Sunday, February 10, 2013

Dr. Bruce L. Smith's Letter to Montana H.B. 312 Hearing

It is unfortunate that the majority of the public does not know the details involved in much of the testimony given at a legislative hearing. It would go along way in educating the public in many matters. For example, often a person testifying, especially concerning a controversial bill, is limited by time to make specific points or provide verbal documentation. Sometimes all they get to do is list their name, any association affiliation and whether they are proponents or opponents of the bill. Unless requested, we don't see the physical documentation that is hand delivered to these committees.

Fortunately, I was sent a copy of a very important letter that was submitted  by Nick Gevok of the Montana Wildlife Federation (the day before the hearing), to the Agriculture Committee. The Agriculture Committee heard testimony concerning HB 312, sponsored by Rep. Alan Redfield, on January 31st, 2013. This letter is from Dr. Bruce L. Smith, who introduces some of his credentials in his first paragraph. He is also the author of an awesome reference book on elk - "Where Elk Roam: Conservation and Biopolitics of Our National Elk Herd" and appears in the documentary, "Feeding the Problem", which I highly suggest everyone watch. Below is his very telling and damning letter.

Thank you Dr. Smith for submitting such important testimony against HB 312.


January 29, 2013

House Agriculture Committee
Montana House of Representatives
Helena, Montana

Dear members,

After reading HB 312, I wish to offer the following comments.

By way of introduction, I spent 30 years as a wildlife scientist and manager, most of those with the U.S. Fish and Wildlife Service, and the final 22 years as the wildlife biologist at the National Elk Refuge in Jackson, Wyoming. In that capacity, I did research on elk population biology and ecology, but more importantly in regard to HB 312, I coordinated the refuge’s winter feeding program and was responsible for monitoring disease among the elk , including brucellosis. In that capacity I worked with a host of federal and state agency personnel and private groups to mitigate diseases among the elk and their potential for transmission to livestock.

Although I understand that HB 312’s broad intent is to provide the means of authorizing agency responsibilities for testing and prevalence reduction of brucellosis in livestock and wildlife, I find some of the proposed bill’s language so general and vague as to be subject to individual interpretation.

Specifically, Section 1 (2) parts a and b include, in part, the language “eliminated or minimized as much as possible,” and “prevalence reduction procedures” regarding brucellosis in bison and other species of wildlife (which I assume to mean elk).

While I appreciate Montana state government’s interest and efforts to limit the effects of brucellosis on the livestock industry and individual producers, therapeutic tools for accomplishing what Section 1(2) parts a and b reference were largely developed for monitoring/managing/eliminating brucellosis in cattle. Cattle testing procedures are less useful and certainly less practically applied in free-ranging wildlife. Capturing or confining and testing wildlife is expensive, stressful to wildlife, and potentially contrary to principles of managing wildlife as free-ranging public resources. More importantly, the wording I referenced, because of its vague nature, could be interpreted to empower agency administrators to establish and implement management guidelines that could negatively impact wildlife herds.

Tools for reducing prevalence of brucellosis, and for that matter other diseases in free-ranging wildlife, are limited compared to those for remedying the disease among infected herds of cattle: tools such as prophylactic vaccinations, culling, test and slaughter, or whole herd depopulation. My experience in Wyoming shows that available vaccines (S19 and RB51) are so marginally efficacious in protecting elk against field strain brucellosis infection and preventing brucellosis-induced abortions that they are not a viable management tool. Wyoming’s experimental test and slaughter program—implemented to greatly reduce or eliminate brucellosis in feedground elk—was abandoned after 5 years due to its tremendous budgetary costs and failure to achieve the program’s goal. The most cost-effective means of limiting exposure and infection of susceptible cattle herds to brucellosis from potentially infected bison or elk are to calfhood vaccinate cattle herds and proactively implement practices that limit species sympatry and comingling during periods when transmission is most likely to occur.

To this point, the stated language I referenced in this proposed legislation could conceivably commit Montana to the slippery slope of imposing livestock husbandry practices on the public’s free-ranging wildlife. I suspect that is not the intention of HB312, so I suggest reconsidering the bill or redrafting it with language that’s far more specific and more limited in scope regarding “reducing” and “eliminating” disease in wildlife, and more appropriately focuses on how the interests of the livestock industry can be protected through management procedures that have been demonstrated to be successful and are cost effective.


Bruce L. Smith, Ph.D.
44 Duncan District Road
Sheridan, MT 59749

Now this letter refers to the study, "Using Test and Slaughter to Reduce Prevalence of Brucellosis in Elk Attending Feedgrounds in the Pinedale Elk Herd Unit of Wyoming; Results of a 5 Year Pilot Project" From this study, the following quote states, "Thus, capturing 35% to 60% of cow elk attending a feedground and removing seropositive individuals over a 5 year period does not appear to prevent transmission events." Now if capturing 35-60 percent of the cow elk in a feedlot and baited situation doesn't prevent transmission events, what kind of success is ever possible for a wild, free roaming elk population like we have here in Montana? Test and Slaughter is never going to succeed on our landscape, especially since we have elk that travel between Wyoming and Idaho.

Montana House Bill 312, is a farce. Test and Slaughter of Montana elk is not viable, not possible in eradicating brucellosis on a wild landscape, and would fly in the face of all that Montana hunters and conservationists, wildlife biologists and the average citizen have done to bring these elk back from the brink of the late 1800's and early 1900's. For further reading, please see the previous blog post, Back From the Brink, Back To the Brink?

Help stop the proposed massive test and slaughter of Montana's elk.
Please take a moment to send a message to the Montana Legislature:
Call: 406-444-4800  or fill in the online form and submit- 

Select Committee 
Use the Committee drop down menu to select Agriculture 
Type in HB 312 in the Bill Number Box
Select Against in the Vote portion
Type in a short message in the message box if you wish
Click the Send Message button

HB 312 Video Stream
Click on the third link, under the screen, HB 312 - Revise laws relating to brucellosis - Alan Redfield.

Kathryn QannaYahu

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