| In
1995, the World Heritage Committee of the United Nations Educational,
Scientific and Cultural Organization, declared Yellowstone
National Park as a World Heritage Site in Danger due to threats
to park bison, water quality, cutthroat trout, inadequacy
of park roads, overuse by tourists, and from mining activities
beyond park borders. In 2003, Yellowstone was removed from
the in “Danger” list because of “considerable
efforts” made by the National Park Service to address
the threats. Though the Committee felt the park was no longer
in “danger,” it asked the National Park Service
to provide progress reports on the original threats.
Last month, the Yellowstone National Park released a draft
of its fourth progress report. In it, the National Park Service
trumpets the success of its 2000 Interagency Bison Management
Plan describing it as a “carefully crafted consensus-based
plan” that “has now been successfully implemented
for seven years.” The National Park Service explains
that the plan is “incremental” and that it “becomes
more wildlife-friendly … with each incremental success
achieved.”
Such claims are not just inaccurate, they are blatantly deceptive
intended only to placate the Committee while avoiding the
truth. The Interagency Bison Management Plan has been an abject
failure resulting in the unnecessary killing of nearly 2,100
bison since its inception. The bison are needlessly hazed
and harassed, shot, and captured and slaughtered because approximately
half of the herd have been exposed to Brucella abortus –
the bacterium the causes brucellosis. To prevent the transmission
of brucellosis from bison to cattle, bison who approach or
cross Yellowstone’s northern and western boundaries
are targeted for removal. The fact that there has never been
a confirmed case of bison transmitting the bacteria to cattle
under natural conditions, that no cattle are grazed adjacent
to the western boundary of the park during the winter and
spring when bison migrate, or that only pregnant female bison
pose even a theoretical risk of transmission has not prevented
the National Park Service from participating in the wholesale
harassment and slaughter of bison, including bulls, calves,
yearlings, and non-pregnant females since 2000.
The Interagency Bison Management Plan is a politically motivated
plan designed to placate livestock agencies and allied industries
while discounting the will of the public - an overwhelming
majority of whom strongly opposed the government’s plan
- and ignoring the best available scientific evidence and
sound ecological principles for managing native wildlife species.
Though allegedly based on the concept of adaptive management,
the state and federal agencies, including the National Park
Service, have failed to make any substantive adaptations to
the plan despite growing evidence of the park being home to
two or more genetically distinct subpopulations and/or that
the risk of bacteria transmission (if any risk exists) is
infinitesimally small. Indeed, the National Park Service has
never even assessed the actual risk of transmission fearing
that the results would demonstrate – as they would –
that the death toll of over 4,000 bison since 1985 was unnecessary.
It’s slaughter of bison is also entirely inconsistent
with NPS policies which require the preservation of natural
wildlife abundances and distributions and the protection of
“the full range of genetic types of animal populations
by perpetuating natural evolutionary processes and minimizing
human interference with evolving genetic diversity.”
Moreover, though the Interagency Bison Management Plan is
based on a three step approach under which bison management
was to be minimally less aggressive over time, the plan is
hopelessly stuck on step 1 even after eight years of implementation
and several years after the National Park Service claimed
step 3 would be in place.
Buffalo Field Campaign calls on all Buffalo Soldiers to set
the record straight and to tell the National Park Service
to tell the truth to the World Heritage Committee. Don’t
let the National Park Service continue to hide behind its
deceptive rhetoric and lie to the Committee about the threats
that the IBMP poses to Yellowstone bison. The National Park
Service is currently accepting comment on its draft report
to the Committee.
Comments should be sent, telefaxed, or e-mailed to:
Ms. Suzanne Lewis, Superintendent
Yellowstone National Park
P.O. Box 168
Yellowstone National Park, WY 82190-0168
Telefax: (307) 344-2005
E-mail: suzanne_lewis@nps.gov
The comment deadline is January 25, 2008
so please act soon. If you send your comment by e-mail make
sure to include in the subject line “Comments on Draft
World Heritage Committee Report” so that your comments
are not missed.
If possible, please send a copy of your comment letter to
Buffalo Field Campaign (P.O. Box 957, West Yellowstone, MT,
59758; Telefax: (406) 646-0071; e-mail: bfc-media@wildrockies.org)
so that we can compile all comments and send them directly
to the World Heritage Committee.
If you would like to read a copy of the 9-page draft report
to the Committee it is available at http://www.nps.gov/yell/planyourvisit/world-heritage-committee-report.htm.
When submitting your comments please consider making the following
points. Alternatively, feel free to copy and use the attached
letter though, if possible, spend a few minutes to personalize
your letter.
1. The Interagency Bison Management Plan
is a politically motivated plan designed to placate cattle
interests while ignoring the vast majority of the public who
believe that America’s last wild bison, not cattle,
should be given precedence on public lands surrounding Yellowstone
National Park.
2. There has never been a confirmed case
of brucellosis transmission from bison to cattle under natural
conditions making the entire basis of the IBMP invalid.
3. The National Park Service has participated
in the unnecessary slaughter of nearly 2,100 bison since 2000
and over 4,000 bison since 1985 despite no concrete evidence
of a transmission risk or, even if a risk is theoretically
possible, no proof that the risk is anything more than extraordinarily
remote.
4.
There are no cattle grazing on lands adjacent to Yellowstone
National Park’s western border during the winter removing
any justification for harassing and killing bison.
