Note: these comments were prepared by Dr. Mark McBeth, Ph D. Political scientist McBeth has been studying the bison - brucellosis issue for about a year.
Comments
Environmental Impact Statement for the Interagency Bison
Management Plan for the State of Montana and Yellowstone National Park
The preferred alternative is nothing more than a restated "Interim Bison Management Plan" (IBMP). The IBMP seemed benign at first glance but its implementation nearly destroyed the last remaining wild herd of bison in the United States.This EIS and its preferred alternative is flawed because it does not address the major issues of problem definition, and it allows the State of Montana to dictate wildlife policy to the federal government. The EIS preferred alternative seems only concerned with maintaining an arbitrary population range of 1,700 to 2,500 bison. There is no scientific agreement on the carrying capacity for bison in the park. If the problem is really cattle and brucellosis then three major issues must be addressed.
1. Brucellosis Transmission from Bison to cattle.
The entire EIS is based on the unproven assumption that bison can transmit brucellosis to cattle. How can you make public policy on an unproven assumption? Public policy should be made through a careful process of risk assessment. In reality, the risk of transmission is very low or non-existent. Transmission has never been demonstrated in wild conditions.
A Texas A & M study (Davis, et. al, 1990) demonstrated that a female bison that had been shot up with high doses of brucellosis transmitted the disease to a cow after the cow licked the after-birth left by the mother bison. The study does not necessarily apply to wild settings however because the cow and bison were in a small enclosed corral and the bison was shot up with extremely high doses of brucellosis. Keiter (1998) writes similarly of the Davis, et al. study, "This experiment has been severely criticized for its use of an unusually large infective dose and for its limited utility in the Yellowstone setting, where bison and cattle are free-ranging and not confined in close quarters." The National Academy of Science report's (1998) executive summary (page 4) states, "the risk of transmission from bison to cattle is small, but it is not zero." In addition, the report states, "the current risk of transmission from YNP bison to cattle is low because domestic cattle adjacent to the park are vaccinated, cattle are monitored by federal agencies, and ranchers are vigilant." In addition, citizens do not believe that transmission is likely (see survey results).
In addition, testing for brucellosis is terribly imprecise.
Current tests produce many false-positives as well as false negatives. With such weak scientific information bison slaughter is not justified. In the past, Montana has argued that even though there is no documented-scientific risk and testing is imprecise, the safe policy is to kill the bison. This is a bizarre method to make public policy and most certainly reveals that the underlying agenda of the bison killing is really bison population control and Montana retaining control of federal lands outside the park.
Scientific studies by impartial scientists must be conducted.
2. Number of Cattle Around the Park.
I have not been able to document the exact number, but all of my sources contend that there are only 2,000 cattle in potentially affected areas around the park. Should Montana and the federal government spend millions of taxpayer dollars on a bison management plan in order to protect 2,000 cattle? Many of the cattle are Idaho cattle that are wintered in Montana. Why does Montana want to pay so much money to protect Idaho cattle? The more rational public policy action would be to find alternative public ranges for these cattle. In addition, APHIS could designate the zone around the park as a high risk brucellosis area and keep the rest of Montana classified as brucellosis free. Ranchers who want to graze cattle next to the park would have to assume the risk and potential costs of inspections. Why should the public subsidize 2,000 cattle at the cost of killing thousands of bison?
3. Bison and Cattle on the Range
Bison are most likely to be on the public ranges in December, January, February, March, and early April. Cattle do not arrive on these lands until mid-June. In August, 1997, APHIS allowed low risk bison (yearlings, bulls, cows who had already dropped their young) on these lands before June 15th.
The State of Montana refused this revised plan because they stated that other states still might consider their cattle potentially infected and impose costs. How would bison grazing in February lead to brucellosis infection in June? The most liberal study has stated that potentially the brucellosis virus could live exposed in just the right conditions for up to 60 days. Other studies state that the virus dies once it is exposed. Again, imperfect science. Why kill bison based on such findings?
