Yellowstone Bison: Interagency Plan and Agencies' Management Need
Improvement to Better Address Bison-Cattle Brucellosis		 
Controversy (07-MAR-08, GAO-08-291).				 
                                                                 
Federal and Montana state agencies have long been entangled in	 
controversy over bison leaving Yellowstone National Park. Some of
these bison, as well as elk and other wildlife, have a contagious
disease called brucellosis, which can cause pregnant animals to  
abort. Montana livestock owners and government officials fear	 
that if bison are allowed to leave the park, the disease could	 
spread to cattle, potentially threatening the economic health of 
the state's livestock industry. To help manage this issue, three 
federal and two state agencies have been implementing a bison	 
management plan that they agreed to in 2000. This report	 
discusses (1) the progress made in implementing the bison	 
management plan and (2) the plan's soundness and the		 
effectiveness of the agencies' implementation of it for managing 
bison-related issues in and near Yellowstone National Park. GAO  
reviewed documentation and research on bison and brucellosis and 
interviewed federal and state officials and key stakeholders.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-291 					        
    ACCNO:   A81263						        
  TITLE:     Yellowstone Bison: Interagency Plan and Agencies'	      
Management Need Improvement to Better Address Bison-Cattle	 
Brucellosis Controversy 					 
     DATE:   03/07/2008 
  SUBJECT:   Animal diseases					 
	     Animal welfare					 
	     Cattle						 
	     Disease control					 
	     Federal/state relations				 
	     Infectious diseases				 
	     Interagency relations				 
	     Livestock						 
	     Livestock products 				 
	     National parks					 
	     Schedule slippages 				 
	     Wildlife conservation				 
	     Wildlife management				 
	     Zoonotic diseases					 
	     Program goals or objectives			 
	     Yellowstone National Park (WY)			 

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GAO-08-291

   

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Report to Congressional Requesters: 

United States Government Accountability Office: 

GAO: 

March 2008: 

Yellowstone Bison: 

Interagency Plan: 

and Agencies' Management Need Improvement to Better Address Bison- 
Cattle Brucellosis Controversy: 

GAO-08-291: 

GAO Highlights: 

Highlights of GAO-08-291, a report to congressional requesters. 

Why GAO Did This Study: 

Federal and Montana state agencies have long been entangled in 
controversy over bison leaving Yellowstone National Park. Some of these 
bison, as well as elk and other wildlife, have a contagious disease 
called brucellosis, which can cause pregnant animals to abort. Montana 
livestock owners and government officials fear that if bison are 
allowed to leave the park, the disease could spread to cattle, 
potentially threatening the economic health of the stateï¿½s livestock 
industry. To help manage this issue, three federal and two state 
agencies have been implementing a bison management plan that they 
agreed to in 2000. 

This report discusses (1) the progress made in implementing the bison 
management plan and (2) the planï¿½s soundness and the effectiveness of 
the agenciesï¿½ implementation of it for managing bison-related issues in 
and near Yellowstone National Park. GAO reviewed documentation and 
research on bison and brucellosis and interviewed federal and state 
officials and key stakeholders. 

What GAO Found: 

The federal and state agencies implementing the interagency bison 
management plan have made less progress than they originally 
anticipated. These agenciesï¿½the U.S. Department of Agricultureï¿½s Animal 
and Plant Health Inspection Service and Forest Service; the Department 
of the Interiorï¿½s National Park Service; Montana Fish, Wildlife and 
Parks; and the Montana Department of Livestockï¿½had expected to progress 
to step two of the three-step plan by winter 2002ï¿½2003. Each of the 
planï¿½s three successive steps for managing bison is intended to 
incrementally increase tolerance of bison roaming outside the park. As 
of late 2007, however, the agencies remained in step one because they 
have yet to meet two important conditions for moving to step twoï¿½first, 
that no cattle graze on a ranch north of the park, and second, that a 
safe and effective remote brucellosis vaccine-delivery system be 
available for bison. Nevertheless, the agencies have completed a number 
of other tasks called for in the plan, including maintaining the 
separation of bison and cattle in space and time and conducting some 
scientific research. Combined, the agencies have spent more than $2 
million annually implementing the plan, with the federal government and 
state agencies funding about 95 percent and 5 percent of these 
expenditures, respectively. The agencies have no estimate regarding how 
long it will take to meet the conditions for starting step two, nor 
have they revised their estimated dates for reaching step three, which 
was expected by winter 2005ï¿½2006. 

Key deficiencies in the plan, and the agenciesï¿½ implementation of it, 
limit their effectiveness with regard to managing bison-related issues. 
The plan has two broadly stated goals: to ï¿½maintain a wild, free-
ranging population of bison and address the risk of brucellosis 
transmission.ï¿½ The plan, however, contains no clearly defined, 
measurable objectives as to how these goals will be achieved, and the 
partner agencies have no common view of the objectives. As a result, 
the agencies have no way to determine the effectiveness of the plan or 
of their management efforts. Also, in developing the plan, the agencies 
adopted an adaptive management approach that promotes flexible decision 
making in the face of uncertainties as outcomes from management actions 
and other events become better understood. But the agencies have not 
adequately implemented adaptive management, in that they (1) have not 
established critical linkages among clearly defined objectives (which 
are absent from the plan), information about the impacts of their 
management actions obtained through systematic monitoring, and 
decisions regarding adjustments they make to the plan and their 
management actions; (2) have continued to act more as individual 
entities, rather than as a cohesive interagency group; and (3) have not 
adequately communicated with or involved key stakeholders, such as 
conservation groups, livestock industry groups, and private landowners. 
Consequently, their decision making more often resembles trial and 
error than adaptive management and also lacks accountability and 
transparency. 

What GAO Recommends: 

GAO is recommending that Agriculture and Interiorï¿½with the Montana 
state agenciesï¿½improve their accountability, transparency, and 
management of Yellowstone bison by developing measurable objectives and 
reporting yearly on progress, among other actions. The agencies, except 
for Montana Fish, Wildlife and Parks that provided no comments, 
generally concurred with GAOï¿½s recommendations. 

To view the full product, including the scope and methodology, click on 
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-08-291]. For more 
information, contact Robin M. Nazzaro at (202) 512-3841 or 
[email protected] 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Agencies Have Made Less Progress Than Anticipated in Implementing the 
Interagency Bison Management Plan: 

Key Deficiencies in the Plan, and the Agencies' Implementation of It, 
Limit Their Effectiveness with Regard to Managing Bison-Related Issues: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Comments from the Department of Agriculture: 

Appendix III: Comments from the Department of the Interior: 

Appendix IV: Comments from the Montana Department of Livestock: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Table: 

Table 1: Estimated Annual Bison Management Expenditures (Unadjusted for 
Inflation), by Agency, Federal Fiscal Years 2002-2007: 

Figures: 

Figure 1: The Greater Yellowstone Area: 

Figure 2: Estimated Population of Yellowstone Bison since 1901: 

Figure 3: Bison Management Zones Specified in the Interagency Bison 
Management Plan and Related Bison Migration Patterns: 

Figure 4: The Adaptive Management Process: 

Figure 5: Estimated Annual Federal and State Bison Management 
Expenditures (Unadjusted for Inflation), Federal Fiscal Years 2002- 
2007: 

United States Government Accountability Office: 

Washington, DC 20548: 

March 7, 2008: 

The Honorable Nick J. Rahall, II: 
Chairman: 
Committee on Natural Resources: 
House of Representatives: 

The Honorable Maurice D. Hinchey: 
House of Representatives: 

Long symbolic of the vastness of North America's plains, American 
buffalo, or bison, today roam freely only in a few places, including 
Yellowstone National Park. The park lies at the heart of the Greater 
Yellowstone Area, which overlaps portions of Idaho, Montana, and 
Wyoming and encompasses two national parks, six national forests, and 
several national wildlife refuges and wilderness areas. Outside the two 
national parks, privately owned lands are interspersed throughout these 
federal lands, including the Royal Teton Ranch, which, as we previously 
reported, has been a focus of federal land conservation efforts near 
the park since the late 1990s.[Footnote 1] The park's herd--which has 
grown from fewer than 25 bison in 1901 to nearly 5,000 animals as 
estimated in late summer 2007--is the largest free-ranging bison herd 
in the United States and one of the few U.S. herds that show no 
evidence of genetic mixing with cattle. As their population has grown 
and they have roamed beyond the park's boundaries onto surrounding 
private and public lands in Montana, Yellowstone bison have been at the 
center of a controversy that has raged for more than two decades. 

Throughout the winter and early spring, tens, sometimes hundreds, of 
bison move naturally between Yellowstone National Park and adjacent 
public and private lands, some of which may also be used by livestock 
owners to graze cattle. Some of the bison, as well as elk and other 
wildlife in and around the park, harbor a contagious and untreatable 
disease, brucellosis, which can cause pregnant animals to abort their 
calves. Fears of this disease and differing wildlife management 
philosophies have contributed to the long-running controversy. 
Specifically, many ranchers and some of the federal and state officials 
responsible for brucellosis management believe that if wildlife poses a 
disease transmission risk to cattle, it is the diseased wildlife that 
should be the focus of management efforts. Some conservationists, in 
contrast, argue that ranchers and government agencies should strengthen 
disease mitigation and management efforts within the livestock 
industry, such as limiting livestock grazing on national forest lands 
near the park, vaccinating cattle, or improving fencing of cattle 
herds. Moreover, while brucellosis-infected bison and elk in Montana 
both present a risk to the cattle industry, bison have historically 
been subject to strict disease-control measures, including slaughter 
when they attempt to leave the national park, whereas elk--which have a 
lower incidence of brucellosis but are more numerous than bison--are 
allowed to roam with relatively few restrictions. No known cases of 
brucellosis transmitted from bison to cattle have been documented in 
the wild and some conservationists point to this fact to suggest that 
current bison management actions are unnecessary. In contrast, 
Montana's State Veterinarian maintains that this absence of 
documentation does not indicate a low risk of transmission, but rather 
provides evidence that the various park boundary control programs to 
manage Yellowstone bison have been effective. Furthermore, Montana 
livestock owners and government officials fear that if such a 
transmission did occur, the economic consequences to the state's 
livestock industry could be devastating. A brucellosis infection 
identified in a single cattle herd in Bridger, Montana, in May 2007 
underscored rancher's fears. While the source of the infection has not 
been determined, the Montana Department of Livestock indicated that the 
infection was unlikely to have come from bison. 

In an effort to begin defusing this controversy, five federal and state 
agencies--the Forest Service and the Animal and Plant Health Inspection 
Service (APHIS), within the U.S. Department of Agriculture; the 
National Park Service (Park Service), within the Department of the 
Interior; and Montana Fish, Wildlife and Parks as well as the Montana 
Department of Livestock--agreed in the early 1990s to develop a joint, 
long-term bison management strategy. Under different mandates and 
authorities, these agencies all have some jurisdiction over the bison 
management effort. The Park Service is responsible for resources--both 
habitat and wildlife--within the park's boundaries. Outside the park in 
Montana, the Forest Service manages habitat on national forest lands, 
while the state's Fish, Wildlife and Parks is responsible for managing 
habitat on some state-owned lands and wildlife on all lands, including 
national forest lands. In addition, because of concern over the risk 
that brucellosis-infected bison may pose to the livestock industry, the 
Montana state legislature in 1995 granted the Department of Livestock 
the authority to take certain actions on public or private land with 
respect to bison originating from the park, including removing or 
destroying them. APHIS is responsible for controlling and preventing 
the spread of communicable and contagious diseases of livestock, 
including brucellosis. Since APHIS first instituted a national 
brucellosis control program in 1934, billions in federal, state, and 
industry funds have been spent trying to eradicate the disease from 
cattle across the nation. As of February 2008, APHIS announced that for 
the first time in the 74-year history of the brucellosis control 
program, all 50 states have been declared brucellosis free. 

