Stop APHIS from Harming Wild Bull Bison

Without adequate notification to the public, in late-February, the Animal & Plant Health Inspection Service (APHIS) department of Veterinary Services (VS) released an Environmental Assessement that outlines their intention to immobilize bull bison in the field in order to study their semen and blood. Their purported reasons for undertaking this study are to determine if bull bison can transmit brucellosis. APHIS intends to dart and immobilize wild bull bison - up to 50 individuals - on Gallatin National Forest lands north and west of Yellowstone's boundary. APHIS has not disclosed the immobilization chemical they intend to use on bison. APHIS also wishes to conduct another phase of this study inside Yellowstone National Park, on bull bison during the rut (mating) season. Yellowstone has flatly denied APHIS's requests for permits, demonstrating that this study is undesireable and unnecessary.

It is already widely accepted that bull bison pose a zero risk of transmitting brucellois to domestic livestock, and there has never been a documented case of any wild bison transmitting the livestock disease brucellosis back to cattle. APHIS is also under the false impression that wild bull bison would actually choose to mate with domestic cows, however, in the history of cattle being on the buffalo's landscape, this has never happened. Artificial insemination is the only means by which to cross Bison bison with domestic cattle.

Buffalo Field Campaign is adamently opposed to this study as it is unwarranted, poorly thought out, lacks critical information as well as the necessary permissions APHIS needs to carry it out. More importantly, it will be dangerous to bulls and possibly other buffalo, and will result in absolutely no benefit to wild bison. APHIS also put forth minimal effort to notifiy the public that this Environmental Assessment was available for public comment, so Buffalo Field Campaign has requested an extension for public comment, but currently there is very little time in which to act. APHIS's comment period ends on Tuesday, March 23, 2010. However, everyone who cares about wild bison should continue to send in comments even after the closing of the public comment period.

TAKE ACTION FOR BULL BUFFALO! Please personalize the suggested comments below, and in your own words tell APHIS that they should not proceed with this study.

Download and read APHIS's EA.

Who is APHIS?

Subject:

Your Letter:

RE:  Comments on Animal & Plant Health Inspection Service, Veterinary Services Environmental Assessment for the Study of Shedding and Venereal Transmission of Brucella abortus by Bison Bulls in the Greater Yellowstone Area.

Thank you for the opportunity to comment on USDA Animal & Plant Health Inspection Service (APHIS) Veterinary Service’s (VS) Environmental Assessment for the Study of Shedding and Venereal Transmission of Brucella abortus by Bison Bulls in the Greater Yellowstone Area.
 
I am concerned and actively involved with protecting the last remaining descendants of indigenous bison in North America to occupy their original range in the Greater Yellowstone ecosystem.

I would like to go on record as being adamantly opposed to this proposed study and actions taken against bison outlined therein.  My concerns and questions are outlined below.

1. APHIS has given inadequate public notification on release of its Environmental Assessment to study wild buffalo bulls, and the period for public comment is insufficient to review its study in full, which lacks critical information.

* The release of the EA on IBMP.info and APHIS's website cannot be expected to service as fair and available dissemination of the document without more specific notification (i.e. agency email lists, announcement at IBMP public meetings).  Also, notification for the public comment period was not posted on IBMP.info. Your research document was simply posted on the library page without public notice.  Therefore, there was very little time allowed for me to digest the information in your proposed study and I am requesting an extension to the public comment period to 30 days, and no less than 15 days.

2. APHIS does not identify the geographical range of its activities and the numbers, groups, and ages of bull bison for each breeding group or subpopulation in the population required for study during phase 1.

* While the total number of bulls required for tests during phase 1 of the study is explained there is no mention of how many bulls will be studied in each specific area; i.e. 25 in Gardiner and 25 in West Yellowstone, or 49 in West Yellowstone and one in Gardiner.  This information is extremely relevant for the public’s knowledge because this study could effectively mean all bulls in one or both of the proposed study area could be affected.
* The age range and groups of bull bison required for phase 1 is not communicated in the EA.  This is pertinent information for several reasons.  
* First, if APHIS' study can be done on bull bison who have not yet left their family groups then the impact to those family groups must be considered, as well as the potential safety risks the workers of the study may face while gathering fluids from wild buffalo in the field.  
* Secondly, if valid data can only be gathered from mature mating bull bison then selection of those mating bulls should be done so that no invalid data is gathered.  Also the impact on bachelor groups must be considered and communicated in the EA if bull bison are to be selected from such groups, as well as the potential risks to workers who enter into habitat occupied by bull bison cohorts. 
* Due to the lack of precise information in the EA on how cohorts, family groups, bull bachelor groups, are impacted I request that these details and situations be considered and communicated with the public in an additional evaluation by APHIS and opened to public review and comment.

