The following document offers win/win suggestions for improving wild bison management in Montana, protecting private property rights, and better protecting our brucellosis-free status, while embracing bison as valued native wildlife.

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Subject: Six Southwest Montana County Commissions’ Hearing on Brucellosis and Buffalo Management

Dear County Commission Members:

The Gallatin Wildlife Association (GWA) is a non-profit volunteer wildlife conservation organization representing hunters and anglers in Southwest Montana and elsewhere. Our mission is simply to protect habitat and conserve fish and wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future generations to enjoy. Thank you for the opportunity to submit this written testimony on behalf of the GWA. For the benefit of the commissioners my name is Glenn Hockett and my professional background is in rangeland, livestock and wildlife management. I have a bachelors of Science degree from Montana State University in Rangeland Management, 1982.

Common Ground: Brucellosis is an important livestock disease and its potential impact to the livestock industry is serious. I suggest no one wants one more cow anywhere to get this disease. Also, let’s agree no one has any interest in seeing Montana, Idaho or Wyoming loose their brucellosis-free livestock status. As well, it is imperative that private property rights be protected. I suggest we can all work together to better protect private property rights, better protect the brucellosis-free livestock status’ of the 3 States and better manage (restore and conserve) native wild bison as valued and viable wildlife to each state. However, I feel it is imperative to first discuss an area of potential disagreement - the concept that brucellosis can be reasonably eradicated from all wildlife within the Greater Yellowstone Area. I will start there.

Can Brucellosis be eradicated from the wildlife dependent on the Greater Yellowstone Area? This is the core question regarding the future of wildlife management in this region. I urge all concerned to understand brucellosis is eradicated by capturing, testing and slaughtering exposed animals. Think about that for a moment – capturing, testing and slaughtering all the exposed wildlife within the vast and remote 18 million acre 3 state Greater Yellowstone Area. Recently, the Montana Stockgrowers Association, R-Calf and Montana Farm Bureau crafted positions calling for the federal government’s Animal and Plant Health Inspection Service (APHIS) to do exactly that, eradicate brucellosis in the entire 3 state Greater Yellowstone Area. However, the questions of how, when, where, by whom and at what cost this immense federal undertaking will take place remain unanswered. While most admit such an undertaking will be extremely costly, extremely problematic and result in severe consequences to wildlife, significant questions remain about whether such an undertaking is even possible.

Brucellosis is endemic to a variety of wildlife and land ownerships throughout the vast 3 state Greater Yellowstone Area (Keiter 1997). Furthermore, there is an unbroken chain of elk and brucellosis from the feedgrounds in Wyoming and Idaho to the winter ranges in southwest Montana (Smith 2000). Science indicates feedgrounds, not bison or elk are the primary vector for disease transmission (Smith 2001; Ferrari and Garrott 2002). GWA supports the phased elimination of all wildlife feedgrounds as well as the protection through fencing of all livestock feedgrounds that can not be removed in a win-win fashion. Although brucellosis will likely remain an endemic part of the Greater Yellowstone Area wildlife even if the feedgrounds are replaced in Wyoming and Idaho with additional habitat, its prevalence will be significantly reduced. Coupled with cost effective livestock best management practices to protect against transmission from native wildlife is the most reasonable course of action to pursue.

Please realize elk and bison are not the only brucellosis-exposed wildlife species in the Greater Yellowstone Area. Grizzly and black bears are known to be exposed as well. The extent moose, bighorns, mule deer, white-tailed deer, antelope, rodents, coyotes, wolves, birds and other wildlife are exposed remains uncertain. To get a sense of what it would take to attempt to capture, test and eradicate brucellosis from all the wildlife species within the 18 million acre Greater Yellowstone Area one must contemplate a huge federal government takeover of state’s rights over wildlife. The infrastructure, logistics and costs necessary to conduct such a massive wildlife hazing, containment, confinement, capture, vaccinate and/or slaughter program across the Greater Yellowstone Area is daunting even to imagine. This vast and remote landscape includes 2 National Parks, 6 National Forests, 3 National Wildlife Refuges, 6 Wildlife Management Areas in southwest Montana, at least 22 feedgrounds in Wyoming and Idaho, the Wind River Indian Reservation and a variety of other public and private lands. Some of the most important habitat occurs on private land. Will the federal government be willing to force its way onto private lands in an attempt to accomplish this goal?

