![]() In December of 2018, Earthjustice submitted a letter to NER on our behalf concerning the severe risks to the integrity of the refuge associated with supplemental feeding of elk on the refuge (Attachment 1 to these comments in entirety). ![]() 668dd et seq.) (“Improvement Act”), the mission of the National Wildlife Refuge System (NWRS), the purposes of the NER, and the 2007 Bison and Elk Management Plan (“BEMP”). Our organizations have a longstanding interest in the proper management of the NER, consistent with the National Wildlife Refuge Administration Act as amended by the National Wildlife Refuge System Improvement Act (16 U.S.C. These comments and attachments are submitted on behalf of Defenders of Wildlife, Sierra Club, and the National Wildlife Refuge Association. Thank you for the opportunity to provide comments on the National Elk Refuge (“NER”) Draft Bison and Elk Management Step-down Plan (“SDP”) and associated Draft Environmental Assessment (“EA”). Submitted electronically to: Draft Bison and Elk Management Step-down Plan and Draft Environmental Assessment
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