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West Yellowstone, Montana
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slaughter of Yellowstone's wild free roaming buffalo

Total Yellowstone
Buffalo Killed
Since 1985
7,842
(past counts)

Yellowstone Bison Slaughter
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Yellowstone Bison Quarantine Plan
Press Release - 3/23/10
Groups File Suit to Protect Quarantined Bison & Public Trust Lawsuit Seeks to Secure Public Access to Bison and Prevent Privatization of Calves

Bison calves held in quarantine facility
40
(122 killed) FAQ
Video: Why Yellowstone Buffalo Should Not Go To Turner
People in Charge of the Bison Quarantine

Joe Maurier, Director
Montana Fish, Wildlife and Parks
1420 E. 6th Ave., P.O. Box 200701
Helena, MT 59620-0701
(406) 444-3186 phone
(406) 444-4952 fax
jmaurier@mt.gov

Dr. Jack Rhyan
USDA APHIS Veterinary Services
National Wildlife Research Center
4101 LaPorte Avenue
Fort Collins, CO 80521
(970) 266-6000
(970) 266-6032 fax
Jack.C.Rhyan@usda.gov

Montana Fish, Wildlife and Parks Commissioners have final say on translocation of bison.
They can be contacted by email: fwpcomm@mt.gov

District 1 - Bob Ream, Chairman, 521 Clarke Street, Helena, MT 59601 (406) 461-3202
District 2 - Dan Vermillion, Vice-Chairman, PO Box 668, Livingston, MT 59047 (406) 222-0624
District 3 - Ron Moody, Commissioner, 109 Bach Avenue, Lewistown, MT 59457 (406) 538-2698
District 4 - A.T. Stafne, Commissioner, PO Box 1027, Poplar, MT 59255 (406) 768-2300
District 5 - Shane Colton, Commissioner, 335 Clark, Billings, MT 59101 (406) 259-9986
Public Comments on Quarantined Buffalo

Appeal of Montana Department of Fish, Wildlife, and Parks (FWP) Decision To Transfer Phase IV Quarantine Feasibility Study Bison to Turner Enterprises, Inc., Robert Hoskins (Word document,100kb)
Buffalo Field Campaign comments (PDF, 164kb)
Buffalo Field Campaign supplemental comments (PDF, 585kb)
GravelBar comments (PDF, 118kb)
Helena Hunters and Anglers Association comments (PDF, 120kb)
Paul Richards and Conservation Congress comments (PDF, 120kb)
Summer Nelson comments (PDF,344 kb)
Background

National Park Service_ Permit to USDA APHIS to use captured bison from Stephens Creek for a quarantine study (PDF, 7.1MB)
Bison Quarantine Feasibility Study Q & A
(PDF, 48kb)
Aune and Rhyan_A Proposed Feasibility Study of Bison Quarantine Procedures (PDF, 504kb)
Yellowstone National Park_Transfer of Surplus Bison under the IBMP (PDF, 81.9kb )
USDA_ History and Status of the Bison Quarantine Feasibility Study (PDF, 44kb)

News Articles

Turner bid for Yellowstone bison draws protest - 1/08/10
Ted Turner gets OK for Yellowstone bison on ranch- 12/03/09
Yellowstone bison could go to Turner's Mont. ranch- 11/10/09

Analysis and Decision Docs

APHIS Bison State and Federal Test Reports, BFC FOIA Request, Incomplete Info (PDF, 148kb)
APHIS Bison Quarantine Appointment Books, BFC FOIA Request, Incomplete Info (PDF, 68kb)
Bison Quarantine Feasibility Study Summary, 2011 (PDF, 324kb)
History & Status of the Bison Quarantine Feasibility Study, April 2009 (PDF, 44kb)
Memorandum of Understanding Between Montana, Fish, Wildlife, and Parks, Montana Department of Livestock, and Turner Enterprises, Inc.
(PDF, 288kb)
Bison Quarantine_Phase IV Bison Translocation Draft EA December 2009 (PDF, 954kb )
Montana Fish Wildlife & Parks_REQUEST FOR PROPOSALS November 2009 Disposition of Quarantine Facility Bison (PDF, 38.5kb)
Montana Fish Wildlife & Parks_REQUEST FOR PROPOSALS August 2009 Disposition of Quarantine Facility Bison (Word Document, 58kb)
Bison Quarantine_Phase IV Bison Translocation Decision Notice March 09 (PDF, 492kb)
Bison Quarantine_Phase IV Bison Translocation Final EA March 09 (PDF, 660kb)
Bison Quarantine_Phase IV Bison Translocation EA Feb 09 (PDF, 960kb)
BISON QUARANTINE_FEASIBILITY STUDY First Status Report June 06 (Word Document, 64kb)
Bison Quarantine_Phase II & III Decision Notice June 06 (PDF, 2.9MB)
Bison Quarantine_Phase II & III Feasibility Study Dec 05 (PDF, 1.3MB)
Bison Quarantine_Phase II & III Scoping Notice 2005 (Word Document, 40kb)
Bison Quarantine_Phase I Decision Notice Jan 05 (PDF, 236kb)
Bison Quarantine_Phase I Preliminary EA Oct 2004 (PDF, 268kb)