Remember, brucellosis is eradicated by capturing, testing and slaughtering exposed animals. Yet calls for eradication in wildlife continue. The questions of how, when, where, by whom and at what cost must be answered honestly before pursuing such an immense federal policy of wildlife/brucellosis eradication. I will state for the record it is my professional opinion the answer to the question can brucellosis be eradicated from the wildlife dependent on the Greater Yellowstone Area in a reasonable fashion is NO! If you disagree, please seriously consider the scientific, economic, environmental, social and political consequences of pursuing such a policy in and around our first National Park.

Feedgrounds not Bison and Elk are the Primary Vector for Disease Transmission: In Grand Teton National Park, free-ranging brucellosis-infected bison are sympatric with cattle (Ungulate Research at the Northern Rocky Mountain Science Center 2007). These bison and cattle have been sharing the same range and/or occupying overlapping geographic areas for years without interbreeding. Research has shown bison are displaced by and generally avoid cattle, bison cows isolate themselves from other bison and cattle during parturition and brucellosis in bison does not affect reproductive synchrony. While pathogen exposure does occur, disease transmission to cattle has never been documented. Good news for both cattle and bison.

As well, some may claim bison if allowed to access the same winter ranges used by elk will “infect” elk with brucellosis. For the record, this hypothesis has been scientifically tested in Yellowstone Park by Montana State University researchers Ferrari and Garrott (2002). They studied high density elk and bison populations sharing the same range in close proximity during the winter and spring within Madison-Firehole drainage. Despite close association between these two species during the primary window of transmission (February – June), a sample of 73 adult cow elk indicated the prevalence of sero-positive animals in the Madison-Firehole was not significantly different (P > 0.05) from other elk populations that do not associate closely with bison. Furthermore, the sero-prevalence in the Madison-Firehole was lower (P < 0.05) than the sero-prevalence in populations associated with winter feeding operations. Close contact between bison and elk during the winter and spring did not result in increased levels of disease exposure in elk (Ferrari and Garrott 2002).

Free-ranging elk in southwest Montana have significantly lower sero-prevalence rates than elk frequenting winter feedgrounds in Wyoming (Montana FWP undated). Furthermore, feedgrounds, whether for wildlife or livestock appear to be the main vector for disease transmission between species that share the same feed line (Smith 2001; Ferrari and Garrott 2002).

The good news in southwest Montana there are very few livestock feedgrounds and no wildlife feedgrounds, except the Stephens Creek capture facility and feedground periodically operated by Yellowstone National Park near Gardiner to confine bison. Livestock feedgrounds such as the CUT Trestle Ranch Property (640 acres) near Gardiner can be protected with fencing during the February to June transmission period. Win-win agreements to remove the conflict would also work, as other classes of livestock or grazing after July 1 are sound prevention measures.

The Current Interagency Bison Management Plan, hereafter the “Plan”: The Plan focuses on large scale hazing, capture, containment, confinement, vaccination, shooting and/or slaughter of native bison in an attempt to control and/or eradicate brucellosis in Montana. Is this sound public policy? No. The Plan must be improved to better protect private property rights, our brucellosis-free livestock status and better manage bison as valued and viable native wildlife in southwest Montana, all objectives of the signed record of decision (Montana Department of Livestock and Montana Department of Fish, Wildlife & Parks 2000). Only bison, not brucellosis are eradicated from Montana under this Plan.

