7—Cold Mountain Cold Rivers Complaint

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, educational,

religious, and recreational interests of Plaintiff and its staff

and members have been, and continue to be, adversely affected by

implementation of the Defendants’ bison management activities,

including the hazing, capture, and slaughter of bison and the

disruption of other wildlife and their habitat.

III. FACTUAL BACKGROUND

14.

The preceding paragraphs are realleged as if set forth

in full herein.