have consistently raised concerns on how the Forest has addressed issues with soil compaction and disturbance and risks associated with elk density and disease transmission. We raised these concerns in our comments in June of 2013 on the DSEIS. Unfortunately, as a permitter of elk feedgrounds, the BTNF, the only forest in the Rocky Mountain area to permit this kind of wildlife program on this scale, has essentially become complicit in causing harm to soils, plant communities, and wildlife and has allowed for elevated risk to elk and other cervids from debilitating and deadly diseases for decades. The Forest continues to agree that concentrated elk use and the feeding operation does compact the soil. (ROD page 8) Page 3 of the ROD attempts to incorporate design features (#4) to address this concern. Forest Service monitoring of soil disturbance class and percent detrimental soil disturbance will occur about every five years. And (#6) Feeding operations will be conducted over 18 inches of snow or frozen ground as much as possible to reduce the potential for soil compaction from feeding sleds and hoofed animals. The incorporation of design features to minimize soil compaction and erosion may benefit soil compaction and disturbance, only if the requirement explicitly prohibits feeding on thawed ground. It is important for the Forest Service to clarify this point because it is common for feeding to occur before or after snowmelt on state feedgrounds as the WGFD justifies elk feeding in response to other criteria (aside from lack of available forage, such as conflicts on private land.) Density impacts of congregating elk on feedgrounds on soil disturbance and compaction is similarly linked to the function of disease transmission and artificially high concentrations during the winter. The Forest service should address the both of these issues in seeking solutions that distribute elk on the landscape more effectively. We disagree that the Forest does not have a clear role in managing the potential for disease transmission on federal lands as deferred to the WGFC in the ROD I clearly understand and acknowledge that the Commission s action of feeding results in artificially high concentrations of elk during winter and early spring which increases risk of disease transmission (Johnson, 2014; Appendix 7; and Appendix 3 in the 2015 Final SEIS). The Forest Service is working in cooperation with the Commission and other federal agencies to support brucellosis and other disease management efforts. It is the responsibility of the Commission to direct the management of wildlife populations, including studying and managing the potential for disease transmission and determining acceptable levels of disease prevalence and risk. We disagree with this conclusion and believe it is the responsibility of the Forest to manage impacts to Forest lands specific to soil disturbance and disease transmission. We raised similar

9 issues in our comments in relation to disease management and density implication. It's not always necessarily numbers of elk that is the important variable in calculating risk from transmissible diseases, it can also be density of infected and vulnerable animals, rates of contact, length of contact and so forth. Ironically, WGFD has provided research on the benefits of reducing density in relation to feeding patterns on elk feedgrounds. In their 2011 BMAP update (cited in FSEIS pg. 189) it states Creech et al. (In Review) compared Low-Density (LD) to traditional feedlines via datalogging radio collars and digital video cameras and found that LD feeding reduces elk-to-fetus contacts by 66%-75% and, based on an appropriate SIR disease model, may substantially reduce seroprevalence in elk if implemented over a decade or more. WGFD recommends low density feeding methods as Best Management Practice for target feedgrounds. However, Alkali Creek feedground remains off the list of target feedgrounds. 5 We feel that the BTNF should modify the above design features to reduce disease transmission risks and negative impacts associated with soil compaction and disturbance. This is a novel, practical consideration that WGFC has already implemented on some state feedgrounds that would benefit the resources at Alkali feedground and the surrounding forest lands. Remedy: The existing design feature #6 would be improved by stating; Feeding operations would cease in the absence of over 18 inches of snow or frozen ground to reduce the potential for soil compaction from feeding sleds and hoofed animals. Further, #3 could be improved by stating, WGFD would implement low density elk feeding techniques, as described in the WGFD best management practices, at Alkali Creek feedground and Forest Service monitoring of soil disturbance class and percent detrimental soil disturbance will occur at least every five years. BTNF did not adequately consider forage availability in the Record of Decision. Throughout the EIS process, our organizations raised concerns that the BTNF should consider if feeding is necessary at Alkali feedground given the abundant natural forage and winter range protections in the Gros Ventre. Currently, the BTNF has no oversight on the determination of whether feeding is necessary, even on years when snow conditions, forage availability and private land conflicts would not necessitate supplemental feeding. Despite the fact that there are 17,109 acres of crucial winter range for elk in the project area and over 100,000 of acres of winter range in the entire Gros Ventre drainage, there is no mention of determining whether feeding is necessary given available forage or forage conditions in the ROD. Additionally, there have been efforts to improve winter range through habitat treatments and reduction of conflicts using fencing on private lands. There are many opportunities to further these programs and assistance is available from conservation groups such as our own to mitigate conflicts. These suggestions were dismissed because the Forest Service does not have the 5 WGFD Target Feedground Project. WGFD, Cheyenne, Wyoming.