Currently only two small zones immediately north and west of Yellowstone National Park define a politically drawn limit for wild bison in southwest Montana. The numbers of bison are limited to a maximum of 100 animals in each area, never after May 15 (April 15 on the north side) and their fate is dictated by the Montana Department of Livestock (DOL). DOL may take nearly any means necessary to remove the animals from Montana at any time (MCA 81-2-120). Access to critical habitat, in particular winter ranges used by elk is severed for bison by the current Plan zone boundaries. Furthermore, the population of wild bison in this critically important herd and landscape is reduced to zero each spring with no chance for restoration in southwest Montana due to government imposed regulations established in the Plan. This occurs despite vast landscapes of suitable, conflict-free, year round bison habitat in southwest Montana. The Plan must be “re-zoned” to recognize this political, inconsistency between management of elk and other wildlife that have been exposed to brucellosis and bison.

Charting a New Course for Wild Bison in Yellowstone National Park and Montana: What is the current status of wild bison in Montana? We have asked for a status review from the Montana Department of Fish, Wildlife & Parks (FWP), which is still pending (correspondence dated March 3, 2007). However, according to the Montana Legislature wild bison in southwest Montana are considered a species in need of disease control (MCA 81-2-120; 87-1-216). They are also considered a “game animal’ (87-2-101). Other wild bison in Montana are considered a species in need of management (87-1-216) as well as a game animal (87-2-101). However, the only other “wild” herd we are aware of is intensively managed in captivity behind a high fence within the National Bison Range at Moiese, and some of these animals have cattle genes.

Internationally, data being collected by the North American Bison Specialists Group’s Species Survival Commission is just as startling. This draft report indicates throughout North America there are less than 8,000 wild plains bison, which are not confined by fences. Nearly 4,000 of those animals are found in the herd(s) dependent upon Yellowstone National Park and the surrounding landscape I am discussing here. Boyd (2003) discusses the dire situation for plains bison across North America in more detail. A sense of urgency is warranted.

As noted earlier, in southwest Montana DOL and the state veterinarian, under the Plan approved by the governor, may use any feasible method listed in MCA 81-2-120 to physically remove or destroy a live wild bison. In essence, the current Plan is perpetuating the ecological extinction of this highly valued big game species in Montana.

The GWA has maintained wild bison are ecologically extinct in Montana and unnecessarily burdened by government intervention codified in the Plan. The Plan specifically prevents a viable, free-ranging bison herd in southwest Montana. Under the Plan and laws established in Montana, in particular MCA 81-2-120, it appears bison meet all 5 criteria for listing under the Endangered Species Act (see section 4(a) of the Act). However, our recommendations for the protection and connection of critical wild bison habitat in southwest Montana represent an opportunity to change that, a necessary scientific minimum if you will for turning the corner on a sound recovery and conservation plan. The good news is most of what is necessary is already in place. We just need to get out of the bison’s way.

Is the Park Service’s natural regulation model coupled with Montana’s elk habitat and public hunting model a sound management option for wild bison in southwest Montana? Yes. We suggest the elk model in Yellowstone National Park and southwest Montana provides a sound foundation to develop win-win recovery and conservation solution for wild bison and livestock in the region. Habitat is the key.

Protecting and Connecting Critical Habitat in Southwest Montana – Establishing the Scientific Minimum: A series of Wildlife Management Areas (WMAs) have already been purchased and protected with sportsmen’s dollars in southwest Montana. These WMAs provide crucial winter ranges used by elk and other wildlife and include the Dome Mountain WMA in the Upper Yellowstone basin, the Gallatin WMA in the Upper Gallatin watershed and the Wall Creek WMA in the Upper Madison valley (Gallatin National Forest Map West Half 2003). As well, the Forest Service owns important habitat in the Lee-Metcalf and Abaroka-Beartooth wilderness areas, where elk and other brucellosis-exposed wildlife roam freely. Private landowners in the area, many which own no susceptible livestock, especially some of the larger landowners have a keen interest in wildlife recovery and conservation (Dome Mountain Ranch in the Upper Yellowstone and the Sun Ranch in the Upper Madison valley). They are important partners in this effort and their tolerance and/or appreciation for helping restore and conserve wild Montana bison is critical.

