Is Governor Bullock sanctioning test and slaughter of Montana's elk, bison, moose and deer?

At the Interagency Bison Management Program on November 21, 2013, MT DOL's State Veterinarian stated, during the Brucellosis Seroprevalence discussion, that they would be conducting a capture, test, slaughter and vaccination program with the wild bison exiting Yellowstone National Park, beginning this February. Familiar with the academic papers on the unrealistic and uneconomical subject, as well as the 0.0-0.3% risk that wild bison could possibly transmit the livestock disease brucellosis, back to domestic cattle (no documented case of wild bison to domestic cattle transmission has ever occurred in the wild), I emailed Governor Bullock, to share the science with him, in hopes that he would stop the DOL's 2014 slaughtering of thousands of bison as they exited the Park, as they did in the winter of 2005/2006 and again in 2008. The reply I received, which turned out to be canned, was such a factual, politicized disappointment involving elk and bison, I had to write a rebuttal to correct all the literal bullshit. Below is my reply, with Governor Bullocks email following. I have also included my original bison vaccination citations email below his. So if you like to read in chronological order, start at the bottom. I have received no reply from the Governor's office from this Dec. 26th rebuttal email.

Additional notes, I have repeatedly requested Montana's official position on brucellosis in wildlife, including the Governor's office, and received no such policy statement. I have also researched and uncovered documents that show the State has signed onto USDA APHIS's Brucellosis Management Plan (posted soon) with APHIS, whose current mission statement is the eradication of brucellosis in wildlife - the elk and bison (as well as other cervids) of the the GYA. 

Governor Steve Bullock's Email on Elk and Bison Brucellosis

Montanan's public and our public trust wildlife deserve better!

Please contact Governor Steve Bullock and voice your concern that test and slaughter/vaccine programs are not efficient, economical, nor socially acceptable management tools for our treasured and public trust wildlife.

Governor Steve Bullock
406-444-3111
Toll Free: 855-318-1330
FAX: 406-444-5529
Email: governor@mt.gov
Mail: Office of the Governor
PO Box 200801
Helena MT 59620-0801 

MT Department of Livestock & Livestock Association Brucellosis Statements

Below is a link to the EMWH webpage dealing with the Sept. 10th testimony that Montana's DoL, Dr. Marty Zaluski gave before the Texas Animal Health Commission concerning their brucellosis rule change on cattle imports from Montana, Idah and Wyoming, the 2 GYA states affected by the brucellosis issue. There are a number of statements that we dont normally hear here in Montana on this subject, from the DoL on brucellosis. When I requested the written public comments from TAHC, I received a 72 page pdf file which not only included Zaluski's 50 pages, but statements from the Montana Stockgrowers Association, Montana Cattlemen's Association, some Montana ranchers. The pdf file is broken up by submitter for easier viewing. Also available are the audio files of the testimony. I really hate transcribing, so I have only done the main testimony from Dr. Marty Zalusky, not all the questions and his answers that followed yet. Mr. Palmers testimony on audio file 10 is also pertinent.
http://www.emwh.org/issues/brucellosis/livestock%20tahc.htm

DoL, "Montana's DSA includes 282 operations with 73,200 cattle and domestic bison. This fiscal year, 42,025 of the 73,200 animals have been tested to achieve a 99% confidence that the disease (if it exists) is present at a rate of less that 0.008%. The chance that any one Montana animal is brucellosis positive is 0.00024%." "In comparison, the state of Montana has an annual infection rate of 0.007% with five affected herds over six years since 2007." "There is no documented case of bulls spreading brucellosis." "So what happens is you have cattle properties that are typically on the flats, the river bottoms and the prairies, and then you have the elk ground that is alot of time in the forest. So its not like those elk are on private property typically, and in fact often times those elk are on BLM or Forest Service land," "So there are practices, its not like they come down on the flats, then spread out five fetuses and they take off."
Heres a really good one - no mention of bison, "So really the DSA in the state of Montana is in southwest Montana. And it is designed to identify the cattle at risk from brucellosis positive elk. So we know that brucellosis positive elk are in southwest Montana, they can potentially expose cattle and so the key to identifying the cattle at risk is to identify where the brucellosis positive elk are."

