NATIONAL WILDLIFE FEDERATION®
People and Nature: Our Future Is in the Balance

Northern Rockies Project Office
240 North Higgins, # 2 - Missoula, MT 59802
406-721-6705 - 406-721-6714 [fax] - www.nwf.org

February 17, 2003

Mary Bloom, Project Leader
Bureau of Land Management
111 Garryowen Road
Miles City, MT 59301-0904

RE: Comments on Statewide Final Oil and Gas Environmental Impact Statement and Amendment of the Powder River and Billings Resource Management Plans.

Dear Ms. Bloom:

The National Wildlife Federation (NWF) is the nation's largest conservation and education organization with a membership committed to the conservation of our wildlife and natural resources. We appreciate the opportunity to comment on the Final Environmental Impact Statement (FEIS) for the Oil and Gas Environmental Impact Statement and Amendment of the Powder River and Billings Resource Management Plans for the Bureau of Land Management and State of Montana.

NWF has worked extensively on issues related to conservation of grasslands, sage grouse, prairie dogs, aquatic resources, and threatened and endangered species for many years. We have a long-standing interest and are currently deeply engaged in conservation efforts for these resources, and believe that CBM development poses a serious threat to these and other natural resources.

In general we feel the FEIS is deficient in several regards. In particular, we cannot support adoption of preferred Alternative E, nor any other alternatives presented; we have several reasons for our inability to do so.

On May 14, 2002 we provided extensive comments on the draft EIS. Many of our comments were not adequately addressed in the final EIS, so we attach them again here to serve as our comments to the final EIS. It is our honest belief that the BLM and the State of Montana have a clear legal obligation to carefully reconsider the FEIS and preferred alternative based on new information and numerous substantial issues raised here and elsewhere. Several actions proposed within these documents constitute an irrevocable commitment of resources which could harm significant flora and fauna held in trust by the agency and state.

We appreciate this opportunity to comment, look forward to the Record of Decision, and hope that our comments and concerns will be reflected therein.

Sincerely,

Tom France, Esq.
Director

Ben Deeble
Regional Sage Grouse Project Coordinator