With a problem definition incorporating the three above points, the following common-sense solutions should be implemented:
1. Allow bison full use of the public lands outside the park from the time cattle leave the ranges in the late fall until cattle arrive on the land in mid-June. After mid-June, monitor bison and cattle interaction. Nearly all bison are in the interior of the park by mid-June.
2. All cattle near the park must be vaccinated for brucellosis.
3. Find alternative grazing lands for ranchers who graze cattle near the park. The land near the park is by no means ideal grazing lands because of its high elevation.
4. Create bison buffer zones of private lands bought by environmental groups and public monies.
5. Reinstate, a public (ethical, fair-chase) bison hunt outside of the park in Montana and allow no more than 100 bison to be killed by hunters each year.
References
Davis, D.S., J.W. Templeton, T.A. Ficht, J.D. Williams,, J.D. Kopec, and L.G. Adams. 1990. "Brucella abortus in captive bison. I. Serology, bacteriology, pathogenesis, and transmission to cattle. Journal of Wildlife Dis. 26(3): 360-371.
Interim Bison Management Plan. August 6, 1996. Department of Livestock. State of Montana.
Keiter, Robert B. 1997. "Greater Yellowstone's Bison: Unraveling of an Early American Wildlife Conservation Achievement." Journal of Wildlife Management, volume 61, no. 1: 1-11.
National Academy of Sciences. 1998. "Brucellosis in the Greater Yellowstone Area." Norman F. Cheville, Principal Investigator, Dale R. McCullough, Principal Investigator, Lee R. Paulson, Project Director. Washington, D.C.: National Academy Press.
Appendix
In February, 1998, a survey was mailed to 225 households and businesses in Gardiner and West Yellowstone, Montana. One hundred and twenty five (125) returned the survey. The results and questions are reported below.
Gardiner and West Yellowstone Citizen Views_________________________________________________________________
Strongly Disagree=0 Strongly Agree=6
Statements 0 1 2 3 4 5 6 Mean Transmit 31 16 7 15 7 11 13 2.35 Use of Forests 22 7 3 7 9 14 37 3.67 Symbol 5 3 7 15 14 15 41 4.43 Ranching/
economics11 10 16 23 17 13 10 3.06 Wildlife/
environment5 3 15 22 20 18 16 3.68 Co-exist 5 6 7 11 20 18 31 4.20 Snowmobile Trails 55 11 7 11 6 2 6 1.39
Questions. Respondents were asked how strongly they agree or disagree with the following statements. A zero represented "strongly disagree," a 3 was "neutral," and a 6 represented "strongly agree."
1. "Yellowstone bison are likely to infect cattle with brucellosis." Only 31% of respondents agreed with the statement. (This statement is at the center of the controversy. If bison are unlikely to transmit brucellosis the problem is minimized or non-existent).
2. "Yellowstone bison should be allowed the full use of the national forest lands outside of Yellowstone." Sixty percent of respondents agreed with this statement.
(The larger issue at stake in the bison controversy is whether wildlife should have full use of national forest lands or whether this land should be reserved for cattle grazing).
3. "Yellowstone bison are an important symbol of the American West and should be protected." Seventy percent of respondents agreed with this statement.
4. "Ranching is the most important economic asset in Montana." Forty percent of respondents agreed with this statement.
(The Governor of Montana and other Montana elected officials have consistently stated that ranching is the state's most important economic asset and that the killing of bison is justified to save this dominant industry).
5. "Wildlife and the environment are the most important economic assets in Montana." Fifty four percent of respondents agreed with this statement.
6. "Environmentalists and ranchers can co-exist and in fact share many of the same values." Fifty four percent of respondents agreed with this statement. (This statement tested whether citizens see the ranching-environmental conflict as irreconcilable or whether they believe common ground and hence long-term solutions to this and other controversies are possible).
7. "Snowmobile trails allow bison to leave the Park and therefore they should be closed."