MSA, "There is an extremely low risk of brucellosis transfer posed by cattle coming out of Montana. While a small area of Montana in the Greater Yellowstone Area (GYA) is affected by rare transfers of brucellosis from wildlife, the state of Montana has proven highly effective in its efforts to mitigate the spread of brucellosis."
Mr. Palmers testimony (audio file 10) on behalf of the Matador Cattle Company (Koch Industries), the owner of the Beaverhead Ranch in southwestern Montana, discussing how little of an issue this is, "the majority of those times those elk are not calving in the same location as the cows."
Darrel Stevenson, Stevenson Angus Ranch, "As you can see the rate of incidence is extraordinarily low and our policing system has proven to manage with superb efficiency....Why isnt the science trusted? As reviewed in the attached, incident rate in Montana is low and imported cattle to Texas become even lower with a pre-shipment test? With no documented case of bulls spreading Brucellosis, why are they bundled into the concern?"

I would like to ask this same question of the DoL who shot the lone bull bison on the Dome Mountain WMA after hazing it off the Dome Mountain Ranch (private property rights ignored) and shooting the 2 bull bison on the west side. DoL knows that bulls dont spread brucellosis, nor the bison to cattle, which is why he only addresses elk in his presentation. And based on the science and stats presented by Zaluski, as well as the statements from the associations and ranchers, brucellosis from elk is extremely low, extraordinarily low and easily manageable, mitigated. So why in Montana do they inflame the dialogue on this issue and we dont hear this kind of testimony and science?

I think it is time that we put wildlife management back into the hands of the FWP as far as bison are concerned and keep it there as far as the elk are concerned. Remove "eradication/elimination of brucellosis from wildlife reservoirs" from our Fish, Wildlife and Parks documents/statements, such as that which FWP is signed onto in the IBMP; support natural regulation of these wildlife in the Gallatin National Forest and the Yellowstone National Park, as it should be (their signatures should not be on the IBMP eradication/elimination of brucellosis either). Brucellosis is a minimal disease threat to the cattle industry (more cattle are killed by weather or vehicular accidents each year than years of extremely low brucellosis transmission from elk), which can be managed through the DoL herd plans that Zaluski describes, as well as efforts from FWP in minimizing possible transmission of brucellosis through approved Elk Working Group measures such as encouraging security and forage on public lands and hazing from private. 



Kathryn QannaYahu

Montana's Elk Management In Areas With Brucellosis

The following post is a complex and interwoven subject, dealing with Montana's Elk Management In Areas With Brucellosis; the original 12 member Elk Brucellosis Working Group; the FWP Commission's adoption of the Proposed Final Recommendations on Jan. 10, 2013; the subsequent implementation of this program by Quentin Kujala who led the Elk Brucellosis Working Group; and the obstruction, lack of accountability and transparency in what should be a scientifically managed, multi-stakeholder public process concerning our public trust elk in Montana with the local elk brucellosis working groups. I highly suggest eating large amounts of organic dark chocolate to help process, of which copious amounts were utilized in the researching, analyzing  and presenting of this data for over half a year.

This article or any other similar action was not my first choice. It is the result of being forced to this action by numerous situations with some FWP employees, concerning myself and other concerned conservation sportspeople here in FWP Region 3. When you are confronted with the rejection of responsible wildlife science, excluded from the public process, stonewalled by the officials when you repeatedly protest these occurrences, when you have exhausted due process, you are left with the court of public opinion. Which is where I am at now. The purpose of this article is to bring awareness and thereby, hopefully, accountability and transparency to this process according to Montana Statues and the FWP Commission approved Proposed Recommendations. 

To make it easier to deal with the data, I have converted many documents obtained into PDF's and PNG's (you may need to zoom the image for better viewing) for universal viewing and printing. I hope that readers will look into the research and verify my statements, for I never expect anyone to just take my word for it. Beyond the verification, my greater hope is that Montana's conservationist sportspeople, wildlife and habitat advocates and general concerned public citizens will utilize the email links and phone numbers provided at the bottom to comment, question, complain to those in charge and fight for our elk, so that they do not go the way of the wild bison in Montana - hazed, shot, subjected to brucellosis test and slaughter, such as Rep. Alan Redfield suggested in his HB 312 - the elk brucellosis test and slaughter bill during this last legislation.There is  bigger picture here, which will have to be covered in a post all its own - the fundamental objectives of APHIS, USAHA and the DOL of eliminating brucellosis from known reservoirs - which includes elk.

July 11, 2013 is the next original Elk Brucellosis Working Group Meeting, that will review process and compile a report to the FWP Commission in Aug. There is only 1/2 hour public comment scheduled for this meeting.