Efforts to develop a long-term bison management strategy in the early 
1990s were slow, largely because of the five agencies' differing 
wildlife management philosophies. The Park Service opposed efforts to 
manage bison in any way that would restrict the animals' ability to 
roam freely and thereby go against the park's policy to manage wildlife 
by natural regulation--a policy that allows factors such as climate, 
food supply, and predation to regulate most wildlife populations in the 
park. During that period, however, APHIS, which is committed to 
eradicating brucellosis in the United States, argued that wildlife 
should be tested for exposure to the disease and, if infected, 
slaughtered to prevent its spread. In 1995, Montana sued the Park 
Service and APHIS, fearing that the federal agencies' conflicting 
wildlife management policies might cause APHIS to downgrade the 
brucellosis classification of Montana's livestock, which has been 
certified since 1985 to be free of brucellosis. Under APHIS's 
brucellosis eradication program, a classification downgrade could 
result in significant economic consequences to both individual herd 
owners and the state. For example, a downgrade could restrict the 
state's livestock producers' access to interstate and international 
markets. To settle Montana's lawsuit, the federal and state governments 
agreed to develop interim bison management procedures and an 
environmental impact statement for managing bison long term.[Footnote 
2] In 1996, the agencies began implementing an interim bison management 
plan, which resulted from the settlement agreement. After four more 
years of mediated negotiations--nearly a decade after joint planning 
efforts began--an interagency bison management plan for the Yellowstone 
bison was agreed upon by the five federal and state partner agencies in 
December 2000.[Footnote 3] 

The agreed-upon plan includes three successive steps for managing bison 
on the northern and western boundaries of Yellowstone National Park in 
areas to which some bison typically attempt to migrate in the winter 
and early spring. The plan's two stated purposes, or goals, are to 
"maintain a wild, free-ranging population of bison and address the risk 
of brucellosis transmission to protect the economic interest and 
viability of the livestock industry in Montana." Although managing the 
risk of brucellosis transmission from bison to cattle runs throughout 
the bison management plan and the plan's outlined management actions 
demonstrate the agencies' long-term commitment toward eventually 
eliminating brucellosis in Yellowstone bison, the plan itself does not 
seek to eliminate brucellosis in bison. Instead, through its successive 
management steps, it aims to create and maintain separation between 
bison and cattle in space and time that is sufficient to minimize the 
risk of brucellosis transmission. Ultimately, each step of the plan is 
intended to incrementally increase tolerance for bison to roam outside 
the park. For example, under step two, up to 100 bison testing negative 
for exposure to brucellosis will be allowed to migrate to a bison 
management zone outside the park's northern boundary, where they are 
prohibited before step two is reached. When step three is fully 
implemented, the same number of bison will be allowed to pass into this 
same zone but will not have to be tested beforehand. Even under step 
three, however, the plan calls for management actions, including 
driving bison toward the park's interior (hazing),[Footnote 4] and 
capturing those that do not remain inside to prevent more than 100 
bison from exiting the park into this bison management zone. The 
captured bison testing positive for brucellosis would be sent to 
slaughter while the bison testing negative may be returned to the park, 
sent to a bison quarantine facility, sent to slaughter, or removed for 
approved research. 

Given the uncertainties regarding brucellosis and bison behavior at the 
time that the partner agencies were crafting their bison management 
plan, the agencies adopted an adaptive management approach--one that 
would allow them to modify the plan as better information became 
available through scientific research and operational experience. 
According to adaptive management experts, this approach enables 
managers to operate in the face of uncertainty and to learn by doing, 
thereby leading to improved understanding and more-effective management 
over time.[Footnote 5] In principle, learning in an adaptive management 
setting involves systematically testing--either operationally, 
scientifically, or both--different management alternatives to gain 
knowledge. The alternatives are developed on the basis of the best 
information available at the time, and, as management proceeds, 
techniques that do not work are modified or replaced by others. 
Adaptive management shares a number of key features with best 
management practices--such as those articulated in the Government 
Performance and Results Act of 1993 and the Comptroller General's 2004 
forum on high-performing organizations[Footnote 6]--including 
identifying clearly defined, measurable, and results-oriented 
management objectives; designing and implementing a monitoring plan; 
making decisions based on management objectives; effectively managing 
partnerships while maintaining accountability to Congress and the 
public; and actively involving key stakeholders over time to engender 
public support. 

In this context, this report discusses (1) the progress made in 
implementing the interagency bison management plan and (2) the 
soundness of the plan and the effectiveness of the agencies' 
implementation of it with regard to managing bison-related issues in 
the Greater Yellowstone Area. 

To address these objectives, we interviewed officials from the Park 
Service; Forest Service; APHIS; Montana Fish, Wildlife and Parks; and 
the Montana Department of Livestock to obtain information about the 
progress the agencies have made in implementing the interagency bison 
management plan. We collected and reviewed available documentation of 
agency management practices, accomplishments, and expenditures related 
to bison and brucellosis management and recent scientific research on 
various topics related to brucellosis and wildlife, including the 
safety and effectiveness of brucellosis vaccines and available tools 
for diagnosing the disease. To obtain a wide range of perspectives on 
the federal and state agencies' implementation of the plan, we also 
interviewed numerous individuals from key stakeholder constituencies, 
including conservationists, livestock industry representatives, local 
ranchers, permittees of public livestock grazing allotments, Native 
American tribes, hunting enthusiasts, lessees of private land, and 
other private landowners. Appendix I presents a more detailed 
description of our objectives, scope, and methodology. We conducted 
this performance audit from January 2007 through March 2008 in 
accordance with generally accepted government auditing standards. Those 
standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Results in Brief: 

Since the interagency bison management plan took effect in 2000, the 
partner federal and state agencies have made less progress than they 
anticipated in implementing the plan. Each successive step of the three-
step plan details various management actions that are intended to 
incrementally increase tolerance for bison roaming outside the park. As 
of December 2007, the agencies remained in step one of the plan, even 
though they had expected to move to step two of the plan by winter 2002-
2003. The agencies have yet to meet two important conditions for 
advancing to step two. First, before step two may begin, the plan 
requires that cattle no longer graze in the winter on lands north of 
the park belonging to the Royal Teton Ranch; as of December 2007, 
negotiations between Montana Fish, Wildlife and Parks and ranch owners 
to end cattle grazing on these lands were still in progress. Second, 
the plan requires development of a safe and effective remote 
brucellosis vaccine-delivery mechanism for bison allowed in the West 
Yellowstone area. The Park Service expects to release its evaluation of 
remote delivery methods for use within the park for public comment in 
summer 2008. Although the partner agencies remain in step one, they 
have carried out a number of other tasks called for in the plan. For 
example, the agencies have implemented management actions to keep bison 
separate from cattle in space and time; conducted some scientific 
research on brucellosis; verified the safety of a brucellosis vaccine 
in bison, and vaccinated a limited number of bison calves and yearlings 
on a limited basis; and taken steps to ensure the vaccination of all 
cattle within certain areas close to the park's northern and western 
boundaries. Since 2002, the federal and state partner agencies have 
spent more than $2 million annually to implement the plan, with the 
federal government and state agencies funding about 95 percent and 5 
percent of these expenditures, respectively. Meanwhile, according to 
partner agency officials, the agencies have no estimated time frame for 
completing the remaining two conditions for moving into step two of the 
plan or for reaching step three, which they had expected to reach by 
winter 2005-2006, leaving the expected date for full implementation of 
the plan unknown. 

Key deficiencies in the plan, and the agencies' implementation of it, 
limit the agencies' effectiveness in managing bison-related issues. 
According to general best management practices and adaptive management 
principles, clearly defined, measurable objectives are needed to 
provide a sound basis for selecting and monitoring management actions, 
triggering changes to those actions, and determining the effectiveness 
of the plan. The plan, however, does not have clearly defined, 
measurable objectives, and the partner agencies share no common view of 
the objectives. In fact, several agency officials acknowledged that no 
metrics or parameters have been identified for measuring how well the 
agencies are meeting the plan's stated goals. In addition, the partner 
agencies have not fully implemented an adaptive management approach 
because they (1) have not established critical linkages among clearly 
defined objectives (which are absent from the plan), information about 
the impacts of their management actions obtained through systematic 
monitoring, and decisions regarding adjustments they make to the plan 
and their management actions; (2) have continued to operate more as 
individual entities than a cohesive interagency group; and (3) have not 
adequately communicated with or involved key stakeholders. 

We recommend that the Secretaries of Agriculture and the Interior 
direct the federal partner agencies to work with their state agency 
partners to improve the management of bison in and near Yellowstone 
National Park by, for example, clearly defining measurable objectives, 
and to enhance the agencies' collaboration and accountability to the 
public on this issue, including annually reporting on the agencies' 
progress. 

We provided the federal departments of Agriculture and the Interior and 
Montana's Fish, Wildlife and Parks and Department of Livestock a draft 
of this report for review and comment. In written comments, the 
Department of Agriculture, the Department of the Interior, and the 
Department of Livestock generally agreed with our conclusions and 
recommendations (see apps. II, III, and IV, respectively). Montana 
Fish, Wildlife and Parks provided no comments on our report. 

Background: 

The greater Yellowstone region covers about 20 million acres 
overlapping Idaho, Montana, and Wyoming. Commonly called the Greater 
Yellowstone Area, Greater Yellowstone Ecosystem, or just Greater 
Yellowstone, the region is home to numerous species of wildlife, 
including bison. It encompasses two national parks--Yellowstone and 
Grand Teton--as well as several other federally managed areas, 
including the Gallatin, Custer, Shoshone, Bridger-Teton, Caribou- 
Targhee, and Beaverhead national forests; the National Elk Refuge; and 
the John D. Rockefeller, Jr., Memorial Parkway. Privately owned lands, 
including the Royal Teton Ranch north of Yellowstone National Park and 
west of the Yellowstone River, are interspersed throughout these 
federal lands, and a number of towns dot the landscape (see fig. 1). 
The Greater Yellowstone Area has also earned the distinction, according 
to APHIS, of being the nation's last known reservoir of the brucellosis 
bacterium, Brucella abortus, which is present in the region's bison and 
elk populations. 

Figure 1: The Greater Yellowstone Area: 

This figure is a map of the greater Yellowstone area. 

[See PDF for image] 

Source: GAO image developed from National Park Services data. 

[End of figure] 

Bison, which are native to the Greater Yellowstone Area, were observed 
by early travelers both before and after Yellowstone National Park was 
created in 1872. Bison hunting and poaching in the late 1800s 
substantially diminished the Yellowstone herd, and, by 1901, fewer than 
25 animals remained (see fig. 2). To save this wild herd from 
extinction, park managers in 1902 imported 21 bison from captive herds 
in Texas and Montana. Although the wild and captive herds were 
initially kept separate, they began to intermingle between 1915 and 
1920, and after the 1920s, little or no effort was made to keep the two 
populations separate. By the 1930s, the park's wintering bison had 
increased to more than 1,000 head, and the park began managing the herd 
by shipping animals to public parks, zoos, and privates estates around 
the country. From the 1920s through the late 1960s, the bison herd was 
managed through culling, supplemental feeding, and other activities 
until the park instituted a policy of natural regulation of wildlife 
populations, whereby a species' population size is left to respond to 
environmental conditions like climate or food supply without human 
interference. By the early 1980s, the bison herd had grown to more than 
2,300 head, and bison were increasingly reported moving beyond the 
park's boundaries into Montana. During the mid-1980s through 1999, a 
total of 3,176 bison that crossed outside the park's northern or 
western boundaries were killed, under a series of park boundary area 
management approaches implemented by the Park Service and Montana. 
Since 2000, boundary area management action by federal and state agency 
officials have lethally removed more than 1,900 bison, but the herd has 
continued to grow, with nearly 4,700 head counted in late summer 2007. 

Figure 2: Estimated Population of Yellowstone Bison since 1901: 

This figure is a combination line and bar graph placed over a 
photograph of grazing bison. The line represents bison counted 
(estimated population), and the bars represent bison removed. In the 
graph, the X axis represents the year, and the Y axis represents the 
number of bison. 

Year: "1901"; 
Bison counted (estimated population): 44; 
Bison removed: 0. 

Year: 1901; 
Bison counted (estimated population): 47; 
Bison removed: 1. 

Year: 1901; 
Bison counted (estimated population): 51; 
Bison removed: 7. 

Year: 1901; 
Bison counted (estimated population): 74; 
Bison removed: 0. 

Year: 1901; 
Bison counted (estimated population): 79; 
Bison removed: 0. 

Year: 1901; 
Bison counted (estimated population): 84; 
Bison removed: 2. 

Year: 1901; 
Bison counted (estimated population): 95; 
Bison removed: 1. 

Year: 1901; 
Bison counted (estimated population): 118; 
Bison removed: 5. 

