The Bridger-Teton National Forest has started the ball rolling on whether the Wyoming Game and Fish Department should receive a long-term permit to continue elk winter feeding and related management programs on forest lands.

A 45-day public comment period started Monday on the proposed special-use permit study document.

Conservationists worry, however, that the planned environmental impact statement might be so narrowly drawn as to have a foregone conclusion: to approve the land-use permit without looking at what Game and Fish is actually doing on national forest lands.

"I'm afraid the Forest Service might have their blinders on and ignore the widespread presence of brucellosis in feedground elk, or the threat posed by chronic wasting disease that is moving ever closer to the feedgrounds," said Tim Preso, an EarthJustice attorney based in Bozeman, Mont.

Franz Camenzind, executive director of the Jackson Hole Conservation Alliance, said he'd like to see the Forest Service do more than look at how Game and Fish is using national forest ground, and look at what that use is and means to the environment.

Camenzind said he didn't like to see a planning document "loaded for one outcome."

The public has until Sept. 17 to file postmarked comments on the scope of the analysis. The draft environmental impact statement is expected in January 2008, and the final environmental impact statement is expected in May 2008. Monday's notice was published in the Federal Register.

Mary Cernicek, spokeswoman for the Bridger-Teton, said public comment will help determine what the scope of the environmental impact statement will be.

"The public will tell us what the issues are," she said.

Three groups - the Greater Yellowstone Coalition, Jackson Hole Conservation Alliance and Wyoming Outdoor Council - are suing the Forest Service for allowing Game and Fish to feed elk on forest land without proper permits. The groups also have sought a halt to Game and Fish's elk test-and-slaughter pilot program, in which feedground elk found to have been exposed to brucellosis are killed.

U.S. District Judge Alan Johnson took the latter issue under advisement last October. Preso, who represents the three groups, said they're still waiting for Johnson's ruling.

Game and Fish has operated the elk feedgrounds on the Bridger-Teton for more than 50 years, and has requested long-term authorization to continue this established use. Both agencies have been criticized by conservation groups for a lack of formal permits, with some feedgrounds operating decades before the current federal environmental review process was started in the 1970s.

In light of the endemic presence of brucellosis in feedground elk and the possible effects of chronic wasting disease, which is similar to mad cow in bovine species, the feedgrounds should now be subject to review, Preso said in an October hearing before Johnson.

Brucellosis is a disease that can cause cattle to abort. It was introduced to wild animals in the early 20th century through cattle. Northwest Wyoming is one of the last pockets of the disease left in the country. Feedgrounds are considered to transmit the disease more readily between animals because it congregates them, but closing feedgrounds could mean starving elk and elk in ranchers' haystacks.

Chronic wasting disease has not been detected in the western Wyoming elk herds, but Preso said it could soon reach the area. Chronic wasting disease is a fatal neurological disease that affects deer, elk and moose. Animals show no signs of illness throughout much of the disease's course. In terminal stages of the disease, animals typically are emaciated and display abnormal behavior.

Biologists say chronic wasting disease could rapidly spread among the elk crowded together on winter feedgrounds, with epidemic potential.

Eric Keszler, spokesman for the Game and Fish Department, said the agency sees problems associated with elk feedgrounds, "but we see bigger problems in closing the feedgrounds."

The department and livestock interests are concerned that closure of the state's 22 feedgrounds would lead to mingling of hungry elk with cattle on area ranches, Keszler said, and that would lead to the transmission of brucellosis to Wyoming livestock.

Keszler said the purpose of the test-and-slaughter program is to see if the agency can reduce the prevalence of brucellosis in elk that frequent the feedgrounds in northwest Wyoming.

Preso said he agrees that Wyoming has the right to manage its wildlife, but he said the federal government is obligated to review the environmental impact of the feedgrounds, which are located on land owned by the Forest Service or the Bureau of Land Management.

The Forest Service's current proposed action is to authorize the continued use of forest lands by Game and Fish for corrals, sheds, chutes, and feeding grounds associated with the ongoing winter elk management program. The specific areas are the Fish Creek, Pritchard Creek (Dog Creek), Muddy Canyon, Fall Creek, Alkali Creek, Upper Green River and Patrol Cabin campgrounds.

Three preliminary alternatives have been identified by the Bridger-Teton: not allowing feedgrounds; authorization for continued use of feedgrounds, and authorization of the proposed use with modifications.

The preliminary issues identified by the Forest Service, which do not include wildlife diseases, include:

* Concentrated use of the specified areas by elk could affect local habitat due to heavy browsing of willows and other shrubs.

* Concentrated use of the specified areas during warmer spring days could hurt soils due to trampling on the area.

* Importing of hay would increase the possibility of introducing noxious weeds.