3. APHIS, VS' study impacts public access to recreational areas and decisions on closure require agency permits. .

* It is stated in the EA that only permit(s) from Montana, Fish, Wildlife and Parks is needed to complete phase 1 of the proposed study.  I contend that additional permit(s) are needed from U.S. Forest Service, Gallitan National Forest (GNF) to effect the closure APHIS intends.  My reasons for this are the spatial issues concerning where phase 1 of the study will take place, and also oversights on APHIS, VS's part in understanding the access and recreational aspects of the lands they seek to utilize during phase 1.
* It is stated in the EA, Sec. 2. 'Human Health and Safety' under letter c. 'Other Potential Land Users', "During the time and in Zone 2 locations proposed for the study, USFS does not allow recreational activities on USFS land because of IBMP operational activities".  This is not the case; any closure that happens on USFS, GNF land due to IBMP operational activities is a moving and temporary closure that surrounds an active haze and is lifted after that haze.  Forest closures in effect for Zone 2 include a bald eagle nesting closure off Forest Road 610 in the vicinity of three occupied bald eagle nests on Horse Butte peninsula. Additionally, each spring there is a grizzly bear closure in effect for Zone 1 so bears can access winterkill securely in the Duck Creek, Richards Creek, Campanula Creek and Fir Ridge drainage. Therefore, APHIS would need to seek permission from GNF to implement additional closures to perform the proposed actions in the EA and permits from the USFS, GNF are required.   If APHIS is seeking secure closure of public recreational lands, it should disclose what discussions, if any, it has had with the USFS, and what if any commitments have been made or secured to immobilize and handle wild buffalo on the Forest. Also, the human health and safety concerns for other potential land users as it is currently stated in the EA is inaccurate and needs to be re-evaluated and communicated after its revision with the public.
*  The same inaccuracy is stated in the EA again, in Sec. 3 'Vegetation and Physical Environment' under letter c. 'Recreational and Cultural Land Use', sub-number (1) 'Recreational Land Use'.  Here it is stated that, "During the time frame and location for the proposed study activities, recreational activities are restricted because of IBMP operational activities that occur in Zone 2 at that time of the year.  Therefore, no changes would occur to land use by recreationists during this time of year as a result of the study activities".  This is untrue.  Any restrictions in the area due to IBMP operational activities are as stated above; Moving and temporary closures that surround an active haze are lifted after that haze.  The areas proposed for phase 1 included day-use recreational areas and over-night campgrounds on the Gallatin National Forest.  There would absolutely need to be changes that occur to land use by recreationists during the time frame proposed for phase 1 due to the proposed study activities for phase 1. 
*  A question I have concerning the proposed study activities for phase 1 are; in which areas does APHIS, VS assume that the USFS, GNF has closed or restricted land use by recreationist that are also frequented by bull bison during the proposed timeframe for phase 1?  APHIS, VS has assumed available areas for the studies data to be collected that do not exist.  What will be the response to these problems in the field when they are realized?
* Due to the inaccuracies in the EA, as described above, I request that APHIS, VS re-evaluate the impact to public land use and access issues that will occur due to proposed study activities during phase 1, and communicate these findings with the public before a decision is made.

4.	APHIS lacks the participation and permits from Yellowstone National Park that are needed to fully complete both phases of its study as proposed and outlined in the EA.

•	To complete phase 2 of the proposed study during the rut season APHIS, VS would need to receive permission and permits from the NPS, Yellowstone National Park (YNP).  YNP has stated that they have refused to grant this permit several times in the past and they see no reason why they would grant the permit in the future.  Therefore, phase 2 of the study as proposed (during the rut) in the EA cannot happen in YNP.  If APHIS, VS contends that there is "no tolerance" for bull bison in Montana where can they garner their data during the proposed time frame for phase 2.  And if there are bull bison in Montana during the proposed timeframe of phase 2 then there is obviously some tolerance for bull bison in Montana.  As this EA is entitled, "Study of Shedding and Venereal Transmission of Brucella abortus by Bison Bulls in the Greater Yellowstone Area", and appears that key data cannot be gathered for assessing the role of bison bulls in venereal transmission of brucellosis, we feel this EA as currently outlined is moot, and alternatively needs to be completely redone to reflect that bison bulls inside Yellowstone National Park will not be sampled as part of APHIS study.