Year: 1901; 
Bison counted (estimated population): 149; 
Bison removed: 3. 

Year: 1901; 
Bison counted (estimated population): 168; 
Bison removed: 2. 

Year: 1901; 
Bison counted (estimated population): 192; 
Bison removed: 28. 

Year: 1901; 
Bison counted (estimated population): 215; 
Bison removed: 8. 

Year: 1901; 
Bison counted (estimated population): 243; 
Bison removed: 0. 

Year: 1901; 
Bison counted (estimated population): 270; 
Bison removed: 4. 

Year: 1901; 
Bison counted (estimated population): 348; 
Bison removed: 18. 

Year: 1901; 
Bison counted (estimated population): 397; 
Bison removed: 11. 

Year: 1901; 
Bison counted (estimated population): 451; 
Bison removed: 0. 

Year: 1901; 
Bison counted (estimated population): 504; 
Bison removed: 46. 

Year: 1901; 
Bison counted (estimated population): 501; 
Bison removed: 17. 

Year: 1920; 
Bison counted (estimated population): 602; 
Bison removed: 7. 

Year: 1920; 
Bison counted (estimated population): 647; 
Bison removed: 56. 

Year: 1920; 
Bison counted (estimated population): 748; 
Bison removed: 14. 

Year: 1920; 
Bison counted (estimated population): 789; 
Bison removed: 0. 

Year: 1920; 
Bison counted (estimated population): 830; 
Bison removed: 109. 

Year: 1920; 
Bison counted (estimated population): 931; 
Bison removed: 23. 

Year: 1920; 
Bison counted (estimated population): 1008; 
Bison removed: 41. 

Year: 1920; 
Bison counted (estimated population): 1057; 
Bison removed: 58. 

Year: 1920; 
Bison counted (estimated population): 1109; 
Bison removed: 106. 

Year: 1920; 
Bison counted (estimated population): 1124; 
Bison removed: 132. 

Year: 1920; 
Bison counted (estimated population): 1078; 
Bison removed: 0. 

Year: 1920; 
Bison counted (estimated population): 1032; 
Bison removed: 0. 

Year: 1920; 
Bison counted (estimated population): 986; 	
Bison removed: 0. 

Year: 1920; 
Bison counted (estimated population): 939; 
Bison removed: 0. 

Year: 1920; 
Bison counted (estimated population): 893; 
Bison removed: 0. 

Year: 1920; 
Bison counted (estimated population): 847; 
Bison removed: 109. 

Year: 1920; 
Bison counted (estimated population): 674; 
Bison removed: 17. 

Year: 1920; 
Bison counted (estimated population): 755; 
Bison removed: 25. 

Year: 1920; 
Bison counted (estimated population): 811; 
Bison removed: 67. 

Year: 1920; 
Bison counted (estimated population): 868; 
Bison removed: 3. 

Year: 1940; 
Bison counted (estimated population): 809; 
Bison removed: 213. 

Year: 1940; 
Bison counted (estimated population): 869; 
Bison removed: 202. 

Year: 1940; 
Bison counted (estimated population): 964; 
Bison removed: 11. 

Year: 1940; 
Bison counted (estimated population): 747; 
Bison removed: 407. 

Year: 1940; 
Bison counted (estimated population): 932; 
Bison removed: 0. 

Year: 1940; 
Bison counted (estimated population): 791; 
Bison removed: 238. 

Year: 1940; 
Bison counted (estimated population): 876; 
Bison removed: 0. 

Year: 1940; 
Bison counted (estimated population): 960; 
Bison removed: 237. 

Year: 1940; 
Bison counted (estimated population): 1126; 
Bison removed: 0. 

Year: 1940; 
Bison counted (estimated population): 1094; 
Bison removed: 228. 

Year: 1940; 
Bison counted (estimated population): 1035; 
Bison removed: 0. 

Year: 1940; 
Bison counted (estimated population): 976; 
Bison removed: 250. 

Year: 1940; 
Bison counted (estimated population): 1227; 
Bison removed: 0. 

Year: 1940; 
Bison counted (estimated population): 1477; 
Bison removed: 139. 

Year: 1940; 
Bison counted (estimated population): 1350; 
288. 

Year: 1940; 
Bison counted (estimated population): 1258; 
373. 

Year: 1940; 
Bison counted (estimated population): 843; 
273. 

Year: 1940; 
Bison counted (estimated population): 821.5; 
12. 

Year: 1940; 
Bison counted (estimated population): 800; 
44. 

Year: 1940; 
Bison counted (estimated population): 800; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 869; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 975; 
Bison removed: 148. 

Year: 1960; 
Bison counted (estimated population): 819; 
Bison removed: 370. 

Year: 1960; 
Bison counted (estimated population): 821; 
Bison removed: 6. 

Year: 1960; 
Bison counted (estimated population): 388; 
392. 

Year: 1960; 
Bison counted (estimated population): 226; 
Bison removed: 54. 

Year: 1960; 
Bison counted (estimated population): 397; 
Bison removed: 3. 

Year: 1960; 
Bison counted (estimated population): 418; 
Bison removed: 4. 

Year: 1960; 
Bison counted (estimated population): 556; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 592; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 565; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 713; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 837; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 873; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 1068; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 1125; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 1252; 	
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 1626; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 1727; 
Bison removed: 0. 

Year: 1960; 
Bison counted (estimated population): 1803; 
Bison removed: 0. 
	
Year: 1980; 
Bison counted (estimated population): 2396; 
Bison removed: 0. 

Year: 1980; 
Bison counted (estimated population): 2239; 
Bison removed: 0. 

Year: 1980; 
Bison counted (estimated population): 2160; 
Bison removed: 0. 

Year: 1980; 
Bison counted (estimated population): 2229; 
Bison removed: 0. 

Year: 1980; 
Bison counted (estimated population): 2217; 
Bison removed: 88. 

Year: 1980; 
Bison counted (estimated population): 2291; 
Bison removed: 57. 

Year: 1980; 
Bison counted (estimated population): 2433; 
Bison removed: 6. 

Year: 1980; 
Bison counted (estimated population): 2644; 
Bison removed: 35. 

Year: 1980; 
Bison counted (estimated population): 3159; 
Bison removed: 569. 

Year: 1980; 
Bison counted (estimated population): 2606; 
Bison removed: 4. 

Year: 1980; 
Bison counted (estimated population): 3178; 
Bison removed: 14. 

Year: 1980; 
Bison counted (estimated population): 3426; 
Bison removed: 271. 

Year: 1980; 
Bison counted (estimated population): 3304; 
Bison removed: 79. 

Year: 1980; 
Bison counted (estimated population): 3551; 
Bison removed: 5. 

Year: 1980; 
Bison counted (estimated population): 3956; 
Bison removed: 427. 

Year: 1980; 
Bison counted (estimated population): 3398; 
Bison removed: 433. 

Year: 1980; 
Bison counted (estimated population): 3436; 
Bison removed: 1084. 

Year: 1980; 
Bison counted (estimated population): 2105; 
Bison removed: 11. 

Year: 1980; 
Bison counted (estimated population): 2239; 
Bison removed: 94. 

Year: 1980; 
Bison counted (estimated population): 2444; 
Bison removed: 0. 

Year: 2000; 
Bison counted (estimated population): 2949; 
Bison removed: 6. 

Year: 2000; 
Bison counted (estimated population): 3283; 
Bison removed: 202. 

Year: 2000; 
Bison counted (estimated population): 4045; 
Bison removed: 244. 

Year: 2000; 
Bison counted (estimated population): 4195; 
Bison removed: 280. 

Year: 2000; 
Bison counted (estimated population): 4215; 
Bison removed: 115. 

Year: 2000; 
Bison counted (estimated population): 5015; 
Bison removed: 998. 

Year: 2000; 
Bison counted (estimated population): 3889; 
Bison removed: 66. 

Year: 2000; 
Bison counted (estimated population): 4694; 
Bison removed: 0. 

[See PDF for image] 

Source: GAO analysis of National Park Service data; photo GAO. 

[End of figure] 

Bison, as well as wildlife such as elk, may carry the bacterial disease 
brucellosis, which is also contagious to humans and domestic animals. 
Known in humans as undulant fever, brucellosis can be hard to diagnose 
because early symptoms, such as intermittent fever and joint pain, are 
shared with several other diseases; although rarely fatal, the disease 
can be debilitating. However, thanks to widespread pasteurization of 
dairy products since the early twentieth century, very few cases of 
undulant fever have occurred in the United States, and the disease 
today poses a risk mainly to hunters, large-animal veterinarians, and 
ranchers. In some animals, including cattle, the disease can cause 
abortions, infertility, reduced milk production, lameness, and swollen 
joints. In the Yellowstone area, bison and elk are the disease's 
principal wildlife hosts. Results of blood tests done by the Park 
Service over the past several decades indicate that about half of the 
Yellowstone bison have been exposed to brucellosis. Some bison may 
develop immunity or have a natural resistance to the disease, while 
other animals may develop recurrent infections and remain carriers and 
a source of exposure and possible infection for other animals. 

The first known case of brucellosis in Yellowstone bison was reported 
in 1917 and is believed to have been transmitted from domestic cattle. 
Transmission occurs primarily through ingestion of infected products of 
birth or abortion. As a result, the risk of transmission is greatest if 
cattle and bison are in each other's presence immediately after 
birthing. Although vaccinating cattle provides some protection, it does 
not eliminate the infection risk, as evidenced since 2004 by instances 
of brucellosis transmission from infected wildlife to vaccinated cattle 
in Idaho and Wyoming. Within the scientific community and among people 
interested in bison management, opinions differ about whether it is 
most appropriate to control or to eradicate the disease. Within the 
regulatory community, however, APHIS officials remain committed to 
establishing the means to suppress and eliminate contagious livestock 
diseases, including brucellosis. 

Although both bison and elk carry brucellosis, the two species are 
managed differently by federal and state agencies. Yellowstone bison 
are subject to strict disease-control measures, ranging from capture 
and vaccination to slaughter, whereas elk herd movements are not 
restricted. Agency officials indicate that this difference in 
management approach stems largely from the lower prevalence of 
brucellosis in elk than in bison, combined with the tendency of elk to 
feed at higher elevations than bison and to calve in isolation, thereby 
lessening the risk of transmission.[Footnote 7] This difference in 
management remains even though there have been multiple suspected elk- 
to-cattle transmissions in recent years in Idaho and Wyoming, some of 
which have been detected through DNA testing; the National Research 
Council reported in 1998 that the risk of transmission from bison to 
cattle was low; and there have been no known cases of brucellosis 
transmitted from bison to cattle in a wild, uncontrolled setting. APHIS 
scientists note, however, that although transmission in the wild is 
difficult to document--particularly given the decades-long effort to 
maintain separation between bison and cattle--controlled tests have 
proven that it is possible for bison to transmit the disease to cattle. 
We reported in 1997 that the extent to which domestic cattle risk 
infection through exposure to diseased bison and elk--either from 
mingling directly with infected wild animals or from using rangeland 
where infected wild animals had previously grazed--was the subject of 
the bison management controversy between the federal and state agencies 
because the risk of such transmission had not been quantified.[Footnote 
8] Scientists and researchers disagreed on even the most basic factors 
influencing the risk of transmission, such as whether studies on cattle 
are applicable to bison. Ten years later, such debates continue. 

To keep bison away from cattle and mitigate the risk of brucellosis 
transmission, the interagency bison management plan describes agency 
activities to restrict bison movement to or through bison management 
zones within or just beyond the park's boundaries near Gardiner, 
Montana, on the north, and near West Yellowstone, Montana, on the west 
(see fig. 3).[Footnote 9] During step one of the three-step plan, bison 
attempting to leave the park on the north side are to be hazed, 
captured, or killed, and a limited number of bison on the west side of 
the park--as many as 100 animals--that test negative for brucellosis 
exposure are allowed to roam in bison management zones outside the 
park. Once this limit on the west side is reached, additional bison 
crossing beyond the western boundary are also to be hazed, captured, or 
killed. The plan states that all captured bison are to be tested for 
brucellosis exposure at capture facilities located on the park's 
northern and western boundaries.[Footnote 10] Partner agency officials 
may take a variety of actions with captured bison testing negative for 
exposure to the disease, including vaccinating and temporarily holding 
them in the northern capture facility for release back into the park or 
removing them for research. Bison that test positive for brucellosis 
exposure are generally to be sent to slaughter. 

