PLEASE TAKE A LOOK AT THIS LETTER and NOTE THE ORGANIZATIONS AGAINST!!!
The Honorable Tom Udall The Honorable Martin Heinrich
United States Senate United States Senate
110 Hart Senate Office Building 540D Dirksen Senate Office
Washington, DC 20510 Washington, DC 20510
June 17, 2013
Dear Senators Udall and Heinrich:
Our organizations, which represent millions of sporting conservationists, have reviewed S. 285 ?To designate the Valles Caldera National Preserve as a unit of the National Park System, and for other purposes.? We are well aware of the historic attempts to protect this property and have been aware that the experiment with making the property a public/private enterprise has been a challenge. Additionally, we are aware that a hearing was held on April 23, 2013 regarding S. 285 before the Energy and Natural Resources Subcommittee on National Parks and that the New Mexico Department of Game and Fish has expressed its opposition to S. 285 in a letter to Senator Udall on June 3, 2013.
Several of the undersigned organizations have long been concerned over legislation to move the Valles Caldera National Preserve (VCNP) to the National Park Service (NPS). For instance, the Rocky Mountain Elk Foundation provided a letter of comment in July 2010 to the Senate Energy and Natural Resources Committee opposing the transfer of the VCNP to the NPS. The National Wild Turkey Federation testified before the Committee that same year expressing their belief that if a transfer was needed, it should be to the U.S. Forest Service. With this in mind, the undersigned organizations wish to make it clear that this letter neither supports nor opposes dissolution of the Valles Caldera Trust.
We are opposed to transferring the VCNP to the NPS. The VCNP, while covering approximately 89,000 acres, does not represent an ecosystem, but more resembles an island surrounded almost entirely by the Santa Fe National Forest. It does not seem prudent to create yet another jurisdictional boundary for this important wildlife habitat that would only serve to complicate management of wildlife and other natural resources.
The enabling legislation (Public Law 106-248, the Valles Caldera Preservation Act) specifically charges the Secretary of Agriculture with primary powers over the Preserve while management will be under the auspices of the Valles Caldera Trust. Sect. 110 addresses the termination of the Valles Caldera Trust at the end of the twentieth full fiscal year following acquisition. The section further goes on to state ?in the event of termination of the Trust, the Secretary shall assume all management and administrative functions over the Preserve, and it shall be managed as a part of the Santa Fe National Forest, subject to all laws applicable to the National Forest Systems.? The groups signed below strongly advocate adhering to the intent of the enabling legislation passed on January 24, 2000.
With regards to recreational hunting, we believe that NPS policy, management and administration are likely to further complicate wildlife resource management on the VCNP. Section 3 of the bill appears to protect hunting:?the Secretary, in consultation with the New Mexico Department of Game and Fish, shall permit hunting and fishing on land and waters within the Preserve in accordance with applicable Federal and State laws, and may, designate zones in which, and establish periods during which, no hunting or fishing shall be permitted for reasons of public safety, administration, the protection of wildlife and wildlife habitats, or public use and enjoyment.?
However, we believe the language gives the Administration too much discretion that could easily result in the drastic reduction or elimination of hunting on the VCNP. This concern is coupled to the fact that NPS policy and procedures generally try to minimize or eliminate hunting on lands they manage. The National Park System has limited units where big game, upland game bird or waterfowl hunting are allowed and with approximately 3,000 elk on the property, for example, we need an agency with experience in active wildlife and habitat management administering this area.
A petition is circulating claiming that the VCNP ?will lose virtually all protections in 2015 if Congress does not include it in the National Park System as a National Preserve.? Aside from the fact that 2015 has not arrived, the enabling Act for the VCNP clearly made provision for the protection of the VCNP should the Valles Caldera Trust be terminated. Further, the U.S. Forest Service (USFS) has a long history of managing public lands for multiple-use including hunting, fishing, trapping, access, game and non-game management, as well as wildlife habitat, recreation management, and the protection of cultural resources .
Several of the undersigned organizations met with your staff on June 11th to discuss the concerns we have over the transfer of Valles Caldera to the NPS rather than the USFS, if Congress decides that it is appropriate to dissolve the Valles Caldera Trust. The opportunity to open a dialogue about the bill was much appreciated and we look forward to further communication. Your offices both have a history of being strong voices for wildlife conservation and wildlife habitat management. However, the signatories still believe that transferring management of the preserve to the NPS rather than the USFS, now or in the future, is inconsistent with the original intent of Congress and would be contrary to the interests of America?s hunting and fishing conservationists.
Finally, during the meeting we also discussed the development of language that would advance the opportunities for hunting and angling on existing National Park Service units and would like to discuss this concept in more detail in the future, however we do not believe that the VCNP is the appropriate location to test this language. Please feel free to contact any of our organizations or you may also call or email Blake Henning with the Rocky Mountain Elk Foundation at 406-523-0273 or
[email protected].
Sincerely,
Archery Trade Association
Association of Fish and Wildlife Agencies
Bear Trust International
Boone & Crockett Club
Bowhunting Preservation Alliance
Catch-A-Dream Foundation
Congressional Sportsman?s Foundation
Conservation Force
Masters of Foxhounds Association
Mule Deer Foundation
National Association of Forest Service Retirees
National Rifle Association
National Shooting Sports Foundation
National Wild Turkey Federation
North American Bear Foundation
North American Grouse Partnership
Orion ? The Hunters? Institute
Quality Deer Management Association
Rocky Mountain Elk Foundation
Ruffed Grouse Society
Safari Club International
Theodore Roosevelt Conservation Partnership
Wild Sheep Foundation
Wildlife Forever
Wildlife Management Institute
cc: Members of the Senate Energy and Natural Resources Committee
Members of the New Mexico Congressional Delegation
Secretary of Agriculture Tom Vilsak
Secretary of the Interior Sally Jewell
Chief of the U.S. Forest Service Tom Tidwell
Director of the National Park Service Jonathan Jarvis