The Upper Gallatin: The protection and connection of wildlife habitat in the Upper Gallatin canyon has been an ongoing effort for years. The vast majority of this landscape is already in public ownership. I suggest the best area for the restoration and conservation of wild bison in Montana on a year round basis is to these public lands in the Upper Gallatin watershed. This land area is roughly defined by the area south of Levinski ridge at the Big Sky turnoff east of the river to the Gallatin-Yellowstone divide and south of the developed private land in the Big Sky area west of the river to the Gallatin-Madison divide. This includes land in the Porcupine, Elkhorn, Buffalo Horn, Tepee, Taylor Fork, Sage, Monument, Snowslide, Bacon Rind and other smaller tributaries to the Gallatin River in Montana. These lands include the Gallatin WMA, Gallatin National Forest lands as well as 5 small Dude ranches who enjoy and benefit from wildlife. There is also a vast landscape in Yellowstone National Park that lies within the Upper Gallatin watershed where bison can be restored and conserved on a year round basis (see Gallatin National Forest Map West Half 2003).

The Upper Yellowstone: There is also an important history of wildlife habitat protection and connection in the Upper Yellowstone Basin, which continues today. The opportunity for wild bison recovery and conservation extends north of Yellowstone Park to the Dome Mountain WMA near Six-mile Creek east of the Yellowstone River. The Dome mountain bench is defined by a rock cliff that forms a natural barrier (a former bison jump) near the Yellowstone River to the west. The Dome Mountain Ranch, an incredible wildlife habitat on about 5,000 acres owned by Fred Smith lies to the south and adjoins the Gallatin National Forest near Dome Mountain. Robb Smith owns the 8,000 acre R and D Ranch west of the river in the same area. As I understand it, both owners are conservation minded, own no cattle and are interested in managing for native wildlife. Public lands extend south to the mouth of Yankee Jim Canyon between Dome and Sphinx mountains. Joe Brown, Slip & Slide, Cedar, Bassett, Maiden Basin, and Little Trail creek all provide potential conflict free public land habitat for migrating bison east of the river. However, all of these public lands are currently mapped as “zone 3” a drop dead zone for wild bison. The Eagle creek bench and Deckard Flats area to Bison and Bald Mountains are within the current “zone 2”, which allows for limited bison tolerance, at least seasonally (never more than 100 never after April 15th).

The Upper Madison: The protection and connection of wildlife habitat in the Upper Madison valley has been an ongoing effort for years. Numerous public/private partnerships have developed and nearly half of the valley’s private lands have been protected from urban development by various conservation easements and/or acquisitions. The opportunity to embrace wild bison recovery and conservation in the Upper Madison valley to Indian creek east of the Madison River and to the Wall Creek WMA west of the river is at our fingertips. I suggest the excellent work being conducted with local landowners to implement incentive based conservation easements and acquisitions continue and include “brucellosis-proof” livestock management options where livestock grazing is an objective, including state and federal lands. The proposed Sun Ranch conservation easement is a case in point.

Sun Ranch Conservation Easement: The Sun Ranch property is an internationally recognized and nationally important wildlife winter range on over 18,000 acres in the upper Madison Valley. The landowner, Roger Lang, is a native fish and wildlife enthusiast with a strong restoration and conservation ethic. The Nature Conservancy has already partnered with the Sun Ranch to protect 6,800 acres on the northern end of the property.