Figure 3: Bison Management Zones Specified in the Interagency Bison 
Management Plan and Related Bison Migration Patterns: 

This figure is a map showing the bison management zones specified in 
the interagency bison management plan and related bison migration 
patterns. 

[See PDF for image] 

Source: GAO image developed from National Park Service and Forest 
Service data. 

[End of figure] 

Under both steps two and three of the plan, the majority of bison must 
be prevented from leaving the park, and the few bison that are allowed 
to leave are generally to be restricted and monitored within the bison 
management zones and other management areas. Step two on the park's 
north side will allow up to 100 bison testing negative for brucellosis 
to be released into these bison management zones; pregnant females are 
to be monitored using radio telemetry, and all bison are to be hazed 
back into the park or otherwise removed by April 15 of each year. Under 
step two, on the park's west side, up to 100 bison that have not been 
tested will be allowed to exit the park, and officials are required to 
vaccinate these bison remotely; May 15 is the deadline for all bison to 
be back in the park. Similarly, in step three, an effective remote 
vaccination program must be operating in the park before up to 100 
untested bison will be allowed out of the park into the bison 
management zones on both the north and west sides. However, except in a 
few locations, if more than 100 bison attempt to migrate beyond the 
park's northern and western boundaries, under step three they are to be 
hazed, captured, or killed. Many of the management actions specified in 
step one are to continue indefinitely, even when step three is fully 
implemented. 

A brucellosis outbreak among domestic cattle in Montana would likely 
have the following direct effects: (1) abortion of calves, (2) 
decreased weight gain by calves, (3) delays in calf production, (4) 
increased rates of culling and replacement, and (5) increased testing 
and vaccination costs. Furthermore, the presence of the disease could 
also restrict access by the state's livestock producers to interstate 
and international markets, resulting in potentially severe economic 
impacts, particularly for producers of breeding stock. Under APHIS's 
brucellosis eradication program, if a single herd of livestock becomes 
infected, the infected animals are to be slaughtered, the herd 
quarantined or slaughtered, and the herds in the surrounding area 
tested to ensure that the disease does not spread. If no additional 
infections are found within 24 months, the state may retain its 
brucellosis-free status. If, however, an additional herd were found to 
be infected with brucellosis, the state's classification would be 
lowered, and additional interstate testing requirements would be 
imposed statewide. Because of the increased movement of potentially 
exposed or infected bison out of Yellowstone National Park, some states 
have threatened to require additional testing of any cattle entering 
their states from Montana and Wyoming. Such actions could have 
significant economic consequences to Montana's livestock industry if 
downgrading occurred, similar to those experienced by Idaho and Wyoming 
when their brucellosis certifications were downgraded after outbreaks 
in 2004 and 2005, respectively. By one calculation, Montana officials 
estimated that a downgraded status would have an annual economic impact 
on the state of at least $4 million. However, these officials noted 
that this estimate was likely to be low because they considered only 
the cost of additional testing required for cattle--not other factors, 
such as increased operating costs, impacts on agricultural markets, or 
direct effects on producers. A more complex economic analysis conducted 
for the partner agencies showed potential annual economic impacts of 
the increased testing as high as $16.3 million and, with a potential 
decrease in out-of-state demand, an estimated $9.8 million to $38.8 
million decrease in the price of cattle. 

Faced with complex issues like the bison-cattle brucellosis 
controversy, wildlife and natural resource managers have been 
increasingly encouraged to use an adaptive management approach as a way 
to work within a dynamic natural environment that has become 
complicated by people moving into and development within or near these 
areas. In addition, a move toward accountability and transparency in 
natural resource management, demanded by the general public, has led to 
a growing need for collaborative, structured approaches to decision 
making. Adaptive management emerged in the late 1970s and 1980s as one 
such approach, rooted in parallel concepts found in business and 
science best-management practices. In 2004, the National Research 
Council defined adaptive management as a process that promotes flexible 
decision making in the face of uncertainties, as outcomes from 
management actions and other events become better understood. This 
approach (1) emphasizes collaboration among resource managers, 
researchers, and stakeholders and stakeholder involvement and (2) 
encompasses several closely linked steps, including assessing the 
problem, designing a plan that includes measurable management 
objectives and exploring alternative ways to meet them, predicting the 
outcomes of alternatives and implementing one or more of them, 
monitoring the impacts of the selected management actions, and 
evaluating and using the results to adjust management actions (see fig. 
4). 

Figure 4: The Adaptive Management Process: 

This figure is a flowchart showing adaptive management process. 

From the top, going in a clockwise motion, the text reads: 

Assess problem; 
Design plan to include specific objectives; 
Implement management alternative(s); 
Monitor impacts; 
Evaluate effects of management actions; 
Adjust management actions. 

[See PDF for image] 

Source: GAO analysis of Department of the Interior information. 

[End of figure] 

Although adaptive management has been widely discussed in academic 
literature for decades and has been called for in many resource- 
planning documents and cited by resource managers, it has rarely been 
implemented effectively in practice, according to some experts. In the 
early 1990s, for example, in a plan intended to defuse a bitter 
controversy over the need for habitat for the threatened spotted owl 
and the desire to log old-growth forests in the Pacific Northwest, the 
Forest Service attempted to shift its forest management practices 
toward an adaptive management paradigm, with mixed results. Still, 
adaptive management continues to be viewed as a potentially useful 
decision-making approach for engaging partners collaboratively in 
managing shared natural resources. As recently as 2007, for example, 
the Department of the Interior produced guidelines for adaptive 
management and developed a training program to acquaint its staff with 
its practice and implications.[Footnote 11] 

Agencies Have Made Less Progress Than Anticipated in Implementing the 
Interagency Bison Management Plan: 

The partner federal and state agencies have made less progress in 
implementing the interagency bison management plan than they originally 
anticipated. When the agencies agreed to the plan in December 2000, 
they expected to progress to step two by winter 2002-2003; as of 
December 2007, however, they remain in step one. Specifically, the 
agencies have not yet met two significant conditions for moving into 
step two: first, that no cattle graze on the Royal Teton Ranch north of 
Yellowstone National Park and, second, that a safe and effective remote 
vaccine-delivery mechanism be available. The agencies have, however, 
completed a number of other tasks called for in the plan, including 
management actions to keep bison and cattle separate in space and time; 
some scientific research, such as investigating the persistence of the 
Brucella abortus bacterium in the environment; and additional measures 
to prevent the spread of the disease to livestock. The agencies have 
spent in excess of $2 million annually on plan implementation since 
2002, with the federal government funding at least 95 percent of these 
costs and the state agencies funding the remainder. As of December 
2007, the agencies had no estimate for how long it will take to 
complete the conditions for moving to step two, nor do they have plans 
to revise their estimated dates for reaching step three. 

Agencies Remain in Step One of a Three-Step Plan: 

Although the federal and state partner agencies had anticipated 
progressing to step two on the north and west sides of the park by 
winter 2002-2003, they have not yet met the following two significant 
conditions necessary for doing so: 

* On the park's north side, the remaining condition for moving to step 
two is that cattle no longer graze on the Royal Teton Ranch north of 
the park. A lease agreement to graze cattle on the ranch was set to 
expire in 2002, and when the plan was written, the partner agencies 
expected that no cattle would remain on the ranch after that date. In 
1999, the federal government sought to acquire the ranch's grazing 
rights in perpetuity to keep the land cattle-free, but negotiations 
between the government and ranch owners failed in early 2000 because of 
irreconcilable differences of opinion over the monetary value of those 
rights. Nevertheless, when the plan was finalized later in 2000, the 
requirement that no cattle graze on the ranch remained in the plan as a 
condition for moving to step two. Meanwhile, the ranch owners continued 
to graze cattle on the ranch, and negotiations over removal of these 
cattle did not resume until 2005, when the ranch owners agreed to 
discuss with Montana Fish, Wildlife and Parks a possible deal for the 
grazing rights. According to a Montana Fish, Wildlife and Parks 
official, the parties have tentatively reached agreement on a 30-year 
grazing lease that would remove cattle from the property and provide a 
corridor for a limited number of bison to travel across the ranch in 
winter to access national forest system land north of the ranch. As of 
December 2007, issues needing to be resolved in order for the agreement 
to be finalized included obtaining funding commitments from various 
sources for the tentatively negotiated lease price and determining 
which entity would be responsible for the installation and maintenance 
of the infrastructure, such as fencing and cattle guards, to delineate 
the bison corridor. 

* On the park's west side, progressing to step two is contingent on 
meeting another key condition, the development of a safe and effective 
remote vaccine-delivery mechanism. The Park Service moved toward this 
goal in January 2004, when it established that RB51, a brucellosis 
vaccine originally developed for cattle, was also safe for bison calves 
and yearlings. Once a safe vaccine was identified, the Park Service 
began developing a draft environmental impact statement evaluating 
remote delivery alternatives for a parkwide vaccination program. For 
example, Park Service worked with Colorado State University researchers 
to develop an improved way to encapsulate the brucellosis vaccine in a 
special biobullet that could be remotely administered to bison using 
air rifles. Park Service officials expect to release their draft 
environmental impact statement for public comment in summer 2008. 

Agencies Have Completed a Number of Plan Tasks: 

As of December 2007, the agency partners had completed a number of 
other tasks called for in step one of the plan. For example: 

* In 2002, the agencies established interagency operating procedures 
outlining their respective roles and responsibilities for restricting 
bison to areas generally within or just beyond the park's boundaries. 
Outside the park, the Montana Department of Livestock has the lead 
responsibility for all bison management actions and may request 
assistance from Montana Fish, Wildlife and Parks; the Forest Service; 
APHIS; and the National Park Service. Inside the park, Park Service has 
the lead responsibility for all bison management actions. In November 
2007, the agencies updated these procedures, providing greater details 
regarding responsibilities related to law enforcement, private property 
protection, and media relations, among others. 

* The agencies have also conducted scientific research, such as 
investigating the persistence of the brucellosis-causing bacteria in 
the environment, to better understand transmission risks. Agency 
officials have determined that their findings on the amount of time the 
bacteria remained viable in the environment validated the amount of 
time required by the plan to separate bison and cattle grazing on the 
same lands. Other agency research has included extensive testing to 
identify a safe vaccine for bison and to evaluate the vaccine's risk to 
wildlife other than bison. The results of this research enabled the 
agencies to verify the safety of RB51 for delivery by injection to 
bison calves, and the agencies vaccinated a limited number of calves 
and yearlings (about 120) in 2004 and 2005. According to a park 
official, a team of Park Service researchers also annually collect a 
variety of bison data, including data on survival (especially the 
survival of females and calves), movement patterns on the landscape, 
and estimated population. 

* Two of the partner agencies--APHIS and the Montana Department of 
Livestock--have implemented additional risk mitigation measures 
identified in the plan to prevent the spread of the disease to 
livestock. These measures include ensuring that all vaccination- 
eligible cattle (calves and yearlings) within specific bison management 
zones on the north and west sides of the park have been vaccinated and 
annually testing cattle that graze seasonally in these management zones 
to help monitor and prevent the spread of the disease. According to 
APHIS officials, all ranchers with cattle in the bison management zones 
are in compliance with the vaccination risk mitigation measure, and 
Montana Department of Livestock officials ensure that annual testing is 
completed on cattle that graze seasonally in these zones. 

Partner Agencies Have Spent More Than $2 Million Annually to Implement 
the Plan: 

Since 2002, the partner agencies have spent more than $2 million 
annually implementing plan activities, including bison management 
actions and research (see table 1). Federal funding has exceeded 95 
percent of these annual expenditures and state funding has composed the 
remainder (see fig. 5). National Park Service and APHIS expenditures 
make up most of the federal spending. APHIS provides nearly $1 million 
annually to the Montana Department of Livestock for bison operations 
and research activities, in addition to what APHIS spends on its own 
operating costs. 

Table 1: Estimated Annual Bison Management Expenditures (Unadjusted for 
Inflation), by Agency, Federal Fiscal Years 2002-2007: 

National Park Service; 
2002: $1,200,000; 
2003: $1,148,075; 
2004: $1,207,175; 
2005: $1,204,300; 
2006: $1,316,000; 
2007: $1,182,463; 
Total: $7,258,013. 