5.	Lack of cited evidence by APHIS, VS to support the purpose of its study.

*  Several of APHIS, VS's stated purposes for conducting these proposed studies are not backed by any evidence and/or are contradicted by participating partners of the IBMP.
*  One of the stated purposes of these proposed studies is to assess the possible role bull bison may play in venereal transmission of brucellosis to domestic cattle.  There is no evidence that in the wild a bull bison would seek out a domestic cow to mate with.  An assumption of this magnitude, that plays such a major role in implementing such studies, should be supported by evidence before it is ever considered a reason to perform such studies.  Grand Teton National Park, from my perspective, is 100 years of evidence that this would not happen in nature.  On that landscape bison and domestic cattle co-exist and there has never been a documented occurrence of bull bison mating with domestic cattle.
*  It is also stated in the EA, that from possible outcomes of these studies bull bison maybe granted tolerance in Montana.  It is stated by APHIS, VS that currently bull bison have "no tolerance" in the state of Montana.  Dr. Martin Zaluski, State Veterinarian and paid employee for the Department of Livestock (DOL), was quoted less than two month ago from this date (March 19, 2010) as saying he is, "still committed to tolerance for bull [bison] in Zone 2".  This is in direct contradiction to APHIS's claims on the possible benefits for bull bison as a result of this study.  The tolerance bull bison currently encounter in Montana is not enough, but there is also no evidence suggesting that any data gathered from these studies would encourage Montana to show more tolerance for bull bison in the state.
*  Due to the lack of evidentiary support for reasons to conduct the proposed studies, and the impact on bull bison involved in the study I request that this study be dissolved in its entirety.

6.	Undisclosed information concerning the chemical to be use for immobilization and reversal.

*  The specific chemical to be used in these proposed studies should be defined in the EA for the public.  APHIS has failed to provide the information necessary for the public to submit informed comments regarding the chemical’s effect on large game species or specifically bison.  Due to the omission of these substances to be used in the proposed studies I request that the EA be revised to include the chemicals and that the public be given time to review, and comment on the revised EA.  APHIS must provide full disclosure for the chemicals/drugs they intend to use on bull bison for this inappropriate study.

7.	No discussion for contingency plans concerning possible problems with chemical immobilization and reversal of wild bull bison

*  There is no discussion in the EA about the possibilities for unforeseen problems concerning immobilization of wild buffalo in the field and/or chemical reversal miscues.
*  What is APHIS, VS's protocol for bison bulls not going down after a first successful darting with immobilization drugs?
*  What is APHIS, VS's protocol if bison bulls do not respond to initial chemical reversal?
*  What will APHIS, VS's response be if the gathering of fluids takes longer than the 20 minutes proposed in the EA? 
*  What is APHIS, VS's protocol if an unexpected predator or threatened species like grizzly bears enters the area of the proposed study during and or after bison bull have been chemically immobilized?
*  What is APHIS, VS's protocol for unexpected physical and/or psychological problems that may manifest in bull bison after chemical reversal?
*  What are the protocols for APHIS, VS if an adequate amount of data cannot be gathered by the end of the 2011 migration, as outline in the EA?  Are there plans now or will APHIS, VS create such plans to extend the proposed studies where there is insufficient data gathered?
*  Although these issues are likely to arise during the course of these proposed studies the public should be aware of APHIS, VS's plan to mitigate potential risks to its researchers and bull bison from said unexpected events.  For these reasons I request that the EA be revised to include such protocols and possibilities and the public be given time to review and comment on the revisions.

In closing, I feel strongly that this Environmental Assessment is poorly thought out, dangerous to bison bulls and other wild bison, lacking information and permission, and completely unwarranted.  APHIS also seems to have attempted to sneak this Environmental Assessment through without proper notification to the public, which leads me to believe your intentions seriously lack integrity.  Therefore, I request formally that APHIS take "No Action" on this proposed EA.

I also request that you add my contact information to your database and inform me of your agency's actions on all issues affecting America's last wild bison population.

I look forward to your response to my comments.

Dr. Brian McCluskey

APHIS Veterinary Services
USDA-APHIS Veterinary Service Area Office
208 North Montana Avenue, Suite 101
Helena, MT 59601
US