Basic Elk Management In Areas With Brucellosis and Events Timeline

•  Fall 2011 - FWP and Commission initiate the Elk Management Guidelines in Areas with Brucellosis Working Group
• 1/12/2012 - a 12 member Working Group, chosen from over 40 applicants by FWP Director Joe Maurier, are notified of their acceptance. Noland and Raths are also ag/livestock, making 8 of the 12 members with ag/livestock interests.
• 9/11/2012 - FWP Commission tentative adoption of Working Group Proposed Recommendations
• 10/31/2012 - 1st FWP wildlife biologist comments against draft Proposed Recommendations. This one is a large list of points and very pertinent, "There are some points here that take us down some very dangerous roads. They are playing interests against one another, and I really have to wonder where the sportsmen’s voice is in all this. We could be paying landowners to fence out elk? Paying for vaccination? All the while reducing elk populations and thusly elk opportunities for sportsmen? I really hope that SOMEONE in our agency stands up to some of the points presented in here, or we may face some major problems in the future.", 2nd wildlife biologist comments. "Are livestock producers and other constituents willing to stand by this when other members of the public , MOGA, etc cry foul on us?" Neither of these statements were provided to the Working Group members, nor the FWP Commissioners. Names or identifiers have been blocked out to protect the conscientious biologists. Additional Science - Dr. Mark Albrechts chart (collaborated with Dr. Thomas Roffe) on Brucellosis Transmission from Elk Populations, Brucellosis Science Workshop Summary chart by Dave Hallac (YNP). 2012 Brucellosis Designated Surveillance Area (DSA). Zoom charts for better resolution.
• 14/11/2012 - Dr. Mark Albrecht's (member of the Working Group) letter to FWP Commission asking them to reconsider their vote on the Proposed Recommendations. This letter was first sent to Quentin Kujala to see if it should be passed on to the Commission members.
• 1/10/2013 - FWP Commission vote to approve Proposed Final Recommendations with commissioner's amendments. Dan Vermillion suggests that implementations go through Regional Supervisor and Regional Commissioner for authorization. Dan Vermillion is the Regional Commissioner. Commission minutes (page 5) verifying amendments and vote approval. At this point Gallatin Wildlife Association notifies FWP that they would like to participate in the local working group process.
• Feb.-April 2013 elk dispersal hunts take place, $2000 stack Fencing paid to ranchers with sportsmen dollars (1st request before Final Recommendations were even voted on, more fencing in Feb., county commissioner has bigger stacks, wants more money (at least two documented cases of fencing showed the ranchers did not allow "public hunting access for wildlife distribution and population management". I do not have the forms, as I requested, for the other cases, nor a listing of all the cases as I requested.) , hazing - hunt details below
• 2/15/2013 - 1st local brucellosis working group meeting at a Mill Creek rancher, Jim Melin's ranch, Friday Meeting, where 2 Gallatin Wildlife Association members (MWF affiliates), one of which Glenn Hockett the president, were on their way to Livingston to participate and are called, told they cannot attend that it is private, by FWP employee, directed by Quentin Kujala, approved by FWP Commission Chair Dan Vermillion as a "smart move".
• 4/22/2013 - 2nd local brucellosis working group meeting at Park County Rod and Gun Club. Again, invitation from one of the Park County Rod and Gun Club members is rescinded and we are told it is a private meeting by Quentin Kujala. Kathryn QannaYahu receives clarification from Pat Flowers, Region 3 Supervisor, that according to Montana Statutes, this is a public meeting while the FWP employees are there and presenting. She takes Montana statues and goes to meeting anyway, despite Kujala's obstruction and is admitted to meeting. See email below for this verification. Kujala stated he checked with legal beforehand, but in a conversation with Dokter, not knowing Kujala stated this, she confirmed it was a public meeting while FWP was there. Montana Annotated Code
• 4/24/2013 - Kathryn QannaYahu, as a concerned member of the public,conservation hunter and wildlife advocate emails official complaint letter concerning local working group meeting's obstruction with Quentin Kujala, Ken McDonald, Pat Flowers and Dan Vermillion. Kujala replies to recipients, "to make no response." No response was ever made by these officials, which prompted the Information Request.
• 5/3/2013 - Kathryn QannaYahu files official Information Request Relating to Elk Management in Areas of Brucellosis with FWP Director Jeff Hagener. Hagener forwards request to Ken McDonald stating, "We need to comply with this request". Ken McDonald forwards to Quentin Kujala stating, "My first inclination is to send her to the website where the workgroup documents were placed. If she comes back for more..."
•  5/24/2013 - Kathryn QannaYahu receives a CD in the mail with 388 sporadic emails, a fraction of the requested documentation.
• 6/14/2013 - After trying to call FWP Dir. Jeff Hagener about obstruction and partial Information Request fulfillment, Kathryn QannaYahu is told Hagener will not be available until mid-July, call is forwarded to FWP attorney Rebecca Jakes Dockter, who advises to send Hagener another Information Request email outlining the missing documentation. Email is sent and according to return receipt, opened at 8:31 PM. This has not been fulfilled.
• 6/24/2013 - Realizing I forgot to include the hunt roster information request in the unfulfilled information request, I sent another.
• 7/1/2013 - Hunt Roster reply from Dokter, via Kujala.
  HD 317 (zoom to see clearly), HD 560 . Actually, anyone without a legal degree, reading my request will be able to see, once again, I have not received all of what I asked for - order the rosters were at, as of January 10th, which hunters were utilized on which dates since then - to current date, where they hunted, what the classification of the hunt was labeled (game damage, dispersal, etc.) and what they harvested.
• 7/4/2013 - Rest of documentation has still not been received, nor any response to obstruction process by Hagener.