Forest Service; 
2002: 100,215; 
2003: 150,000; 
2004: 103,172; 
2005: 95,763; 
2006: 100,278; 
2007: 90,000; 
Total: 639,428. 

Animal and Plant Health Inspection Service[A]; 
2002: 916,610; 
2003: 925,284; 
2004: 1,151,667; 
2005: 1,156,540; 
2006: 1,806,067; 
2007: 1,570,408; 
Total: 7,526,576. 

Montana Department of Livestock; 
2002: 6,053; 
2003: 47,628; 
2004: 19,504; 
2005: 18,533; 
2006: 20,353; 
2007: 16,906; 
Total: 128,977. 

Montana Fish, Wildlife and Parks[B]; 
2002: 59,329; 
2003: 62,983; 
2004: 58,363; 
2005: 68,778; 
2006: 62,119; 
2007: 67,723; 
Total: 379,295. 

Total; 
2002: $2,282,207; 
2003: $2,333,970; 
2004: $2,539,881; 
2005: $2,543,915; 
2006: $3,304,817; 
2007: $2,927,500; 
Total: $15,932,288. 

Source: GAO analysis of National Park Service; Forest Service; Animal 
and Plant Health Inspection Service; Montana Department of Livestock; 
and Montana Fish, Wildlife and Parks data. 

Note: Data provided by the agencies were, in most cases, estimates of 
expenditures for bison management activities. Expenditures for bison 
management activities include personnel and equipment costs for bison 
hazing operations, capture facility operations and maintenance, 
security, public relations, interagency coordination, disease testing, 
vaccination, the vaccination environmental impact statement, and 
training. We assessed the reliability of these estimates and found them 
to be sufficiently reliable for the purposes of our work. 

[A] APHIS annual expenditure totals include the agency's expenditures 
for operating costs as well as the funds it provides to the Montana 
Department of Livestock for bison operations and research activities. 
The Montana Department of Livestock uses these funds to pay personnel 
and purchase equipment used for bison management activities outside the 
park and to contract with Montana Fish, Wildlife and Parks to conduct 
research on elk, pregnant bison, and the quarantine feasibility study. 

[B] Montana Fish, Wildlife and Parks' expenditures were provided on a 
state fiscal year basis, but since most of the bison management 
expenditures occur within the corresponding federal fiscal year, no 
conversion was performed. 

[End of table] 

Figure 5: Estimated Annual Federal and State Bison Management 
Expenditures (Unadjusted for Inflation), Federal Fiscal Years 2002- 
2007: 

This figure is a combination vertical bar graph showing estimated 
annual federal and state bison management expenditures (unadjusted for 
inflation), federal fiscal years 2002-2007. The X axis represents the 
year, and the Y axis represents the percentage. The following values 
are approximate. 

2002; 
State: 100; 
Federal: 97. 

2003; 
State: 100; 
Federal: 95. 

2004; 
State: 100; 
Federal: 97. 

2005; 
State: 100; 
Federal: 96.5. 

2006; 
State: 100; 
Federal: 97.5. 

2007; 
State: 100; 
Federal: 97. 

[See PDF for image] 

Source: GAO analysis of National Park Service; Forest Service; Animal 
and Plant Health Inspection Service; Montana Department of Livestock; 
and Montana Fish, Wildlife, and Parks data. 

[End of figure] 

In addition to these annual costs, the Forest Service and the 
Department of the Interior also spent nearly $13 million in the late 
1990s to purchase land and a conservation easement just north of the 
park.[Footnote 12] The land was acquired to protect geothermal 
resources; improve recreational access; and provide habitat for a 
variety of wildlife species, including bison. The conservation easement 
was purchased to prohibit development on the private land, such as the 
construction of commercial facilities and roads. 

Agencies Have Not Revised Plan Timeline Estimates: 

The agencies have no estimate for how long it will take to complete the 
remaining two conditions for moving to step two, nor do they have plans 
to revise their estimated dates for moving to step three, which they 
had expected to reach by winter 2005-2006. According to agency 
officials with whom we spoke, they have not completed the requirements 
in step one as quickly as they had expected, in part, they said, 
because the original estimates in the plan were overly optimistic. 
Neither have they revised their estimated timelines for reaching steps 
two and three because, according to a Forest Service official, such 
efforts would not be the best use of their time, given the number of 
variables beyond the agencies' control. For example, the agencies have 
limited control over when, or even if, cattle will no longer graze on 
the Royal Teton Ranch. Consequently, partner agency officials have 
discussed, but have no plans for, revising the estimated completion 
dates as stated in the plan, leaving the expected date for reaching 
step three uncertain. 

Key Deficiencies in the Plan, and the Agencies' Implementation of It, 
Limit Their Effectiveness with Regard to Managing Bison-Related Issues: 

Key deficiencies in the bison management plan, and the agencies' 
implementation of it, limit their effectiveness with regard to managing 
bison-related issues. The plan lacks clearly defined, measurable 
objectives against which actual outcomes can be compared to guide the 
agencies' decision making and to measure the effectiveness of their 
actions. Without such objectives, the agencies lack a sound basis for 
selecting and monitoring their management actions, triggering 
adjustments to those actions, and determining the plan's effectiveness. 
In addition, the agencies' failure to adequately implement an adaptive 
management approach has limited the effectiveness of their bison 
management efforts. The agencies adopted an adaptive management 
approach in the plan so that they could continue to address 
uncertainties related to bison and brucellosis, while still taking 
actions to manage bison. But their efforts to implement an adaptive 
management approach have been undermined because all components of 
adaptive management--from collecting information about their management 
actions through a systematic monitoring program to adjusting their 
management actions--should flow from clearly defined objectives, which 
are absent from the plan. In addition, while adaptive management 
principles emphasize effectively managed partnerships and active 
involvement of stakeholders, the agencies have acted more as individual 
entities than as a cohesive interagency group, and they have not 
adequately communicated with or involved stakeholders. Consequently, 
the agencies' decision making lacks accountability and transparency, 
more often resembling trial and error or crisis management, rather than 
adaptive management. 

The Plan Lacks Clearly Defined, Measurable Objectives: 

The interagency bison management plan lacks clearly defined, measurable 
objectives against which actual outcomes can be compared to guide the 
agencies' decision making and to measure the effectiveness of their 
actions. Objectives in adaptive management plans should specify desired 
measurable outcomes, be achievable given the capacities of the natural 
resource system being measured and the political or social system 
within which management occurs, and indicate the time frame for 
achievement. Explicit articulation of measurable objectives helps to 
distinguish adaptive management from trial and error, because the 
objectives direct and justify the exploration of specific management 
options over time. 

The interagency bison management plan does not have clearly defined, 
measurable objectives, and the partner agencies share no common view of 
the objectives. Consequently, the agencies have no sound basis for 
making decisions or measuring the success of their efforts. Although 
the plan includes a section titled "Objectives," this section does 
little more than state the plan's overall goals to maintain a free- 
ranging bison herd and to address the risk of brucellosis transmission 
to protect the livestock industry. When we asked officials of the five 
partner agencies to refer us to the specific objectives by which they 
are managing, their responses varied. Some agency officials referred to 
the overall goals, others directed us to 14 tasks the agencies 
identified in a 2005 status review,[Footnote 13] still another cited 9 
objectives from the final environmental impact statement that preceded 
the adopted plan, and one official could not recall any objectives. 
Although the items they referred to were not completely distinct from 
one another, they were not included in the plan as objectives and 
lacked the specificity and metrics needed to provide a sound basis for 
making decisions about management actions and measuring the 
effectiveness of those actions. The plan specifically states that it 
does not identify how the agencies will measure success or failure. In 
fact, several agency officials acknowledged that they had not 
identified metrics or parameters for measuring how well they are 
meeting the plan's stated goals. 

Absent explicitly stated, clearly defined, measurable objectives, the 
agencies share no common view regarding how they are assessing the 
effectiveness of the bison management plan. For example: 

* Most of the agency officials referred to the overarching dual-purpose 
statement--"to maintain a wild, free-ranging population of bison and 
address the risk of brucellosis transmission to protect the economic 
interests and viability of the livestock industry in Montana"--as their 
guide for measuring the plan's effectiveness. Yet this statement leaves 
much to interpretation. For example, to describe how the partner 
agencies intend to "address" the risk of brucellosis transmission, the 
plan interchangeably uses the terms "minimize" and "reduce," despite 
the different meanings of these words, and the plan does not define 
either of these terms. The terms also imply that there is a recognized 
baseline risk from which to measure, but despite a general agreement 
among resource managers and scientists that the risk brucellosis- 
infected bison pose to domestic cattle is low, but greater than zero, 
the agencies have not conducted a risk assessment to better quantify 
the risk of brucellosis transmission and establish a baseline. 

* Some agency officials noted that any risk of brucellosis transmission 
to cattle greater than zero is unacceptable, and that a better measure 
for assessing the plan's effectiveness is the extent to which the 
disease is becoming less prevalent. Disagreement remains, however, 
among professionals in wildlife science, disease, and management and in 
livestock disease and management on some central issues relating to 
brucellosis in Yellowstone bison, including brucellosis prevalence. The 
disagreement persists because, as agency officials noted, the method 
currently used to determine prevalence--a blood test indicating 
exposure to the bacterium, rather than the presence of the bacterium 
itself, which is the best diagnostic tool available at present--is a 
poor indicator of the actual percentage of infectious animals in the 
population. Long-term averages of opportunistically, rather than 
systematically, collected data from Yellowstone bison indicate that the 
fraction of bison that have been exposed to the bacterium falls between 
40 and 50 percent, and limited testing of bison captured during 
management actions from 2001 to 2006 showed an exposure rate generally 
between 35 and 55 percent. Within a herd, however, the number of 
animals capable of transmitting the bacterium is generally fewer than 
the number of animals with positive blood tests. Data suggest that the 
percentage of infected animals--those capable of transmitting the 
bacterium--may be as low as 2 percent or as high as 46 percent of 
animals testing positive for exposure. Further complicating the 
agencies' ability to determine the actual prevalence of the disease 
within the population is that, according to brucellosis experts, some 
animals can test negative for exposure and still be infected, while the 
age and sex of the animal can also influence test results. Researchers 
have developed a new method that specifically tests for the presence of 
the brucellosis bacterium rather than the antibodies to the bacterium, 
offering a potential new management tool.[Footnote 14] This test, 
however, has not yet been validated for field use with bison. 

* Still other agency officials believe the plan has been effective 
because under the plan, they have prevented commingling of bison and 
cattle, no proven transmission of brucellosis from bison to cattle has 
occurred, and agency cooperation has improved. 

Agencies Have Not Adequately Implemented an Adaptive Management 
Approach: 

The partner agencies have not adequately implemented an adaptive 
management approach, which is the management strategy the agencies 
specified in the plan. In principle, adaptive management distinguishes 
itself from simple trial and error by its structured decision-making 
approach, which emphasizes accountability and transparency. Adaptive 
management is defined in the bison management plan as testing and 
validating the proposed risk management and other management actions 
with generally accepted scientific and management principles. 
Nevertheless, several agency officials told us that the agencies 
interpret the definition differently with respect to its operational 
implications under the plan. Yet while different philosophies exist 
about how adaptive management can be implemented, certain essential 
characteristics transcend them. These characteristics include (1) 
linkages among key steps, such as identifying clearly defined, 
measurable management objectives; designing and implementing a 
monitoring program to systematically obtain information--either 
operationally, scientifically, or both--about the impacts of management 
actions and to reduce uncertainties; and making decisions about 
adjustments to management actions based on what is learned; (2) 
collaborating with agency partners; and (3) communicating with and 
engaging key stakeholders. 