North American Bison or bison are an historic native species to the Sun Ranch and the surrounding landscape (Atkinson and Groves 2006). Wild bison from Yellowstone National Park attempt to migrate to the winter ranges in the Madison Valley each year, but they are stopped by DOL and other government agents due to concerns over brucellosis-transmission to certain susceptible livestock. Roger Lang is pursuing a conservation easement on this property with the U.S, Forest Service, FWP and the Trust for Public Lands. I suggest the Sun Ranch Conservation Easement be structured in such a way that all wildlife, including wild bison migrating within the Greater Yellowstone Area, be assured access to the habitat protected under the easement. This can be done in a win-win fashion while still providing for periodic domestic livestock use (July 1 turnout dates, adult vaccinations with RB51 vaccine, and/or steers, spayed heifers, horses and/or mules).

Thousands of elk currently use the Sun Ranch property for winter range and some stay through spring to calve. Some of these elk have been exposed to brucellosis and/or a variety of other livestock diseases (Hamlin and Ross 2002, FWP undated, and personal communication with Neil Anderson FWP Lab Supervisor and Tom Linfield former Montana State Veterinarian). As well, the majority of these elk summer outside of Yellowstone Park in the Upper Gallatin (85%+), including the Taylor Fork watershed where the U.S. Forest Service administers two cattle allotments. “Brucellosis-proofing” livestock management on the Sun and in the Taylor Fork is a good idea whether wild bison ever get here or not, because the current Plan confines only bison not brucellosis. As well, the general public will not tolerate a large scale wildlife capture, test and slaughter program aimed at eradicating brucellosis in all the elk and other wildlife in southwest Montana.

These areas in the Upper Gallatin, Madison and Yellowstone basins represent critical habitat, the scientific minimum if you will for viable and sustainable bison recovery and conservation in southwest Montana.

What about the bison quarantine research project being lead by FWP? The high fence Phase I and II compounds of the quarantine research project are actually federal government research facilities leased and controlled by APHIS. The Phase I facility on the Brogan private property was transformed from a horse pasture to a federal research facility without any National Environmental Policy Act environmental analysis. The Phase I environmental assessment (EA) merely stated this was an existing federal research facility. When did that happen? Formerly, it was a horse pasture.

The stated goal of this project is to determine if brucellosis can be eliminated from wild bison, so these important genetics can be restored to historic habitat and managed as native wildlife in other locations, preferably public lands in Montana. However, current Montana law (MCA 81-2-120) specifies only the DOL State Veterinarian can certify whether a bison is brucellosis-free. Furthermore, these quarantined bison, even if deemed “brucellosis-free” can only be sold to someone else to defray costs of the quarantine project; or transferred to qualified tribal entities that participate in the disease control program (81-2-120). Thus, public ownership and management of these animals as native wildlife in the public interest remains a false hope of this expensive experiment under current law. As well both the Phase I and II projects require wildlife proof double fencing in the middle of one of the most important big game migration corridors in the world. The locations of these facilities further sever critically important wildlife migration corridors.

What about Serving Agriculture? APHIS can implement a voluntary testing program certifying any susceptible livestock entering and/or leaving the Greater Yellowstone Area as brucellosis-free, thus eliminating any interstate marketing restrictions for these livestock. Steers and spayed heifers can be grazed without restriction as well. Horses and mules are also fine. However, in the unfortunate event two different herds of susceptible livestock are found to be infected with brucellosis, a worse case scenario, APHIS, can separate out the specific area of the state to be managed as Class A. Regionalization makes sense if necessary, to protect the rest of the state from undue government burden.

Better livestock vaccines have been developed (RB51 Plus) as well and annual adult vaccinations with existing vaccines (RB51) have proven to increase efficacy for protection against brucellosis transmission to over 95%. This is great news. Has the Plan adapted? Furthermore, research has shown brucellosis is largely a seasonally contagious disease with the primary window for transmission to be February through June, the pre-calving abortion period (Montana FWP undated; Aune unpublished). Again, this is great news. In addition, some classes of livestock are essentially “brucellosis-proof” – steers, spayed heifers, horses and mules. Thus, proactive incentives to encourage livestock best management practices, such as annual adult vaccinations with RB51, approval of RB51 Plus in livestock, brucellosis-proof turnout dates (July 1 through January) and/or brucellosis-proof classes of livestock are sound and respectful public policy and brucellosis prevention mitigation measures.

