No self-sustaining herds of wild plains bison exist on National Forest System lands.

That alarming, eye-opening finding comes from Nancy Warren, the U.S. Forest Service’s Region 2 Threatened, Endangered, and Sensitive Species Program Leader.

Ironically, Warren's finding was made in a new finding withdrawing her recommendation to list American bison as a species of concern. Why?

Because Shoshone National Forest Supervisor Joseph G. Alexander raised his concern that such a listing may conflict with Wyoming’s management scheme. Sound familiar?

As the Custer Gallatin National Forest revises its forest plan, Regional Forester Leanne M. Marten, in coordination with Forest Supervisor Mary C. Erickson, must decide to designate species of conservation concern.

It is the strongest decision that can be made for American bison because the National Forest planning rule requires "a viable population of each species of conservation concern." 36 CFR § 219.9 (2012).

A viable population is one that "continues to persist over the long term with sufficient distribution to be resilient and adaptable to stressors and likely future environments." 36 CFR § 219.19 (2012).

"[A] species of conservation concern is a species, other than federally recognized threatened, endangered, proposed, or candidate species, that is known to occur in the plan area and for which the regional forester has determined that the best available scientific information indicates substantial concern about the species’ capability to persist over the long-term in the plan area." 36 CFR § 219.9(c) (emphasis added).

Warren’s finding bears repeating: not one intact self-sustaining herd of wild American bison can be found on 160 million acres of National Forest lands in the western United States.

Without clear direction classifying American bison as a species of conservation concern, and enforceable standards to provide habitat and diversity, the next forest plan cannot be relied upon to ensure the viability and persistence of the migratory species on the Custer Gallatin National Forest.

The strongest shared comment we can make is for Regional Forester Leanne M. Marten to list American bison as as species of conservation concern in Region 1.

Just as importantly, Regional Forester Leanne M. Marten must provide a reasoned response to the evidence presented in public comment in support of listing American bison as a species of conservation concern.

Substantial evidence has already been submitted, more will be forthcoming. The evidence must be officially addressed in a reasoned response. Ask for it in your comments.

As you may have heard, last year the Custer Gallatin National Forest told the public they stopped evaluating and do not consider American bison a species of conservation concern.

That announcement, made at a packed wall to wall forest plan meeting in Bozeman, Montana, provoked an overwhelmingly disagreeable response from the people in attendance. The unanimity of the public’s negative reaction surprised me. The people know.

Stand your ground. Lead with the strongest comment you can make for American bison.

The American bison residing in Yellowstone are a living monument and the only representative intact population of the wildlife species remaining in the wild.

American bison deserve more than recognition as a species of conservation concern. Much more.

Nitsíniiyi’tak, Pidamaya, Thank you.

Darrell Geist, habitat coordinator
Buffalo Field Campaign