Recently, there were a number of articles written on the Bison Transfer Agreements between the National Park Service and two Tribal organizations; the InterTribal Buffalo Council (ITBC) and the Confederated Salish and Kootenai Tribes of the Flathead Nation (CSKT).
These Bison Transfer Agreements transfer live plains bison from Yellowstone National Park to the Tribal organizations for transport directly to slaughter facilities, the products of which become the property of the Tribal organization.
Thanks to the Buffalo Field Campaign, these contracts were made known and circulated after the Nov. 2013 Interagency Bison Management Plan meeting. And thanks to the BFC, they have been ever vigilant, keeping a protective eye on our wild bison, alerting the public when they are in danger. Without the BFC, the majority of the public would not know the treatment of these iconic wild bison.I know that I could not be in the field witnessing what they do, without getting myself arrested, repeatedly. So I support them in any other way I can.
Everyone is in an uproar and I fully agree. We should not be capturing these treasured wild bison and sending them to slaughter. But, here is my thought - instead of everyone venting all their outrage and frustration at the YNP, the stewards of this wildlife treasure, why don't we direct our collective energies to the real authors of this travesty - USDA's Animal and Plant Inspection Service (APHIS) and the Montana Department of Livestock (DOL)!
If you read the agreements, it states, "Pursuant to the Interagency Bison Management Plan signed by the federal government and the State of Montana in 2000, the abundance of Yellowstone bison is managed towards an end-of-winter guideline of 3,000 animals. The plan also directs actions such as vaccination and selective culling of animals to reduce brucellosis prevalence and lessen the risk of transmission from bison to cattle in Montana." The agreement explains that hunting (of those bison that exit the Park) has been a tool for this bison reduction, "but this tool has not been effective at reducing the prevalence of brucellosis in the population." This is why the "culling" is taking place and the agreements with the ITBC and the CSKT.
Who is the real adversary of Bison?
So here's the necessary question - Who demanded the IBMP mandated end-of-winter guideline of 3,000 animals that Yellowstone National Park is forced to comply with? Reduction of brucellosis prevalence and lessening the risk of transmission from bison to cattle in Montana is an APHIS and DOL objective. Their real objective is the eradication of brucellosis in wildlife. IBMP Objective 4. Commit to the eventual elimination of brucellosis in bison and other wildlife (they're going after our elk now).
This DOL forced bison population number was evidenced by the Jan. 13, 2014 Board of Livestock meeting in Helena, where the DOL Board discussion and comments continued to center around reducing YNP bison numbers. Then, Executive Director Christian MacKay describes a history of conflict between YNP and the State of Montana, again, bringing up population management. "I see this as a potential to start getting at some of that conflict, start getting - We want this from you (repeated statements of low bison population numbers), you want this from us (expanded bison habitat in Montana - not an objective of the YNP committing some sort of National Park sprawl and taking over Montana). When you get to what we want, we can offer what we have."
"Meanwhile, by 1994, the bison population peaked at 4,200 animals, the highest since the nineteenth century. At the same time, livestock and veterinary interests refocused on bison management and asserted their influence. The professional veterinary association, USAHA (United States Animal Health Association), that includes the Montana and many other state veterinarians as members, issued five brucellosis resolutions in 1995. One resolution stated the expectation that brucellosis and overpopulation of bison and elk threaten cattle. Together with the Western States Livestock Health Association, composed of seventeen Western state veterinarians, USAHA pressured APHIS to downgrade the status of states that allowed wild bison to roam after exposure to brucellosis. Even though USAHA is not an official policy-making body, it is respected enough to revoke Montana's status without a scientific or legal basis. The Montana state legislature also changed the primary authority for managing bison from DFWP to DOL - an agency with a mandate to 'protect the health and well-being of the livestock industry and economic well-being of ranchers' and without previous experience or responsibility in wildlife management. Thus the perspectives of livestock management became more influential in the management of wild bison that roam outside the Park and into Montana." - Finding Common Ground, pg. 135.
Wyoming Common Ground Letter
It took me 3 1/2 months of digging, and FOIA's, but I finally found the letter referenced in Christina Cromley's chapter, Bison Management in Greater Yellowstone - Finding Common Ground. Thank you Wyoming State Archives!
