4—Cold Mountain Cold Rivers Complaint
Forest, and Yellowstone Park. The conservation-related, ecological, aesthetic, educational, and
recreational interests and human values of Plaintiff and its members have been, and continue to be,
adversely affected by implementation of the Defendants’ bison management plan, including the
hazing and slaughter of bison associated with the bison capture facility, and the disruption of native
wildlife and the ecosystems where such activities are occurring.
Plaintiff Buffalo Field Campaign is a nonprofit organization founded to stop the
slaughter of Yellowstone’s wild buffalo herd, to protect the natural habitat of wild free-roaming
buffalo and other native wildlife, and to work with people of all Nations to honor the sacredness of
the wild buffalo. Plaintiff’s members reside in, travel through, and utilize the Greater Yellowstone
Ecosystem, including the Horse Butte Area, the Gallatin National Forest, and Yellowstone Park.
As part of their work, they have been actively documenting wildlife habitat impacts from hazing,
capture and slaughter activities associated with the bison management activities conducted by the
MDOL with the assistance of other Montana State and Federal agencies. The conservation-related,
ecological, aesthetic, educational, religious, and recreational interests of Plaintiff and its members
have been, and continue to be, adversely affected by implementation of the Defendants’ bison
management activities, including the hazing and slaughter of bison and disruption of wildlife and
the ecosystems where such activities are occurring.
Plaintiff The Ecology Center, Inc. is a non-profit, public-interest conservation
organization working to protect biological diversity and ecosystem integrity, primarily in the Wild
Rockies bioregion, including Montana and the Greater Yellowstone Ecosystem. The Ecology
center staff have been actively involved in trying to stop the slaughter of Yellowstone’s wild bison
herd, to protect the natural habitat of wild free-roaming bison and other native wildlife. As part of
their work, they have been actively working to prevent harm to bald eagles and other protected
migratory birds that are being harmed by activities associated with the MDOL and other Montana
State and Federal agencies bison management activities. Plaintiff’s staff and members reside in,
travel through, and utilize the Greater Yellowstone Ecosystem, including the Horse Butte Area, the
Gallatin National Forest, and Yellowstone Park. The conservation-related, ecological, aesthetic,
