Buffalo Field Campaign- A Concept Paper for a New Direction for the Bovine Brucellosis Program

To whom it may concern:

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. Please consider these concerns we have about APHIS’ proposal to continue done the failed path of brucellosis eradication in the Greater Yellowstone Area.

We are commenting on a 14-page document, dated September 2009. We understand this is Document ID: APHIS-2009-005-002. Please also add us to any future mailings about this proposal.

We find this proposal to be a serious threat to wildlife, especially wild ungulates, of the Greater Yellowstone Ecosystem. We support the concept of a Greater Yellowstone Designated Surveillance Area and support proposals for more intensive management of livestock to prevent disease transmission. However, we believe the vague proposals for controlling and eliminating brucellosis in wildlife of the Greater Yellowstone Ecosystem are impracticable if not impossible. They are also unacceptable to the public of Montana, particularly to hunters.
It is irresponsible to imply that Brucella can be eradicated from wildlife, especially elk, of the Greater Yellowstone Area without providing any details of how such an eradication program would be conducted or confronting the costs in dollars and in lost wildlife with associated recreational and commercial values. We note that while the document includes a program objective of “protecting the national livestock herd”; there is no mention of protecting our treasured national wildlife values.

There are about 100,000 elk in the Greater Yellowstone Area, perhaps more, along with numerous other wild mammals. About 10,000 elk calves are produced annually. These are wild animals roaming over an immense remote area of both public and private lands. Much of this land is inaccessible except on foot. Given the number, inaccessibility, wariness and turnover of this population, how can APHIS conceive of delivering vaccinations, contraceptives, or a lethal dose to all the elk in the GYA? Moreover, how will treated animals be marked, so that efforts aren’t applied multiple times to the same animal? What will this endless and no doubt unsuccessful program cost? We contend a thorough economic and environmental analysis of this proposal is warranted before APHIS makes a final decision.

We find it disappointing that the document does not specifically mention the elk feedgrounds in Wyoming and Idaho and the bison feedground in Montana at Stephens Creek. We are also disappointed there was no discussion about the potential habitat solutions in Montana, Idaho and Wyoming. Feedgrounds facilitate high levels of Brucella infection in elk and other wildlife. If you intend to decrease the prevalence of Brucella infection in wildlife these feedgrounds should be eliminated and habitat solutions should be embraced for native ungulates and other wildlife in the GYA.

Thank you for this opportunity to comment on this APHIS concept paper.

Sincerely,

Glenn Hockett
Volunteer President, Gallatin Wildlife Association