5. Even if there were a risk of transmission,
this risk is limited to pregnant bison making the slaughter
of bison bulls, calves, yearling, and non-pregnant females
entirely unnecessary and augmenting the need for a credible
transmission risk analysis which the National Park Service
has consistently avoided for over twenty years.
6. The National Park Service has grossly
failed to adapt the Interagency Bison Management Plan in response
to new information including evidence of two or more genetically
distinct bison subpopulations in the park and further proof
that the risk of bacteria transmission is virtually nonexistent
(if any risks exists) as the bacterium is quickly killed as
environmental conditions change in the spring.
7. The Interagency Bison Management Plan
is hopelessly stuck in step 1 eight years after implementation
and many years since step 3 was supposed to be in place demonstrating
the inadequacy of the plan and providing ample justification
for a new plan based on the best available scientific evidence.
8. Considering that the entire Interagency
Bison Management Plan was based on the desire to protect approximately
2,200 cows (a number which has now declined to 1,500), it
is an enormous waste of bison lives and millions of taxpayer
dollars every year.
9. The Interagency Bison Management Plan
represents a direct and unnecessary threat to Yellowstone’s
bison and must be replaced with a plan that focuses on cattle
-who originally infected the bison with brucellosis - and
which closes high-risk public grazing allotments, mandates
cattle vaccination, pays ranchers to remove cattle from their
private lands or requires cattle ranchers to fence in their
cattle to avoid direct contact with bison.
10. Stop misleading the World Heritage Committee
and start telling them the truth about bison management in
Yellowstone National Park.Sample LetterJanuary 2008
SAMPLE LETTER TO SUZANNE LEWIS
Ms.
Suzanne Lewis, Superintendent
Yellowstone National Park
P.O. Box 168
Yellowstone National Park, WY 82190
Dear Ms. Lewis:
I am writing to ask you to tell the truth to the World Heritage
Committee about the ongoing threats to Yellowstone’s
bison posed by the Interagency Bison Management Plan. I understand
that the National Park Service will soon submit an update
to the Committee about the ongoing threats to Yellowstone
and I am concerned that the report’s assessment of threats
to Yellowstone’s bison is inaccurate and deceptive.
Contrary to the report’s findings, the Interagency Bison
Management Plan has not been “successfully implemented
for seven years.” The Interagency Bison Management Plan
has been an abject failure succeeding only in the unnecessary
slaughter of nearly 2,100 bison since its implementation.
It has been hopelessly stuck on step 1 with no indication
that any progress is being made. Though it is ostensibly an
adaptive management plan, to date its all been about management
with virtually no substantive adaptation. The National Park
Service, for example, hasn’t altered the plan at all
despite increasing evidence of two or more genetically distinct
bison subpopulations in the park or in response to studies
documenting the limited persistence of the Brucella abortus
bacteria under changing environmental conditions as winter
turns to spring. Don’t you think the World Heritage
Committee should be advised that the National Park Service
is intentionally ignored such new scientific evidence while
continuing to participate in the inhumane and unnecessary
hazing and killing of Yellowstone’s bison?
The Interagency Bison Management Plan was also not “carefully
crafted” or a “consensus-based plan” as
characterized in the draft report. It was a politically motivated
plan with its outcome based on a need to placate the livestock
agencies and their industry allies while discounting the will
of the people and ignoring the best available scientific evidence.
As you know, there has never been a confirmed case of brucellosis
transmission from bison to cattle under natural conditions
and even if transmission were theoretically possible, only
pregnant females could possible transmit the bacteria. Even
pregnant female bison can’t transmit the bacteria to
cattle if no cattle are present as is the case during winter
on public and private lands adjacent to Yellowstone’s
western border. Yet, the National Park Service routinely participates
in the capture and slaughter of bison bulls, yearlings, calves,
and non-pregnant females who pose absolutely no risk of transmission.
The fact that any transmission risk is, at best, extraordinarily
remote, begs for a comprehensive assessment of transmission
risk – an analysis that the National Park Service has
purposefully avoided for two decades in fear of the results.
It is imperative that the World Heritage Committee is advised
of these facts and that the National Park Service tell the
Committee why it has ignored multiple requests to engage in
a risk analysis.
There is nothing about the Interagency Bison Management Plan
that is “wildlife friendly” as it sole purpose
is to unnecessarily mistreat and slaughter bison for the sole
benefit of the cattle industry and in violation of National
Park Service policies. Its focus on bison is entirely misplaced
and the cost to taxpayers of the plan’s ongoing implementation
to protect approximately 1,500 cows is outrageous.
For these reasons and because the plan is stuck on step 1,
it is clear a new plan, a more rational and scientifically
sound plan, must be developed. Such a plan should focus on
the few cattle who are grazed in areas used by bison and should
place the burden on the rancher to protect his cattle instead
of constantly harassing and killing Yellowstone’s bison.
Refocusing the plan onto cattle makes sense considering that
cows originally infected bison with brucellosis and since
managing cattle is far easier and more appropriate than manipulating,
mismanaging, and killing America’s largest, genetically
pure, and truly wild remaining herd of bison. By mandating
cattle vaccination against brucellosis, closing public allotments
of concern, paying ranchers not to run cattle on private lands
and/or requiring their cows to be fenced in, the National
Park Service and its cooperating agencies can ensure that
Yellowstone’s bison are not threatened by agency mismanagement.
Such actions will allow the National Park Service to provide
the World Heritage Committee with real reason to heap praise
on the National Park Service instead of accepting the Committee’s
praise on making progress based on deception and lies.
Sincerely,
Your
Name
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