15069 Robles Grandes Dr.
Rancho Murieta, CA 95683
February 26, 2016
Mr. Dan Ashe, Director
U.S. Fish and Wildlife Service
1849 C. Street
Washington, D.C. 20240
Dear Dan:
You may not remember me. I believe the last time we met was nearly eighteen years ago in Albuquerque, New Mexico, while I was serving as the Assistant Regional Director for Refuges and Wildlife in Region 2. As a retired, forty-year employee of the Fish and Wildlife Service (Service), dedicated to the management and protection of units of the National Wildlife Refuge System (NWRS), I was stunned recently to learn that the Service, under your leadership, supports legislation that would “transfer lands comprising the National Bison Range to be held in trust by the United States” for the Confederated Salish-Kootenai Tribes (CSKT) in Montana…..as announced in Regional Director Noreen Walsh’s memorandum to the refuge field folks in the Mountain-Prairie Region.
That decision contravenes your earlier assurances in a September 16, 2011 letter to former Assistant Secretary of the Interior Nathaniel Reed, in which you stated, “The Service cannot and will not ‘turn over’ management of NBR or any other refuge to CSKT or any other non-Service entity. Under any future AFA, NBR will remain a unit of the National Wildlife Refuge System under direct guidance of the Service’s on-site Refuge Manager. You went on to say, “We are confident that a strong partnership, with the Service and CSKT employees, working together, under the direction of the Refuge Manager, is the best way to continue managing the NBR to achieve the Refuge’s purposes, and the mission of the National Wildlife Refuge System.”
That statement was a clear, unambiguous expression of your commitment to protect the NBR and other units of the NWRS and not allow it or other refuges to be bargained away to appease the political, economic, or other self-serving interests of non-Service entities. Refuge field folks and retirees felt re-assured and applauded this clear statement of your dedication to preserving the ultimate integrity of the NWRS from such future threats.
The recent pronouncements by Service sources, notably Regional Director Walsh and Chief of Refuges Cynthia Martinez, to try to rationalize this radical departure from your earlier position are seen by many as contrived.
To suggest that the NBR should be relinquished because bison are no longer endangered, and, therefore, the refuge no longer serves its purpose, objectives and contribution to the NWRS, ignores its historical place in American history, the role this herd continues to play in the effort to preserve natural bison populations and the total values of the refuge, as clearly defined by Congress in the Refuge Improvement Act. We’re talking about a viable, fully successful, fully functional national wildlife refuge that maintains a herd of genetically unique and diverse bison in carefully maintained and artfully managed natural habitat for the education and enjoyment of future generations of all Americans. And it has done so for 108 years!
The examples being given to suggest that this action is not precedent-setting are simply not comparable. Some are former migratory waterfowl easement areas that permanently lost their water supply, another is the former Mescalero fish hatchery, which was closed for two years due to severe weather damages before being turned over to a tribe from among several tribes whose commercial and recreational fishing programs it was originally built to support! Please, don’t insult our intelligence.
Your spoke persons have said that any proposed legislation to place the NBR in trust for the CSKT would be unique to that refuge, and not affect any other refuge. Yet, the Service has identified 37 or 38 refuges as available for tribal negotiations for Annual Funding Agreements (on a Federal Register List that may, at any time, be added to by tribal or Bureau of Indian Affairs request).
The Service’s track record for successfully negotiating AFAs is not good. Its’ efforts to respond to the CSKT’s demands at NBR have repeatedly failed over a period now approaching 20 years, at tremendous cost to the Service (and, ultimately, the tax payers who fund its programs) and with enormous adverse impacts on professional refuge staff members. It failed quite simply because the Service couldn’t acquiesce to the demands of the tribe to take over complete control and management of the refuge under existing law. In the absence of any apparent resistance from the Secretary of the Interior, or the agency tasked with the responsibility for protecting and managing the refuge in trust for the American public, it now appears that a sympathetic Congress will likely do what the tribes couldn’t. And we are to believe that this can’t happen again on any of those 37 or 38 other refuges, including the sixteen refuges in Alaska? Theodore Roosevelt will roll over in his grave!
Also, I’m not at all clear on what you mean when you say that implementing landscape conservation strategies “…is how the day to day work of the agency needs to be done from now on….”. You seem to be implying that traditional refuge establishment and management is no longer valid, and that that helps justify the disposal of the NBR and, presumably, other so-called “stand alone refuges”. What ever happened to the NWRS objective of preserving a diversity of American wildlife and wildlife habitats, as we strive to fulfill our commitments under the several Migratory Bird Treaties, Cities, the Endangered Species Act, among many other National and International commitments?