Cromley's quote was, "Frustrated by the agencies' handling of the issue and believing their interests were not being addressed, a group of ranchers, conservationists, and hunters in Jackson Hole, Wyoming, wrote a letter to the Clinton administration in January 1997, in the midst of the crisis. They requested that APHIS stop threatening to downgrade the state's brucellosis-free status. Ranchers in Jackson Hole, they noted, had been running cattle next to bison for more than thirty years with no outbreaks of brucellosis...The most direct response by APHIS was to force Wyoming ranchers to submit to a station review of their brucellosis-control measures. The review involved thousands of dollars in brucellosis-testing costs for Wyoming ranchers. In February 1997, however, APHIS did respond positively to pressure from other federal agencies and the federal family meetings. It acknowledged that a state's brucellosis-free status cannot be revoked unless there is an uncontrolled outbreak of brucellosis. In other words, the mere presence of bison with brucellosis was no longer adequate grounds for APHIS to threaten or penalize a state's livestock producers. Nevertheless, Montana officials continue to haze, shoot, or capture and slaughter virtually all bison crossing into Montana." Finding Common Ground, pg. 138.
The RE: Brucellosis Management in Wyoming Letter was better than I hoped for. Portions copied below.
"Over the years, the agriculture and conservation communities of Wyoming have worked to protect our open space while sustaining a robust ranching economy and maintaining viable wildlife populations on the land we all respect. We are joining forces now to demonstrate our continued commitment to these values and to urge you to redirect several brucellosis management proposals now before the public that we view as serious challenges to our shared values."
"First, we feel that if the rule changes set forth in the Federal Register become standard operating procedure, Wyoming's Brucellosis Free Status will be in immediate jeopardy, if these proposals are enacted, control of the world's largest population of free roaming bison will be essentially turned over to APHIS, a Federal agency who's operational expertise does not include wildlife management. Third, if these proposals are adopted, it will lead to the unnecessary killing of hundred, if not thousands of wild bison (and eventually elk)."
"We ask you to understand that the ranchers of this area are not asking for the measures proposed in the above mentioned documents and that they are not asking for the removal of wildlife from their public grazing areas. We ask you to understand that the conservation community is not asking that the ranchers remove their cattle from public wildlife range. We ask you to understand that the ranches of this area view the possibility of brucellosis transmission from wildlife to cattle to be so insignificant that it poses no real threat to their interests. Nor does the conservation community view brucellosis as a threat to wildlife populations. We ask you to understand that the real threat to our interests are the proposals originating from and/or driven by APHIS and the unfounded premise that brucellosis poses a real threat to man and beast."
"We urge you to concentrate your management efforts on non-lethal and non-invasive methods of minimizing the already insignificant risk of disease transmission rather than concentrating on the eradication of brucellosis via the lethal and costly methods now being proposed."
What is the potential brucellosis risk from wild bison?
"The estimated percentage of cattle exposure risk from the Yellowstone bison herd was small (0.0 - 0.3% of total risk) compared with elk which contributed 99.7 - 100% of the total risk" - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk, and Cattle in the Northern Greater Yellowstone Area (2010), which Montana DoL's State Veterinarian, Dr. Marty Zaluski, was one of 7 authors on. - page 41. That 0.3% is not from a documented percentage, it is an academic safety net, just in case something ever happens. "To date, no documented transmission of brucellosis from Yellowstone bison to cattle has occurred." "The organizers' intent was that conclusions and recommendations from the panel would be considered by the National Park Service in decision-making on the potential implementation of future vaccination programs, and that the workshop report also would inform short- and long-term adaptive management decisions on and strategies for disease management activities associated with the IBMP." Brucellosis Science Review Workshop Panelists Report 2013.
For a long time, everyone just assumed it was the bison transmitting the livestock disease brucellosis back to the cattle, but the science of genetics has proved that it was the elk genotype that transmits to cattle. "Our results indicate that elk and cattle isolates are virtually identical genetically, differing by only one to two mutational steps. On the contrary, bison B. abortus differed from cattle and elk by 12-20 mutational steps."- DNA Genotyping Suggests that Recent Brucellosis Outbreaks in the Greater Yellowstone Area Originated from Elk, 2009. Molecular Epidemiology of Brucella abortus Isolates from Cattle, Elk, and Bison in the United States, 1998 to 2011, 2012.