Talking Points for Phase I & II

Buffalo Field Campaign Written Comments

Summary: The topic of quarantine in relation to Yellowstone buffalo has received significant attention in recent years, particularly in the past few months. USDA’s Animal and Plant Health Inspection Service (APHIS), with assistance from the MT Department of Fish, Wildlife and Parks (FWP), has recently approved the first phase of a quarantine feasibility study. The study involves taking 100 buffalo calves captured under the Interagency Bison Management Plan when the population of the Yellowstone herd numbers more than 3000. At least half the buffalo will be slaughtered and culture tested for brucellosis. The remaining buffalo will be held over for phase two, which is expected to be similar in nature. If any buffalo remain after phase two, they will enter phase three, the calving phase. More buffalo will be slaughtered and tested. If any buffalo remain, they may be placed at their final release site to be held behind a fence for one more year and then finally released as “wild” buffalo. The buffalo will be held in a 400-acre facility for phase one. They will be periodically tested for brucellosis and artificially fed as necessary. Future phases of the study will occur at similar sites. While this is not the only possible scenario for quarantining Yellowstone buffalo, it is the only one currently under consideration by APHIS. APHIS has not prioritized the development of alternative diagnosis tools for brucellosis or potential novel treatments for the disease. Further, AHPIS has adamantly objected to tribal involvement in the quarantine process.

Problems with quarantine of Yellowstone Buffalo:
1. Genetics: The Yellowstone buffalo herd is unique. Yellowstone buffalo are the only buffalo with a continuous history of being wild and unfenced. They are genetically unique, exhibiting the highest level of genetic diversity of all buffalo in the world. Actions which remove a very specific segment of the Yellowstone herd will have drastic impacts on the genetic diversity of targeted subpopulations. Specifically, the APHIS plan calls for removing 80 female buffalo calves and 20 male calves on an annual basis. While no analysis has been conducted on the impacts to this specific population, it is likely that such a removal will constitute a 50% reduction in female calves that have survived their first winter. Because selection will also include the slaughter of sero-positive calves and only involve those that migrate out of Yellowstone, the specific impact on the subpopulation from which the test subject calves derive will be devastating to the future of that subpopulation.

2. Domestication: Quarantine of the extent proposed by APHIS for Yellowstone buffalo is not consistent with standard wildlife management practices. Quarantine periods of short duration have been used with other species with some success and with significant impacts to the quarantined animals once released. The type of quarantine proposed is specifically a technique for domestic livestock. The quarantined buffalo will be subjected to human handling throughout the process and will receive supplemental feed. They will be isolated from other members of the herd from which they learn the techniques necessary for survival in the wild. They will be exposed only to other buffalo in their age class and will lose the family structure characteristic of wild animals. Breeding will occur in captivity with male buffalo that will not compete for breeding rights, thus disturbing the natural selectivity and behavior that would be exercised in the wild. Quarantine, captive breeding, and artificial feeding will cause a breakdown of family structure, unnatural breeding patterns, and a general loss of skills learned from natural settings and seasonal migration. In short, the buffalo that survive quarantine will be much like domestic buffalo and therefore will not benefit species conservation. They will be like other captive herds, which would make a more suitable population for such programs.