Agencies' Plan Implementation Lacks Linkages among Critical Steps 
within Adaptive Management: 

The first essential component of adaptive management--linkages among 
management objectives, information obtained through a systematic 
monitoring program, and decisions regarding adjustments to the plan and 
their management actions--is impaired, in part, because the plan itself 
lacks clearly defined, measurable objectives. Additionally, the 
agencies have not designed a monitoring program to systematically 
collect data from their management actions, nor have they set forth a 
coordinated research agenda to resolve remaining critical uncertainties 
related to bison and brucellosis-related issues. A Park Service 
official acknowledged that the agencies have not designed or 
implemented an evaluation approach to validate or modify the bison 
management plan, as needed, but said that each agency has its own 
monitoring efforts, and these results are brought to the interagency 
partner meetings. He said, for example, that the Park Service conducts 
surveillance for all wildlife species and has developed a long-term 
bison monitoring program. The data collected on bison include 
population size, survival rates, and movement patterns. Another Park 
Service official said that officials conducting bison management 
operations use this information, but the agencies need a better focus 
on what factors to monitor and what their decision thresholds should be 
for management actions under the bison management plan. In contrast, 
according to a Montana Fish, Wildlife and Parks official, this state 
agency is not monitoring any specific variables related to the bison 
management plan. Park Service, APHIS, and Montana Department of 
Livestock officials also told us that they are not testing any 
hypotheses or the assumptions on which the plan is based. Furthermore, 
the agencies have no process to collectively review new scientific 
information related to brucellosis, much less to assess how the plan 
may need to be changed to reflect the latest information. A Park 
Service official acknowledged that within the intent of the plan, the 
agency partners probably need to revisit new science as part of 
adaptive management. 

In the absence of a systematic monitoring program, the agencies have 
lost opportunities to collect data that could help resolve important 
uncertainties. The plan states that all captured bison are to be tested 
for exposure to brucellosis, but fewer than half of those captured 
since 2001 have been tested. For example, in early winter 2006, the 
agencies lost an opportunity to collect scientific data on about 900 
bison. Park Service officials captured these bison as they attempted to 
leave through the park's northern boundary. The bison were consigned to 
slaughter without being tested at the capture facility because the Park 
Service determined that they would not be used for research and could 
not be held in the capture pens until the spring for release back into 
the park. The Park Service and APHIS had instead made arrangements to 
collect and test samples from the bison upon slaughter. According to 
APHIS officials, however, Montana's governor prohibited Montana 
Department of Livestock officials, who are responsible for hauling 
captured bison to slaughter under a federally funded cooperative 
agreement, from transporting the bison in this case, primarily to avoid 
negative press for the state. As a result, APHIS was left to arrange 
for hauling the bison to slaughter, and the officials who were to 
collect and test samples from the bison were instead reassigned to 
assist with the transportation efforts. 

The agencies cite the following actions as examples of how they have 
used adaptive management, but because their decision making lacks 
linkages to clearly defined, measurable objectives and information 
gained through a systematic monitoring program or research, the actions 
more closely resemble trial and error than adaptive management: 

* The agencies made three formal management changes in November 2006. 
In a memorandum to the administrative record, the agencies formally 
documented three changes to their 2006-2007 operating procedures. These 
changes included modifying hazing operations to allow bison to remain 
in certain areas outside the park, increasing tolerance for bull bison 
under certain conditions, and clarifying that a reference in the bison 
management plan to a population size of 3,000 is not a target for 
population adjustment, but rather a population indicator to guide 
implementation of risk management activities. It is not clear, however, 
what objectives these changes were intended to serve or how the 
agencies planned to assess whether the effects of these changes aligned 
with a desired outcome. For example, with regard to hazing, rather than 
push bison outside the park back into it, where they were unlikely to 
remain, the agencies agreed to haze the bison from areas of high 
transmission risk--where cattle would graze in the spring--to areas of 
lower transmission risk--such as public lands surrounding the park 
where cattle do not graze. In making this change, however, the agencies 
did not articulate the basis for it or what they hoped the outcome 
would be. In addition, the memorandum stated that the reference in the 
plan to a population size of 3,000 bison was a management threshold, 
not a population target. Yet this statement is incongruous with several 
statements throughout the plan and record of decision specifying that 
the agencies will control the population size as a brucellosis risk 
mitigation measure. 

* The agencies have observed effects of their management actions. Most 
agency officials with whom we spoke noted that they are not testing 
specific hypotheses or assumptions on which the plan is based, but are 
instead observing the effects of their management actions and then 
making changes they believe are necessary. Yet, without desired 
outcomes expressed in clearly defined, measurable objectives, it is 
unclear how the agencies assess whether and how to change their 
management. For example, when revising their operating procedures for 
2007-2008 in November 2007, agency officials reconsidered the hazing 
approach they applied in spring 2007 that was outlined in the November 
2006 memorandum to the record because of the unusual number of bison-- 
several hundred--that remained outside the park beyond the May 15 
deadline. Agency officials indicated that if the extent of bison 
migration from the park is similar to or more severe than last year, 
they are prepared to haze more aggressively, hazing earlier and pushing 
bison deeper into the park, despite no identified transmissions of 
brucellosis from bison to cattle. The agencies have not issued a 
subsequent memorandum to the administrative record to document this 
change, nor do the 2007-2008 operating procedures specify the 
conditions that would trigger such aggressive hazing. With no 
connection to a clear management objective, the agencies' decision to 
modify their management approach on the basis of an unprecedented 
situation--as the events of spring 2007 were characterized by one Park 
Service official--seems little more than a reaction to avert recurrence 
of a politically charged situation. In fact, some agency officials 
admitted that they generally operate in a reactive, crisis-management 
mode when dealing with spring bison migrations from the park. 

* The agencies have conducted research on some critical uncertainties 
related to bison and brucellosis. When the agencies developed the bison 
management plan, several questions lacked answers, such as how long 
brucellosis-causing bacteria could survive in the environment, the 
likelihood that a pregnant female testing negative for exposure to the 
bacteria could shed the bacteria, and how to best diagnose the disease. 
Beyond identifying and conducting the following research projects in 
the plan, the agencies have no coordinated research agenda to address 
other uncertainties. APHIS and Montana Fish, Wildlife and Parks staff 
conducted studies during 2001 to 2003 to learn more about how long the 
bacteria would survive under certain environmental conditions. In 3 of 
the past 7 years, the agencies have also monitored 39 pregnant females 
that initially tested negative for exposure to brucellosis to determine 
if they shed the bacteria into the environment during abortion or 
birth. Regarding bacterial survival in the environment, the agencies 
used the study results to validate specifications in the plan related 
to the required separation in time between bison and cattle--a process 
that aligned with adaptive management principles. In the absence of a 
systematic program to collect information through monitoring and 
research for use in decision making, however, it is not clear how the 
agencies have used the results of monitoring pregnant females or 
weighed relevant science conducted by other researchers when 
considering changes to the plan. 

Partner Agencies Operate More as Individual Agencies Than as a Cohesive 
Interagency Group: 

The agencies recognized in the plan that a coordinated, cooperative 
management effort--a second essential component of adaptive management-
-was necessary for plan implementation. Nevertheless, they operate more 
as independent entities within their respective jurisdictions and 
authorities. Although all of the agency officials with whom we spoke 
said that coordination and cooperation among the partners has improved 
since the plan began, and some said that they seek interagency support 
when making decisions within their respective jurisdictions, others 
said that finger-pointing has been an issue when it comes to taking 
responsibility; still others admitted that the agencies could be doing 
more to portray a shared message. For example, Montana Department of 
Livestock officials said that the agencies need a strategy that better 
communicates to the public that decisions are made and supported by all 
five agencies. In addition, the operating procedures specify that the 
Park Service is the lead decision-making agency within park boundaries, 
while the Montana Department of Livestock takes the lead on most issues 
outside the park. But the plan and the operating procedures are silent 
on where the responsibility lies for administrative duties of the 
interagency group. To date, the agencies have shared responsibility for 
scheduling and leading meetings. A Park Service official said, however, 
that it has been difficult to coordinate both technical staff and 
decision makers from all agencies for meetings and pointed out that 
bison management is an added duty for most of the staff involved. APHIS 
officials said the lack of a lead agency for administrative functions, 
such as scheduling and documenting interagency meetings, has been a 
challenge to more coordinated efforts and that having a single agency 
responsible for administrative functions would help keep the group 
moving forward. 

The Agencies Have Not Adequately Communicated with or Engaged 
Stakeholders: 

A third component essential to adaptive management is communication 
with and involvement of key stakeholders. The agency partners generally 
believe that they have engaged stakeholders and provided sufficient 
opportunities for their involvement, but several of the stakeholders we 
spoke with continue to have concerns about the agencies' transparency 
with the public. 

Agency officials said that since the plan began, they have held 
multiple public meetings related to bison management. Still, these 
meetings have generally taken place during business hours, and the 
discussion topics and decisions from these meetings have not been 
documented or kept in a central location convenient for public access. 
As a more comprehensive outreach effort, the partner agencies hosted 
two large-scale evening open houses--one in January 2007 and another in 
December 2007--to inform the public on a variety of bison management 
related topics. At the January 2007 meeting, the agencies solicited 
stakeholder views on several bison management related topics, but until 
early December 2007, they had not shared with the public a summary of 
the ideas expressed at the January meeting or an explanation of how 
they intended to use the information they gathered. At the second open 
house in early December 2007, the agencies publicly reviewed the 2006- 
2007 operations; provided an overview of plans for the upcoming 2007- 
2008 season; discussed the feedback they received during the January 
2007 open house; and conducted discussion sessions about bison 
operations, brucellosis in Montana, and progress made to date on the 
plan. These efforts notwithstanding, the agencies also lack a 
mechanism, such as a coordinated interagency annual report, by which to 
document for the public their collective progress related to the plan. 
As a result, the agencies lack accountability among themselves and to 
the public, and it is difficult for the public to obtain information 
without attending the meetings or contacting each individual agency. 

Several of the conservation groups, livestock industry groups, 
ranchers, and private landowners with whom we spoke expressed a common 
concern about the agencies' lack of transparency with the public. Some 
of the stakeholders with whom we spoke attended the January 2007 
interagency open house and thought it provided a good forum for 
discussing ideas, but questioned how the stakeholders' views expressed 
at the meeting would be used. Similarly, one stakeholder shared his 
frustration over the agencies' failure to consider information he had 
provided relevant to potential areas for expanded bison habitat. Others 
cited a need for the agencies to obtain and present to the public more 
factual, scientific research information to eliminate uncertainties and 
reduce the amount of factual distortion that continues to perpetuate 
the controversy related to bison management. A common concern expressed 
among stakeholders--that the agencies were not adhering to certain plan 
provisions--may also indicate that agencies' communication efforts have 
not been clear. Specifically, several stakeholders believe that the 
plan specifies a population target of 3,000 bison that the agencies are 
failing to maintain. In fact, the record of decision states that "as an 
additional risk management measure, the agencies would maintain a 
population target for the whole herd of 3,000 bison," and that specific 
measures may be undertaken to reduce the herd's size when the estimated 
population exceeds 3,000 animals. Park Service officials believe the 
November 2006 memorandum to the record clarified that this reference is 
not a target for population adjustment, but rather a population 
indicator to guide implementation of risk management activities; 
nonetheless, the difference in understanding persists. 

Conclusions: 

While the interagency bison management plan put an end to litigation 
among the federal and state agencies and established a forum for 
continued negotiations and more cooperative action, the decades-long, 
bison-related controversies continue: bison are still hazed and 
slaughtered every year, and livestock owners are still concerned about 
the significant economic consequences if Montana's cattle industry 
loses its brucellosis-free status. Even if the agencies improve their 
management and fully implement the current plan through step three, we 
believe the controversies will continue, in part because critical 
underlying differences among agency mandates, management philosophies, 
and political interests have not been resolved. In addition, the plan 
lacks clearly defined, measurable objectives to guide the agencies' 
bison management actions, and the agencies are not adequately applying 
an adaptive management approach in implementing the plan. Moreover, the 
agencies' implementation of the plan has remained fragmented, because 
no single entity is accountable for coordinating and steering the 
management, research, and resolution of these bison-related issues. In 
addition, the agencies' management lacks the accountability and 
transparency expected by the public and Congress. Meanwhile, the 
federal government continues to spend millions of dollars on 
uncoordinated management and research efforts, with no means to ensure 
that these efforts are focused on a common outcome that could help 
resolve the controversies. Because the plan is not a brucellosis 
eradication plan, concerns about brucellosis transmission will still 
require the agencies to actively manage bison moving from the park into 
Montana, even if they fully implement all steps of the plan. Given 
these realities, improvements in the partner agencies' implementation 
of the plan, including more systematic application of an adaptive 
management approach, could contribute greatly to helping address the 
larger brucellosis issue in the Greater Yellowstone Area. Multiple 
recent suspected transmissions of brucellosis from elk to cattle in the 
area have highlighted the importance of addressing this disease in its 
broader wildlife and ecological context, and doing so could have 
significant implications for the future management of Yellowstone 
bison. 