 Dispersal Hunt partial details. Due to the fact that I only received a small portion of my Information Request, I do not have complete details of this process. Here is what I do have. But first, I would like to lay some groundwork on this subject. 

On March 8, 2013, Brett French wrote an article, Northern park elk population still dropping. Wolf biologist Doug Smith and FWP biologist Karen Loveless are quoted concerning the declining elk numbers in the northern elk herd. The numbers this year are listed as being a 6% decline. The average decline is 8% in recent years.

"FWP counted only 11 calves per 100 cows last year, said Karen Loveless, an FWP biologist based in Livingston.'That’s really poor,' she said. 'As long as we have calf survival that low, I’m still really concerned.' To maintain the elk population, she said, calf recruitment would have to double to about 20 percent. To increase the herd, the recruitment rate would have to rise to 30 percent. The northern herd has been below that 30 percent rate for more than a decade, she added. 'Our objective for northern range elk wintering in Montana is 3,000 to 5,000,' Loveless said."

As a result of this article, in conjunction with my working group research I requested this years elk survey. Karen Loveless had not finished the final survey report but sent her stats.   The Mill Creek hunt was in HD 317. MAP (zoom). Recommendation for dispersal hunt at Mill Creek. 317's objective was 900. The count was 756. In the previous years report from Karen, she writes of district 317, "In 2012, 651 elk were observed, compared to 908 elk observed in 2011, 636 elk observed in 2010, and 937 in 2009. This count is 28% below the Elk Management Plan objective of 900 elk." This years count of 756 is 16% below objective.

Elk Management update PDF's recently released by FWP Region 3, Region 5

So why if the herd is in decline and these districts are below objective, is FWP having elk dispersal hunts there? 

Email from Kujala, dated May 2, 2013, 

"Sirs—
I have heard from Rep. Redfield (Paradise Valley). He is complimentary of the current brucellosis-related efforts that include the late season dispersal hunts in Regions 3 and 5. I also understand he is interested in a summer meeting with landowners to talk about an extended cow hunt. Not really sure if this means the next iteration of dispersal hunts or an antlerless elk hunt that is defined more within the context of biennial season setting. Regardless, something we should visit on—for now I offer this as an FYI for you to contemplate and prepare for any next conversation we need to have. Please forward to your staff as you see fit. Obviously one possibility here is an interaction with the 5-week season discussion.
Thanks and sorry, Q"

This is the same Rep. Alan Redfield that sponsored the  HB 312 elk brucellosis test and slaughter bill this year. He is also one of the Paradise Valley ranchers contacted by FWP for the first rancher local working group meeting.
 

Recent (July 2, 2013) email from Dr. Bill Mealer, a member of the Safari Club, to other Safari Club members, adding FWP Commission Chairman Dan Vermillion (Livingston resident), complaining about the late dispersal hunts. Vermillion states that he authorized the Mill Creek hunts.


Elk Brucellosis Talking Points/Questions

Are after Feb 15 hunts a good idea?

What do the biologists think? (At least 2 commented negatively in internal letters)

Should hunts be implemented without open and transparent public discussion involving all 4 interest groups identified by the working group? (Hunters, livestock producers, wildlife enthusiasts, and non-livestock producing landowners) 

What was done with the gut piles? (leaving fetuses behind may actually increase the risk of transmission)

Since the game damage hunt format is being used did the landowners allow public hunting during the general season? ( What is public hunting?  Block management?  The neighbors?  Relatives?  This needs to be defined and checked)

Is there any conservation easement on the property by any organization that allows for winter range use? (If the landowner has previously been compensated for winter range use we question spending more sportsman dollars.)

Were other options tried first? – hazing, fencing?