3. Purpose and Need: Quarantine has been proposed for Yellowstone buffalo in the context of a need to control population growth and to promote restoration of buffalo to other areas. However, population pressures are due to artificial constructs. The target population of 3000 buffalo for Yellowstone National Park is not based on the ecological carrying capacity of the park. Further, if winter range habitat is extended for the buffalo, the potential for greater populations of buffalo will be greatly expanded. If those extensions of habitat are consistent with migratory patterns, it is possible for buffalo to naturally move to areas currently considered for the placement of quarantined buffalo. Management plans to address the risk of brucellosis transmission could be developed for the new areas to insure the retention of Montana’s brucellosis class free status.

4. Native American Tribes: Native American tribes, who have a vested interest in the restoration of buffalo to tribal lands, have not been included in the planning and development of buffalo relocation proposals. Tribal reservation lands present the best possible scenario for buffalo relocation programs because as sovereign nations, the tribes have a greater ability to manage land use to be consistent with the principles of quarantine without the need for the domesticating influence of small heavily regulated pastures and artificial feed.
Conclusion: Quarantine is an inappropriate tool for Yellowstone buffalo. The genetic uniqueness and historical significance of Yellowstone buffalo requires that management decisions be carefully considered and thoroughly evaluated. Quarantine of the nature proposed is exclusively suited for domestic animals and is not consistent with accepted wildlife conservation practices. Quarantine that focuses on specific population segments, age, and sex classes will have a drastic effect on the genetic diversity of the buffalo. Such selection will compromise the future of the buffalo that remain in Yellowstone and will not succeed in creating other herds with the cherished characteristics of the Yellowstone buffalo. The need for invasive population management and relocation of buffalo should be discussed in the context of expanded habitat options in the Greater Yellowstone Area. Native American tribes must be involved in the development and implementation of buffalo restoration projects. Respect for the sacred nature of Yellowstone buffalo must be at the forefront of decisions determining their future.

Email your comments to BisonQuarantineEA@mt.gov or

Send them to Bison Quarantine EA,
Montana Fish, Wildlife and Parks
P.O. Box 200701,
Helena, MT 59620-0701;
Fax: 406-444-4952.
 
Talking Points for Quarantine EA Phases II and III
The Final Environmental Impact Statement (FEIS) for the Interagency Bison Management Plan (IBMP), to which the agencies have tiered the quarantine EA is inadequate in its discussion of the long-term impacts of a large scale quarantine program on the remaining population of bison in and around Yellowstone National Park. Additionally, circumstances surrounding bison management have changed dramatically from the expectations of the IBMP after five years of implementation. Most importantly, habitat that is supposed to be currently available for bison is still denied and bison are currently being captured and will be slaughtered because of this failure. Quarantine, according to the FEIS is supposed to be a tool for use when socially acceptable conditions have been met. The current structure of bison management is woefully inadequate to provide for the long-term future of free-roaming wild bison within and surrounding Yellowstone National Park. In other words, the preliminary conditions for pursuing a plan to quarantine bison have not been met. The agencies must focus attention on reorganizing the IBMP to reflect the current situation. Rather, with this plan, the agencies are moving full steam ahead with some aspects of the Plan while ignoring the most important issues for the future of wild free-roaming bison in the Greater Yellowstone Area. As much as 5 million dollars will be spent on this quarantine experiment over the next 6 years. This money and associated resources could be better spent resolving land use conflicts to gain sufficient habitat for the current population of bison making one of the supposed needs for quarantine obsolete.

The desire to pursue this quarantine experiment will influence the agencies decisions as to capturing bison, particularly on the western boundary where the agencies have primarily used hazing over the past three years instead of the massive capture operations that will be required to fill the quarantine facility. The process began last spring as the Montana Dept. of Livestock (MDOL) captured nearly 200 wild buffalo, sending 96 to slaughter, in order to attain 17 brucellosis test negative calves for quarantine. This number was later reduced to 14 because three of the bison later tested positive for the bacteria. Therefore, to achieve the desired 100 calves in each of two years of the experiment, the agencies will capture thousands of wild buffalo, sending at least half to slaughter. Once captured, the agencies could choose to send all bison except those quarantined to slaughter as is currently the case with operations at the north boundary. While the agencies claim that the quarantined bison would otherwise be slaughtered, the truth is that the there is room for flexibility in the IBMP as evidenced by the operations in the western boundary area in 2003 and 2004 when relatively few bison were captured and slaughtered even though the herd exceeded the target population of 3,000.