Recommendations for Executive Action: 

We recommend that the Secretaries of Agriculture and of the Interior 
direct the federal agencies to work with their state agency partners to 
take the following five actions: 

To improve the management of Yellowstone bison in the national park and 
the state of Montana: 

* Clearly define measurable objectives to express desired outcomes and 
refine, revise, or replace the plan and agency operating procedures as 
needed to reflect these objectives. 

* Systematically apply adaptive management principles, including 
defining specific scientific and management questions to be answered, 
identifying the activities to be conducted to answer them, developing a 
monitoring program to assess the impacts of those activities, and 
incorporating the results into the bison management plan. 

To enhance interagency collaboration, promote transparency, and 
strengthen the agencies' accountability to the American public: 

* Establish a single publicly available repository, on a Web site or at 
a location easily accessible to the public that includes all documents 
reflecting decisions made and actions taken with respect to plan 
implementation. 

* Report annually to Congress on the progress and expenditures related 
to the plan's measurable objectives once these have been clearly 
defined. 

* Appoint a group comprised of a representative from each of the 
partner agencies or designate one of the five interagency partners 
(perhaps on an annual rotating basis) as a lead entity for plan 
oversight, coordination, and administration. 

Agency Comments: 

We provided the federal departments of Agriculture and the Interior; 
Montana Fish, Wildlife and Parks; and the Montana Department of 
Livestock a draft of this report for review and comment. The Department 
of Agriculture, the Department of the Interior, and the Montana 
Department of Livestock generally agreed with our conclusions and 
recommendations; their written comments and our response to the 
Department of the Interior's comments appear in appendixes II, III, and 
IV, respectively. The federal departments and the state agency also 
provided technical comments that we incorporated into the report as 
appropriate. Montana Fish, Wildlife and Parks provided no comments on 
the report. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to interested 
congressional committees; the Secretaries of Agriculture and the 
Interior; Montana Fish, Wildlife and Parks; the Montana Department of 
Livestock; and other interested parties. We will also make copies 
available to others upon request. In addition, the report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff members have any questions regarding this report, 
please contact me at (202) 512-3841 or [email protected]. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. Key contributors are listed in 
appendix V. 

Signed by: 

Robin M. Nazzaro: 

Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

Our objectives were to determine (1) the progress made in implementing 
the interagency bison management plan and (2) the soundness of the plan 
and the effectiveness of the agencies' implementation of it with regard 
to managing bison-related issues in the Greater Yellowstone Area. 

To address both of the objectives, we obtained and reviewed relevant 
documentation, including the bison management final environmental 
impact statement, record of decision, and interagency bison management 
plan; interagency operating procedures; and the interagency status 
review. We also interviewed officials from the Park Service; the Forest 
Service; APHIS; Montana Fish, Wildlife and Parks; and the Montana 
Department of Livestock. In addition, in January and February 2007, we 
conducted a field visit to Yellowstone National Park and surrounding 
areas to gain a greater understanding of bison management issues and 
activities performed by the agencies under the interagency bison 
management plan. While we were there, we visited the bison management 
zones identified in the plan, bison capture facilities, and various 
private lands on the north and west sides of the park. We also attended 
an interagency open house to hear public concerns related to the 
agencies' implementation of the bison management plan and met with 
representatives of the Royal Teton Ranch to understand their interests 
related to bison and bison management activities on and around their 
private lands. 

To enhance our understanding about the progress the agencies have made 
in implementing the interagency bison management plan, we also obtained 
and reviewed scientific research and reports on various topics related 
to brucellosis and wildlife, including the safety and effectiveness of 
brucellosis vaccines, vaccine delivery systems, and diagnostic tests 
for brucellosis. In conjunction with this effort, we also interviewed 
researchers with the U.S. Geological Survey Northern Rocky Mountain 
Science Center, the APHIS National Wildlife Research Center, and the 
Agricultural Research Service National Animal Disease Center. In 
addition, we requested from the federal and state partner agencies 
expenditure data related to bison management activities for federal 
fiscal years 2000 through 2007. The agencies were able to provide 
complete data only for federal fiscal years 2002 through 2007, and most 
of these data were estimated, rather than actual, expenditures. We 
assessed the reliability of these estimates and found them to be 
sufficiently reliable for the purposes of our work. We used these data 
to estimate the amount of money spent annually on bison management 
activities and how the expenditures were shared among the federal and 
state agencies. 

In addition to the interviews, relevant documentation, and field visits 
that we have previously discussed, we performed a number of other steps 
to determine the soundness of the interagency bison management plan and 
the effectiveness of the agencies' implementation of it with regard to 
managing bison-related issues in the Greater Yellowstone Area. We 
assessed the plan and the agencies' implementation of it against 
generally recognized best management practices, including those 
contained in the Government Performance and Results Act of 1993, the 
Comptroller General's 2004 forum on high-performing organizations, the 
Department of the Interior Technical Guidance on Adaptive Management, 
and select peer-reviewed adaptive management articles. Such practices 
include clearly defining measurable, results-oriented management 
objectives; designing and implementing a plan to monitor management 
actions; making decisions based on management objectives; effectively 
managing partnerships while maintaining accountability to Congress and 
the public; and actively involving key stakeholders over time to 
engender public support. We also conducted semistructured interviews of 
partner agency officials regarding their implementation and management 
of the interagency bison management plan, focusing specifically on 
their application of adaptive management principles, changes made to 
the plan, views on the effectiveness of the plan, interagency 
cooperation and coordination, and communication with and engagement of 
stakeholders. In addition, we conducted semistructured interviews of a 
judgmental sample of 30 local individuals and groups representing 
varied interests in bison management activities, including 
conservationists, livestock industry representatives, local ranchers, 
permittees of public livestock grazing allotments, Native American 
tribes, hunting enthusiasts, lessees of private land, and other private 
landowners. Our questions of these individuals and groups focused on 
the partner agencies' bison management activities and communication 
with and involvement of the public. We selected these individuals and 
groups from listings of those who provided written comments on the 
draft environmental impact statement, attended the interagency public 
meeting on January 31, 2007, or were identified to us as interested 
parties. 

We conducted this performance audit from January 2007 through March 
2008 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Department of Agriculture: 

USDA: 
United States Department of Agriculture: 

Forest Service: 
Caring for the Land and Serving People: 
Washington Office: 

1400 Independence Avenue, SW: 
Washington, DC 20250 

File Code: 1420: 
Date:  

Ms. Robin Nazzaro
Director, Natural Resources and the Environment: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Nazzaro:

Thank you for providing the United States Department of Agriculture 
(USDA) with the opportunity to review and comment on the draft U.S. 
Government Accountability Office (GAO) draft report entitled 
"Interagency Plan and Agencies' Management Need Improvement to Better 
Address Bison- Cattle Brucellosis Controversy." This is an extremely 
complex management issue and we commend you and your colleagues, Diane 
Lund, Jamie Meuwissen, and David Bixler, for conducting the broadest 
possible inquiry and working so closely with all the involved agencies 
and stakeholders. I am responding to the audit with the concurrence of 
the Animal and Plant Health Inspection Service (APHIS). 

We believe that the GAO Report's Recommendations for Executive Action 
will improve the management of bison in the greater Yellowstone area. 
Specifically, the refining of the Interagency Bison Management Plan, to 
better define measurable objectives, will improve ongoing and future 
operating procedures; and that improvements can be made to enhance 
interagency and stakeholder collaboration and communication. The 
agencies have already begun to create a central repository for 
documentation related to the Interagency Bison Management Plan, and 
designate on a rotating basis a lead administrative agency among the 
five partner agencies. We are proposing a number of factual 
clarifications found in the enclosure that you should consider. 

We appreciate the opportunity to review and comment on the GAO report. 
We are committed to using the recommendations of the GAO, and working 
with partner agencies and the public to continue moving bison 
management forward. 

Sincerely,

Signed by: 

Abigail R. Kimbell. 

Enclosure: 

[End of section] 

Appendix III: Comments from the Department of the Interior: 

Note: GAO comments supplementing those in the report text appear at the 
end of this appendix. 

The Associate Deputy Secretary Of The Interior: 
Washington: 

February 26, 2008: 

Ms. Robin Nazzaro: 
Director, Natural Resources and Environment: 
Government Accountability Office: 
441 G Street, NW.: 
Washington, DC 20548: 

Dear Ms. Nazzaro: 

Thank you for providing the Department of the Interior the opportunity 
to review and comment on the Government Accountability Office Draft 
Report entitled, "Yellowstone Bison Interagency Plan and Agencies' 
Management Need Improvement to Better Address Bison-Cattle Brucellosis 
Controversy," (GAO-08-291). 

The National Park Service and the United States Geological Survey under 
the Department have reviewed the draft report and appreciate the 
report's methodical and comprehensive summary of the Interagency Bison 
Management Plan and progress to date by the partner agencies. This is 
an extremely complex issue, and we commend the auditors for their 
efforts to give the issue the broadest possible inquiry and work so 
closely with all the agencies and stakeholders involved. We support the 
report's overarching conclusion that refining the plan is appropriate 
and feasible to informing ongoing and future management. 

The National Park Service believes that, in addition to the interagency 
coordination and management efforts to date, there is value in refining 
and improving the metrics of management objectives and actions as well 
as improving communication with stakeholders and collaboration among 
the partners. We are committed to incorporating these recommendations 
and making these improvements with the partner agencies and the public. 

General Comments: 

Brucellosis Prevalence Rates: 

The USGS suggests that the report would benefit from additional detail 
in this area. The report is correct in stating that the method 
currently employed reflects only exposure to Brucella ahortus, the 
bacterium which causes brucellosis, and not whether the animal is 
capable of transmitting the disease. However the test results can be 
further complicated by the age and gender of the animals being sampled. 
Thus, any comparison between populations, or of the same population 
over time, should consider age and sex structure. Additionally, a 
published study by researchers at the Idaho National Engineering and 
Environmental Laboratory has shown that it is possible to detect 
Brucella DNA in blood samples rather than antibodies to Brucella and 
thereby determine actual infection. This technique has the potential to 
be an important management tool by reducing the uncertainty described 
in the previous paragraph. 

The draft report discusses areas of significant disagreement, including 
disagreement on brucellosis prevalence. It includes the statement, 
"This disagreement persists because, as agency officials' notes, the 
method currently used to determine prevalence ï¿½a blood test indicating 
exposure to the bacterium rather than presence of the bacterium itself, 
which is the best diagnostic tool available at presentï¿½is a poor 
indicator of the actual percentage of infectious animals in the 
population." The USGS agrees with this assessment of the current test 
and suggests that the recognition of a potential new and highly 
valuable management tool is an important consideration. 

Elk to Cattle Transmission: 

The draft report references "multiple recent" transmissions of 
brucellosis between elk and cattle. We feel that "multiple" may suggest 
to readers that elk-to-cattle transmission is a frequent occurrence, 
while to the best of our knowledge there have been only two documented 
cases in the previous 5 years. The distinction in this clarification 
has important management implications. If indeed elk-to-cattle 
transmission is becoming a common occurrence, there may also be a need 
to begin managing elk through hazing, culling, etc., similar to current 
bison management. The USGS is familiar withï¿½at mostï¿½two cases of likely 
elk-to-cattle transmission of Brucella, one in Idaho approximately 5 
years ago and one in Montana during the summer of 2007. This differs 
from the report's reference to events in Idaho and Wyoming. 


Recommendations For Executive Action: 

All five recommendations are directed to both the DOI and the USDA. 

Recommendation 1: The recommendation is to work with the State agency 
partners to improve the management of Yellowstone bison in the national 
park and the state of Montana. Define measurable objectives to express 
desired outcomes and refine, revise, or replace the plan and agency 
operating procedures as needed to reflect these goals and objectives. 

Response: We agree that clearly defined and measurable objectives, to 
express desired outcomes, be developed in order to refine or revise the 
agency operating procedures. The original operating procedures jointly 
developed and signed by both the Federal and State agencies in 2002, 
were updated and re-signed by all partner agencies in 2007 to 
incorporate several adaptive management adjustments to the plan. NPS 
does not agree with the portion of this recommendation that suggests 
the plan be replaced. 