10 jurisdiction to stop elk feeding (Page viii, FSEIS). Further, the Forest Service dismissed concerns of available forage, because WGFD would continue to feed on private, state, and other federal lands even if a permit is not issued for this feedground, elk will continue to congregate on WGFC feedgrounds and therefore continue to under-utilize transitional and winter ranges regardless of the amount of forage available. (FSEIS, Page 9) In GYC s June 2013 comments on the DSEIS we reiterited our joint concerns made during the public comment process on the DEIS in We stated; When analyzing a range of alternatives to elk feedlots, the BTNF must include analyses of elk transitioning to completely using natural forage on big game winter ranges to survive the winters. Maps of big game winter ranges designated by the USFS, NPS, FWS, BLM, and WGFD can be obtained from the WGFD; the winter ranges consist of many tens of thousands of acres and may spread across USFS, NPS, FWS, BLM, State and other lands. Winter ranges adjacent to current feedlot sites as well as winter ranges at reasonable distances from feedlot sites must be considered, as should the feasibility of the elk to access those ranges. The BTNF must assess the amount of forage on designated winter ranges left after the growing season that may be used by big game during winter. They must calculate the tonnage of forage using scientifically valid production plots, or use available information that may be applied to similar slopes, elevations, snow pack, and vegetation types as exist on the various winter ranges. Most importantly, the USFS should calculate the ability of that amount of forage to sustain the estimated number of elk using the range (i.e., carrying capacity). Because the stated purpose and need for a federal action determines the range of alternatives, it is essential that the Forest Service clearly articulates the project s purpose and need from the USFS perspective and not simply adopt the WGFC objectives for the project as its own. (40 C.F.R ). WGFD also demonstrates the value of available winter range to elk in the vicinity of Alkali feedground as described in the FSEIS on page 82. Based on three models, the (2004) estimated a carrying capacity of 3,375 7,641 elk (183 days) during years of mean spring fall precipitation; 5,063 11,463 elk during wet years; and 1,519 3,440 elk during dry years. Elk numbers averaged 4,427 before routine feeding occurred (years ), and ranged from 692 to 9,128 individuals (Anderson 1958, cited in WGFD 2004). Based on these data, forage production and availability on native range is sufficient to support historic (pre-feeding) numbers, except for winters preceded by dry spring fall seasons (WGFD 2004). We continue to believe that there is a need for the Forest Service to determine whether feeding is necessary on an annual basis and that this need could be easily addressed with the addition of design features within the Preferred Alternative and ROD. The FSEIS documents a model of interagency cooperation that is used in determining whether and when to initiate feeding on the National Elk Refuge (NER). Each year, forage conditions are monitored regularly by Game and Fish and National Elk Refuge personnel. The decision of when to start and stop feeding is typically made jointly. (FSEIS, Page 189) Similarly, we believe that the BTNF and WGFD biologists should cooperatively investigate forage conditions and jointly determine when or if feeding is initiated and ended at Alkali feedground.

11 Remedy: Similar to the process that is used to determine when feeding starts and stops on the NER, the BTNF should include as a design feature in the ROD a joint effort between BTNF wildlife biologists/botanists and WGFD personnel to determine feeding initiation and cessation. Specific thresholds for forage utilization and available forage would be developed that can be coordinated with the feeding regimes on the nearby feedgrounds and conflicts with private landowners. This would assist in creating an interagency effort to address those conflicts and maximize elk use of natural forage available in the Gros Ventre watershed. Conclusions We thank you for this opportunity to provide objections on this FSEIS and ROD and we look forward to continuing the dialogue with the USFS on this and related issues. We are hopeful that this relatively new process within Forest Management pursuant to 36 CFR 218 Subpart B, will have a positive impact in addressing many of our past comments and the issues we have raised above. We welcome a conversation in person to discuss the remedies that we suggest. While none of the remedies would immediately eliminate feeding, they would all provide for integrating science and compliance with governing laws in a way that benefits these valuable resources. GYC and the Alliance are committed to developing better long-term solutions that address the impacts of elk feedgrounds on the ecological function and recreational economies of western Wyoming and the Greater Yellowstone Ecosystem. Thank you for your consideration of these objections. Respectfully, Chris Colligan, lead objector Wildlife Program Coordinator Greater Yellowstone Coalition P.O. Box 4857 Jackson, WY (307) Siva Sundaresan Conservation Director Jackson Hole Conservation Alliance P.O. Box 2728 Jackson, WY (307)