The justification for implementing the quarantine experiment is that the population currently exceeds 3,000, the IBMP target. However, this number is entirely arbitrary and is supposed to be subject to the adaptive management process. 3,000 is supposedly the number of bison that the agencies can manage effectively for spatial and temporal separation between wild bison and domestic cattle that may graze in the area. However, since implementation of the IBMP in 2001, the population has remained consistently over 3,000 and there has been no concern expressed by the agencies about managing for temporal and spatial separation. Additionally, the definition of temporal separation is subject to the adaptive management process, yet modifications based on the latest science have still not been considered. Montana still retains its brucellosis free status and there is no current threat to that classification based on the population of bison in and around Yellowstone National Park. In other words, the supposed need for quarantine is unjustified based on a review of the current situation.

The Phase II facility description in the preferred alternative specifies a total pasture area of 60 acres for 50 captive two-year old bison. According to the description, the acreage will be divided with 25 bison housed in a 30-acre pen for at least one full year. This constitutes cruel and inhumane treatment on its face and is a far cry from the 400-600 acres originally described in the scoping process for bison quarantine that began in 2003. The agencies claim that this site is most appropriate precisely because of its small scale. The originally planned Phase II site at Daily Lake is much larger but garnered criticism from elk hunters because the land was originally purchased as elk winter range and may interfere with elk migrations. The agencies have entirely sacrificed the minimal well being of the quarantined bison by choosing this miniscule site.

Analysis in the FEIS for the IBMP of bison quarantine does not discuss impacts significant to the human environment beyond a cursory discussion of the economic impact on Native American tribes of receiving live bison. Even this discussion is not relevant to the current proposal because of the restriction on using quarantined bison for commercial uses outlined throughout the environmental review process. Neither does the purpose and need section adequately analyze bison quarantine. The requirement established in the FEIS to “initiate separate NEPA analysis to determine the location, design, and operation of such a facility” (p194) does not satisfy the intention of NEPA to fully analyze significant impacts to the human environment. Therefore, the required level of analysis is a complete Environmental Impact Statement of the entire bison quarantine protocol. Additionally, while certain components of this project are considered experimental and may not have long-term impacts, the fact remains that bison that finish the experimental protocol will be relocated outside the GYA and will be used to found additional bison herds. There are significant long-term impacts both on the bison currently residing in the GYA and to the overall conservation effort for bison in North America.

The agencies should conduct a full Environmental Impact Statement for the full scope of bison quarantine. According to 40 CFR 1508.25, the scope of the analysis should include all phases of bison quarantine from the assembling of bison calves in phase 1 to the placement of certified brucellosis negative bison outside the GYA, including the implications of a successful quarantine protocol on the remainder of the bison population within the GYA. Segmentation of the analysis of this program masks the significant impacts on the human environment and ignores the cumulative impacts of this undertaking.
 
Bison Quarantine EA
Montana Fish, Wildlife and Parks
PO Box 200701
Helena, MT 59620-0701
Fax: 406-444-4952

4/14/05
Dear Reviewer:
Please accept the following comments on the proposal to develop phases 2 and 3 of a bison quarantine feasibility study on behalf of the Buffalo Field Campaign and myself.

The primary issues that are of concern with the continuation of a quarantine feasibility study involve:
1. The humane treatment of bison throughout the process of capture, handling, and transport of bison from YNP and the facility design and handling procedures in the various facilities.
2. The domestication of bison that “graduate” from the study for release.
3. The impacts of removing seronegative bison calves that might otherwise be released on the dynamics of bison herds within the Park and in surrounding areas.
4. The potential for quarantine to be used as an excuse to continue with the intensive management actions of the IBMP rather than employ the adaptive mechanisms of the Plan that might allow for greater tolerance of untested bison in an expanded range.
5. The lack of a corresponding process of NEPA compliance from APHIS.
6. The overall cost of the project and the lack of a cost/benefit analysis of alternative means to expand the range of YNP bison.