(See comment 1.): 

Recommendation 2: The recommendation is to work with the State agency 
partners to improve the management of Yellowstone bison in the national 
park and the state of Montana. Systematically apply adaptive management 
principles, including defining specific scientific and management 
decisions to be answered, identifying the activities to be conducted to 
answer them, developing a monitoring program to assess the impacts of 
those activities, and incorporating the results into the bison 
management plan. 

Response: We agree with the recommendation to incorporate adaptive 
management principles (and associated specific questions, activities, 
and monitoring) into the plan, through adjustments to the Operating 
Procedures. This will be accomplished through NPS participation in the 
IBMP Inter-Agency Working Group. 

(See comment 2.): 

Recommendation 3: The recommendation is to enhance interagency 
collaboration, promote transparency, and strengthen the agencies' 
accountability to the American public. Establish a single, publicly 
available repository on a Web site or at a location easily accessible 
to the public that includes all documents reflecting decisions made and 
actions taken with respect to plan implementation. 

Response: We agree with the recommendation to establish an internet Web 
site for open access to public documents generated through 
implementation of the plan. This will be accomplished through NPS 
participation in the IBMP Inter-Agency Working Group. 

(See comment 3.): 

Recommendation 4: The recommendation is to enhance interagency 
collaboration, promote transparency, and strengthen the agencies' 
accountability to the American public. Report annually to Congress on 
the progress and expenditures related to the plan's measurable 
objectives once these have been clearly defined. 

Response: We agree with the recommendation to report annually to 
Congress on progress and expenditures related to the plan's measurable 
objectives once these have been clearly defined through the Operating 
Procedures. This will be accomplished through NPS participation in the 
IBMP Inter-Agency Working Group. 

(See comment 4.): 

Recommendation 5: The recommendation is to enhance interagency 
collaboration, promote transparency, and strengthen the agencies' 
accountability to the American public. Appoint a group comprising a 
representative from each of the partner agencies or designate one of 
the five interagency partners (perhaps on an annual rotating basis) as 
a lead entity for plan oversight, coordination, and administration. 

Response: We disagree with that portion of the recommendation to 
designate one of the agency partners as the lead entity for plan 
oversight, coordination, and administration. The respective Federal and 
Montana RODs direct each partner agency to adhere to their respective 
agency mandates and policies. We agree with a recommendation to 
continue the prevailing IBMP interagency working group (established in 
2002) with a designated lead agency to chair meetings comprised of 
representatives from the partner agencies for plan oversight, 
coordination, and administration. 

(See comment 5.): 

Technical corrections are addressed separately and enclosed. 

If you have any questions, please contact Rebecca Bageant, USGS Audit 
Liaison Officer, at (703) 648-4328, or Ernestine Armstrong of NPS at 
(202) 354-1958.

Sincerely, 

Signed by: 

James E. Cason: 

GAO's Response to the Department of the Interior's Comments: 

Our responses to the Department of the Interior's comments are numbered 
below to correspond with specific passages in the department's comments 
(reproduced on pp. 39-42). 

1. We emphasize that clearly defined, measurable objectives need to be 
reflected in the bison management plan. We expect that the agencies 
would subsequently make commensurate changes to the operating 
procedures to ensure that their management actions are aligned with 
these objectives. To the extent that the National Park Service, in 
cooperation with the other partner agencies, can adequately accomplish 
this alignment by refining or revising the existing bison management 
plan and agency operating procedures, replacing the plan may not be 
necessary. 

2. We believe it is essential that the partners incorporate adaptive 
management principles into the bison management plan and subsequently 
modify the operating procedures to ensure systematic application of 
these principles to their management actions. In addition, we believe 
that this recommendation should be implemented by the entity we 
recommend, rather than by the IBMP Inter-Agency Working Group 
referenced in the department's response, as further explained in 
comment 5. 

3. We believe that this recommendation should be implemented by the 
entity we recommend, rather than by the IBMP Inter-Agency Working Group 
referenced in the department's response, as further explained in 
comment 5. 

4. As we noted in comment 1, we expect that the measurable objectives 
be clearly defined in the bison management plan and be used as 
benchmarks for reporting the agencies' progress to Congress. We believe 
that this recommendation should be implemented by the entity we 
recommend, rather than by the IBMP Inter-Agency Working Group 
referenced in the department's response, as further explained in 
comment 5. 

5. The department states that it agrees with a recommendation to 
continue the prevailing IBMP Inter-Agency Working Group and notes that 
the department would accomplish a number of our recommendations through 
participation in this group. We did not recommend that the partner 
agencies continue the prevailing IBMP Inter-Agency Working Group to 
implement this or any other of our recommendations. As evident in our 
findings, we believe the agency partners' efforts to operate as a 
cohesive interagency group to oversee, coordinate, and administer the 
bison management plan have been inadequate to date, which led to our 
recommendation that a more structured lead entity be appointed for such 
functions. Furthermore, none of the partner agencies, including the 
Park Service, had identified this group by name or referenced it as 
having responsibilities for these functions during the course of our 
review, and only the Park Service referenced it in commenting on our 
draft report. We envision that the responsibilities of the lead entity 
we have recommended would include, but would not be limited to, 
activities such as scheduling and documenting interagency meetings, 
creating and maintaining a central repository of information related to 
the bison management plan, and coordinating the agency partner's annual 
report to Congress. We do not believe that this entity will interfere 
with the partner agencies' ability to adhere to their respective 
mandates and policies. 

[End of section] 

Appendix IV: Comments from the Montana Department of Livestock: 

Department Of Livestock: 
State Of Montana: 

Board Of Livestock - (406) 444-7323: 
Helena, Montana 59620-2001: 
Brands Enforcement Division - (406) 444-2045: 
Animal Health Division - (406) 444-2043: 
Centralized Services Division - (406) 444-9040: 
Meat & Poultry Inspection Division - (406) 444-5202: 
Milk & Egg Bureau - (406) 444-9761: 

February 8, 2008: 

Dear Mr. David Bixler, Assistant Director, 

The Montana Department of Livestock appreciates the time and effort the 
Government Accountability Office has taken to study the Interagency 
Bison Management Plan. In the 1930s, the USDA began focusing on 
eradicating brucellosis from livestock, and with the State of Texas 
gaining Brucellosis Class-Free Status in early February 2008, this goal 
was finally achieved. With this monumental event, the issue of 
brucellosis in the GYA is likely to gain even greater attention, and we 
welcome the opportunity to improve the Interagency Bison Management 
Plan based on the GAO review. 

The Montana Department of Livestock has reviewed the draft report 
(Government Accountability Office Report GAO-08-291) on Yellowstone 
bison management and we concur with the overall conclusions that the 
Interagency Bison Management Plan would be improved with: 

* More clearly defined management objectives linked to the adaptive 
management framework; 

* Increased interagency coordination to improve interagency 
cohesiveness; 

* Improved communication with the public and affected interest groups. 

The Montana Department of Livestock is committed to working with the 
partner agencies to incorporate these improvements into the Interagency 
Bison Management Plan. We have prepared specific comments to the report 
(attached). We appreciate the diligent work of the staff assigned to 
this project. 

Sincerely,

Signed by: 

Marty Zaluski, DVM: 
State Veterinarian: 
Montana Department of Livestock: 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Robin M. Nazzaro, (202) 512-3841 or [email protected]: 

Staff Acknowledgments: 

In addition to the individual named above, David P. Bixler, Assistant 
Director; Ellen W. Chu; Richard Johnson; Diane Lund; and Jamie 
Meuwissen made key contributions to this report. Also contributing to 
the report were Elizabeth Curda, Sandy Davis, Bernice Dawson, Timothy 
Guinane, Carol Henn, Lynn Musser, Omari Norman, Kim Raheb, Jeremy 
Sebest, and Jena Sinkfield. 

[End of section] 

Related GAO Products: 

Yellowstone National Park: Preliminary Observations on the 
Implementation of the Interagency Bison Management Plan. GAO-07-638T. 
Washington, D.C.: March 20, 2007. 

Wildlife Management: Negotiations on a Long-Term Plan for Managing 
Yellowstone Bison Still Ongoing. GAO/RCED-00-7. Washington, D.C.: 
November 30, 1999. 

Wildlife Management: Issues Concerning the Management of Bison and Elk 
Herds in Yellowstone National Park. GAO/T-RCED-97-200. Washington, 
D.C.: July 10, 1997. 

Wildlife Management: Many Issues Unresolved in Yellowstone Bison-Cattle 
Brucellosis Conflict. GAO/RCED-93-2. Washington, D.C.: October 21, 
1992. 

[End of section] 

Footnotes: 

[1] GAO, Yellowstone National Park: Preliminary Observations on the 
Implementation of the Interagency Bison Management Plan, GAO-07-638T 
(Washington, D.C.: Mar. 20, 2007). 

[2] Under the National Environmental Policy Act of 1969, agencies 
evaluate the likely environmental effects of projects they are 
proposing using an environmental assessment or, if the projects are 
likely to have a significant effect on the environment, a more detailed 
document known as an environmental impact statement. 

[3] The interagency bison management plan is included as part of the 
federal Record of Decision for Final Environmental Impact Statement and 
Bison Management Plan for the State of Montana and Yellowstone National 
Park. For purposes of this report, we refer to this combined document 
as "the plan," unless otherwise specified. 

[4] To haze bison is to drive them away from a facility or location by 
means of horseback, all-terrain vehicle, helicopter, or other methods. 

[5] C. S. Holling, ed., Adaptive Environmental Assessment and 
Management (New York: John Wiley and Sons, 1978); K. N. Lee, Compass 
and Gyroscope: Integrating Science and Politics for the Environment 
(Washington, D.C.: Island Press, 1993); Kimberly J. Reever Morghan et 
al., "Successful Adaptive Management--The Integration of Research and 
Management," Rangeland Ecology and Management, vol. 59, no. 2 (2006); 
and C. Walters, Adaptive Management of Renewable Resources (New York: 
Macmillan, 1986). 

[6] Government Performance and Results Act of 1993, Pub. L. No. 103-62, 
107 Stat. 285 (1993), as amended, and GAO, Comptroller General's Forum: 
High-Performing Organizations, GAO-04-343SP (Washington, D.C.: Feb. 13, 
2004). 

[7] According to the Montana Department of Livestock, management of the 
risk of brucellosis transmission from elk to cattle is being addressed 
through the Greater Yellowstone Interagency Brucellosis Committee, in 
which all of the partner agencies are represented. 

[8] GAO, Wildlife Management: Issues Concerning the Management of Bison 
and Elk Herds in Yellowstone National Park, GAO/T-RCED-97-200 
(Washington, D.C.: July 10, 1997). 

[9] The plan mentions certain Gallatin National Forest and private 
lands north and west of the park, such as the Eagle Creek/Bear Creek 
region and portions of the Lee Metcalf Wilderness as other management 
areas outside of the plan's designated bison management zones. Bison 
are allowed to graze in these other areas year-round without agency 
interference because cattle generally do not graze on these lands. If 
bison migrate out of the park and into one of these areas, agency 
officials are required to monitor them; if bison attempt to move beyond 
these areas, the plan requires agency officials to either keep them 
within those areas or slaughter them. 

[10] Current brucellosis tests involve determining whether a blood 
sample taken from an animal contains antibodies to the brucellosis 
bacterium. The presence of these antibodies indicates that the animal 
has been exposed to the bacterium in quantities sufficient to trigger 
antibody production but does not necessarily mean the animal is 
infected with, or ill from, the disease itself. 

[11] Department of the Interior, Adaptive Management: The U.S. 
Department of the Interior Technical Guide (Washington, D.C.: 2007). 

[12] GAO-07-638T. 

[13] National Park Service; USDA Animal and Plant Health Inspection 
Service; USDA Forest Service; Montana Department of Livestock; and 
Montana Fish, Wildlife and Parks, A Status Review of Adaptive 
Management Elements, 2000 to 2005 (September 2005). The intent of the 
review was to provide an assessment of how successful the bison 
management plan has been in achieving the goals set forth in the final 
environmental impact statement and records of decision issued by the 
state and federal agencies. 

[14] According to the U.S. Geological Survey, a published study by 
researchers at the Idaho National Engineering and Environmental 
Laboratory (now known as the Idaho National Laboratory) has shown that 
it is possible to detect Brucella abortus DNA in blood samples rather 
than antibodies to Brucella abortus and thereby determine actual 
infection. 

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