Also, how does your newly discovered strategy fit the Desert, Kofa and Cabeza Prieta NWRs in the Southwest? Geographically they are not connected. Their Desert Bighorn Sheep populations are also not connected in any physical sense. Yet, collectively they helped and continue to help preserve Desert Bighorn Sheep and the critical habitat they depend upon. Each of them is quite large, and their biota unique and diverse, although not fully achieving the “landscape scale” found in the Alaska refuges or the current expressed concepts of the Landscape Conservation program.
While I recognize that you are institutionalizing landscape conservation thinking in a way that hasn’t been done in the past (and I applaud that), the concept is not new to the Service.
It’s that kind of thinking that drove the Prairie Pothole protection efforts in the mid-West; it’s what drove the Service from very early on to protect critical migratory waterfowl migration and wintering habitats within the context of their flyways; it’s what led early pioneers of the agency to establish three, distinct bison herds on refuges in Oklahoma, Nebraska and Montana to help ensure the continued survival of natural bison populations; it’s what influenced Ed Crozier and his refuge planning team in Region 3 during the 70’s to broaden the scope of individual refuge planning to include what he called the “area of ecological concern”. It’s what influenced me when I initiated a refuge master planning effort at the Malheur refuge during that period, with the strategy to incorporate the entire Harney Basin in our planning considerations, since many of the migratory waterfowl and other water bird populations we were dealing with on the refuge were and are highly dependent upon private lands adjacent to the refuge. (I never got to complete that planning effort due to my later move to Alaska, but I do understand that the current refuge manager, much to his credit, has actively and successfully pursued that concept with the local community).
It’s a concept that would have helped make the Service’s earlier Private Lands Initiative more successful (and refuges potentially more effective) had it been universally tied closely to refuges, as it was in Regions 1 and 3
My point is: recognize that the concept or strategies that you now promote has been at work and germinating for decades…perhaps nearly as long as the NBR and the other early conservation areas were established; and finally, as you look at the forest, don’t overlook the fact that a fully functioning forest is made up of individual trees…all with a purpose, and all contributing to the whole.
When established in 1908, the NBR was one of 52 Theodore Roosevelt preserves that formed the precursor to what later evolved into the National Wildlife Refuge System, which, along with lands preserved within the National Park and National Forest Systems, formed a national land conservation legacy that has been held in trust and managed by the federal government for the benefit of all Americans ever since. It is a wildlife habitat protection system unrivaled by any other Nation in the World, with its’ over 560 refuges now representing and protecting the enormous range of wildlife and wildlife habitat diversity found in our fifty states and territorial areas.
Protecting that legacy challenges every generation, with the most serious being those schemes that would remove individual refuges or portions of refuges from federal stewardship and national public ownership. As a former Refuge Manager and refuge administrator at the Regional level, I am fully aware of the range of threats refuges have faced throughout their history. I also learned that the first line of defense against such threats is those responsible for protecting and managing the Refuge System. I always felt that responsibility very strongly while I served the Refuge System, and felt confident that that sense of responsibility was shared by my superiors within the Service and the Department.
The NBR was my first refuge as a manager. I put my heart and soul into this beautiful and highly productive area. I learned a lot in the process, including a full understanding of the multiple benefits it provided to the community, the region and, yes, to the Nation. I’m proud of my tenure there, and the efforts of one of the finest, most dedicated refuge staffs I’ve ever encountered. It will break my heart if this wonderful area is taken out of the Refuge System and reduced to serving the singular interests of only two Indian tribes – whatever they might choose those interests to mean, and whoever they might choose those interests to serve.
An author writing of natural area values in general recently said that what people come to love, they want protected. The American people love their National Park System, their National Forest System, and, yes, their National Wildlife Refuge System. The American public expects, and has a right to expect that their refuges will be protected within the Refuge System. If you doubt the veracity of that statement, then I suggest you place the question of whether any fully functioning unit of the Refuge System should be turned over to a non-Service entity before the American public.
I acknowledge that this letter is probably an exercise in futility…that the proposal to move the NBR out of the refuge system has likely moved far beyond your control…if you every had it. I’m convinced that if that transfer does occur, those who care about the future integrity of the Refuge System, and its history, will soon come to regret it.
Sincerely,
Joseph P. Mazzoni, Sr.
Cc: Sally Jewell, Secretary of the Interior
Jim Kurth, Deputy Director
Noreen Walsh, Regional Director
Cynthia Martinez, Chief, NWRS