HUMANE TREATMENT
The current methods employed by the Montana Deptartment of Livestock and cooperating agencies for capturing, testing and transporting bison lack a concern for the well being of bison in general and demonstrate the need for a specific protocol for the humane treatment of bison as wildlife. Current practices cause significant and unnecessary stress on captured animals. Operations typically involve running bison at an aggressive pace for more than ten miles to the Duck Creek trap using snowmobiles, horses, ATV’s, helicopters and cracker rounds. The bison enter the facility in fear and are then subjected to intensive handling by livestock agents who appear to demonstrate a particular zeal in using aggressive livestock techniques including excessive use of “hot shot” cattle prods and overhead activity. The FEIS for the IBMP discusses humane treatment techniques that would minimize stress and injury to bison in capture facilities. Montana Livestock agents at the Duck Creek facility and NPS agents at Stephen’s Creek have blatantly disregarded these recommendations and continue to treat captured bison inhumanely in the facilities. While there are currently no laws to protect wild bison from inhumane treatment, there is a legal basis for humane treatment of bison in research and quarantine facilities. If bison captured at Duck Creek and Stephen’s Creek are bound for quarantine, then the Animal Welfare Act should apply from the initial handling of the bison and throughout the process of quarantine. The current facilities at Duck Creek and Stephen’s Creek are not sufficient to guarantee the well being of bison. Many bison are injured in the facilities, (one bison died awaiting transport at the Stephen’s Creek facility due to injuries sustained in captivity) the design of both facilities contributes to both stress and injury, agents are not trained or certified to handle wild bison in the facilities according to a protocol for humane treatment standards, no independent review of the Duck Creek facility has been allowed by the agencies while bison are captive, and a comprehensive and enforceable standard for humane treatment of bison in handling facilities has not been established or implemented.

Details of quarantine facility design at Brogans and Dome Mountain should be made available to the public. An independent review of the facilities should be conducted and recommendations implemented before any bison are placed in facilities. Both facilities should be openly accessible to the media and independent observers to ensure humane treatment of bison. The facilities and protocol for transport and handling of bison should be in compliance with the Animal Welfare Act and should be made available to the public for review. Modifications to both the Duck Creek and Stephen’s Creek facilities should be made to reduce stress and injury to captive bison. An independently reviewed and enforceable protocol for the humane treatment of bison should be developed and implemented if quarantined bison will be processed through the Stephen’s Creek and Duck Creek facilities. The Duck Creek facility should be openly accessible to the media and independent observers to ensure humane standards of handling. Hazing practices should be independently reviewed and modified to reduce stress on captured bison.

DOMESTICATION OF QUARANTINED BISON
The current protocol for quarantining captured bison from YNP targets only seronegative long calves. These bison will be between the ages of nine months and one year of age when they are captured. Some of them, especially those whose mothers are not pregnant may still be nursing when captured. Bison typically stay with their family group until at least two years of age. Female bison will remain with their family groups indefinitely. Young bison gain a wealth of experience from their elders. The dynamics of the herd are learned and established primarily in the second and third years as bison mature in the presence of the rest of herd. Younger bulls learn mating rituals through competition with older bulls and patterns are established that may continue throughout the life of a particular buffalo to the benefit of the rest of the herd through natural selection. Bison in Yellowstone National Park, while certainly familiar with humans, are not typically handled by humans and demonstrate a level of wildness that is unknown in comparison to other genetically pure bison. It has taken the bison in Yellowstone many years to recover their wild character compromised by previous handling and captivity before 1967. Some bison, particularly those in the Pelican Valley, have never been handled by humans, giving Yellowstone bison their unique position among all other herds.

Captured and quarantined calves will not have developed into their full nature as wild animals before their captivity. Breeding in the wild is an integral part of the natural behavioral patterns developed by bison over tens of thousands of years. Past activity that has compromised this wild nature should not be used as an example for the development of programs that further erode the wildness of the bison. It has taken a long time for the bison in YNP to recover from the invasive human activities of the past. Many of the past activities when viewed with hindsight were clearly misguided. The only reason that brucellosis exists in GYA wildlife is due to the forced captivity of bison in the Park and poor decisions of managers. The addition of bison to YNP at the turn of the twentieth century is hardly something that should be looked at with pride. A hands off approach at that time would have eventually led to a disease free herd of truly wild and pure bison that exhibited the particularly unique genetic characteristics that bison in the GYA had before human intervention. If lessons are to be leaned from the past, they should be that of caution and the exercise of restraint in intervening in the natural patterns of wild animals.

The bison that will “graduate” from the quarantine feasibility study cannot be considered “wild” animals upon their release. It will take generations before they will exhibit any resemblance to the wild bison of YNP. In fact, they may never truly redevelop a wild character without exposure to bison that have not been through the protocol. There is an ancient wisdom to the bison in YNP because of their connection to the wild days of old. These intensively handled, relocated bison will lose this natural connection and their sense of place in unfamiliar surroundings.