Cost of implementation and if any of the cost was paid for with anything but sportsman dollars– biologist and staff time, fencing cost, hazing cost. (Fundamental objective #3 is cost effectiveness)  How many sportsman dollars are being spent?  And staff/biologist time counts,  as it appears they spend extensive time trying to appease livestock producers.

What license was used by those participating? – for the later hunts it appears the 2012 license would have expired so was a 2013 tag used?

Did the hunts keep the elk away?

Is the area at or below objective? ( if below should we be harvesting more elk?) HD 313 we are BELOW objective by 25% and HD 317 we are BELOW objective 16% (according to the local wildlife biologists statistics), yet hunts took place.

Were blood samples collected? 

What has been done to create an educational presentation for potential working groups utilizing responsible science and wildlife management, not politics?  ( Having good information that represents science is important if any group is to make headway on this problem) 

Is a rancher’s kitchen table the appropriate place to have meetings?  Will the result be equitable and fair?  Are all parties represented?  Is FWP seeking long term solutions or just hoping to give the rancher something? 

So are these working groups or deals between FWP and ranchers?  I think that needs to be clear.  Don’t call this a public process if it is not – remember members of the MWF affiliate Gallatin Wildlife Association were told on two occasions NOT to attend these meetings and complaints citing Montana Statutes public process were ignored by FWP officials.

Bottom line:

Open and transparent meetings and communication involving all interested user groups is the only way to achieve a long-term solution. (Numerous conservation/wildlife advocate groups were contacted to see if they were contacted, any time after Jan. 10, 2013, by FWP for their participation in this local working group process. All have stated they were not and were not even aware of what was going on here in FWP Region 3 and 5. They are becoming aware now.)

Since we are seeking to minimize transmission and not to eradicate, this will be a challenging process.  We must push to minimize transmission NOT to eradicate.  The first fundamental objective is minimize transmission.  HB 312, introduced by Rep. Alan Redfield, sought to eradicate. Several FWP e-mails seems to really focus on Rep. Redfield’s desires.  He needs education NOT appeasement.

Official Contacts for questions, comments and complaints
I would highly suggest carboning a witness for accountability, since obstruction has been seen in some cases.

Governor Steve Bullock - 406-444-3111   governor@mt.gov

Tim Baker, Policy Advisor for Natural Resources - 406-444-7857  tbaker@mt.gov

FWP Commissioners - (406) 444-7826   fwpcomm@mt.gov
District 1, Gary J. Wolfe - (406) 493-9189 
District 2, Dan Vermillion - (406) 222-0624 dan@sweetwatertravel.com
District 3,  Richard Stuker - (406) 357-3495
District 4, Lawrence “Larry” Wetsit - (406) 650-7071
District 5, Matthew Tourtlotte - (406) 698-9696

FWP Director Jeff Hagener - (406) 444-3186  jhagener@mt.gov
FWP Deputy Director Mike Volesky - 406) 444-4600  mvolesky@mt.gov

Ken McDonald, Bureau Chief - (406) 444-5645  kmcdonald@mt.gov

Quentin Kujala, Wildlife Mngmnt Section Chief - (406) 444-5672  qkujala@mt.gov

Pat Flowers, Region 3 Supervisor  -  (406) 994-4050  PFlowers@mt.gov



Main Elk Brucellosis Working Group Members

Mr. Mark R. Albrecht - mralbrecht62@gmail.com 
Mr. John C. Anderson - jck@3rivers.net
Mr. Ed Bukoskey - goosehaven@rangeweb.net 
Mr. Joe Cohenour - utopiamt@optimum.net 
Mr. Rick Douglass - RDouglass@mtech.edu 
Mr. Rick Gibson - rgrs@wispwest.net 
Mr. Lorents Grosfield - lorents@mcn.net 
Mr. Ken Hamlin - knphamlin@bresnan.net 
Mr. Raymond Marxer - ramarxer@gmail.com 
Mr. Charlie Noland - chrlsnoland@yahoo.com 
Mr. William Raths - dick.nancy.raths@gmail.com 
Mr. C. Thomas Rice - trice@beaverheadcounty.org



Here's to accountability and transparency in Montana's Elk Management In Areas With Brucellosis.




Kathryn QannaYahu, concerned member of the public, conservation naturalist hunter and fisher (I have done primitive net and basket fishing to learn how, so I cant just say angler), wildlife advocate with traditional ag/livestock background now converted to organics and sustainability. Did I leave anything out? Oh yeah, Gallatin Wildlife Association and Montana Wildlife Federation member (but not writing this post on their behalf).
katqanna@gmail.com