How much Bison Habitat is enough? Private landowners will both lead and limit this effort in southwest Montana. The entire area I discussed can be seen on a Gallatin National Forest Map – West Side 2003. For those who believe this is too much land for wild bison, please consider the following. Dary (1974) estimated the historic range used by bison extended over a 3 million square mile area. Lott (2002) estimated the historic bison population to be about 30 million animals, although there are estimates as high as 75 million (Dary 1974). Regardless, it is clear the historic range and numbers of North American bison were extensive. The critical habitat outlined here in southwest Montana is less than 1,000 square miles, which represents less than 0.033% of the bison’s historic range. The entire 18 million acre Greater Yellowstone Area covers 28,125 square miles, yet represents less than 1% (0.9375%) of the bison’s historic range. Currently, 3,000 – 4,000 bison occupy Yellowstone National Park. This is only 0.013% of the historic bison population. A population increase to 8,000 animals would still only represent 0.026% of the historic population. It seems to me, protecting and connecting this habitat in southwest Montana to restore and conserve this critically important herd is the least we can do.

Where do we go from here? We can work together to better respect private property rights, better protect Montana’s brucellosis-free livestock status, and better manage (restore and conserve) native bison as valued and viable Montana wildlife. It is time to vastly improve the current Plan. Access to critical habitat in southwest Montana must be protected and connected to ensure wild bison can be restored and conserved for future generations to enjoy. I would be happy to meet with any county commissioner, member of Congress or other interested party to discuss the ideas presented here in more detail. Please consider coming to southwest Montana to tour the areas in question. I would be happy to show you around.

Thank you for considering my comments on behalf of the GWA.

Sincerely,

Glenn Hockett
Volunteer President, Gallatin Wildlife Association

Literature Cited

Atkinson, E. and C. Groves. 2006. Wildlife and their habitats in the Madison Valley. Wildlife Conservation Society. 11pp.

Boyd, D.P. 2003, Conservation of North American Bison: status and recommendations. MS Thesis, Faculty of Environmental Design, University of Calgary, Calgary Alberta. 222 pp.

Dary, D.A. 1974. The buffalo book – the full saga of the American animal. Sage Books, The Swallow Press Inc., Chicago IL, 374pp.

Ferrari, M.J., and R.A. Garrott. 2002. Bison and elk: brucellosis seroprevalence on a shared winter range. J. Wildl. Manage. 66:1246-1254.

Hamlin, K.L. and M.S. Ross. 2002. Effects of hunting regulation changes on elk and hunters in the Gravelly-Snowcrest Mountains, Montana. Montana Dept. Fish, Wildlife & Parks, Helena, MT, Fed. Aid Project W-120-R-Apr. 2002. 237 pp.

Keiter, R.B. 1997. Greater Yellowstone's bison: Unraveling of an early American wildlife conservation achievement. Journal of Wildlife Management. 61:1-11.

Lott, D.F. 2002. American bison a natural history. Univer. of Calif. Press, Berkeley and Los Angles CA. 229 pp.

Montana Fish, Wildlife & Parks. Undated. Montana elk - brucellosis management plan. FWP, Helena, MT. 40 pp.

Montana Department of Livestock and Montana Department of Fish, Wildlife & Parks. 2000. Interagency bison management plan for the state of Montana and Yellowstone National Park Record of Decision. 20 pp.

Smith, B.L. 2000. Jackson Hole - the big herds. Bugle Magazine, Fall 1991, updated in 2000. 7 pp.

Smith, B.L. 2001. Winter feeding of elk in western North America. J. Wildl. Manage. 65(2):173-190.

Ungulate Research in the Northern Rocky Mountain Region Issues, Opportunities and Challenges. 2007. Available online at: http://www.nrmsc.usgs.gov/research/ungulate_research.htm
Reviewed 1/30/07.

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