IMPACTS ON THE POPULATION DYNAMICS OF THE YELLOWSTONE HERD

Current operation of the IBMP includes the testing and release of seronegative bison in addition to the slaughter of seropositives. The removal of seronegative calves from the population for quarantine along with the slaughter of seropositive calves is resulting in the removal of an entire age class from the subpopulation of bison that are migrating outside Park borders. If capture activities intensify over the coming months, it is entirely possible that long calves will be removed from a subpopulation of nearly 500 bison. The elimination of this age class will have negative impacts on the dynamics of the affected subpopulation. Analysis of this impact on the specifically affected subpopulation should be analyzed before this activity continues and intensifies. The slaughter of all captured buffalo based on the target population of 3000 bison should not be used as a justification or a reason to exclude this analysis from the discussion. The fact is that current operations do allow for the release of seronegative bison and therefore the impacts of removing long calves from the population should be analyzed.

IMPACTS ON FUTURE MANAGEMENT OPTIONS WITHIN THE GYA
The addition of quarantine to the current management scheme under the IBMP may have significant impacts on the possibility of adapting the Plan to accommodate a larger population of bison that can roam freely in an expanded range within the GYA. Acquisition of additional habitat in the northern and western boundary areas, the removal of grazing leases on public lands, the incorporation of new science on the transmissibility of brucellosis between bison and cattle, a recalculation of the target population, and the redefinition of the necessary size and period of spatial and temporal separation are all factors that may lead to greater tolerance of untested bison in the GYA. If the IBMP ever advances to stage three, there will be a level of untested bison tolerated in the northern and western boundary areas. The achievement of a “successful” quarantine protocol may lead to the desire for capture operations that would otherwise not be conducted in stage three. If there is a desire to provide bison for quarantine, then it will be necessary to continue capturing, testing and slaughtering bison that may otherwise roam freely.

APHIS NEPA COMPLIANCE
The categorical exclusion claimed by APHIS to avoid NEPA analysis of the quarantine feasibility study is not consistent with the intent of the National Environmental Policy Act. The proposed study is not simply a research project with no long-term impacts. If all of the bison were slaughtered and cultured and the project was discrete, then the research exemption might apply. However, some bison presumably will be relocated outside the GYA at the end of the protocol. Therefore, for all intents and purposes, the proposed study is the beginning of quarantining and relocating bison from YNP and should be reviewed in its entirety, including the long-term impacts on the human environment of relocating bison from YNP. Additionally, Montana Fish, Wildlife and Parks should expand the current analysis to look at the entirety of the proposal and conduct an Environmental Impact Statement on all aspects of quarantine.

COST/BENEFIT ANALYSIS
A comprehensive cost/benefit analysis of the quarantine proposal as compared to other means by which the range of YNP bison might be expanded and population pressures reduced should be conducted by FWP as part of this process. Due to the detailed formulation of costs associated with the quarantine protocol and the efforts made by FWP to acquire land specifically to accommodate phase three, an analysis of habitat acquisition within the GYA that may expand the current range of bison migrating into Montana should be conducted. An analysis of the benefits in establishing populations of “non-wild” bison on ranges outside the GYA should be analyzed in relation to the benefits of protecting and expanding the range of wild bison within GYA.

CONCLUSION
I encourage FWP to consider the above factors in creating a NEPA compliant document relative to the addition of phases two and three to the quarantine feasibility study. There are significant impacts to the environment that should be analyzed in relation to the overall scope of the project. Additional information should be provided by FWP in order for the public to adequately analyze the impacts of quarantine. FWP should create a NEPA document that is inclusive of the entire quarantine protocol including the future impacts on the remaining bison in the GYA if the protocol is “successful” and implemented on a larger level. The analysis should include a discussion of how quarantine will impact the possibilities of other adaptations to the IBMP that may provide for more tolerance and an expanded range for untested bison within the GYA. A cost/benefit analysis of the project at this stage should be conducted based on the overall cost in relation to alternative means to accomplish some of the same goals outlined in the proposal. FWP should encourage APHIS to fully participate in the NEPA process openly and with regard to the overall impacts of the proposal.

Thank you for your consideration of the above concerns with relation to the continuation of the quarantine feasibility study. Please accept these comments for the record and keep me informed on all decisions and documents relevant to bison quarantine.

Respectfully submitted,
 

Joshua Osher
Buffalo Field Campaign

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