(Note from Susan Lamson of the NRA: Below is the letter that I sent to Secretary Norton today. Thanks much, Cliff McDonald, for your help.)

September 23, 2003

The Honorable Gale A. Norton Secretary of the Interior U.S. Department of the Interior 1849 C Street, N.W. Washington, D.C. 20240

Dear Secretary Norton:

The undersigned organizations and their membership of sportsmen and wildlife management specialists ask for your leadership in the development of a department-wide policy addressing an important aspect of wildlife management on federal lands.

The policy we are seeking would authorize the construction, operation and maintenance of water developments for the benefit of wildlife.

The policy will have particular relevance to federal lands in the West and to bighorn sheep, mule deer and desert birds.

Land managers of the various agencies that administer wilderness areas, national monuments and national preserves are frequently confused about their responsibilities with respect to wildlife that reside in these areas.

They mistakenly assume that stewardship of the land is separate from -- and takes precedence over -- the wildlife that live on that land.

Consequently, in an effort to restore the lands to a "wilderness" or "preserve" condition, they feel compelled to remove man-made developments upon which this wildlife relies.

These efforts in returning the land to a 'pristine' state come at a great cost to the animals that eventually perish from the lack of viable waters sources.

Each time this occurs, conservation and wildlife groups must expend substantial effort to protect the water developments required by these animals.

The cost of these battles to agencies, NGOs and wildlife is unnecessary and can easily be prevented.

The issue has already surfaced in three separate units under three Interior agencies.

In 2000, the Fish and Wildlife Service was challenged in its interpretation of the Wilderness Act when it sought to disallow the maintenance of dozens of water developments that had been built in the Cabeza Prieta and Kofa National Wildlife Refuges.

That issue was resolved by reaffirming the Service's authority to approve the use of motorized vehicles and equipment within wilderness areas for work conducted on water developments.

The issue next arose in the East Mojave National Preserve, in the land use plan developed by NPS under authority of the California Desert Protection Act.

In this instance, the NPS administered the Preserve under the misguided notion that manmade developments used by wildlife or constructed for the benefit of wildlife, as well as motorized access for their operation and maintenance, were precluded by the redesignation of the area to "preserve" land.

NPS actions stymied the many local residents, working through sportsmen's clubs, who sought to voluntarily maintain these water developments.

These volunteers have been forced to stand idle while some of the water developments have been removed and others have fallen into complete disrepair.

As a consequence, the wildlife in the area have been deprived of necessary water sources.

Instead of conserving wildlife, the NPS has caused many animals to sicken and die.

Most recently, a similar situation has arisen involving BLM's Sonoran Desert National Monument and the maintenance of 16 water developments.

In this situation, a group of environmental organizations challenged BLM's Environmental Assessment and FONSI (Finding Of No Significant Impact), which would have allowed the Arizona Game and Fish Department to perform the needed maintenance.

A 'stay of maintenance' has been issued and the case is before the IBLA.

In the meantime, the wildlife suffers.

It becomes clear, Madame Secretary, that a department-wide policy is needed to support the construction, operation and maintenance of water developments on federal lands where they provide a direct benefit to wildlife.

Otherwise, the issue will continue to surface, to the detriment of the natural resources these areas were established to protect and enhance.

We have found nothing in federal law that suggests water developments and the motorized means to maintain them are prohibited on federal lands, regardless of designation.

We would be pleased to talk with you about this policy initiative.

The points of contact for coordination on this effort are Bill Horn with U.S. Sportsmen's Alliance at 202-659-5800, Susan Lamson with the National Rifle Association at 703-267-1541, and Anna Seidman with Safari Club International at 202-543-8733.

Sincerely,

Arizona Deer Association Arizona Desert Bighorn Sheep Society California Deer Association CampFire Club of America Congressional Sportsmen's Foundation Dallas Safari Club Foundation for North American Wild Sheep Izaak Walton League of America Mule Deer Foundation National Rifle Association Pope and Young Club Quail Unlimited Recreation Sports and Business Association Ruffed Grouse Society Safari Club International Shikar-Safari Club, Inc. U.S. Sportsmen's Alliance Wildlife Forever Wildlife Management Institute Yuma Valley Rod and Gun Club

cc:

Judge Craig Manson, Assistant Secretary, FWP

Rebecca Watson, Assistant Secretary, LMM

Kathleen Clarke, Director, BLM

Fran Manella, Director, NPS

Steve Williams, Director, FWS

Very important attached testimony from Billie Roney

September 24, 2003

Roney Land & Cattle Co. (since 1853)

Chico, California

roney@cwo.com

Just to add a cattle rancher's perspective: There are instances on the Forest Service lands where even something as mundane as off-stream watering troughs are designed to prevent accidental drowning off small wildlife. On the land with which I am so familiar, water developments that have been designed for livestock use have greatly benefited wildlife, and in many, many cases created new habitat. Of course that issue opens up another can of worms in that after many decades of creating these improvements, the ranchers are systematically being removed from the land, using these very same "man made" habitats as the justification for their removal. It is ironic, but it is a fact. The BLM is wrestling with ownership and maintenance of water sources developed by ranchers. Before 'Rangeland Reform,' ranchers did indeed own these improvements. The benefits to wildlife have been enormous, and the impetus for their maintenance and creation was viable as an asset to the ranchers both intrinsically and financially. I believe that the new administration is far more willing to look at the issues brought up in this letter, than at previous times, if not for anything other than the fact that "pristine" is more of a useless, nebulous term that has often spelled condemnation for wildlife. The ranchers I work with have long been involved with the issues of habitat improvements on federal lands. Your concerns as well as theirs, have much in common.