6—Cold Mountain Cold Rivers Complaint

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.

12.

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.

13.

Plaintiff The Ecology Center, Inc. is a non-profit,