And of that 99.7-100% risk that elk will spread burcellosis to Montana's cattle - Dr. Marty Zaluski testified, "The chance that any one Montana animal is brucellosis positive is 0.00024%."
APHIS & DOL Misdirection
This is not really a disease issue, it never has been. This has been a political issue, driven by APHIS and MT DOL. So long as politics, rather than the science of wildlife biology, dictates the terms, we will not see an end to this decades old travesty against these iconic bison and APHIS/DOL are already adding elk to the political slaughter.
Recently, in his desperation to direct another point of attack against our wild bison, MT DOL's State Veterinarian, Dr. Marty Zaluski was quoted in a Reuters article, Montana livestock official favors bison hunting in Yellowstone. "A top Montana Department of Livestock official is pushing a proposal to allow hunting of bison inside Yellowstone National Park for the first time in its 142-year-old history to keep their numbers in check.
Marty Zaluski, Montana state veterinarian and member of a federal, state and tribal team that oversees bison in and around Yellowstone, said hunts in the park of the nation's last purebred herd of bison would lessen conflicts tied to their management." "Zaluski said hunting of the animals inside the park would protect cattle that graze in Montana near Yellowstone and bring the 4,600-strong herd closer to the population target of 3,000 to 3,500. He said it would also lessen the public relations fallout tied to the slaughter of animals that leave the park. 'What I'm saying here is we have the potential to move this intractable issue forward. Hunting needs to be looked at more seriously as a possible solution,' Zaluski said."
A public relations fallout Zaluski does not want pointing to MT DOL! This is just another APHIS & DOL misdirection. Just as they have used the Native Americans to advocate for brucellosis eradication, being the recipients of these slaughtered and culled bison, they are now trying to bait the hunters (baiting is illegal in Montana) to clamor for the opportunity and apply pressure on the YNP to open up their gates to public hunting.
Thankfully, the Lacey Act of 1894, Chapter 72, Sec 4, referring to the Yellowstone National Park, states, "That all hunting, or the killing or wounding, or capturing at any time of any bird or wild animal, except dangerous animals, when it is necessary to prevent them from destroying human life or inflicting an injury, is prohibited within the limits of said park;"
"Publicity surrounding the exploits and eventual capture of Edgar Howell, an infamous poacher from Cooke City, highlighted the absurd penalty he endured for killing one of only a few dozen buffalo left in Yellowstone: expulsion from the park. Public outrage at the lack of stiff punishment for Howell spurred the passage of the Lacey Act of 1894, which still provides penalties for harming the park’s wildlife and other 'natural curiosities or wonderful objects.' " - Change at park enduresThrowing our collective energies against the Yellowstone National Park, when they are bound by the IBMP contract and cannot manage bison as wildlife, as all their other wildlife are, is like blaming the victim. We need to publicly give them a base of support to stand against these APHIS and DOL agenda's. If bison were allowed to be wildlife when they left the Yellowstone National Park and entered Montana, none of this would be happening!
If we focus our "Public outrage" against the real adversaries of our wildlife - APHIS and Montana's DOL, we can effect the change we want. Please contact the address at the bottom, to express your outrage at Montana refusing to treat wild bison as wildlife when they enter Montana, instead of diseased vermin to be slaughtered and dictating terms of 3000 herd objective in YNP.
Change.org Petition to Sue Masica, National Park Services, Intermountain Regional Director, to request the National Academy of Sciences conduct a scientific review of Wildlife Brucellosis in the Greater Yellowstone Area. We need the science in our wildlife management, not politics and special interests.
Montana's Governor Steve Bullock, who is ultimately over the MT DOL. Governor Steve Bullock
Toll Free: 855-318-1330
Mail: Office of the Governor
PO Box 200801
Helena MT 59620-0801
Montana Policy Advisor for Natural Resources
Tim Baker 406-444-7857
Mt Department of Livestock
Christian MacKay, Executive Officer
MT DOL State Veterinarian
Dr. Marty Zaluski
APHIS IBMP representative
Dr. Don Herriott